D.Conn.: This drug case SW was broad but the attachments narrowed it enough

“The warrant here, although broad, did not lack particularity in terms of data to be searched. The warrant incorporated two attachments relevant to this inquiry. See Groh v. Ramirez, 540 U.S. 551, 557-58 (2004) (establishing that a court may construe a warrant with reference to a supporting application or affidavit). First, in Attachment A, it clearly specified the property to be seized and searched-Defendant’s cell phone-as well as the appropriate time and place such seizure may occur as further described in Attachment B. … Next, in the first paragraph of Attachment B the warrant limited itself to searching for data that might reveal evidence that Defendant violated 21 U.S.C §§ 841(a)(1), 843(b), and 18 U.S.C. § 1956, the drug trafficking offenses for which he was a suspect. … Attachment B then lists several categories of data that might have revealed evidence of this activity, such as ‘photographs and videos’ as well as encrypted communications, contact lists, ‘notes, records, ledgers, and documents indicative of drug trafficking.’ … By incorporating Attachments A and B, the warrant lists the charged crimes, describes the item to be seized, and describes the information to be searched in connection with the specified criminal conduct.” As for the search and seizure of a cell phone, the fact the phone search was delayed was not unreasonable. The papers contemplated the delay in normal processing of cell phone searches. United States v. Harry, 2022 U.S. Dist. LEXIS 20312 (D.Conn. Feb. 4, 2022).*