A search warrant for email can be for servers outside the jurisdiction of the court. United States v. McGuire, 2017 U.S. Dist. LEXIS 114471 (D. Nev. Feb. 9, 2017).
The Coast Guard was surveilling Arroyo Quemada Beach in Santa Barbara County for panga boats smuggling marijuana. They saw activity consistent with smuggling and offloading what could have been marijuana. The SBSD also came to surveil and what they saw gave them reasonable suspicion for stopping the vans leaving the area of the boats. United States v. Garcia, 2017 U.S. Dist. LEXIS 116407 (C.D. Cal. July 24, 2017).*