E.D.Va.: SW for Manafort’s house is upheld

(1) “In sum, the warrant here (i) identified the items to be seized in relation to specific Subject Offenses, (ii) included an illustrative list of records to limit the discretion of executing agents, and (iii) provided a sufficient description of the categories of items to be seized given the nature and circumstances of the crimes at issue. Accordingly, the warrant was adequately particularized and suppression on this ground is inappropriate.” (2) The officers detailed specific information that electronic devices would be found in defendant’s home. “These facts, taken together, lend ample support to the common-sense conclusion reached by the magistrate judge here, namely that probable cause existed to believe (i) that defendant’s electronic devices would contain evidence relevant to the Subject Offenses and (ii) that the devices in question would be located at defendant’s residence.” (3) “In sum, the warrant here also satisfied the breadth requirement of the Fourth Amendment by adequately limiting the scope of the warrant by the probable cause on which the warrant was based. Accordingly, suppression on this ground is unwarranted.” (4) Even if the search warrant was issued without probable cause, the good faith exception would save it. (5) The search warrant was not executed unreasonably. United States v. Manafort, 2018 U.S. Dist. LEXIS 116033 (E.D. Va. July 12, 2018).*