A search warrant to Skype that produced vague information about its account holder that essentially could have been anyone because there was no verification by Skype was insufficient to show probable cause, and plaintiffs get summary judgment on that question. The state judge who signed off on the search warrant later reversed himself and found no probable cause. “Moreover, there was actually evidence indicating that the suspect had supplied a false email address in registering with Skype.” Finkelstein v. San Mateo County Dist. Attorney’s Office, 2018 U.S. Dist. LEXIS 198857 (N.D. Cal. Nov. 21, 2018).
The CI’s identity isn’t subject to disclosure except when a material witness, and there’s no such showing here. United States v. Taylor, 2018 U.S. Dist. LEXIS 196412 (D. Minn. Nov. 19, 2018).*