N.D.Fla.: Email SW didn’t required search protocol be stated in SW

“The officers followed a reasonable protocol in conducting the search. The protocol was not in the warrant, but this did not render the warrant defective. See United States v. Khanani, 502 F.3d 1281, 1290 (11th Cir. 2007). And in any event, the warrant was not so plainly defective that officers could not rely on the warrant in good faith. See United States v. Leon, 468 U.S. 897, 104 S. Ct. 3405, 82 L. Ed. 2d 677 (1984). [¶] The officers seized only material authorized by the warrant.” United States v. Giovanni, 2018 U.S. Dist. LEXIS 106199 (N.D. Fla. June 25, 2018).

Omitted material wasn’t a Franks violation because probable cause would still have been found. “The warrant described the things to be seized with sufficient particularity. The Eleventh Circuit has made clear that a description is not defective just because it relies in part on a reference to the underlying offense. … And in any event, the description was not so plainly deficient that officers could not rely on the warrant in good faith.” United States v. Giovanni, 2018 U.S. Dist. LEXIS 106200 (N.D. Fla. June 25, 2018).*