Google and NCMEC did not conduct Fourth Amendment searches when they encountered child pornography tied to his email account. They did private searches for their own purposes, and NCMEC did not expand Google’s private search. United States v. Ringland, 2019 U.S. Dist. LEXIS 311 (D. Neb. Jan. 2, 2019).
The defense doesn’t get the informant’s name just on a desire to talk to the informant in the hopes of getting exculpatory information. United States v. Mills, 2019 U.S. Dist. LEXIS 23 (E.D. Mich. Jan. 2, 2019).* Similar is information on a “tipster.” United States v. Clayborne, 2019 U.S. Dist. LEXIS 70 (E.D. Wis. Jan. 2, 2019).*