D.Minn.: Affidavit at scene of execution of SW helps narrow its overbreadth

“Given the scope and pervasiveness of the fraud alleged, the search warrant issued for Ms. Natysin’s home was not overly broad.” “This finding is supported in part by the fact the affidavit accompanied the warrant to the search and was available for officers conducting the search to refer to. This affidavit helps further define the ‘overarching purpose of the search,’ which was to discover evidence related to a well-defined fraudulent wire transfer scheme. See id. The fact that the warrant permitted seizure of items maintained or stored by Ms. Natysin’s husband does not render the warrant overbroad in this circumstance, where the fraud alleged is widespread and where fraudulent payments were concealed by being made to bank accounts owned by Ms. Natysin’s husband.” United States v. Natysin, 2018 U.S. Dist. LEXIS 165364 (D. Minn. Aug. 27, 2018), adopted, 2018 U.S. Dist. LEXIS 164911 (D. Minn. Sep. 26, 2018).

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