D.Nev.: Email SW limited to a date range and containing keywords was particular

Email search warrant limited to a date range and containing keywords was particular. United States v. Cariani, 2019 U.S. Dist. LEXIS 177059 (D. Nev. Oct. 10, 2019):

After reviewing the search warrant, the Court finds that it is not overbroad, and the items to be seized within are described with sufficient particularity. As an initial issue, Cariani confuses the difference between disclosure and seizure. While the warrant required Apple to disclose the entire contents of Cariani’s email address as electronically stored information (‘ESI’), it only allowed the government to seize content starting from December 1, 2014, and only the content related to the identified search terms. (ECF No. 40-1 at 6). The Ninth Circuit has repeatedly rejected the argument Cariani makes here, most notably in U.S. v. Flores, 802 F.3d 1028 (9th Cir. 2015). …

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