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UNITED STATES DISTRICT COURT
for the
Central District of California

In the Matter of the Search of:
Information associated with account identified as
ray.sw.chan@gmail.com that is within the possession, custody,
or control of Google, Inc.

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Case No. 2:18-MJ-1881

WARRANT PURSUANT TO 18 U.S.C. § 2703
To:

Any Authorized Law Enforcement Officer

An application by a federal law enforcement officer requests the production and search of the following data:
See Attachment A
The data to be produced and searched, described above, are believed to contain the following:
See Attachment B
I find that the affidavit, or any recorded testimony, establishes probable cause to produce and search the data
described in Attachment A, and to seize the data described in Attachment B. Such affidavit is incorporated
herein by reference.
AUTHORIZED LAW ENFORCEMENT OFFICER/S IS/ARE HEREBY COMMANDED to serve this
warrant on Google, Inc. in the daytime, between the hours of 6:00 a.m. and 10:00 p.m., within 14 days from the
date of its issuance.
GOOGLE, INC. IS HEREBY COMMANDED to produce the information described in Attachment A within
10 calendar days of the date of service of this order. GOOGLE, INC. IS FURTHER COMMANDED to
comply with the further orders set forth in Attachment B, and, pursuant to 18 U.S.C. § 2705(b), shall not notify
any person, including the subscriber(s) of the account/s identified in Attachment A, of the existence of this
warrant.
The officer executing this warrant, or an officer present during the execution, shall prepare an inventory as
required by law, and shall promptly return this warrant and the inventory to the United States Magistrate Judge
on duty at the time of the return through a filing with the Clerk’s Office.
AUTHORIZED LAW ENFORCEMENT OFFICER/S IS/ARE FURTHER COMMANDED to perform
the search of the data provided by Google, Inc. pursuant to the procedures set forth in Attachment B.
7/20/2018 @ 1:18 pm
Date and time issued: _______________________

/S/

ALEXANDER F. MACKINNON
Judge’s signature

Los Angeles, CA
City and State: ____________________________

Alexander F. MacKinnon, U.S. Magistrate Judge
Printed name and title

AUSA: Veronica Dragalin (x0647)

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Case Document 2 Filed 07/20/18 Page 2 of 10

 

 

Page ID #:130
Return
Case No: Date and time warrant served on provider:
if; (5th

 

 

Inventory made in the presence of' ?34 (Lu, 9?

 

Inventory of data seized: 1
[Please provide a description of the information produced]

1044,,? Newt ab Aown\0o\rQer?L mu 

fruit. sub. dam @Wa? (LN.

 

Certification

 

 

I declare under penalty of perjury that I am an o?icer involved in the execution of this warrant, and that this
inventory is correct and was returned along with the original warrant to the designated judge through a ?ling
with the Clerk?s O?ice.

Date: ll iquiotf) W1

Executing o?cer ?s s?nature

Printeci name and title

 

 

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ATTACHMENT A
PROPERTY TO BE SEARCHED
This warrant applies to information associated with the
account identified as ray.sw.chan@gmail.com and being used by
RAYMOND CHAN, that is within the possession, custody, or control
of Google, Inc., a company that accepts service of legal process
at its headquarters located in Mountain View, California,
regardless of where such information is stored, held, or
maintained.

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ATTACHMENT B
ITEMS TO BE SEIZED
I.

SEARCH PROCEDURE
1.

The search warrant will be presented to personnel of

Google, Inc. (the “PROVIDER”), who will be directed to isolate
the information described in Section II below.
2.

To minimize any disruption of service to third

parties, the PROVIDER’s employees and/or law enforcement
personnel trained in the operation of computers will create an
exact duplicate of the information described in Section II
below.
3.

The PROVIDER’s employees will provide in electronic

form the exact duplicate of the information described in Section
II below to the law enforcement personnel specified below in
Section IV.
4.

With respect to contents of wire and electronic

communications produced by the PROVIDER (hereafter, “content
records,” see Section II.10.a below), law enforcement agents
and/or individuals assisting law enforcement and acting at their
direction (the “search team”) will examine such content records
pursuant to search procedures specifically designed to identify
items to be seized under this warrant.

The search shall extract

and seize only the specific items to be seized under this
warrant (see Section III below).

The search team may use

forensic examination and searching tools, such as “EnCase” and
“FTK” (Forensic Tool Kit), which tools may use hashing and other
sophisticated techniques.
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5.

If the search team encounters immediately apparent

contraband or other evidence of a crime outside the scope of the
items to be seized, the team shall immediately discontinue its
search pending further order of the Court and shall make and
retain notes detailing how the contraband or other evidence of a
crime was encountered, including how it was immediately apparent
contraband or evidence of a crime.
6.

The search team will complete its search of the

content records as soon as is practicable but not to exceed 120
days from the date of receipt from the PROVIDER of the response
to this warrant.

The government will not search the content

records beyond this 120-day period without first obtaining an
extension of time order from the Court.
7.

Once the search team has completed its review of the

content records and created copies of the items seized pursuant
to the warrant, the original production from the PROVIDER will
be sealed -- and preserved by the search team for authenticity
and chain of custody purposes -- until further order of the
Court.

Thereafter, the search team will not access the data

from the sealed original production which fell outside the scope
of the items to be seized absent further order of the Court.
8.

The special procedures relating to digital data found

in this warrant govern only the search of digital data pursuant
to the authority conferred by this warrant and do not apply to
any search of digital data pursuant to any other court order.
9.

Pursuant to 18 U.S.C. § 2703(g) the presence of an

agent is not required for service or execution of this warrant.
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II.

INFORMATION TO BE DISCLOSED BY THE PROVIDER
10.

To the extent that the information described in

Attachments A is within the possession, custody, or control of
the PROVIDER, including any information that has been deleted
but is still available to the PROVIDER, or has been preserved
pursuant to a request made under 18 U.S.C. § 2703(f), the
PROVIDER is required to disclose the following information to
the government for the TARGET ACCOUNT listed in Attachment A:
a.

All contents of all wire and electronic

communications, including services such as Gmail, associated
with ray.sw.chan@gmail.com, and limited to that which occurred
on or after May 24, 2018,1 and all contents associated with
ray.sw.chan@gmail.com, and limited to that which occurred on or
after April 1, 2013, including:
i.

All records (including content records and

the stored application data) pertaining to the Google Document
publicly available at
https://docs.google.com/document/d/1PxaIuhLMVwuJEbWJ4OpUB2i1kC3i
ougbLTEwjNHPjbc/edit?usp=sharing_eil&ts=5adce9d1, including logs
of accounts that accessed or edited the document;
ii.

All records (including content records and

the stored application data) pertaining to any Google service

1 To the extent it is not reasonably feasible for the
PROVIDER to restrict any categories of records based on this
date restriction (for example, because a date filter is not
available for such data), the PROVIDER shall disclose those
records in its possession at the time the warrant is served upon
it.

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associated with the TARGET ACCOUNT, including services such as
Android, Google Play and Android Market (including payment
information), Google Groups, use of Google Chrome or Google
Chrome Sync (including the content of the data that is synced
between different devices and the identity of such devices),
Google Talk, Google Calendar, Google Docs, Google Drive, Google
Services, Google+, Has Google Profile, Has Plusone, Google
Photos (formerly Picasa), Tasks, iGoogle, Web History, Google
Talk, Google Voice, and Hangouts;
iii. All records (including content records and
the stored application data) associated with the TARGET ACCOUNT
pertaining to Location History and Google Maps, including custom
maps, changes and edits to public places, starred places,
private labels of locations, and saved locations.
b.

All other records and information, including:
i.

All records related to authenticating the

user of the TARGET ACCOUNT, including use of two-factor
authentication or App passwords used to allow access via a
mobile device and the identity of those devices accessing the
TARGET ACCOUNT;
ii.

All records relating to any settings applied

by the user of the TARGET ACCOUNT to cause a message to expire,
to require a recipient to insert a password value to read a
message, to control a recipient’s ability to forward a message,
or to retract access to a message already sent.
III. INFORMATION TO BE SEIZED BY THE GOVERNMENT

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11.

For the TARGET ACCOUNT listed in Attachment A, the

search team may seize:
a.

All information described above in Section

II.10.a that constitutes evidence, contraband, fruits, or
instrumentalities of violations of 18 U.S.C. §§ 371
(Conspiracy), 666 (Bribery and Kickbacks Concerning Federal
Funds), 1341, 1343, and 1346 (Deprivation of Honest Services),
1951 (Extortion), and 1956 (Money Laundering), and 31 U.S.C.
§ 5324(a)(3) (Structuring a Financial Transaction to Evade a
Reporting Obligation), those violations involving RAYMOND CHAN,
JOSE HUIZAR, GEORGE ESPARZA, WEI HUANG, RICKY ZHENG, GEORGE
CHIANG, DERON WILLIAMS, FUER YUAN, YAN YAN, CURREN PRICE, JOEL
JACINTO, AVE JACINTO, and SHAWN KUK, occurring after April 1,
2013, namely:
i.

Information relating to who created,

accessed, or used the TARGET ACCOUNT, including records about
their identities and whereabouts.
ii.

All records relating to JOSE HUIZAR, GEORGE

ESPARZA, WEI HUANG, RICKY ZHENG, GEORGE CHIANG, DERON WILLIAMS,
YAN YAN, CURREN PRICE, MASON SITU, LINCOLN LEE, JOEL JACINTO,
AVE JACINTO, SHAWN KUK, SHENZHEN NEW WORLD GROUP, SHENZHEN NEW
WORLD INVESTMENT, INC., HAZENS, the LA Hotel Downtown, the
Sheraton Universal Hotel, and Luxe Hotel.
iii. All records relating to Las Vegas, including
any receipts, reservation confirmations, flight itineraries,
photographs, and bank records relating to Southwest Airlines,
the Palazzo, Caesar’s Palace, the Wynn, and the Cosmopolitan.
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iv.

All financial records relating to JOSE

HUIZAR, his mother (ISIDRA HUIZAR), and his brother (SALVADOR
HUIZAR), and their respective bank accounts including, but not
limited to, those ending in #0843, #2634, #3900 and #3208.
v.

All records relating to development projects

in and around Los Angeles that relate to foreign investors to
include, but not limited to, HAZENS, GREENLAND, OCEANWIDE and
other foreign investors not yet identified.
vi.

All records relating to Salesian High School

Gala, Proposition HHH, El Grito, and other fundraising
expeditions/campaign contributions.
vii. All records relating to projects in and
around Los Angeles, in which HUIZAR or HUIZAR’s staff, KUK,
ESPARZA, JACINTO, CHAN, CHIANG, or WILLIAMS assisted in
acquiring permits, licenses or other official city processes.
viii.

All records related to meetings, event

invitations, dinners, fundraising events, and community events
including radar screens.
ix.

All records related to La Vue, Ho Kee Café,

and other meeting locations being utilized by the violators.
b.

All records and information described above in

Section II.10.b.
IV.

PROVIDER PROCEDURES
12.

IT IS ORDERED that the PROVIDER shall deliver the

information set forth in Section II within 10 days of the
service of this warrant.

The PROVIDER shall send such

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information to:
SA Andrew Civetti
11000 Wilshire Blvd.
Los Angeles, CA 90024
310-996-4564 (Phone) 310-996-3764 (Fax)
ACivetti@fbi.gov
13.

IT IS FURTHER ORDERED that the PROVIDER shall provide

the name and contact information for all employees who conduct
the search and produce the records responsive to this warrant.
14.

IT IS FURTHER ORDERED, pursuant to 18 U.S.C.

§ 2705(b), that the PROVIDER shall not notify any person,
including the subscriber(s) of the account identified in
Attachment A, of the existence of the warrant, until further
order of the Court, until written notice is provided by the
United States Attorney’s Office that nondisclosure is no longer
required, or until one year from the date the PROVIDER complies
with this warrant or such later date as may be set by the Court
upon application for an extension by the United States.

Upon

expiration of this order, at least ten business days prior to
disclosing the existence of the warrant, the PROVIDER shall
notify the agent identified in paragraph 12 above of its intent
to so notify.

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