This will be your “typical” search warrant template that you would use for

a controlled buy search warrant, this one is for credit cards (identity theft). It
includes “boiler plate” language regarding the seizure of computers and cell
phones, including language to answer telephones. This language should be
applicable to most controlled buy search warrants and other search warrants for
a suspects location. Be sure to read this example before you simply cut and
paste it to ensure that its statements will be true for your Statement of Probable
Cause.

Within the previous ten days, your affiant received information from a confidential
informant hereinafter referred to in this affidavit as CI. The CI told your affiant that a
person known to the CI as Francisco Gonzalez is selling fraudulent credit cards. The CI
knows this as the CI has purchased fraudulent credit cards from Francisco Gonzalez in
the past. The CI told your affiant that Francisco Gonzalez obtains other peoples
identification, including their credit card account numbers and produces fraudulent credit
cards with other person’s credit card account numbers, embossed with false names. The
CI has purchased fraudulent credit cards from Francisco Gonzalez in various locales open
to the public in the County of Los Angeles. The CI described Francisco Gonzalez as a
male Hispanic in his mid thirties, black hair, brown eyes. The CI told your affiant that
Francisco Gonzalez has a cellular number of 310-555-2766. The CI told your affiant that
Francisco Gonzalez drives a maroon Chevy station wagon, and will drive his maroon
Chevy station wagon when meeting the CI in various locales open to the public in the
County of Los Angeles. The CI told your affiant that Francisco Gonzalez lives in San
Luis Beach, and believed the address that Francisco Gonzalez lived was 1234 156th
Street.

Your affiant questioned the CI carefully regarding identity theft and the use and
production of fraudulent credit cards The CI’s answers demonstrated extensive
knowledge about identity theft including, fraudulent credit cards.

Statement of Probable Cause

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Your affiant was able to identify Francisco Gonzalez through departmental resources as
Francisco Javier Gonzalez. Francisco Javier Gonzalez has a DOB of 08-18-71, is a male
Hispanic, 5-08, 180 lbs., black hair, brown eyes. Francisco Javier Gonzalez has a
CDL#A5987562. Francisco Javier Gonzalez has a residence address listed of 1234 W.
154th Street, San Luis Beach Ca. for his CDL as of May 06, 2006.

Within the previous ten days, and armed with this information your affiant caused a
complete and through search of the CI. The CI had no contraband on their person. The CI
was given a quantity of police funds and went to a public place within the County of Los
Angeles and met with Francisco Javier Gonzalez. The CI was kept under constant
surveillance by Special Investigations Unit Detectives while the CI met with Francisco
Javier Gonzalez. After the CI met with Francisco Javier Gonzalez, the CI went to a
predetermined meeting location and met with your affiant. Your affiant was given a
credit card by the CI. The CI told your affiant that Francisco Javier Gonzalez sold the
credit card to the CI when the CI met with Francisco Javier Gonzalez.

Your affiant checked the account number on the credit card believed to be a fraudulent
credit card. The account number (#123456789) belonged to a John Smith in New York,
issued by Bank of America. The account holder was contacted and told your affiant that
his identity and Bank of America account numbers had been stolen/used fraudulently.

Within the previous ten days, surveillance was conducted on Francisco Javier Gonzalez.
Francisco Javier Gonzalez was observed driving a maroon 1998 Mercury station wagon,
Cal Lic#5DTT342.

Within the previous ten days, surveillance was conducted on Francisco Javier Gonzalez
and Francisco Javier Gonzalez was seen entering the location of 1234 W. 154th Street,
San Luis Beach. Francisco Javier Gonzalez used keys to unlock the front door and enter
the residence.

Statement of Probable Cause

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It is your affiant’s experience that dealers/sellers of fraudulent credit cards commonly
sell from their personal residence(s) and other locations (such as: public/private
businesses, open parking lots, other people’s residences, public streets and public
park/recreation areas). They will sell at various locations in order to escape detection of
law enforcement. It is your affiant’s opinion based on experience and training that
seller’s of fraudulent credit cards often use vehicles to transport and store fraudulent
credit cards and will use their vehicle(s) to store and sell fraudulent credit cards from. It
is your affiant’s opinion based on experience and training that seller’s of fraudulent
credit cards will use their residence(s) to store and sell credit cards from.

Based upon the information contained in this affidavit, coupled with your affiant’s
training and experience, your affiant states that the items of fraudulent credit card
(identity theft) paraphernalia and documentation enumerated on Search Warrant &
Affidavit page #3 of this affidavit are articles that are commonly found in, and associated
with, places/persons where fraudulent credit cards and crimes of identity theft are
committed. Your affiant has reason to believe and does believe that there is fraudulent
credit cards being sold and stored from the premise(s) and vehicle(s) for which this
warrant is requested.

Your affiant has been present during the execution of numerous search warrants. In
virtually all of these instances, your affiant has observed utility bills pertaining to the
location and/or personal letters addressed to the occupants of the location within the
residence being searched. On many occasions, your affiant has observed handwritten
notes or papers, photographs, digital cameras (including memory cards and internal
memory storage pictures/video) and video cameras (including memory cards and internal
memory storage pictures/video), keys that fit the location locks, and wallets, purses,
diaries, phone books, and luggage tags, all of which contained in or upon them some
personalization or which tended to identify the owner(s) thereof and thus circumstantially
identified to your affiant the occupant(s) of the premises for the purposes of arrest,
identification and crime charging.

Statement of Probable Cause

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Based upon the facts set forth in this affidavit, it your affiant’s opinion that suspect(s)
listed in the “to be searched page” are selling fraudulent credit cards and that the
suspect(s) are taking orders over the telephone for pickup and delivery. Thus, your
affiant also request this warrant authorize searching officers to answer telephones
(including cellular) and converse (including texting) with callers at the location of this
Search Warrant without revealing the Peace Officers true identity, and note and/or record
any conversations and information received from the telephone calls, including caller
identification information. It is your affiant’s opinion that persons will call ordering
fraudulent credit cards and that such calls will constitute evidence of the commission of a
felony.

It is your affiant’s experience and the experience of other identity theft (credit card)
investigators with whom your affiant has spoken with that suspect(s) who traffic in
fraudulent credit cards frequently possess cellular telephones to enhance their trade.
These suspect(s) use cellular telephones to house buyers and sellers lists, track profits and
losses, store receipts, and to communicate with other persons involved in identity theft
and fraudulent credit cards. Thus, your affiant requests if cellular telephones are located
in possession of suspect(s) and/or location(s) listed in the “to be searched page” being
searched as authorized by this warrant that your affiant be allowed to seize such cellular
telephones. An offsite search of the suspect’s cellular telephone, including all storage
devices, is needed for a complete search of all the data on the cellular telephone may be
necessary, based on your affiant’s experience that suspect(s) who traffic in fraudulent
credit cards and identity theft will use cellular telephones to enhance their trade.

In order to assure that the cellular telephone can be examined (including a forensic
examination) all peripheral equipment, such as powering devices and external storage
devices will need to be collected along with manuals and support documentation. A
forensic examination of the cellular phone(s) in a controlled environment with forensic
equipment may be necessary in order to assist not only your affiant’s investigation, but
also the interests of the suspect(s) in this matter.

Statement of Probable Cause

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It is also your affiant’s experience and the experience of other investigators with whom
your affiant has spoken with that suspect(s) who traffic in fraudulent credit cards and
identity theft frequently possess computers to enhance their trade. These suspect(s) use
computers to house buyers and seller’s lists, track profits and losses, store receipts, and to
communicate with other persons involved in identity theft and fraudulent credit cards.
Thus, your affiant also requests if computers are located in possession of suspect(s) listed
and/or location(s) listed in the “to be searched page” being searched as authorized by this
warrant that your affiant be allowed to seize such computers.

An off site search of the suspect’s computer system, including all storage devices, is
needed as your affiant’s experience has shown that computer systems can store an
equivalent to hundreds of thousands or even millions of pages of information. Also, as
suspect’s can disguise or rename computer files at will, a complete search of all the data
on the computer system may be necessary. This can best be done in a controlled
environment with forensic equipment. This will assist not only your affiant’s
investigation, but also the interests of the suspect(s) in this matter.

In order to assure that the computer system can be forensically examined all peripheral
equipment, such as computer hardware, software and external storage devices will need
to be collected along with manuals and support documentation. Computer hardware
consists of all equipment which can collect, analyze, create, display, convert, store,
conceal, or transmit electronic, magnetic, optical, or similar computer impulses or data.

As evidence in this matter could be stored either on a computer hard drive or on

removable storage devices, such as, floppy disks, CD’s, or tapes, all removable storage
devices would need to be seized. Due to the storage capacity of removable storage
devices an on scene inspection of them would not be practical. With respect to computer
systems and any items listed above found during the execution with this Search Warrant, the
searching Peace Officers are authorized to seize and book said computer systems and any
items listed above and transfer them to a Law Enforcement Agency location prior to
commencing the search of the items. Furthermore, said search may continue beyond the

Statement of Probable Cause

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ten-day period beginning upon issuance of this Search Warrant, to the extent necessary to
complete the search on the computer systems and any items listed above.

Your affiant requests that the identity of the CI remain confidential for the following
reasons: disclosure will jeopardize the life and safety of the CI and disclosure will
destroy the CI’s future usefulness to law enforcement.

Statement of Probable Cause

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