A CI gave emails to government investigators about health care fraud. They and other information provided probable cause for more emails. The warrants were particularized by being limited to eight categories. United States v. Mathieu, 2018 U.S. Dist. LEXIS 192281 (S.D. N.Y. Nov. 10, 2018):
The search warrants are particularized and not overbroad. First, the warrants describe the place to be searched as email accounts firstname.lastname@example.org and email@example.com, which were operated by Google and Yahoo, respectively. Second, the warrants sufficiently describe the items to be seized as email content from between April 1, 2007, to December 31, 2013, related to nine categories detailed in Part III of the warrants. While Defendant argues that the warrants are overbroad because Part II of the warrants directed the service providers to produce “all email content” from the accounts, Part III constrains review of the documents to the eight relevant categories related to the offenses. The warrants therefore satisfy the basic elements of the particularity requirement and are not overbroad. See Zuniga-Perez, 897 F.3d at 123 (internal quotation marks omitted) (“The warrant must describe with particularity the place to be searched and the items to be seized.”).