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Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 1 of 43 PageID #:136

expenditures by sol,rs associatedwith the 25'nward Regular Democratic


organz5-ation are, in fact, personal expenditures. Additionally,
intercepted conversations suggest that sol,rs and his wife are renting
subject Location 4, which suggests that financial documents,
including the apartment lease and other records, will be l-ocated at
this location. For example, ofi or about March 2G, zoLs, at
approximately 11:55 a.m. (call #i87B), sor,rs placed an outgoing
call
on Target Phone 2 Lo a representative of the property
developer behind
The Roosevel-t Co1lect,ion, where subject r,ocation 4 is
located.
ouring the carl, the representative informed solrs that a two
bedroom, two bathroom apartment may become available in ,Ju1y.
so1,rs
informed the representative that he was looking L,o rent right
now
and may purchase a property as an investment Iater.
sol,rs arso said
t.hat he had a unit in River City (Subject lJocation 3) . In another
intercepted calr on or about June 19, 2015, at approximat,eLy 2z4L
p'm- (call- #13375), solrs placed an outgoing call on Target phone
2 to "Roxy" at the Roosevelt Colrection. During the caI1, Roxy
informed solrs that she had received his application, proof
of
income, and a copy of his identification in connection with
his rentar
of an apartment at the Roosevelt Colrection. During the caIr, sol,rs
informed Roxy that he would arrange to have his bank automatically
transfer rent for the apartment on a certain day
v. Subject Location 5

151. As described inAttachmenL E-1, subject r,ocation 5 is the


business premises of the copper Tan and spa, where sol,rs received

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Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 2 of 43 PageID #:137

prostitution services, as described above in paragraphs 59 Lhrough


T5,EsandSg.BasedonsurveillanceandnewsreportsrelatedLo
which
a Chicago Police Department raid on the Copper Tan and Spa,
video
occurred on or about.Tuty 31-, 20L3, Subject Location 5 has
surveillance equipment, which may provide evidence of soLIS's visiL'
the of payment for soLIS's visit, and' the identities of the
meLhod.

individuals who provided. services to soLIS and his companions '


L62 . Ad.ditionallY, according to its websit,e,
which is available

at www.coppertanspa.com, the business accepts mosL credit cards'


Basedonmyt.rainingandexperj-ence,Iknowthatbusinessesthat
in
accept credit cards maintain records of credit card Lransactions
order to receive pa)rment from the lender for the services rendered'
such businesses often maintain other financial records,
including
receipts, checks, bank and savings and loan records of deposit,
sLaLements and ot,her bank records, credit card statemenLs,
money

ord,ers, cashier, s checks, passbooks, cancelled checks, certificaLes


of deposit, Ioan records, customer account information, amd income

and exPense summaries.


1-63. Additionally, businesses such as the copper Tan and spa
ofLen maintain appointment books, calendars, client lists, details
of services rendered, the names of masseuses t'hat a client utilizes'
and other records of client visits, services rendered and conLact
i-nformation.Alltheforegoinginformationwillconstitute
evidence of visits by soLIS and his companions to Lhis
location'

LlZ
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vi. Target Phone 2

1-64. As further described inAttachment F-1, Target Phone 2 is


the cel1u1ar telephone used by SOLIS in the intercepted conversations
and text messages discussed above regarding the Subject Offenses.
165. Based upon my training and experience, f know that
information stored within a cel-lular phone may provide crucial
evidence of the "who, what, why, when, where, and how" of the criminal
conduct under investigation, t,hus enabling the United States to
establish and prove each element or alLernatively, Lo exclude the
innocenL from further suspicion. fn my training and experience, the
information stored within a ceIl phone can indicaLe who has used or
controlled t.he cell phone. This t'user attribution" evidence is
analogous to the search for "indicia of occupancy" while executing
a search warranL at a residence. In this case, establishing SOLIS,s
use of Target Phone 2 wilI, other things, establish his voice
among
identification in wire j-nterceptions made over Target Phone 2. In
addition, contacts lists, inst.anL messaging logs, and communications
(and the data associated with the foregoing, such as date and time)
may indicate who used or controlled the cel-I phone at a relevant time.
Further, such stored electronic data can show how and when the ce}1
phone and its related account were accessed or used. Such "timeline"
information allows investigators to understand the chronological
context of cell phone access, use, and events relating to the crime

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under invesLigation. This "timeline" information may tend to either


inculpat.e or exculpate the cel1 phone account owner.
166. Cellu1ar phones may contain relevanL evidence of the
Subject Offenses, including text messages made or received from
Target Phone 2 t.hat are located in the memory of Target Phone 2, which
messages may provide information regarding the identities of, and
t.he methods and. means of operation and communication used by, Lhe
participanls in the Subject Offenses. Moreover, d"igital photographs
located in t.he memory of Target Phone 2 may contain images of
participants involved in Lhe Subject OffehEes. Moreover, digital
photographs stored in Target Phone 2 may contain images of SOLIS,
SOi,IS's associaLes (including persons involved in or knowledgeable
about the Subject Offenses), places frequented by SOLIS leading up
to and during theSubject Offenses, and locations and

instrumentalities used in committing the Subject Offenseg.


t67. In addition, based on my training and experience, f know

that information stored within a cell phone may indicate the


geographic location of t.he ce}I phone and user at a particular t.ime
(e.g., IocaLion integrated into an image or video senL via email or
text message to include both metadata and Lhe physical location
displayed in an image or video). Stored electronic data may also
provide relevanL insight into the cell phone owner's sLate of mind
as it relaLes to the offense under invesLigation. For example,
informaLion in the cetl phone may indicaLe Lhe owner's motive and
intent to commit a crime (e.g., communications relating to the

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crime),orconsciousnessofguilt(e'g"deletingcommunicationsin
anefforttroconcealthemfromlawenforcement).Unlessthisdata
isdestroyed,bybreakingthecellphoneitselforbyaprogramthat
within the ce11 phone' such
deletes or over-writes the data contained
datawillremainstored.withinthecellphoneindefinitely.
1-68. Through experience as a law
enforcement officer and

throughtheexperienceofotherlawenforcementofficersasconveyed
tome,Ihave].earnedthatindividualsinvolvedincriminaloffenses
commonlyusecellulart.elephonesasameanstocOmmunicate.As
d.et.ailedabove,SoLlsusedTargetPhone2tocommunicaLewithanumber
to the subjeet offenses'
of individuals regard.ing and in connection
often sLore telephone
Individuals involved in criminal 0ffenses also
numbersandnamesornicknamesoffellowconspiraLorsont'heir
telephonesand'thet,elephonesalsoreflectrecentcallhistory.
Finally,individualsoftenusetextmessaginganddigital
photographsinfurtheranceoftheircriminalactivitythataresLored
oncellularterephones.Because,asexplainedabove,Target.Phone
there was Lelephonic
2 ts associated with solrs, because
in the subj ect offenges '
communication between participanLs involved
andbecause,inmyexperienceandintheexperienceofotheragenLs'
defend.antsusetelephonestocontactco-Conspirators,thereis
described further in
probable cause to believe Target Phone 2 '
Att'achmentF-].,containsevidenceoftheSubjeetoffenses.
vaa. Specifics Regarding Searches of Computer
Systems.

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L6g. Based upon my training and experience, and the training


and experience of specially trained computer personnel whom I have
Consulted, searches of evidence from Compulers commonly require
agents to download or copy information from the computers and their
components, or remove most or all computer items (computer hardware,
computer software, and computer related documentation) to be
processed later by a qualified computer expert in a laboratory or
other controlled environment. This is almost always true because of
the following:
a. Computer storage devices can store the equivalent of
t.housand.sof pages of information. Especially when the user wants
Lo conceal criminal evidence, he or she often stores it with deceptive

file names. This reguires searching authorities to examine all the


stored data to determine wheLher it is included in the warrant. This
sorting process can take days or.weeks, depending on the volume of
data sLored, and it wouId. be generally impossible to accomplish this
kind of data search on site.
b. Searching computer systems for criminal evidence is
a highly technical process reguiring expert skill and a properly
conLrolled environmenL. The vast array of computer hardware and
software available requires even computer experts to specialize in
some systems and applications, so it is difficult to know before a
search which expert should analyze the system and its data. The search
of a compuLer system is an exacting scientific procedure which is
designed to protecL the integrity of the evidence and to recover even

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hidden, erased, compressed, password protect.ed, or encr)r'pt,ed f i1es.


since computer evidence is exLremely vulnerabre Lo t.ampering or
destruction (which may be caused by mal-icious code or norma]
activities of an operating system), the controlled environment of
a laboratory is essential to its complete and accurate analysis.
L7o. rn order to fu1Iy retrieve data from a computer system,
the analyst needs all storage media as werl- as the computer. The
analyst needs arr the system software (operating , systems or
interfaces, and hardware drivers) and any applications software
which may have been used to creat.e the data (whether stored on hard
disk drives or on external media).
L71-. In order to gain access to data from a computer system and
t.o fulry analyze t,hat data, an analyst may need to have access to
the following information or equipment: (a) passwords, encrlption
keys, and other access devices that may be necessary to access the
computer equipment; (b) documents or ot.her items demonstrating the
presence or absence of computer software that. would al1ow others to
cont,rol the items, and presence or absence of security software
designed to detect such malicious software,. (c) document.s or other
items d.emonst.rating t.he attachment of oLher computer hardware or
storage media; and (d) counter forensic programs and associated data
that are designed to eliminate data.
l'72. fn addition, a computer, its storage devices, peripherals,
and Internet connection interface may be instrumenLalities of the

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.1 Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 8 of 43 PageID #:143

crime (s) and are subject to seizure as such if Lhey contain contraband
or were used to carry out criminal activity'

vLll-. Procedures To Be FolLowed In Searching


Computers and Electronic Storage Devices.
L73. The warrant sought by this Application will not authorize
the ,'seizure,, of computers and related media within the meaning of
Rule 41(c) of the Federal Rules of Criminal Procedure. Rather the
warrant sought by t.his Application will authorize the removal of
compuLers and related media so that they may be searched in a secure
environmenL. where practicable, however, agents will image the
computers and related media on-site-
L't4. With respect to t.he search of any computers or electronic
sLorage devices seized from the locations identified in Attachment.
A-1, B-1, C-1, D-1, E-1, and F-l- hereto, the search procedure of
electronic dat.a conLained in any such computer may include the
following techniques (the following is a non-exclusive fiit, and the
government may use oLher procedures thaL, Iike those listed below,
minimize the review of information not within the list of items to
be seized as set forth herein):
a. examination of ,lI of the data contained in such
\
compuLer hardware, computer software, and/or memory storage devices
to determine whether t.hat. data falls within the items to be seized
as set forth herein;

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t I Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 9 of 43 PageID #:144

b. searching for and attempting to recover any deleted,


hidden, or encrypted data to determine whether t.hat data falls within
the rist of items to be seized as set forth herein (any data that
is encrypted and unreadable will not, be returned unless law
enforcement personnel have determined that the data is not (1) an
instrumentality of the offenses, (2) a fruit of the criminal
activity, (3) contraband, (4) otherwiseunlawfullypossessed, or (5)
evidence of the offenses specified above);
c. surveying various file directories and the
individual files they contain to determine whether they include data
falling within the list of items to be seized as set forth herein;
d. opening or reading portions of files in order to
determine whether their contents fall within the items to be seized
as set forth herein;
e. scanning storage areas to discover data falling
within the list of items to be seized as set' forth herein, to possibly
recover any such recently deleted data, and Lo search for and recover
deriberately hidden files falling within the list of items to be
seized; an.d/or
f. performing key word searches through aII storage
media t.o determine whether occurrences of language contained in such
storage areas exj-st, that are }ikely to appear in the evidence
described in At,tachments A-2 , B-2, C-2, D-2, E-2, and F-2.
g. Any computer systems and electronic st,orage devices
removed from the premises during the search wil-1 be returned to the

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\r Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 10 of 43 PageID #:145

premises within a reasonabte period of t.ime not to exceed.30 days,


or unless otherwise ordered by the Court.
rv. coNcl.usroN
1,75 . Based on the above informat.ion, I respectfully submit t.hat
there is probable cause to believe that evidence, instrumentalities,
and fruits of the Subject Offenses are 1ocated within t.he Subject
Premises. By this affidavit and application, r request that the
Court issue a search warrant authorizing the search of the Subject
Premises f or the it.ems described in Attachments A-2, B-2, C-2, D-2,
E-2, and F-2.
FURTHER AFFIANT SAYETH NOT.

Steven
SpeciaT Agent
Federal Bureau of Investigation

Sworn to before me and subscribed in my presence


this 27th day of May, 201-6

es Magistrate Judge

t20
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ATTACHMENT A-1

DESCRIPTIONoFPREMISESToBESEARCHED

Tl:.eofficelocatedattL1NorthLaSallestreet,Rooms04'chicago'Il1inois'
of Alderman DANIEL SOLIS' The office is behind
a
which is the city Hall office
name and office
rioor. that states "Committee on Zortrtrg." The office bears SOLIS's

nnmber, 304. The entrance to the office is depicted below:


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ATTACHMENT A.2

I.IST OF ITEMS TO BE SEIZED

Evidence and instru.mentaij.ties concerning rriolaiicn of Title 18, United-

States Cod-e, Seciions 37L,666,1343, L346,1349, and 1951, as follo.rrs:

1. Campaign financral records including financial d-onations, in-krnd

contributions and expenditure records, reports, ledgers and receipts;

2. Information related to fundraising acti..zities including advertisements,

photographs, invitations, letters or records of contributors and/or attendees at


fundraising events;

3. Lists, spreadsheets or other records of potential or actual campaign

contributors including, but not limited to, contributors with potential matters before

the Chicago City Council or a representative body or committee thereof;

4. Calendars, schedules and communications of staff members;

5. Letters and correspondence concerning matters which have appeared

or may likely appear before the Chicago City Council or a representative body or

committee thereof, including the Zoning Committee, actions Daniel Solis has taken

on those matters, as well as benefits received by Daniel Solis from any other party;

6. Credit card statements, bills, payment records/ledgers or receipts;

7. Emplc).ee Faj/nrent recorci-s, tr incl,rrie IF.S rel-orting dccumenis su-ct,

a- f, i.its 1099 c r'Lrl)..


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B. Documents concerning occupancy of the Subject Premises (described

in Atiachment A.-1), such as u'uiJity and telephone bi,lis, mail enize1opes, or a,ddresseci

correspondence; a"nd

9. Computers, electronic devices and removal:le media siorage devices

ivhich may contain information reiaied- to the above items.

10. With respect to any computer equipment or other electronic devices:

a. Passwords, eacryption keys, and other access devices that

may be necessary to access the computer equipment.

b- Documents or other iterns demonstrating the presence or

absence of computer software that would allow others to control the


items, and presence or absence of security software designed to detect

such malicious software.

Documents or other items demonstrating the attachment

of other computer hardware or storage media.

d. Counter forensic programs and associated data that are


' designed to eliminate data.

11. Items in the paragraphs above that are stored in computer media,

including media capable of being read by a cornputer (such as exiernal a-nd iniernal
cor:eputer hard driires, melriorjr .qricl..s, and thumi: d-rives), and electroric <ierrices

;ha:u are ca-Fa-bls cf anal:,:i n;. :rei.ting, :[,srla,.;.i-r-;-, c3.i-,re;:;i,-rg, c,-, tra,:-igr-liir,irr:
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 14 of 43 PageID #:149

electronic or magnetic computer impulses or data (such as cellular telephones and

PDAs), shall be searched in accordance with tlne aitached Addendum.


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ADDENDUM TO ATTACHMENT A.2

Pui:suani io Ruie a1(eX2XB) of the Federal Bules of Criminal Procedure, ihis


"r,rarrant a-uthonzes ihe remo,zal of el"ecironic siatage raedia and co;oying of
electrcnicaliy sioi:ed- information fou-nd in the premrses described in A'ciachmen,c I!-1
so ihai ihe}, m2;' be revie-rrred in a secure en-rironm.ent foi: rnforma'cion coasisl:en,i
vrith the ',rra::r'ani. That revie'w shall be conducied pursuan'c to the foliox,ing
pi'otocol:

The review of electronically stored information and electronic storage meclia


removed from the premises described in Attachment A-1 may include the ioilowing
techniques (the following is a non-exclusive list, and. the government may use other
procedures that, like those listed below, minimize the review of information not
within the list of items to be seized as set forth herein):

a' examination of ali the d.ata contained in such computer hardware,


computer software, and/or memory storage devices to determine
whether that data falls within the items to be seized as set forth in
Attachment A-2;

b. searching for and attempting to recover any deleted, hidden, or


encrypted data to determine whether that data falls within the list of
items to be seized as set forth in Attachment A-2 (any data that is
encrypted and unreadable will not be returned unless law enforcement
personnel have determined that the data is not (1) an instrumentality
of the offenses, (2) a fruit of the criminal activity, (B) contraband, (4)
otherwise unlawfullypossessed, or (5) evidence of the offenses specified
above);

surveying file directories and the individual files they contain to


determine whether they include data falling within the list of items to
be seized as set forth in Attachment A-2; and

d. opening or reading portions of files, and performing key word searches


of r'iles, in order to determine rvhether 'cheir contents fall rcithin ihe
iterns 'uo be seized as se'c for'uh in Atta,climen.i A-2.

Tire gc.,rerr.rrr€l1i, :^ri]i r.eculn e.r:!t, elecircnrc si,crt,p,:e


iescriJ;eC .ir .ar:t:-c,:rr,.,ent, ,ll- -1 rt,;i il_r,i n -! 3 C,:-.rS
.r-r-{'a:a:itses
ilr--.i-..,.': P"f,: j-l':),.t ..t. 'l-1. i,r;: -1,^i
r t:('' ^-
-
|
rl.- --
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removed eiectronic storage media contains coniraband or constitutes an


instrumentality of crime, or unLess otherwise ordered by the Court.
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ATTACHMENT 8.1

DESCRIPTION OF PREMISES TO BE SEARCHED

The office located at 1645 South BIue Island Avenue, Chicago, Iilinois, which

is the 25ih Ward office for Alderma"n DANIEL SOLIS and the location of Citizens

for Danny Solis and the 21thWard Reguiar Democratic Organi zation. The entr.ance

to the office located at 1645 South Biue Island Avenue is depicted in the attached

photograph:
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r_':"a
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ATTACHMENT 8.2

LIST OF ITEMS TO BE SEIZED

Evidence and instrumentalities concerning violation of Title 18, United


,states cod-e, sections 371, 666, 1943, 1rB4G,lz4g, anri 1g51, a-s follows:

1. Campaign financiai records including financial d-onations, in-kind-

contributions and expenditure records, reports, ledgers and receipts;

2- Information related to fundraising activities including advertisements,

photographs, invitations, letters or records of contributors and/or attendees at


fundraising events;

3. Lists, spreadsheets or other records of potential or actual campaign

contributors including, but not limited to, contributors with potential matters before

the Chicago City Council or a representative body or committee thereof;

4. Calendars, schedules and communications of staff members;

5. Letters and correspondence concerning matters which have appeared

or may likely appear before the Chicago City Council or a representative body or

committee thereof, includ.ing the Zoning Committee, actions Solis has taken on

those matters, as well as benefits received by Daniel Solis from any other party;

6. Credit card statements, bills, payment records/ledgers or receipts;

7. Employee payrnent record.s, to include IRS reporting documents such

as iorms 1099 or rrlr2:


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8. Documents concerning occupancy of the Subject Premises (cLescribed in

Attachment B-1), such as utility and teiephone biils, mail envelopes, or addressed

correspondence; and

I' Computers, etrecti:onic de',zices and remo..zable media storage d-evrces

which ma-y contain information related to the abo.re items.

10. With respect to any compuier equipment or oiher electronic devices:

a. Passwords, encrJ4ption keys, and other access devices that

may be necessary to access the computer equipment.

b. Documents or other items demonstrating the presence or

absence of computer software that would allow others to control the


items, and presence or absence of security software designed to detect

such malicious software.

c. Documents or other items demonstrating the attachment

of other computer hardware or storage media.

d. counter forensic programs and associated data that are

designed to eliminate data.

11. Items in the paragraphs above that are stored in computer media,

including media capable of being read by a computer (such as external and" internal
computer hard drives, memory sticks, and thumb drives), and electronic devices

ifhat are cairal:le of analirzing, cr:eating;, riisrtaying, con-,zertinE, cr ira-nsrnitr,iup-


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electroni.c or magnetic computer impulses or data (such as cellular telephones

PDAs), shall be searched in accordance with the attached Addendum.


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ADDENDUM TO ATTACHMENT 8.2

Put:suant to Rule a1(e)(2XB) of the Federai Rules of Criminal procedure, th.is


wa.i:rant authorizes the remo.ral of elecrronic storage media and copyrng cf
elecci:onicaliy s'tored informaiicc fou::d in the premises described j-n Atl,a,chnei,rt
B-_l
sc i'iia''; tbey rne,y be rerzie-wed in a secure e&'/1i'oriment for informa-'bicn consis,uen.i
''riiLh the '/:'ra-ria-11t" That r'evie w sha-ll be co-ad-uc'ue ci i:u-r-span'r ic ihe folicwirip
prcbocol:

The revievr of electronicaliy s'uored infoi'matior and electronic stor.age media


removed from the premises described in Attachment B-1 may inchde the ioilo-r,ring
iechniques (the following is a non-exclusive list, and the government rnay use other
procedures that, like those listed below, minimize the rerriew of information
not
v'zithin the }ist of items to be seizecl a-s set forth herein):

a. examination of all the data contained in such computer hardware,


computer software, and/or memory storage devices to determine
whether that data falls within the items to be seized as set forth in
AttachmentB-2;

b. searching for and attempting to recover any deleted, hidden, or


encrypted data to determine whether that data falls within the list of
items to be seized as set forth in Attachment B-2 (any data that is
encrypted and unreadable will not be returned unless law enforcement
personnel have determined that the data is not (1) an instrumentality
of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4)
otherwise unlawfully possessed, or (5) evidence of the offenses specified
above);

surveying file directories and the individual files they contain to


determine whether they include data falling within the list of items to
be seized as set forth in Attachment B-2: and

d. opening or reading portions of files, and performing l<ey word searches


of files, in order to determine whether their contents fall within the
items to be seized as set forth in "Aitachment B-2.

v;ili i:ei,urri an;i flf oi:age rleiiia renicved f.:um


it l,l.ac].r.-,,,:r. . -B .o0 ,:la,', Ci .-'.',. :,E,,:ril',:,1,-,r.r]
(,'; :ir: (3) ii tirc .-l..ll-ai J' C'l'rr-rn:,1 Pi.'a,-:dlr., g.
-,ia-:.-':: irr:1-rlr 1i. r L'l- -'arl ,,,:l,-tr.'--.Jllt'1,i,.1-r.,i:),,
,, ,tli' ']i I
lr
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ATTACHMENT C.l

DESCRIPTION OF PR,EMISES TO BE SEARCHED

The apartment located at 800 South Wells Street, lJnit 522, Chicago, Illinois.

The apartment is located within a multi-unit building known as River City. The

residence is located on the "RR" level of River City. And address placard with ,nit
number "522" is affixed to the wall adjacent to the entrance. The entrance to Unit

522 is a solid panel entrance door with a silver colored door knocking device

attached.
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 24 of 43 PageID #:159

ATTACHMENT C-2

LIST OF ITEMS TO BE SEIZED


Evidence and instrumentalities concerning violation of Title 1g. United
states code, sections 371, 666, 1848, 1846, LB4g, and lgbl, as follows:

. 1' Items reiating to DANIEL SOLIS's personal finances, loans and


expenditures, to include:

a. Books, records, journals or other records oforiginal entry;

b. Ledgers and other records of assets, liabilities, or capital

account balances;

c. Records of income or expenses including invoices and

receipts;

d. records oflessors or lessee;

e. records of receipts or disbursements;

f. accounting information;

g. bank statements, check registers, or canceled checks;

h. duplicate d.eposit tickets;

i. bank account reconciliations;

j. passbooks, certificates of deposit, money ord.ers, or


cashier's or official checks;

tr.. r'ecold,g of 1:ai,rcl| or er-,;;lclree earlings;


Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 25 of 43 PageID #:160

l. records ofbartering activity such as exchanges ofproperty

or.services;

m. financial statements or copies of tax returns;

n. docurne,ts and items co,celning economic and other

benefits received by Daniel soris from any other party;

2' Credit card statements, bills, payment records/ledgers or receipts;

3' Documents concerning occupancy of the Subject Premises (described

in Attachment C-1), such as utility and telephone bills, mail envelopes,


or addressed
correspondence; and

4' Computers, electronic devices and removable media storage devices

which may contain information rerated to the above items.

5' With respect to any computer equipment or other electronic devices:

a. Passwords, encr5rption keys, and other access devices that

may be necessary to access the computer equipment.

b. Documents or other items demonstrating the presence or

absence of computer software that would" allow others to control the


items, and presence or absence of security software designed" to detect

such malicious software.

Documents or other iterns demonstrating the attach*re,t

o f, o.i lir: r" co ntp i,t c. L ir i,,i,d.,.i, a.i e o:_. s t,o r a p e ri: e c} a-.
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 26 of 43 PageID #:161

d. counter forensic programs and associated data that are

designed to eliminate data.

6. Items in the paragraphs above that are storecl in computer


media, including media capable of being read b5, a computer (sucir as external and

internal computer hard drives, memory sticks, and thumb drives), and electronic

devices that are capable of anaryzing, creating, displaying, converting, or


transmitting electronic or magnetic computer impulses or data (such as cellular

telephones and PDAs), shall be searched" in accordance with the attached


Addendum.
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 27 of 43 PageID #:162

Pursuant to Rule al(e)(2XB) of the Fecleral Rules of Crirninal pr.ocedure, this


rva::rant authorizes the remorzal of electronic storage meclia and cop5ring
of
electronically stoled information for,rnd in the premises clescribe4 in Attachmen1
C-l-
so that they may be reviewed in il $lecure environment fcl. inforrnation
with L'lie '"Varrant- TLrat re.rie.w shall be cr:nduc'i,ed pursualt to theconsistent
foliov,,ing
protcc<;l:

The review of electronicall5, stored information and electronic stor.age me4ia


removed from the premises describecl in Attachment C_1 ma5, include
the iollowing
techniques (the following is a non-exclusive list, and the governrnent may
Llse other
procedures that, iike those listed below, minimize the review
of information not
within the list of items to be seized as set forth herein):

a. examination of all the data contained in such computer hardware,


computer software, and/or memory storage devices to determine
whether that data falls within the items to be seized as set forth in
Attachment C-2;

b. searching for and attempting to recover any deleted, hidde,, or


encrypted data to determine whether that data falls within the list of
items to be seized as set forth in Attachment c-2 (any d"ata that is
encrypted and unreadable will not be returned unless law enforcement
personnel have determined that the data is not (1) an instrumentality
of the offenses, (2) a fruit of the criminal activity, (B) contraband, (4)
otherwise unlawfully possessed, or (5) evidence of the offenses .p".ifi.d
above);

C. surveying file directories and the individual files they contain to


determine whether they include data falling within the tist of items to
be seized as set forth in Attachment C-2; and

d' opening or reading portions of files, and performing key word. searches
of files, in order to determine whether their contents falt within the
iteins to ]:e seized as set, forth in Attachment C_2.

'Ii--te gc,,,'eL::r,.ei:t -,r,r:li rgi-,,1r.i, .rj- elet.': ct,,iil ;iri-oriil-ge


._-, ,"i: edi a r'er:Lo1,'ed fi.,.1,:_. ii:e
ilr'C'!riiSst CCict',rl:i]i] ir,. rr,i.ia-CitlI:-C:.i i...]a,r,,1i1.,i;. ia) a:,-'' I- i.-1. '.-'::-C':', -,--,:,,,,.
rj .-:l-'...ri-l .r.!.- i,c E;,-le 4,1 (c)i-j) cr, (3) :f ir..c ,iCcierr:_.,i '
lt'i,;ICl Oi ..' .._. '...,.].
l. .:q.- 1..
. ,. .,....j
aD
,l
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 28 of 43 PageID #:163

removed electronic storage media contains


instrumentality
contraband
of crime, o, unress otherwise ordered by
or constitutes an
the court.
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 29 of 43 PageID #:164

ATTACHMENT D-l

DESCRIPTION OF PREMISES TO BE SEARCHED

The apartment located at 1135 South Delano Court, Unit 812 East, Chicago.

llliiiois. The apartment is located within a multi-unit apartment complex knovrn as

Tlre Roosevelt Collection. As shown below, the numb er "BLZE" is shown next to the

entlance to the Subject Premises.


Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 30 of 43 PageID #:165

ATTACHMENT D-2

LIST OF ITEMS TO BE SEIZED


Euridence and instrumentalities concerning violation of Title 1g, Ulitecl
si,aies code, sections BT1, 666, 1z4B, ra46,l}4g, and 1g51, as follows:

1. Items relating to DANIEL SOLIS'g personal finances, loans anrl


expenditures, to include :

a. Books, records, journals or other records oforiginal entry;

b. Ledgers and other records of assets, liabilities, or capital

account balances;

c. Records of income or expenses including invoices and

receipts;

d. records oflessors or lessee;

e. records of receipts or disbursements;

f. accounting information, incruding trial balances or work

sheets adjusting, reclassifiring, closing, or reversing entries;

g. bank statements, check registers, or canceled checks;

h. duplicate deposit tickets;

i. bank account reconciliations;

j" passbooks, certificates of deposi,u, rllonej/ ord,ers, or


:asl,ier''s cr lfficia_i cLecLrr;

1... :.,ec:i,,1-r, :f pa..';:cii cr. eLiIlIc.).:: ear._,ii,r3;,..,;


Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 31 of 43 PageID #:166

l. records ofbartering activity such as exchanges ofpropertv

or services;

m. financiai statements or copies of tax returns;

n. documents and items concerning economic ancr otrrer

. benefits received by Daniel soris from any other party;

2' Credit card statements, bills, payment records/ledgers or receipts;

3' Documents concerning occupancy of the Subject premises (described

in Attachment D-1), such as utility and telephone bills, mail


envelopes, or addressed
correspondence; and

4' Computers, electronic devices and removable media storage


devices
which may contain information related to the above items.

5' With respect to any computer equipment or other electronic devices:

a. Passwords, encryption keys, and other access d.evices


that
may be necessary to access the computer equipment.

b. Documents or other items demonstrating the presence


or
absence of computer software that would alrow others to contror the
items, and presence or absence of security software designed
to detect
such malicious software.

c. Docurnents or other items d,emonstrati*g the attachme,t

:f ci,her ccmputer harc vare cr storage n,ed-ia.


Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 32 of 43 PageID #:167

d. counter forensic programs and associated data that are

designed to eliminate data.

6" Items in the paragraphs above that are sior.ecl in comiruter


ileclia, including media capable of being read by a computer (such as
externai a*cl
inter:na} computer hard drives, memory sticks, and thumb drives),
and electronic
clevices that are capable of analyzing, creating, displaying, converting, or
tlansmitting electronic or magnetic computer impulses or d.ata (such
as cellular
telephones and PDAs), shall be searched in accordance with the attached
Acldendum.
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 33 of 43 PageID #:168

ADDENDUM TO ATTACHMENT D.2

Pursuant to Rule 1(e)(2XB) of the Federal Rules of Criminal Procedure, this


-warLant, authorizes the removal of eiectronic storage media and copying of
eiect,.onicall5, 966r*6 information found in the premises described in Attachment D-1
so that, they may be revie,,ved in a secul"e environment for information consistent
.r,il.ir the rvarlant. That revievr shall be conducted pursuant tc the foliowing
irlotocol:

The rerriew of electronically s'uored information and electronic storage media


rernoved from the premises described in Attachment D-1 may include the following
techniques (the foliowing is a non-exclusive list, and the government may use other
plocedures that, like those listed below, minimize the review of information not
rvithin the list of items to be seized as set forth herein):

a. examination of all the data contained in such computer hardware,


computer softwilre, and/or memory storage devices to determine
whether that data falls within the items to be seized as set forth in
AttachmentD-2;

b. searching for and attempting to recover any deleted, hidden, or


encrypted data to determine whether that data falls within the list of
items to be seized as set forth in Attachment D-2 (any data that is
encrypted and unreadable will not be returned unless law enforcement
personnel have determined that the data is not (1) an instrumentality
of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4)
otherwise unlawfully possessed, or (5) evidence of the offenses specified
above);

C. surveying file directories and the individual files they contain to


determine whether they include data falling within the list of items to
be seized as set forth in Attachment D-2; and

d. opening or reading portions of files, and performing key word sealches


of files, in order to determine whether their contents fall rn,ithin the
iiems to be seized as set forth in Attachrnent D-2.

'ILie Eo',rerrln:-ent ..trill retrr,:n ailjr eiect,. criic st,cra g.e nred-ia r'3riri.r reC ftin :,1-:
::r, ,r,;,.:l,l iei,rciiJ,.ed ii; r..t::ii,ii:,- l- D- 'l -,-,;..;i 3 . i-: cf lhe reil:c-,,a1 rur:i,.-r[.i:r.
i;,.r -!'-,t r'c Eui.: ai(c)(2) ,:r l-e) :f rhe .f ',.Cie la,l E rii:r: ,:f rll iir lr r, P .--irr:, . r;,-,
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 34 of 43 PageID #:169

removed electronic storage media contains contraband or constitutes an


instrumentality of crime, or unless otherwise ordered by the Court.
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 35 of 43 PageID #:170

ATTACHMItrNT E-l

I]ESCRIPTION-OF' PR,EM:tSES TCI BE SMARCHE.!]

'L l',e j,-',,i,,-!iie ,.:ril ]::._?c,.ir;=r all ''f;ilF1,rt:-,_- 'f'Etn and ,ll::r-"'' lr;,_::,iill,,i ,,..i

ri''/3r.r1-.r--i- l'l:i:,'-zt:,, i-tlincii:. ir; ioc:iie,J rn ilre frsL ii,:rr.L tl r r,.1,.;-s,1,i;i

s].lo',,,.+ J:elcrr, r,he sigil "Cc1;1:e.*'I'ar.t Ii,. Cl'.,a" liriiigs o.,e],"ilte fi:rsl, j-loo'.: .ii

i'Jeon iight,s ,-.ea-ding "ope1r," "lidassage," ancl "Facial" trrang in Lhe f:;ani, rr,rindorr,, cf

the business" The number "1052" appears over the entrance to the business.
a
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 36 of 43 PageID #:171

ATTACHMENT E-2

LIST OF ITEMS TO BE SEIZED


Evidence and instrui:rentalities concerning violation of Title 1g, Uni,ied
s.iates code, sections sJl, 666, l}4z, 1846, lz4g, and lgb1, namely, i.tei's
evidencing visits
to the Subject Premises (as clefined in Attachment E-1) I:y
Daniel solis and his comi:anions (to include Roberto caldero),
to include the
following items:

1. Video surveillance equipment and recordings;

2' Financial records, including receipts, checks, bank and savings


an4
loan records of deposit, statements and other bank records,
credit card statements,
money orders, cashier's checks, passbooks, cancelled checks,
certificates of deposit,
loan records, customer account inform'ation, and income
and expense summaries.
3' Appointment books, calendars, client lists, details of services
rendered,
the names of masseuses that a client utilizes, and other records
of client visits,
services rendered and contact information; and

4' Computers, electronic devices and removable media storage


devices
which may contain information related to the above items.
a
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 37 of 43 PageID #:172

Pursuant to Rule a1(eX2XB) of the Federal Rules of Criminal procedure,


-warran.-L this
authorizes the I'emo'za-l of electronic stora-ge media and copying
electrcnically siored infoi:n:a',,ion found in the pre:nises described of
in Ati;achment E-i
so -bhat they ma5' be reviewed in a secure environmenL for
information consistent
'wiih the war"rant. 'Ihat le.,,iev,z shall be conducted pursuani to the follorving
protocol:

The review of electronically stored inforrnaiion and eiectronic


storage media
removed from the premises described in Attachment E-1 may
include the following
techniques (the following is a non-exclusive list, and the government
may use other
procedures that, like those tisted below, minimize the
review of infbrmation not
within the list of items to be seized as set forth herein):

a. examination of all the data contained in such computer hardware,


computer software, and/or memory storage devices to determine
whether that data falls within the items to be seized as set forth
in
AttachmentE-2;

b. searching for and- attempting to recover any deleted., hidden,


or
encrypted data to determine whether that data falls within the
1ist of
items to be seized as set forth in Attachment E-2 (any data
that is
encrypted and unreadable will not be returned unless law enforcement
personnel have determined that the data is not (1)
an instrumentality
of the offenses, (2) a fruit of the criminal activiiR (B) contraband, (4)
otherwise unlawfully possessed, or (5) evidence orihe offenses
.p".iri.a
above);

surveying file directories and the individual fites they contain


to
determine whether they incrude data falring within the riit of items to
be seized as set forth in Attachment E-2; and

d. opening or reading portions of files, and performing key word


searches
of file"s, in order to determine wheth"" ihui, contlnts fail within
the
iterns to be seized as set forth in A.ttachment E-2.

'l'l:, e Ctief ni:i,. e tt.t


E ?,ri'r; rj c stcr a ge nr : Jiri i:e r.nc-,.,,:d frc rrr l;l,ie
el-3c.t,.ac
pl:rrris,:s les:ribei i11 E2 .r'i'u!.rirt 3'3 c,a-,,s cl .it,: t:e-,::rrc-.,a.l tinies,,,.
pr-;-i,luani, r' I'rl. Jl,_, .li: l1:icr:rl }ri:: -_f Cri:irri.r:.i 11::e :r,li€. rir::
ia Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 38 of 43 PageID #:173
'l

removed electronic storage media contains contraband or constitutes an


instrumentality of crime, or unless otherwise ordered by the Court.
i? Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 39 of 43 PageID #:174

ATTACHMENT F-1

DESCRIPTIONoFPR0PERTYToBESEARCHED

The cellu-lar 'celephone bearing the numb er (3LZ) 2OB-A292, International

Mobile subscriber Identity Number ('IMSI") 310410840352309, a cellu-lar

telephone on the system operatecl by the service provider AT&T', subscribed


to

"Daniel So1is, 6148 Rob Roy Dr., Oak Forest, IL 60452'"


1,
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 40 of 43 PageID #:175

ATTACHMENT F-2

LIST OF ITEMS TO BE SEIZED

Erridence and instru.menia,liti.es concerning viola.tion of Tj.tle 18, United-

S.i,a,tes Code. Seci;ions 37-1,,666, 1343, 1346, 1349, and 1951, as follows:

1. Items indicating use or control of the cell phone, including contacis

lists, instant messaging logs, call history, and communications (and ihe data

associated. with the foregoing, such as date and time);

Z- Comrnunications, including voicemails and text messages, relating to

the Subject Offenses as d"escribed in the affidavit of Special Agent Steven Noldin

submitted in support of the application for search warrant, including


communications, voicemails and text messages concerning the following:

a. campaign financial records including financial donations, in-

kind. contributions and expenditure records, reports, ledgers and receipts;

b. information related to fundraising activities including


and/or
advertisements, photographs, invitations, letters or record"s of contributors

attendees at fundraising events;

c. lists, spreadsheets or other records of potential or actual

campaign contributors including, but not limited to, contributors with


potential

matters befor.e ,uhe Chicago Cii5z Courncil or a represen'raiive body or commitiee

i1ir=re:'i'.
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 41 of 43 PageID #:176

e. communications concerning matters which have appeared or

may likely appear before the Chicago City Council or a representative body or

committee thereof, including tne Zunrrrg Committee, as well as benefits received by

Daniel Solis from any other party;

. f. credit card statements, bi}ls, payment records/ledgers or


receipts;

g. employee payment records, to include IRS reporting d.ocuments

such as forms 1099 or W2;

3. Dig-ital photographs of co-conspirators or relating to the Subject

Offenses as described in the affidavit of Special Agent Steven Noldin submitted in

support of the application for search warrant; and

4. Items indicating the geographic location of the cell phone and user at a

particular time (e.g., location integrated into an image or video sent via email or

text message to include both metadata and the physical location displayed in an

image or video).
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 42 of 43 PageID #:177

ADDENDUM TO ATTACHMENT F-2

Pursuani to Rule 1(e)(2)(B) of the Federai RuLes of Criminal Procedure, this


--;,zanant authorizes ihe remo.ra-l of electroni.c storage medi,a and copying of
elec'ti:onica.!.1y storer} information fcund in ihe prernises desclibed irl Attachmeni F-1
sc 'blrat 'chey ria5r be reozielved in a secure environn:.ent foi infor'.,na'cion consi,steni
.wi';h tite ,r,rarra-nt. Thai revie:r,, shall be conCucted- pu-i:st-lant to the foli,owing
pro'cocoi:

The review of electronicallS, stored, information and- electronic storage media


removed from the premises described in Attachment F-l may include the following
techniques (the following is a non-exclusive list, and the government may Llse other
procedures that, like those listed beLow, minj.mize the review of information not
within the list of items to be seized as set forth herein):

a. examination of all the data contained in such computer hardware,


computer software, . and/or memory Storage devices to determine
whether that data falls within the items to be seized as set forth in
Attachment F-2;

b. searching for and attempting to recover any deleted, hidden, or


encrypted data to determine whether that data falls within the list of
items to be seized as set forth in Attachment F-2 (any data that is
encrypted and unreadable will not be returned unless law enforcement
personnel have determined that the data is not (1) an instrumentality
of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4)
otherwise unlawfully possessed, or (5) evidence of the offenses specified
above);

surveying file directories and the individual files they contain to


determine whether they include data falling within the list of items to
be seized as set forth in Attachrnent F-2; and

d. opening or reading portions of files, and performing key word searches


of files, in order to determine whether their contents iall within the
items to be seized as set forth in Atiachment F-2.

Tli.- pc,r:r:rry1,:i-tt ll,i.] ret'-r:'rtr z-fr.;,, e1ec,,rcr-ric s'icrag-e n,.eC.ia 1"1,1n,,r-'i frcrr :l'e
',;.iifii1;i 3C Ca:'i' c'l the ie jr-ic:rEr,l t-r-',Less,
I, -,:)r-:!ii:te: descr'.Led llr ,{ir,ochr:€n: ir' l 'P,''-^re,:lrrt
1,i-rr.'l-:ue-r:.. r: P.,:!e
2.11,)(?) :, ill -.,i --li, F: j:ra. P.i.ri'.r ',1 t--t-ir: ,:r:.1 i:. tli':
J

a
Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 43 of 43 PageID #:178

removed electronic storage media contains contraband


instrumentality of crime, or unress otherwise ordered or constitutes an
by the court.