Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 1 of 35

FILED- ENTERED
AO 104 (Rev. 11/13) Tracking Warrant
= D
I Rr. P

UNITED STATEs DISTRICT COURT JAN 19 2017

for the

AT BALTIMORE
District of Maryland CLERK, U.S. DISTRICT COURT
DISTRICT OF MARYLAND
BY DEPUTY

In the Matter of the Tracking of

(Identify the person, or object to be tracked)

property,

Case No. 1(V -336ci- SAO

The* cellular phone bearing numb er (443) 224-0996

TRACKING WARRANT

To: Any authorized law enforcement officer

An application by a federal law enforcement officer or an attorney for the government shows there is reason to believe

that the described above has been involved in and likely will continue to be involved in the criminal
person, property, or object

activity identified in the application, and 9f is located in this district; Dis not now located in this district, but will be at

execution. 0 the activity in this district relates to domestic or international terrorism; Oother:

I find that the affidavit(s), and any recorded testimony, establish probable cause to believe that

(check the appropriate box) Qf using the object 0 installing and using a tracking device

to monitor the location of the person, property, or object will satisfy the purpose set out in Fed. R. Crim. P. 41(c) for

issuing a warrant.

C] I find entry into the following vehicle or onto the following private property to be necessary without approval

or knowledge of the owner, custodian, or user of the vehicle or property for installing, maintaining, and removing the tracking

device:

YOU ARE COMMANDED to execute this warrant and begin using the object or installing the tracking device by

January 8, 2017 (not to exceed ten days) and may continue use for 45 days (not to exceed 45). The tracking may occur

within this district or another district. To install, maintain, or remove the device, you may enter (check boxes as appropriate)

• into the vehicle described above 0 onto the private property described above

• in the daytime 6:00 a.m. to 10:00 p.m. 171 at anytime in the day or night because good cause has been established.

Within 10 calendar days after the use of the tracking device has ended, the officer executing this warrant must both

return it to (United States Magistrate Judge) Duty Magistrate

and - unless delayed notice

is authorized below - serve a copy of the warrant on the person who, or whose property or object, wag tracked.

91 Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.

of and authorize the officer executing warrant to delay notice to the person who, or whose
§ 2705 (except for delay
this
trial),

property or object, will be tracked (check the appropriate box)

for 30 exceed C3 the facts date of

days (not to 30) until, justifefi-g,-IRI~Iafer specific

Date and time issued: Dc'(- ,

lu
Judge's signature

The H6n. Stephanie A. Gallagher, U.S. Judge

City and state: Baltimore, Maryland Magistrate
I

Printed home and title

 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 2 of 35
AO 104 (Rev. 11/13) Tracking Warrant (Page 2)

CaseNo.
1LO-55bi-SAV

Return of Tracking Warrant With Installation

1. Date and time tracking device installed:

2. Dates and times tracking device maintained:

3. Date and time tracking device removed:

4, The tracking device was used from (date and time):

to (date and time):

Return of Tracking Warrant Without Installation

1. Date warrant executed:

2. The tracking information was obtained from (date and time):

to (date and time):

Certification

I declare under the penalty of perjury that this return is correct and was returned along with the original warrant to the designated

judge.

Date:
officer's signature
Executing

Printed narne and title

 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 3 of 35
AO 104 (Rev. 11/13) Tracking Warrant
P11 Pp --
ENTERED
OVED
LOGGED- RE

UNITED STATEs DISTRICT CouRT-

for the JAN 19 2017

District of Maryland Ar DAUTJ~NjIOPIE

DISTRICT COURT
CLERJ~< r~ of-'MARYLAND
DIS I

DEPUTY
In the Matter of the Tracking of BY

,I- f "- 1, f-L-4 I I

or
puentyy e person, properiy, obj-
Case No.
The cellular phone bearing number (443) 823-0866

TRACKING WARRANT

law enforcement officer

To: Any authorized

for the shows there reason to believe

An application by a federal law enforcement officer or an attorney government is

and likely will continue be involved in the criminal

that the person, property, or object described above has been involved in to

and Pf is located in this district; 171is not now located in this district, but will be at
activity identified in the application,
other:
execution; 0 the activity in this district relates to domestic or international terrorism; C]

I find that the and any recorded testimony, establish probable cause to believe that
affidavit(s),

(check the appropriate box)

Qf using the object 0 installing and using a tracking device
of the person, property, or object will in Fed. R. Crim, P. 41 for
to monitor the location satisfy the purpose set out (c)

issuing a warrant.

without approval
0 1 find entry into the following vehicle or onto the following private property to be necessary

of the vehicle for installing, maintaining, and removing the tracking

or knowledge of the owner, custodian, or user or property

device:

device by
YOU ARE COMMANDED to execute this warrant and begin using the object or installing the tracking .

January 8, 2017
- (not to exceed

To
ten days) and may continue use for

remove the device,

45 days (not to

enter
exceed 45). The tracking may occur

within this district or another district. install, maintain, or you may (check boxes as appropriate)

0 into the vehicle described above 0 onto the private property described above

C3 in the daytime 6:00 a.m. to 10:00 p.m.

0 at any time in the day or night because good cause has been established.

calendar days after the use of the tracking device has ended, the officer executing this warrant must both
Within 10

return it to (United States Magistrate Judge) Duty Magistrate

and - unless delayed notice

is authorized below - serve a copy of the warrant on the person who, or whose property or object, was tracked.

result 18 U. C.
91 Pursuant to 18 U. S. C. § 3 103 a(b), I find that immediate notification may have an adverse listed in S.

2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose.
§

or object, will be tracked (check the appropriate box)

property

ig for 30 days (not to exceed 30) 1 until, the facts justifying, ter qk~,6iftt.da e of

Date and time issued:

2d
Judge's signature

and state: Baltimore, Maryland The Hon, Stephanie A. Gallagher, U.S. Magistrate Judge
City
Printed nameand title
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 4 of 35
r

AO 104 (Rev. 11/13) Tracking Warrant (Page 2)

Case No.
I (a
- 5A V

Return of Tracking Warrant With Installation

1. Date and time tracking device installed:

2. Dates and times tracking device maintained:

3. Date and time tracking device removed:

4. The tracking device was used from (date and time):

to (date and time):

Return of Tracking Warrant Without Installation

1. Date warrant executed:

2. The tracking information was obtained ftom (date and time):

to (date and time):

Certification

I declare under the penalty of perjury that this return is correct and was returned along with the original warrant to the designated

judge.

Date:
Executing officer's signature

.
Printed narne and title
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 5 of 35
104 (Rev. Tracking Warrant
AGY 11/13)

RLED ENTERED

UNITED STATEs DISTRICT COURT-L~:: LOGGED_- RECEIVED

for the
JAN 19 2017
District of Maryland

AT BALTIMORE
CLERK, U,S. DISTRICT COURT
In the Matter of the Tracking of DISTRICT OF MARYLAND
BY DEPUTY
the person, or object to be tracked)
(Identify property,

Case No.
The cellular bearing number (443) 559-1201
phone

TRACKING WARRANT

law enforcement officer

To: Any authorized

an attorney for the government shows there is reason to believe

An application by a federal law enforcement officer or

has been involved and likely will continue to be involved in the criminal
that the person, property, or object described above in

activity identified in the application, and Pf is located in this district; 0 is not now located in this district, but will be at

Clother:
execution; 0 the activity in this district relates to domestic or international terrorism;

I find that the affidavit(s), and any recorded testimony, establish probable cause to believe that

Of using the object t7l and using a tracking device

(check the appropriate box) installing

purpose set out in Fed. R. Crim. P. 41

or object will satisfy the (c) for
to monitor the location of the person, property,

issuing a warrant.

be necessary without approval

~
0 1 find entry into the following vehicle or onto the following private property to

for and removing the tracking

or knowledge of the owner, custodian, or user of the vehicle or property installing, maintaining,

device:

YOU ARE COMMANDED to execute this warrant and begin using the object or installing the tracking device by

January 8, 2017
- (not to exceed

To
ten days) and may continue use for

remove
45 days (not to exceed 45). The tracking may occur

within this district or another district. install, maintain, or the device, you may enter (check boxes as appropriate)

0 into the vehicle described above 0 onto the private property described above

C3 in the daytime 6:00 a.m. to 10:00 p.m. 0 at any time in the day or night because good cause has been established.

device has the officer this warrant must both

Within 10 calendar days after the use of the tracking ended, executing

and -unless delayed notice

return it to (United States Magistrate Judge) Duty Magistrate

is authorized below - serve a copy of the Warr ant on

the
person who, or whose property or object, was
tracked.

immediate notification have an adverse result listed in 18 U.S.C.

91 Pursuant to 18 U.S.C. § 3103a(b), I find that may
2705 for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
§ (except

or object, will be tracked (check the appropriate box)

property

the facts justifying, the later spec-Ific, date of

for 30 days (not to exceed 30) 171 until,

Date and time issued:

The Hon.- Stephanie A. Gallqcgher, _~.S. Magistrate Judge

City and state: Baltimore, Maryland
Printed name and title
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 6 of 35
AO 104 (Rev. 11/13) Tracking Warrant (Page 2)

Case No.

Return of Tracking Warrant With Installation

1. Date and time tracking device installed:

2. Dates and times tracking device maintained:

3. Date and time tracking device removed:

4. The tracking device was used from (date and time):

to (date and time):

Return of Tracking Warrant Without Installation

1. Date warrant executed:

2. The tracking information was obtained from (date and time):

to (date and time):

Certification

I declare under the penalty of perjury that this return is correct and was returned along with the original warrant to the designated

judge.

Date:

officer's
Executing signature

Printed name and title

 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 7 of 35

Warrant (Under Seal) ENTERF'

AO 103 (01/09) Order Requiring Assistance in Executing a Tracking FILED1

LOGGEQ_~ KL_'-~Elv_"`

UNITED STATEs DISTRICT COVRT

JAN 19 2017
for the

District of Maryland AT BALTIMORE

TRICT COURT
CLERJ~,Rj J&Dlc
DIST OF MARYLAND
DEPUTY
BY
In the Matter of the Tracking of

to be usedfor tracking)
(Describe the object orproperty

The cellular phone bearing number (443)

224-0996
Case No.
3 30 - SA

A TRACKING WARRANT
ORDER REQUIRING ASSISTANCE IN EXECUTING
(Under Seal)

for the above-captioned cellular telephone.

To: AT&T, its affiliates, or any other service provider

officer or an attorney for the government to direct

has been made by a federal law enforcement
An application

the tracking warrant issued in this case. The court finds

facilities or other assistance, or both, in executing
you to provide

the assistance to be necessary.

assistance in executing the tracking

ORDERED: You and your agents and employees must provide
IT IS

agency and agents, FBI

warrant to the following government

devices or also by provision of real-time

facilities and installing, operating, and monitoring any tracking
by providing
whatever name is known.
location information of the above cellular telephone, by cell-site or GPS, by
it

incurred in
warrant. You may be compensated for reasonable expenses
during the time allowed by the tracking

facilities and assistance.

providing

of the
You and your agents and employees must not disclose the existence of this order,
This order is sealed.

whose or was tracked has been

propeAy
any person until the person ol~ject
or of the investigation to
tracking warrant,

or until authorized to do so by the court.

notified by the government

Date: ptt- . -a-I

(
X ( ~
Judge's signature

The Hon. Gaflagher, U.S. Magistrate Judge

Stephanie,~._
Printed name and title
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 8 of 35

A0 103 (01/09) Order Requiring Assistance in Executing a Tracking Warrant (Under Seal)
- FILED
ENTERED
PFr1__R/

UNITED STATEs DISTRICT COURT JAN 19 2017

for the
AT BALTIMORE
District of Maryland U.S. COURT
CLERK, D,,1,STR1CT
D15 H,
~'r MARYLAND
DEPUTY
I

BY

In the Matter of the Tracking of

(Describe the object orproperty

823-0866
to be usedfor tracking)

Case No. 3 3?0- 5W

The cellular phone bearing number (443)

ORDER REQUIRING ASSISTANCE IN EXECUTING A TRACKING WARRANT

(Under Seal)

for the above-captioned cellular telephone.

To: AT&T, its affiliates, or any other service provider

for the to direct

officer or an attorney government
An application has been made by a federal law enforcement

the tracking warrant issued in this case. The court finds.

facilities or other assistance, or both, in executing
to provide
you

the assistance to be necessary.

and employees must provide assistance in executing the tracking

IT IS ORDERED: You and your agents

and agents, FBI

warrant to the following government agency

devices or also by of real-time

provision
and installing, operating, and monitoring any tracking
by providing facilities

name is known.
information of the above cellular telephone, by cell-site or GPS, by whatever it

location

incurred in
You may be compensated for reasonable expenses
during the time allowed by the tracking warrant.

facilities and assistance.

providing

of this order, of the

You and your and employees must not disclose the existence
This order is sealed. agents

whose object or property was tracked has been

tracking warrant, or of the investigation to any person until the person

or until authorized to do so by the court.

notified by the govermnent

Date:

A. U.S. Magistrate Judge

The Han. Stephanie Gallagher,

Printed name and title

 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 9 of 35

A0 103 (01/09) Order Requiring Assistance in Executing a Tracking Warr ant (Under Seal)
- FILED-
LOGGED-
ENTERED
RECEIVED

UNITED STATEs DISTRICT COURT 19

JAN 2017

for the AT BAILTIMORE

CLERK, U.S. DISTRICT COURT
District of Maryland DISTRICT OF MARYLAND
BY DEPUTY

In the Matter of the Tracking of

the or to be usedfor tracking)

(Describe object property
Case No.
559-1201
The cellular phone bearing number (443)

ORDER REQUIRING ASSISTANCE IN EXECUTING A TRACKING WARRANT

(Under Seal)

for the above-captioned cellular telephone.

To: T-Mobile, its affiliates, or any other service provider

officer or for the to direct

been made by a federal law enforcement an attorney government
An application has

warrant issued in this case. The court finds

facilities or other assistance, or both, in executing the tracking
you to provide

the assistance to be necessary.

and employees must provide assistance in executing the tracking

IT IS ORDERED: You and your agents

and agents, FBI

warrantto the following government agency

devices or also by provision of real-time

facilities and installing, operating, and monitoring any tracking
by providing
name known.
information of the above cellular telephone, by cell-site or GPS, by whatever it is
location

incurred
be compensated for reasonable expenses in
by the tracking warrant. You may
during the time allowed

facilities and assistance.

providing

of this order, of the

This order is sealed. You and your agents and employees must not disclose the existence

the person whose object or property was tracked has been

tracking warrant, or of the investigation to any person until ,

,.
I
~

notified by the government or until authorized to do so by the court

L_~ 1

Date:

The Hon. A. Gallagher, U.S. Magistrate Judge

Stephanie
Printed naine and title
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 10 of 35

AO 102 (01/09) Application for a Tracking Warrant

17 177. :: U
F I L ED

UNITED STATEs DISTRICT COtjIZ4~- LOGGED--

RECEIVED

for the
JAN 19 Z017

District of Maryland

P,T BALTINIORE
U ISTRICT COURT

DRIS
CLE I~
'

CRI& POF MARYLAND

DEPUTY
Matter of the Tracking of
In the BY
to be tracked or describe
(Identify the person
to be tracking)
the object or property usedfor

224-0996 IG , 330-SAV
The cellular bearing number (443) Case No.
phone

APPLICATION FOR A TRACKING WARRANT

have reason to believe that the person,

law enforcement officer or attorney for the government,
1, a federal
has been and likely will continue to be involved in one or more violations of
described above
property, or object
install and
in furtherance of a criminal investigation, I request authority to
21 U.S.C. 846 Therefore,
§ .

determine location. The

of the property or object described above to
use a tracking device or use the tracking capabilities

forth on the attached sheet.

application is based on the facts set

relates to domestic or
R( The or object is located in this 0 The activity in this district

person, property,
international terrorism.
district.

not now located n Other:

0 The person, property,
or object is

but will be at the time of execution.

in this district,

reveal these bases for the warrant under Fed. R. Crim. P. 41 (c): (check one or more)
The tracking will likely

Qf contraband, fruits of crime, or other items illegally

9( evidence of a crime;
possessed;

n who is
used a person to be arrested or a person
Qf property designed for use, intended for use, or
unlawfully restrained.
in committing a crime;

authority to enter the

maintaining or removing the tracking device,
C3 I further request, for purposes of installing,

vehicle or private property, or both:

following

date if more than 30 days: ) is requested under

9( Delayed notice of 30 days (give exact ending

forth on the attached sheet.

3103a, the basis of which is set
18 U.S.C. §

printed name and title

Applicant's

Sworn to before me and signed in

my presence.

Date:
0

Hon A. Gallagher, U.S. Magistrate Judge

Stephanie
City and state: Baltimore, Maryland
Printed name and title
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 11 of 35

AO 102 (01/09) Application for a Tracking Warrant

UNITED STATEs DISTRICT COURT

-
~ FILED~
LOGGED-
fz~N-TERED

RECEIVED

for the
JAN 19 Z017
District of Maryland

AT SALTINAOR2
DISTRICTC0 URT
CLERK,
I U
01STRI OF MARYLAND
DEPUTY
In the Matter of the Tracking of
BY
the to be tracked or describe
(Identify person
to be usedfor tracking)
the object orproperty

The cellular phone bearing number (443) 823-0866 Case No. 33'70 -SA (T-

APPLICATION FOR A TRACKING WARRANT

for the have reason to believe that the person,

officer or attorney government,
1, a federal law enforcement
and likely will continue to be involved in one or more violations of
described above has been
property, or object
to install and,
846 in furtheranc e of a criminal investigation, I request authority
21 U.S.C. § .
Therefore,

above to determine location. The

of the property or object described
use a tracking device or use the tracking capabilities

sheet.
is based on the facts set forth on the attached
application
domestic or
9( The or object is located in this 0 The activity in this district relates to

person, property,
international terrorism.
district.

not now located 0 Other:

0 The person, property, or object is

but will be at the time of execution.

in this district,

P. 41(c): (check one or more)

reveal these bases for the warrant under Fed. R. Crim.
The tracking will likely

if fruits of crime, or other items illegally

contraband,
Qf evidence of a crime;
possessed;

for use, or used 0 a person to be arrested or a person who

is

Qf property designed for use, intended

unlawfully restrained.
in committing a crime;

authority to enter the

or removing the tracking device,
0 1 further request, for purposes of installing, maintaining
vehicle or private or both:
following property,

is requested under
exact ending date if more than 30 days: )
Q( Delayed notice of 30 days (give

set forth on the attached sheet.

3103a, the basis of which is
18 U.S.C. §

printed naine and title

Applicant's

Sworn to before me and signed in my presence.

Date:

and state: Baltimore, Maryland

Hon. Stephanie A. Gallagher, U.S.jLagistrate -Judge
City
Printed name and titie
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 12 of 35

AO 102 (01/09) Application for a Tracking Warrant

~~FILE _~[7-77777--D

UNITED STATEs DISTRICT COURT- LOGGED_ ____ RECEIVED

for the
JAN 19 Z017
District of Maryland

AT 13P11-THA1110RE

COURT
DISTRIKCT
CLERK, U.S.
DISTRICT OF MARYLAND
Matter of the Tracking of DEPUTY
In the 13Y

the to be tracked or describe

(Identify person
the or to be usedfor tracking)
object property

The cellular number 559-1201 Case No.

phone bearing (443)

APPLICATION FOR A TRACKING WARRANT

law enforcement officer or attorney for the government, have reason to believe that the person,
1, a federal

above has been and likely will continue to be involved in one or more violations of
property, or object described

to install and
21 846 Therefore, in furtherance of a criminal investigation, I request authority
U.S.C. § .

described above to determine location. The

device or use the tracking capabilities of the property or object
use a tracking
sheet.
application is based on the facts set forth on the attached

The in this district relates to domestic or

9( The person, property, or object is located in this [7) activity

international terrorism.
district.

0 The person, property, or object is not now located 171 Other:

in this district, but will be at the time of execution.

The will likely reveal these bases for the warrant under Fed. R. Crim. P. 41 (c): (check one or more)
tracking

Qf contraband, fruits of crime, or other items illegally

Qf evidence of a crime;
possessed;

0 arrested or a person who is

Qf property designed for use, intended for use, or used a person to be
unlawfully restrained.
in committing a crime;

or removing the tracking device, authority to enter the

0 1 further request, for purposes of installing, maintaining

following vehicle or private property, or both:

is requested under
9( Delayed notice of 30 days (give exact ending date if more than 30 days:

forth on the attached sheet.

3103a, the basis of which set
18 U.S.C. §
is

4 ~ V le~'
Applicant's signature

TFO John Sieracki, FBI

Applicant's printed name and title

Sworn to before me and signed in my presence.

Date:

Hon. Stephanie A. Gallagher, U.S,. Magistrate Judge

City and state: Baltimore, Maryland
Printed name and title
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 13 of 35
FILED

LOGGED~
- ENTERED
RECEIVED

JAN 19 Z017

LTIMORE
THE UNITED STATES DISTRICT COURT rr P,8
IN
~
.

US j )ISTRICT COURT
CLER<
o~ MWfVLAND
DISTRICT OF MARYLAND E)JSL~R16T
DEPUTY
13Y

INTHE MATTER OF THE CELLULAR

16-330- SAG-
TELEPHONE ASSIGNED CALL NUMBER
(443) 224-0996 and (443) 823-0866 whose

wireless service provider is AT&T Wireless, a

3 31C) - SAV
company headquartered at 208 South Akard,

10'h Floor, Dallas, Texas 75202 and

Filed Under Seal

(443) 559-1201
whose wireless service

is T-Mobile, a company
provider

headquartered at 4 Sylvan Way, Parsippany,

New Jersey 07054

AFFIDAVIT IN SUPPORT OF APPLICATIONS FOR

TRACKING WARRANTS

INTRODUCTION

and state as follows:

1, John Sieracki, being duly sworn, depose

or law enforcement officer" of the United States within the

I am an "investigative

United Code, and am empowered by law to conduct

meaning of Section 2510(7) of Title 18, States

of Title 18, United

and to make arrests for, offenses enumerated in Section 2516
investigations of,

States Code.

2. Your afflant, John Sieracki, has been a member of the Baltimore Police Department

Federal Bureau of Investigation's

currently assigned to the (FBI)
since September of 1992 and is

Public and Border Corruption Task Force. Your affiant successfully completed a six-month basic

Controlled Dangerous Substances (CDS).

of training that included instruction pertaining to
course

Your Affiant has attended more than eight advanced.investigative

courses. My prior assignments

Unit, Drug Enforcement Unit, The Intelligence

include uniformed patrol, District Operations

Division. Your affiant has personally conducted and participated

Section, and The Internal Affairs
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 14 of 35

criminal activity including but not limited to CDS, violent

in hundreds of investigations involving

Your affiant has in the arrest of more than 2,000

crime, and firearms violations. participated

for CDS violent crime, and/or firearms violations and has authored and/or
persons violations,

relating to CDS, violent crime, and/or firearms

executed more than 200 search and seizure warrants

hundreds of physical surveillances of suspected

violations. Your affiant has also participated in

in advanced surveillance techniques

drug distributors and user. Your Affiant has received training

the of both wire and electronic communication. During your

and has participated in interception

conducted interviews of controlled dangerous

Affiants career, I have numerous suspected

distributors and users and am familiar with various methods and techniques used to
substance

transport, distribute and use controlled dangerous substances. Additionally, your Affiant
package,

human to various criminal

has interviewed, handled and operated confidential sources investigate

activities.

well conversations with other agents,

training and experience, as
3. Based on my as

your affiant knows that:

CDS and currency in order to maintain and

traffickers often possess
a. Drug
used
finance their ongoing drug business. They also possess paraphernalia

in the manufacture, packaging, preparation, and weighing of CDS in

traffickers often these items on

preparation for trafficking. Drug possess

them in locations where he or she has ready access to

their person or keep

them, like a home or a vehicle;

b. Drug traffickers often maintain firearms and ammunition in connection with

and that traffickers maintain these

their drug-trafficking activities, drug

items where they have ready access to them, like a home or a vehicle;

traffickers often maintain financial records and financial instruments

c. Drug
transactions and the derived from those
related to their drug profits

transactions including, but not limited to, currency, bank checks, cashier's

checks, receipts, money orders, stocks, bonds, jewelry, precious metals, and

bank and real estate records;

2
Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 15 of 35

traffickers often maintain records of their drug transactions including,

d. Drug
but not limited to, books, ledgers, records and other documents relating to

CDS. Such
the manufacture, transportation, possession, and distribution of
where the have
frequently maintained
documents traffickers ready
are

access to them, like a home or a vehicle;

records and other documents

e. Drug traffickers frequently maintain books,

that identify and contain the names, addresses

and/or telephone numbers of

associates in their or money-laundering activities,

drug-trafficking

but not limited to address books and notes and documents with
including,

telephone numbers,

devices
f. Drug traffickers commonly use and carry telephones and electronic

which store names, addresses, and telephone numbers of coconspirators as

communications with coconspirators.

well as electronic (like text messages)

These individuals often utilize cellular telephones to maintain contact with

their associates using the internet and other applications on their phones;

and videos of
g. Drug traffickers commonly take or store photographs

often on cellular telephone, with coconspirators and of their

themselves,

assets, and drugs;

property,

h. traffickers commonly maintain identification and travel documents,

Drug
but not limited to, tickets, transportation schedules, passports,
including,

notes and receipts related to travel, luggage tags, and motel/hotel receipts;

vehicles to move of drugs and

i. Drug traffickers commonly use quantities

storage and Drug

locations for ftirther distribution.
currency to other

traffickers also store drugs and other evidence of the drug trafficking, like

materials and other paraphernalia, inside their vehicles.

packaging

traffickers often communications devices, vehicles and other

j .
Drug place

own avoid detection of these items by

assets in names other than their to

and even though these items are in another

law enforcement officials, that

or person's name, the drug dealers actually own and continue to use
entity's

these devices and assets and to exercise dominion and control over them;

k. Evidence of property ownership and residence are often present in such

premises;

maintain the items where they have

1.
Drug traffickers commonly foregoing

ready access to them, such as inside their homes and vehicles, as well as

inside combination or key-lock safes or strong boxes, suitcases, storage

cabinets and other types of locked or

lockers, safety deposit boxes, locked

3
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 16 of 35

and hidden for ready access and to

closed containers, compartments,
conceal them from law enforcement authorities; and

aforementioned
in. That drug traffickers commonly maintain many of the

records in electronic format on their cellular telephones.

4. The statements contained in this affidavit are based in part on information provided

Bureau of Investigation
by Special Agents and Task Force Officers (TFOs) of the Federal (FBI),

of investigations and from the review of reports of

and from the review of written reports

debriefings of sources of information and other witnesses.

for tracking warrants under Federal

5. 1 make this affidavit in support of an application

and 18 U.S. C. 2703 (c)(1)(A) for information about the GPS or

Rule of Criminal Procedure 41 § §

call numbers (443) 224-0996

latitude-longitude location of the cellular telephone assigned

and (443) 823-0866 ("Target Cell Phone 3"), whose wireless service
("Target Cell Phone I")

a headquartered at 208 South Alcard, I oth Floor, Dallas,

provider is AT&T Wireless, company

"ATTACHMENT Al - PROVIDER WARRANT," and

Texas 75202, which is described in

Cell Phone whose wireless

assigned call number (443) 559-1201 ("Target 2"),
cellular telephone

headquartered at 4 Sylvan Way, Parsippany, New Jersey

service provider is T-Mobile, a company

which is described in "ATTACHMENT A2 - PROVIDER WARRANT," including

07054,

data and related location information.

prospective, real-time cell-site

determine conclusively the location of Target

6. One purpose of this application is to

and Target Cell Phone 3. However, there is reason to believe

Cell Phones I, Target Cell Phone 2,

currently located in this district because, as

that Target Cell Phone I and Target Cell Phone 3 is

the user of Target Cell Phone 1 and Target Cell Phone 3 is a Baltimore Police
described below,

There also reason to believe that Target

Department Officer who lives in Parkville, Maryland. is

4
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 17 of 35

located in this district because, as described below, the user of Target

Cell Phone 2 is currently

Cell Phone 2 lives in Essex, Maryland.

forth in this affidavit, there is probable cause to believe that

7. Based on the facts set

narcotics and Title 21

possession with intent
21 U.S.C. to distribute
violations of Title § 841,

violations of Title 18 U.S.C.

U. S.C. § 846, conspiracy to possess with intent to distribute narcotics,

of a drug crime, and Title 18 U.S.C. §

924(c), possession of a firearm in furtherance trafficking
§

an obliterated or removed number, have been

922(k,), transportation of a firearm with serial

and will be committed by ,

committed, are being committed,

the user of the Target Cell Phone I and Target Cell Phone 3, and , the user

Cell
of Target Cell Phone 2. There is also probable cause to believe that the location of the Target

of those criminal violations, and will lead to the identification of

Phones will constitute evidence

individuals who in the commission of these offenses. Because this affidavit is being
are engaged

limited purpose of securing a warrant for the information and authorization

submitted for the

described below, I have not included each and every fact known to me concerning this

establish
I have set forth only the facts that I believe are necessary to
investigation. Rather,

cause for the issuance of those warrants.

probable

PROBABLE CAUSE

month of December a Federal Bureau of Investigation (FBI),

8. During the 2016,

Police
Baltimore Division, Confidential Human Source (CHS)l reported that a Baltimore

and
I

Between 1988 and 2006, the CHS was arrested and charged with offenses including murder, kidnapping,
and was sentenced to 232 months of
narcotics offenses. In 2002, the CHS plead guilty to racketeering

documents and sentenced to thirty

imprisonment. In 2011, the CHS was convicted of felony fraud of identification

with felony felony motor vehicle theft, and second degree

months. In 2015, the CHS was arrested and charged theft,

been placed on the inactive docket. Several years ago, the CHS cooperated in an FBI
assault but the case has

district testifying against two defendants. The CHS began cooperating with the
investigation in another including

5
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 18 of 35

whom the CHS identified as , is using her

Department (BPD) officer,

enforcement facilitate the sale and transportation of a

official position as a law officer to help

controlled namely marijuana. According to the CHS, is working

dangerous substance,

in this illegal distribution operation. Specifically,

with a male identified as

and the marijuana from a

will drive the vehicle being used to transport

intends to conduct a drug transaction. On occasion,

stash house to a destination where

the transactions. If during the transportation and

is in possession of a handgun during

law enforcement officers, role in the

sale of marijuana the vehicle is stopped by

and identification and identify herself as a police

criminal conspiracy is to display her police badge

cease their traffic stop and allow

officer. This action will cause the law enforcement officer(s) to

to leave with no further

and the vehicle containing marijuana

for during his illegal

being conducted. Thus, providing cover
investigation

of an
distribution of a controlled dangerous substance (CDS) and possible possession illegal

firearm.

week of December, s/he had a conversation

9. The CHS reported that during the last

and are planning a

with in which reported that

to on December 30, 2016, in order to pick up thirty-five pounds of

trip Philadelphia, Pennsylvania

back to the Baltimore are. also told the CHS

marijuana that they intend to transport

and would be leaving the Baltimore area at approximately 9:30 a.m.;

that

of narcotics in
time, has participated three controlled purchases
August 2016 and since that in
FBI in Baltimore in

of the Grand Jury for one of the investigations. The CHS

two pending drug investigations and has testified in front

The CHS' for Law

has also cooperated with the DEA in Baltimore. is
currently cooperating monetary payment.

based on in the pending FBI drug investigations.

enforcement believes the CHS to be reliable his cooperation

6
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 19 of 35

(35) pounds of marijuana from a

that has made arrangements to pick up thirty-five

will be driving a vehicle, preferably a Dodge

source of supply (SOS) in Philadelphia;

she intends rent from an Enterprise Rental Car Company in Essex; that
Durango, which to

will be driving the vehicle in order to provide cover in the event they are stopped by

the SOS in Philadelphia is a Dominican male who works with a Mexican

law enforcement; that

The CHS reported that invited the CHS to

male who has a SOS in Atlanta, Georgia.

( and on the to Philadelphia.

accompany them
trip

The CHS that this transaction may have been orchestrated by and for
10. suspects

has the or knowledge of a

The CHS does not believe that money for,

of marijuana had mentioned. The CHS

SOS capable of delivering the quantity

believed would normally deal with smaller amounts of marijuana.

11. The CHS reported that owns a 9mm handgun which had been given

removed the serial number on the

to him as gift by more than a year ago.

in his apartment and occasionally

it off." keeps the handgun
handgun by "scratching

when and/or distribute

takes the firearm with them ( and they transport

marijuana.

also relayed to the CHS an incident from approximately one (1) year
12.

and had left a nightclub, drove to apartment in

ago where

and were on conduct a sale

retrieved a half (1/2) pound of marijuana
their way to
Essex, Maryland,

in Essex.
when were stopped by police on Route 702 near apartment
they

and identification and told the officer she was a police

immediately displayed her badge

and them go without further investigation.

officer. The police officer said, "Have a good night" let

The CHS said that was laughing as he told the story because thought

7
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 20 of 35

had been in possession of his 9mm handgun

the incident was funny. Additionally,

at the time of this incident.

with three taken from Facebook,

13. The CHS provided investigators (3) photographs,

One of the photographs depicted a female

of the individual s/he identified as

on the uniform read " Your

wearing a BPD uniform. A name tag displayed

the and identified the individual

with other investigators reviewed photographs
affiant, along

an activate duty police officer employed by the BALTIMORE POLICE

depicted as

DEPARTMENT (BPD). was hired by the BPD on July 19, 2010, and according to

BPD records is currently assigned to the Northwest

District (NWD).

The CHS was a Hispanic male, approximately 25

14. reported that

lived at 1417 Strawflower Road, Apartment K, at the Hartland Apartments in Essex,

years old who

as a
Maryland and has a nickname
of "B". The CHS believes that is employed

law enforcement databases, your

custodian for a school in the Baltimore area. Through researching

date of birth (DOB)

Affiant along with investigators were able to identify

with an address of

driver's license number of and a

, having a Maryland

Identification number of Your Affiant believed that

Maryland State (SID)

the user of Target Cell Phone 2.

is

conducted additional research which

along with
15. Your affiant other investigators

members of the Ocean Maryland, Police Department (OCPD)

revealed that on May 25, 2013, City,

Medical with a sick individual

were assisting Ocean City Emergency Services (EMS) personnel

The incident was documented under CC#

at , Ocean City, Maryland 21842.

an amount of suspected marijuana was observed

During the OCPD's investigation,

8
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 21 of 35

bedroom by one of the police officers. The suspected marijuana

and recovered in a second floor

officer to the OCPD to be subsequently destroyed. No one was charged in

was submitted by the

there were several people located

relation to the suspected marijuana. During the investigation

in addition to the sick individual. Two of the individuals inside of the

inside of the apartment

and
location were positively identified by the officers as

her employer with

16. A query
of BPD databases revealed that provided

Target Cell Phone

that I is
indicates
Target Cell Phone 1. Additionally, open source information

associated with

17. Additionally, provided Target Cell Phone 3 on July 12, 2016 during a

a claim, which occurred while work-ing with the

report of injury to workers compensation, during

BPD.

cell Target Cell

18. The CHS Target Cell Phone 2 as phone.
provided

2 was the Maryland State Correctional Institution's (MCSI) telephone

Phone queried through

number has been in routine contact with an ininate

recording system. It was revealed that this

who is a fifteen sentence for an April 8, 2010,

named serving year

in the use of a felony violent crime.

degree assault and a handgun
/ Specifically,
conviction for first

affiant reviewed a recorded call which occurred on December 5, 2016, at approximately 1:00
your

Cell Phone 2, discussed

Cell Phone 2. , and a male using Target
p.m., to Target

At one point during the conversation, asked how

many issues during the call.

was doing. The two began discuss and the relationship between her and the male

that this male using Target Cell Phone 2 was

using Target Cell Phone 2. Your Affiant believes

and " is a reference about

9
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 22 of 35

19. On December 28, 2016, at 3:45 p.m. the CHS reported the following information

CHS with who

to Task Force Officer (TFO) Mark Williams. The recently spoke

want the CHS traveling with them Philadelphia.

advised the CHS that did not

had been a past cooperator for the federal

researched the CHS and found that s/he

in relation to an investigation of the Latin King Gang.

government

device in order to
20. At that time, the CHS was provided with an audio recording

in recorded conversation with

participate consensually

CHS contacted TFO Williams and stated, "Got him

21. On December 28, 2016, the

does runs
and basically admitted she was doing this for big money and
boss, he spoke up a storm,

He said he
braore. Not just weed, but heroin as well, at a few times coke.
for several connects in

that
wasn't worry about me and was gonna tell her it was cool f6r me to go but if she don't agree,

there wasn't much he could do. But I got him on the recorder."

TFO Williams met with the CHS to recover

22. On December 29, 2016, at 8:40 a.m.

device The CHS reported the following information. The CHS met with
the audio recording

the evening hours of December 28, 2016.

at apartment in Essex during

advised that is "making

The two had a conversation about

of plugs." said that he has known

and has major ties into a lot
serious paper

and money out of the country.

kilogram amounts of heroin
is also sending
"move"

CHS the SOS in Philadelphia is associated with

told the that

advised the CHS that he ( would be receiving two (2) pounds of marijuana for going

on the trip with

statement "making serious paper and has major ties

23. Your Affiant believes that the

money from her involvement in illegal

earning a lot of
a lot of plugs." means that
is
into

10
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 23 of 35

Your also believes that "move" refers

multiple major SOS. affiant
activity and the she has access to

to the transportation and or sale of CDS.

Your Affiant reviewed that audio recordings which were captured on December 28,
24.

2016. The following is a synopsis of the recordings.

4:34:50 p.m. - 7 second recording - noise only, no voice captured

12/28/16 at

12/28/16 at 9:29:11 - 6 second recording - background music, no voice captured

p.m.

9:29:26 p.m. - 5 second recording - noise only, no voice captured

12/28/16 at

have learned that cellular phones communicate

my training and experience, I
25. In

towers that route and connect

wirelessly across a network of cellular infrastructure, including

cellular
individual communications. When sending or receiving a communication, a phone

communication. Law enforcement

broadcasts certain signals to the cellular tower that
its
is routing

or receive calls, and may also initiate a

monitor these signals when cellular initiate
may phones

emit signals. By these

communication with the Target Cell Phones in order to cause it to collecting

of the cellular
can relatively precisely determine the location telephone
signals, law enforcement

itself.

and experience, have learned that AT&T Wireless and T-Mobile

26. in my training
I

cellular access to the general public. I also know that, as a

are companies that provide telephone

technical that allow them

of cellular telephone service have capabilities
general matter, providers

two kinds of information about the locations of the cellular

to collect and generate at least

E-911 Phase 11 data, also known as GPS data or

telephones to which they provide service: (1)

known as "tower/face information" or cell

latitude-longitude data; and (2) cell-site data, also

precise location information about

tower/sector records. E-911 Phase 11 data provides relatively

the cellular telephone itself, either via GPS tracking technology built into the phone or by

it
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 24 of 35

several of the provider's cell towers. Cell-site

triangulating on the device's signal using data from

towers specific geographic areas) that

data identifies the "cell towers" (i.e., antenna covering

and, in some cases, the "sector" faces of

received a radio signal from the cellular telephone (i.e.,

the towers) to which the telephone connected. These towers are often a half-mile or more apart,

and can be 10 or more miles apart in rural areas. Furthermore, the tower
even in urban areas,

serve call made to or from that device.

closest to a wireless device does not necessarily every

Phase
typically less precise that E-911
11 data.
Accordingly, cell-site data is

and I know that AT&T Wireless can provide

27. Based on my training experience,

Phase
using cell-site data and E-911
11 data,
information about the location of Target Cell Phone I

data. also Imow that T-Mobile can provide

GPS data, or other more precise latitude-longitude I

of Target Cell Phone 2 using cell-site data and E-911 Phase 11 data,
information about the location

data.
GPS data, or other more precise latitude-longitude

AUTHORIZATION REOUEST

issue the proposed

request that the Court also tracking
28. Based on the foregoing, I

Provider for GPS, Precision Location, or latitude-longitude data, pursuant

warrant (the Warrant)

and prospective cell-site data

to Federal Rule of Criminal Procedure 41 and 18 U.S.C. § 2703(c)

Criminal Procedure 41 and 18 U.S.C. 2703(c).

pursuant to Federal Rule of
§

to 18 U.S.C. § 3103a(b) and Federal Rule of Criminal

29. 1 farther request, pursuant

until
the Court authorize the officer executing the warrant to delay notice
Procedure 41 (f)(3), that

This
30 days after the collection of information authorized by the warrant has been completed.

is because there is reasonable cause to believe that providing immediate notification

delay justified

defined in 18 U.S.C. 2705. Providing immediate

of the warrant may have an adverse result, as §

would seriously jeopardize the ongoing

notice to the subscriber or user of the Target Cell Phones

12
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 25 of 35

an opportunity to destroy evidence,

as such a disclosure would give that person
investigation,

flee from prosecution, and otherwise jeopardize

change patterns of behavior, notify confederates,

The warrants do not authorize the interception of

the investigation. See 18 U.S.C. § 3103a(b)(1).

text or Internet data, and the warrants prohibit the seizure of any
calls, messages,
any telephone

to the extent that the warrants do authorize the seizure of any wire
tangible property. Moreover,

communication defined in 18 U.S.C. § 2510) or any stored wire or electronic

or electronic (as

reasonable for the collection of cell-site and related location

information, there is necessity

described in
the use of the electronic investigative technique
information, and for

and "ATTACHMENT B2 -
"ATTACHMENT BI - LAW ENFORCEMENT WARRANT,"

to the statutory delayed notification

LAW ENFORCEMENT WARRANT," as required pursuant

See 18 U.S.C. § 3103a(b).

provision.

that the Court authorize execution of the Law Enforcement

30. 1 further request

the potential need to locate the Target Cell Phones

Warrant at any time of day or night, owing to

outside of daytime hours.

in support of this application,

further request that the Court order that all
31. 1 papers

further order of the Court. These

the affidavit and tracking warrant, be sealed until
including

that is neither public nor Imown to all of the

documents discuss an ongoing criminal investigation

there is good cause to seal these documents because

targets of the investigation. Accordingly,

that investigation.
their premature disclosure may seriously jeopardize

13
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 26 of 35
33(oi - sma

to compel the investigative

32. A tracking warrant may not be legally necessary

described in "ATTACHMENT BI - LAW ENFORCEMENT WARRANT" and

technique

LAW ENFORCEMENT WARRANT." I hereby submit

"ATTACHMENT B2 - Nevertheless,

out of an abundance of caution.

the warrant application

Respectfully submitted,

Job4 ~Sieracki

TaslVForce Officer

Federal Bureau of Investigation

Subscribed and sworn to before me

--K-
TH -ffON6RABLE STEPHANIE A. GALLAGHER
UNITED STATES MAGISTRATE JUDGE

14
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 27 of 35

ATTACHMENT Al - PROVIDER WARRANT

Property to Be Tracked

Cell Phone and

The cellular assigned call number (443) 224-0996 ("Target I"),
1. telephone

to the same telephone number, whose wireless service

any other telephones assigned

Oh Floor,
headquartered at 208 South Akard,
I
provider is AT&T Wireless, a company

Dallas, Texas 75202.

Cell Phone and

assigned call number (443) 823-0866 ("Target 3"),
2. The cellular telephone

to the same telephone number, whose wireless service

any other telephones assigned

headquartered at 208 South Al~,ard,

I Oth Floor,
is AT&T Wireless, a company
provider

Dallas, Texas 75202

and Target Cell Phone 3 that within the

Information about the location of Target Cell Phone I is

Wireless including information about the location of

control of AT&T
possession, custody, or

the cellular telephone if it is subsequently assigned a different call number.

 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 28 of 35

ATTACHMENT BI- PROVIDER WARRANT

Particular Things to be Seized

Cell Phone I and Target Cell Phone 3

All information about the location of Target

of forty-five during all times of day and night.

described in Attachment Al for a period days,

about the location of Target Cell Phone I and Target Cell Phone 3" includes all
"Information

GPS latitude-longitude data, and other precise location

available E-911 Phase 11 data, data,

towers" antenna towers covering specific

information, as well as all data about which "cell (i.e.,

faces of the towers) received a radio signal from the

geographic areas) and "sectors" (i.e.,

cellular described in Attachment A.

telephone

in the previous (hereinafter,

To the extent that the information described paragraph

of AT&T AT&T
is within the possession, custody, or control Wireless,
"Location Information")

In addition, AT&T
to disclose the Location Information to the government.
Wireless is required

information, facilities, and technical assistance

Wireless must furnish the government all

of the Location Information unobtrusively and with a

the collection
necessary to accomplish

Wireless' services, including by initiating a signal to

minimum of interference with AT&T

Wireless'
the location of Target Cell Phone I and Target Cell Phone 3 on AT&T
determine

and at such intervals

network or with such other reference points as may be reasonably available,

AT&T Wireless for

The government shall compensate
and times directed by the government.

incurred in furnishing such facilities or assistance.

reasonable expenses

local and long distance telephone

Subscriber identity, including the name, address,

(including start date) and types of service utilized,

connection records, length of service

number make and model, and

or instrument number or other subscriber or identity,
telephone

2
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 29 of 35

such service (including any credit card or bank account

means and source of payment for

number), for Target Cell Phone I and Target Cell Phone 3.

In approving this
This warrant does not authorize the seizure of any tangible property.

See 18
for the seizure of the Location Information.
warrant, the Court finds reasonable necessity

U.S.C. § 3103a(b)(2)

3
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 30 of 35

ATTACHMENT A2 - PROVIDER WARRANT

Property to Be Tracked

number Cell Phone and

1. The cellular telephone assigned call (443) 559-1201 ("Target 2"),

to the same telephone number, whose wireless service

any other telephones assigned

is T-Mobile, a company headquartered at 4 Sylvan Way, Parsippany, New

provider

Jersey 07054.

Information about the location of Target Cell Phone 2 that is within the possession, custody, or

control of T-Mobile including information about the location of the cellular telephone if it is

subsequently assigned a different call number.

4
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 31 of 35

ATTACHMENT 132- PROVIDER WARRANT

Particular Things to be Seized

All information about the location of Target Cell Phone 2 described in Attachment A2 for

times of day and night. "Information about the location, of

a period of forty-five all
days, during

available E-911 Phase GPS data, latitude-longitude

Target Cell Phone 2" includes all 11 data,

information, as well as all data about which "cell towers" (i.e.,

data, and other precise location

and "sectors" (i.e., faces of the towers)

antenna towers covering specific geographic areas)

in Attachment A2.
received a radio signal from the cellular telephone described

To the extent that the information described in the previous paragraph (hereinafter,

within the possession, custody, or control of T-Mobile, T-Mobile is

"Location Information") is

Information to the government. In addition, T-Mobile must

required to disclose the Location

famish the government all information, facilities, and technical assistance necessary to

of the Location Information unobtrusively and with a minimum of

accomplish the collection

location
interference with T-Mobile's services, including by initiating a signal to determine the

of Target Cell Phone 2 on T-Mobile's network- or with such other reference points as may be

and at such intervals and times directed by the government. The

reasonably available,

incurred in famishing such

government shall compensate T-Mobile for reasonable expenses

facilities or assistance.

Subscriber identity, including the name, address, local and long distance telephone

connection records, length of service (including start date)

and types of service utilized,

number or other subscriber number or identity, make and model, and

telephone or instrument

5
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 32 of 35

means and source of payment for such service (including any credit card or bank account

number), for Target Cell Phone 2.

This warrant does not authorize the seizure of any tangible property. In approving this

the Court finds reasonable necessity for the seizure of the Location Information. See 18
warrant,

U.S.C. § 3103a(b)(2)

6
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 33 of 35
FILED_ ENTERED

LOGGED- RECEIVED

JAN 19 2017

THE UNITED STATES DISTRICT COURT FOR THE

AT BALTIMORE
DISTRICT OF MARYLAND CLERK, U.S. DISTRICT COURT
DISTRICT OF MARYLAND
BY DEPUTY

IN THE MATTER OF THE CELLULAR

TELEPHONE ASSIGNED CALL NUMBER /~P- 3-349- SAG

(443) 224-0996 and (443) 823-0866 whose

/49 -
33 70 ~ E46
wireless service provider is AT&T Wireless, a

headquartered at 208 South Akard,

company 16 - 3371- D16
I 01h Floor, Dallas, Texas 75202 and
Filed Under Seal
(443) 559-1201 whose wireless service

provider is T-Mobile, a company

headquartered at 4 Sylvan Way, Parsippany,

New Jersey 07054

GOVERNMENT'S MOTION TO SEAL TRACKING WARRANTS

The United States of America, by and through the United States Attorney for the District

of Maryland, and Assistant United States Attorney Derek E. Hines, respectfully moves this

Honorable Court, for entry of an Order sealing the warrants issued for the above-captioned

phone numbers, as well as the warrant applications, the supporting affidavit signed by FBI TFO

John Sieracki, and sealing this Motion and this Court's Order sealing these matters, and in

support thereof states as follows:

The affidavit in support of the warrant relies upon information provided by witnesses

who have not been publically disclosed as well as from an investigative technique the order for

which remains sealed. The investigation is ongoing, and release of the warrant and affidavit to

the public before the conclusion of the grand jury investigation, could jeopardize the ability of

federal authorities to proceed with this investigation.

Accordingly, the government asks this Court to issue an Order sealing the warrant and all

attachments thereto, the application for the warrant, the affidavit in support of the warrant, the

subsequent tracking warrant returns, this Motion and this Court's Order sealing these matters.
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 34 of 35

of America prays that this Honorable Court issue an

WHEREFORE, the United States

well as the warrant

Order sealing the Warrants issued for the above-captioned phone numbers, as

TFO John and sealing this Motion

signed by FBI
affidavit Sieraeld,
applications, the supporting

and this Court's Order sealing these matters until further order of this Court.

Date: December 29, 2016

Respectfully submitted,

ROD J. ROSENSTEIN
UNITED STATES ATTORNEY

By:
&ek E. Hines

Assistant U.S. Attorney

36 South Charles Street

Fourth Floor

Baltimore, Maryland 21201

(410) 209-4800
 Case 1:18-cv-02444-CCB Document 11-15 Filed 11/16/18 Page 35 of 35
FILED
ENTERED
LOGG.
RECEIVED

JAN 19 2017
THE UNITED STATES DISTRICT COURT FOR THE
AT
DISTRICT OF MARYLAND I3ALT1fVoRE_:
CLERK, U-S,
DISTRICT
DISTRICT Of-- COURT
13Y MARYLAND
DEPUTY

IN THE MATTER OF THE CELLULAR

TELEPHONE ASSIGNED CALL NUMBER I ~ -
33(01 - SAJO

(443) 224-0996 and (443) 823-0866 whose

&Afo

wireless service provider AT&T

33-70 -
is Wireless, a
01,1 1

company headquartered at 208 South Akard,

-j '-) -j I

10'h Floor, Dallas, Texas 75202 and

Filed Under Seal
(443) 559-1201 whose wireless service

provider is T-Mobile, a company

headquartered at 4 Sylvan Way, Parsippany,

New Jersey 07054

ORDER

Upon review of the Motion of the United States of America, the Court hereby adopts the

government's proffer of the reasons for sealing as presented therein, and it is this ) day of

December 2016, ORDER-ED that the Applications, Warrants, Affidavit and the supporting

documents in the above-captioned matter, be placed under seal until further order of this Court.

It is further ORDERED that the Clerk of the Court provide a copy of this Order to the

United States Attorney's Office.

The Honorable Stephanie A. Gallagher

,

United States Magistrate Judge