AO 106 (Rev. 04/10) Application for a Search Warrant

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UNITED STATES DISTRICT COUR

I

for the

Southern District of California

In the Matter of the Search of
(Briefly describe the property to be searched
or identify the person by name and address)
Sch.net
9120 Double Diamond Parkway, Suite 5901,
Reno, NV S9521

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CLERK US DIS IHICT
COUHT
SOUTHERN DISTRICT
OF CALIFORNIA
BY
DEPUTY

Case No.

19MJ1755

APPLICATIONFORASEARCHWAR RANT

r.ASE

UNSEALED PER

ORDER OFCOUR

I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under

penalty of perjury that I have reason to believe that on the following person or property (identifY the person or describe the
property to be searched and give its location):
SEE ATTACHMENT A
(INCORPORATED HEREIN)

located in the

------

District of

Nevada

------

, there is now concealed (identifY the

person or describe the property to be seized):
Sch.net
SEE ATTACHMENT B
(INCORPORATED HEREIN)

The basis for the search under Fed. R. Crim. P. 4l{c) is (check one or more):

rf evidence of a crime;
ff contraband, fruits of crime, or other items illegally possessed;
� property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:

Code Section

Offense Description

1S U.S.C. 247(a)(1), (a)(2)

Intentional obstruction, by force or threat of force of persons in the free exercise of

1S U.S.C. 249(a)(1)

religious belief, resulting in death; willfully causing bodily injury to persons through
the use of a firearm because of the actual or perceived religion of said persons, re

The application is based on these facts:
SEE AFFIDAVIT OF SPECIAL AGENT MICHAEL J. ROD, INCORPORATED HEREIN.

ff Continued on the attached sheet.

0 Delayed notice of

days (give exact ending date if more than 30 days:

-----

) is requested

under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

QlAt\""'<j--

J

-

Applicant's signature

Special Agent Michael J. Rod, FBI

Printed name and title
Sworn to before me and signed in my presence.

Date:

04/2S/2019

City and state:

San Diego, CA

I

Honorable Jill L. Burkhardt

Printed name and title

 1

AFFIDAVIT IN SUPPORT OF

2

AN APPLICATION FOR A SEARCH WARRANT

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I, Michael J. Rod, being first duly sworn, hereby depose and state as follows:
INTRODUCTION

I.

1.

This affidavit is submitted in support of an application for a search

7

warrant, pursuant to lS U.S.C. 2703(a), 2703(b)(l )(A), and 2703(c)(l )(A), for

8

information associated with the following Schan posting with ID 4e267a and No.

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13192921 (hereinafter the "subject posting"), created by John Earnest and others,

1O

known and unknown, and stored at the premises owned, maintained, controlled, or

11 operated by Sch.net, 9120 Double Diamond Parkway, Suite 5901, Reno, NV S9521.
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2.

As described in further detail below, on April 2S, 2019, John Earnest,

armed with an ARl 5 style rifle, conducted an attack at the Chabad of Poway
synagogue, injuring three individuals and killing one individual. He was later
arrested and interviewed and admitted to the Chabad of Poway incident, as well as
an arson at the Dar-ul-Arqam Mosque and Islamic Center on March 24, 2019.
3.

There is probable cause to believe that within Schan, more fully

19

described in Attachment A, will be found evidence of violations of federal law,

20

namely, intentional obstruction, by force or threat of force of persons in the free

21 exercise of religious belief, resulting in death, in violation of 1S U.S.C. § 247(a)(2),
22 willfully causing bodily injury to persons through the use of a firearm because of the
23

actual or perceived religion of said persons, resulting in death, in violation of 1S

24

U.S.C. § 249(a)(l), and damage to religious property, in violation of l S U.S.C. §

25

247(a)(l ), as more fully described in Attachment B.

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4.

I am an investigative or law enforcement officer within the meaning of

2 Title 18, United States Code, Section 2510(7); that is, an officer of the United States,
3

who is empowered by law to conduct investigations of and to make arrests for

4

offenses enumerated in Titles 18 and 21 of the United States Code.

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5.

I am a Special Agent of the FBI, and have been so employed since May

2010. I am currently assigned to the San Diego Field Division. Prior to joining the
FBI, I was a United States Marine Corps Judge Advocate serving on active duty
from November 2001 until May 2010. In my capacity as a Judge Advocate, I
prosecuted and defended violations of the Uniform Code of Military Justice, acted
as the Investigating Officer during criminal proceedings, provided legal assistance
to service members, and advised military commanders on a wide variety of civil and
administrative matters.
6.

I have received twenty-one weeks of training at the FBI Academy in

15

Quantico, Virginia. During that training, I received instruction regarding a wide

16

variety of investigative techniques that are commonly used in support of a wide

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range of the FBI's investigative priorities. The training included instruction

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regarding the use of sources, electronic surveillance techniques, law enforcement

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tactics, search and seizure laws and techniques, surveillance, forensic techniques,

2o

interviewing, and a variety of other subjects. I have acted as the lead investigator on

21 a variety of cases and have participated in multiple cases that have focused on gang
22 related matters.
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7.

Between July 2012 and February 2019, I was assigned to the North

County Regional Gang Task Force (NCRGTF). During my time at the NCRGTF, I
had personal contact with dozens of self-admitted or known gang members and their

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2

 1

associates and have discussed their lifestyles, method of operations regarding violent

2

and property crimes, and their drug trafficking and drug distributing activities. I have

3

participated in investigations involving criminal gang members including but not

4

limited to Hispanic criminal street gangs. In March 2019, I was assigned to the HTTF

5

and have assisted in cases involving human trafficking and the sexual exploitation

6

of adults and children. The facts set forth in this affidavit are based on my own

7

personal knowledge, knowledge obtained from other individuals during my

8

participation in this investigation (including other law enforcement officers), my

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review of documents and computer records related to this investigation, and

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information gained through my training and experience. Because this affidavit is

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submitted for the limited purpose of establishing probable cause for a search warrant,

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it does not set forth every fact that I or others have learned during this investigation.

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PROBABLE CAUSE

II.

A. Chabad of Poway Attack

8.

During the course of my current duties, I have learned the following

from consulting with other state, local and federal law enforcement officers,
including San Diego Sheriff's Department (SDSD) Detectives, San Diego County
District Attorney Investigators, and my fellow FBI agents.
9.

On April 27, 2019 at approximately 11:23 am. San Diego Sheriffs

Communication Center received a 911 call of shots fired at the synagogue located
on Chabad Way in Poway. The reporting party, Dan Sedereff, stated shots were
fired in the synagogue.
10.

During a briefing by the SDSD following the incident, it was reported

that a white male, later identified as John Earnest, entered the synagogue through

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3

 1

the front door and fired several rounds from an AR15 rifle. He then proceeded

2

further into the synagogue where he began firing rounds.

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11.

The SDSD stated that inside the synagogue was off-duty Border Patrol

4

Agent Jonathan Morales who retrieved a revolver weapon from one of the

s

congregation members and chased the suspect out of synagogue firing four shots at

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him as he got into a silver Honda that was parked across the street from the church.

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The Honda fled northbound on Rancho Bernardo Road. Morales then returned the

8

gun to the congregation members who placed it in a black prayer bag and left it in

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the synagogue.

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12.

It was determined by officers that four people were shot and transported

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to the hospital.

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13.

SDSD Deputies responded to the synagogue along with paramedics.

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The synagogue was secured by deputies pending obtaining a search warrant from

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state authorities, which was planned to be executed later that day.

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14.

The same day (April 27, 2019), at approximately 11:30 a.m., a male

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who identified himself as John Earnest called into California Highway Patrol

17

emergency line stating that he had fired shots into the synagogue and was willing to

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surrender to law enforcement. Earnest called from phone number 858.999.1461.

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Earnest gave his location as Phil's BBQ at 17051 West Bernardo Center Dr. He

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stated he was in possession of an AR15 Smith & Wesson MP15 rifle and several

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rounds of ammunition in his vehicle but that he would not use them against law

22

enforcement. During that call, Earnest made the following comments, among others:

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"I just shot up a synagogue. I'm defending my country . . . I'm just trying to defend

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my nation against the Jewish people; they're destroying our people . . . I opened fire

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at a synagogue; I think I killed some people." I am informed and believed that Smith

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& Wesson does not manufacture firearms in the State of California.

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 1

15.

San Diego Police Department ("SDPD") Officers responded to that

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location and took John Earnest into custody without further incident. Seen on the

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front passenger seat was an ARI 5 rifle but no handgun was visible. Additionally, in

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the vehicle was a helmet with a Go-Pro camera on it. SDPD Officers were holding

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the vehicle secure at the location pending obtaining and executing a state search

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warrant.

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16.

While on scene at the vehicle, it was learned that one of the victims,

Laurie Kaye, died as a result of gunshot wounds.
17.

During a public safety interview with SDPD Detective Rudy Castro,

John Earnest confirmed his home address as 10134 Freeport Ct., San Diego CA. He

11 further stated that there were no further weapons at the home. At that time, Earnest
12

did not appear to be under the influence of a controlled substance but did appear to

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have a "flat affect" as though he was detached or unaffected by his actions.

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18.

SDPD SWAT officers and Detectives responded to the residence on

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Freeport Ct. The parents of the suspect were contacted and escorted from the home

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and taken to the Sheriff's Poway substation, pending the execution of a state search

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warrant on their residence. While at the substation, the parents informed law

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enforcement that their son frequently uses a computer in their home.

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19.

Using various search methods, Whitney Buckingham an SDSD system

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data miner, found a manifesto on Pastebin.com written by a person identifying

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himself as John Earnest. In the manifesto, which he named "An Open Letter",

22 Earnest made many anti-Semitic and anti-muslim statements. One such statement
23

which is a direct quote is, "As an individual, I can only kill so many Jews." He states

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he is not a terrorist but that he hates anyone who he sees as a threat to his country.

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Earnest took credit for a fire that had been set at mosque in Escondido a few weeks

26

earlier. His exact statement was "I scorched a mosque in Escondido with gasoline a

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5

 2

week after Brenton Tarrant's sacrifice and they never found shit on me. 11
Additionally, he wrote 11I spray-painted on the parking lot. I wrote 'For

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Brenton Tarrant -t./pol/. 11

1

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20.

FBI Special Agent Maria Solomon observed part of the post-Miranda

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statement of Earnest. During that interview, he informed an SDSO Detective that

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he had adopted his ideology of hate for members of the Jewish religion

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approximately 18 month earlier. Based on my training and experience, I know that

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there is a process in which someone undergoes adoption of radical ideologies. This

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process can take several months or several years before a person actually commits

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to those ideologies. During the interview, Earnest also stated that he was inspired

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by individuals such as Adolph Hitler and Brenton Tarrant.

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B. Dar-ul-Arqam Mosque and Islamic Center Arson

21.

Based on information received from Bureau of Alcohol, Tobacco,

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Firearms and Explosives ("ATF") Special Agent Scott Brahin, on March 24, 2019,

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an unknown individual set fire to a mosque in Escondido, California.

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22.

Specifically, on March 24, 2019, at approximately 3:19 a.m., a 911 call

was placed to report a fire at the Dar-ul-Arqam Mosque and Islamic Center
("mosque"), located at 318 West 6th Avenue in Escondido, California. The
Escondido Fire Department and then Escondido Police Department ("EPD")
responded. First responders learned approximately seven individuals had been
spending the night at the mosque and, at approximately 3:15 a.m., they had observed
flames and rushed outside to extinguish them with a fire extinguisher. First
responders noticed ash or charring along approximately half the length of the
mosque's west side and spray-painted writing on the asphalt parking lot near where
the fire had occurred that read, "FOR BRENTON TARRAN r/pol/." First responders
also noticed the odor of, or similar to, gasoline at the location of the fire.

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23.

Investigators conducted an online search for "Brenton Tarran" and

2

noted that he was arrested for the mass shootings at two mosques in New Zealand

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that occurred on March 15, 2019 and is believed to be a white supremacist.

4

Investigators also learned "r/pol/" is a reference to an online political discussion

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board that has been characterized as predominately racist, espousing views

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embraced by white supremacist groups.

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24.

Investigators reviewed surveillance footage retrieved from a business

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across the street from the mosque. The camera recorded an individual ("suspect")

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park his/her four-door sedan in front of the mosque at approximately 3:00 a.m. In

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the video, the suspect exited the vehicle, walked towards the parking lot where the

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message was later found spray painted, and then returned to the vehicle. Shortly

12

thereafter, the suspect again exited the car carrying a large container and walked

13

toward the area of the mosque where the fire was set. A short time later, at

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approximately 3:15 a.m., a large flash of light and smoke are seen in the video and

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the suspect walked back to the vehicle and drove away westbound on West 6th

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Avenue.

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investigators observed that the suspect appeared to arrive at the mosque on March

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24, 2019 by driving eastbound on West 9th Avenue, northbound on South Escondido

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Boulevard, and then westbound on West 6th Avenue, where he parked in front of

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the mosque. Investigators also observed, as noted above, that the suspect left the area

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by driving westbound on West 6th Avenue. Based on their review of surveillance

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videos, investigators believed that the suspect was driving a 2010 to 2015 Civic

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Honda, silver in color.

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25.

In surveillance videos obtained from businesses along the route,

Earnest's statements in the manifesto that he set fire to the Escondido

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mosque on March 24, 2019, are corroborated by the following. At the time of his

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arrest for the synagogue shooting, Earnest was driving a 2012 Honda Civic, grey in

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color. Additionally, the spray painted message left by the mosque arsonist was not

2

released to the media. The fact that the manifesto specifically makes reference to

3

that message further corroborates that Earnest committed the mosque arson.

4
5

C. Schan Posting

26.

Based on my training and experience, and online research, Schan, also

6

known as Infinitechan or Infinitychan (sometimes stylized as oochan), is an

7

American-based website composed of user-created boards. According to Wikipedia,

8

"An owner moderates each board, with minimal interaction from other site

9

administration."

10

27.

On April 27, 2019, an Anonymous user posted on Schan a posting with

11

thread number 13192921 and posting ID number 4e267a. The posting read in part:

12

It's been real dudes. From the bottom of my heart thank you for

13

everything. Keep up the infographic redpill threads. I've only been

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lurking for a year and a half, yet, what I've learned here is priceless.

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It's been an honor.

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Livestream link is below as well as my open letter. Livestream will
begin shortly. https://www.facebook.com/john.eamest.967SO

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An open letter.

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https://pastebin.com/VXXFOMTW

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https://www.mediafire.com/file/d9oilcmjbenxiyz/Open Letter.pdf.file

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2S.

As discussed above, agents observed the content at the above described

pastebin.com address and observed an open letter believed to be written by Earnest.

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 1 Additionally, on April 27, 2019, Greg Simon of the SDPD located the above
2

described posting that included information about a livestream using a Facebook

3

account, https://www.facebook.com/john.earnest.96780 (i.e., Facebook Account

4

Number 100035547390347, with user name ''john.earnest.96780."). On or about

5

April 27, 2019, following the synagogue shooting, local law enforcement authorities

6

served a search warrant on Facebook for records for the ''john.earnest.96780"

7

Facebook account, pursuant. In response to that request, Facebook provided records

8

which listed the user's phone as 858.999.1461 (the same number Earnest used to call

9

the CHP on April 27, 2019). Facebook verified the number on April 7, 2019.

10

Facebook identified two additional Facebook accounts possibly utilized by the user

11

of the john.earnest.96780 Facebook account, which were accessed via the same

12

browser and the same electronic device.

13

29.

14

-tli''� °'-� c:ML-vrr
above described posting and thread. See Appendix 1, attached to AttaehmefttB. For

15

example, on April 27, 2019, a posting with ID 2d7a65 and thread number 13193230

16

posted, "anyone had a decent read of his manifesto yet?" Another posting, ID

17

cb34c8 and thread number 13193259, stated:

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22

It's very much written for /pol/, he goes into some depth about things
being called falseflags, about how you should start getting
prepared. . . Tarrant was a much more articulate writer, and walked
through his thought process much more, which leads to people being
able to understand (even if they can't publicly admit) why he did what
he did. Earnest's honest passion is his highlight and his weakness - no
boomer is going to read this and suddenly became aware of the JQ."

23
24

Another April 27, 2019 with ID 078285 and thread number 13193283 posted an

25

image of a news station article posted on April 27, 2019 at 12:11 pm. The headline

26
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�

Agents observed that there were several postings responding to, the

9

�

 1

stated, "Multiple people gunned down at Poway Synagogue, police search for

2

shooter."

3
4

D. Basis for Information Sought
30.

Agents seek IP address and metadata information about Earnest's

5

original posting and the postings of all of the individuals who responded to the

6

subject posting and/or commented about it. Additionally, agents seek information

7

about any other posting coming from the IP address used by Earnest to post the

8

subject posting.

9

31.

As discussed above, Earnest made a posting in which he thought to

1O

draw attention to his forthcoming attack on the Chabad of Poway, share his views

11

through his open letter, and offer people the opportunity to observe the attack itself.

12

Several people responded, both individuals who were taken aback about the posting

13

as well as people who were sympathizers. As a result, some of the individuals may

14

be potential witnesses, co-conspirators and/or individuals who are inspired by the

15

subject posting. Based on agents' training and experience, following attacks such

16

as those conducted by Earnest, other individuals are inspired by the attacks and may

17

act of their own accord. For example, as described above, Earnest himself was

18

inspired by the Christchurch event in New Zealand. Regardless of the nature of the

19

comments, the evidence sought to be seized as described in Attachment B is relevant

20

as evidence of Earnest's bias and motivation in committing the hate crimes set forth

21

in Attachment B. Even comments made in response to the subject posting or about

22

it are relevant to Earnest's motivation for his violent attacks to the extent that as

23

explained above, some of the posters may be potential witnesses, co-conspirators

24

and/or individuals who are inspired by the subject posting. As discussed above,

25

Earnest stated in the subject posting, "I've only been lurking for a year and a half,

26

yet, what I've learned here is priceless." This information suggests that Earnest was

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10

 1

inspired and/or educated by individuals who commented on his threads. Based on

2

this information, there is reasonable cause to believe that the information sought,

3

specifically IP address and metadata for all commenters, constitute evidence of his

4

motivation in committing the offenses described herein and are thus relevant and

5

material to an ongoing criminal investigation, information that may be sought by an

6

order issued pursuant to l S U.S.C. § 2703(c) and ( d). That is, the information may

7

lead to the identity of individuals who inspired and/or educated Earnest or are aware

8

of his motivation in committing the attacks.

9

32.

FBI agents have consulted with Sch.net about the kind of information

1o

that the website maintains and understand that Sch.net is an anonymous imageboard

11

and users are not required to create an account or use a name or an email address to

12

post. Hence, regular users usually have no usernames or email addresses linked to

13

their posts. However, agents have also learned that Sch.net has used data forensics

14

in the past to find information about individuals who have posted on Sch.net,

15

including IP address and metadata information (although not if the thread or post has

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n my experience and traming, and the experience and training

of other agents with whom I have consulted with, electronically stored data can be
21

permanently deleted or modified by users possessing basic computer skills. In this

22

case, only if the subject receives advance warning of the execution of this warrant,

23

will there be a genuine risk of destruction of evidence.

24

B.

Prior Attempt to Obtain Evidence

25

34.

The United States is aware that individual users of ch.net contacted law

26

enforcement authorities about the subject posting and may have provided the subject

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28

11

1•

 1

posting to law enforcement authorities. The United States is unaware of other efforts

2

except as described herein.

3

C.

4

35. Ch.net is an Internet company that, among other things, provides electronic

5

communication services to its subscribers. Ch.net's electronic mail service allows

6

its subscribers to exchange electronic communications with others through the

7

Internet.

8

36.

Ch.net

At the creation of a Ch.net account and for each subsequent access to

9

the account, Ch.net logs the Internet Protocol ("IP") address of the computer

1O

accessing the account. An IP address is a unique address through which a computer

11

connects to the Internet. IP addresses are leased to businesses and individuals by

12

Internet Service Providers.

13

particular Ch.net account often identifies the Internet Service Provider that owns and

14

has leased that address to its customer. Subscriber information for that customer

15

then can be obtained using appropriate legal process.

Obtaining the IP addresses that have accessed a

16

D.

Procedures for Electronically Stored Information

17

37.

Federal agents and investigative support personnel are trained and

18

experienced in identifying communications relevant to the crimes under

19

investigation. The personnel of Ch.net are not. It would be inappropriate and

2O

impractical for federal agents to search the vast computer network of Ch.net for the

21

relevant accounts and then to analyze the contents of those accounts on the premises

22

of Ch.net. The impact on Ch.net's business would be severe.

23

'

38.

Therefore, I request authority to seize all content, including electronic

24

mail and attachments, stored instant messages, stored voice messages, photographs

25

and any other content, as described in Attachment B. In order to accomplish the

26

objective of the search warrant with a minimum of interference with the business

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28

12

 1

activities of Ch.net, to protect the rights of the subject of the investigation and to

2

effectively pursue this investigation, authority is sought to allow Ch.net to make a

3

digital copy of the entire contents of the accounts subject to seizure. That copy will

4

be provided to me or to any authorized federal agent. The copy will be forensically

5

imaged and the image will then be analyzed to identify communications and other

6

data subject to seizure pursuant to Attachment B. Relevant data will be copied to

7

separate media. The original media will be sealed and maintained to establish

8

authenticity, if necessary.

9

39.

Analyzing the data to be provided by Ch.net may require special

1o

technical skills, equipment and software. It also can be very time-consuming.

11

Searching by keywords, for example, often yields many thousands of"hits," each of

12

which must be reviewed in its context by the examiner to determine whether the data

13

in within the scope of the warrant. Merely finding a relevant "hit" does not end the

14

review process. Certain file formats do not lend themselves to keyword searches and

15

keyword search text. Many common electronic mail, database and spreadsheet

16

applications, which files may have been attached to electronic mail, do not store data

17

as searchable text. The data is saved in a proprietary non-text format. The volume of

18

storage allotted by service providers increases, the time it takes to properly analyze

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recovered data increases dramatically.

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40.

Based on the foregoing, searching the recovered data for the

21

information subject to seizure pursuant to this warrant may require a range of data

22

analysis techniques and may take weeks or even months. Keywords need to be

23

modified continuously based upon the results obtained. The personnel conducting

24

the examination will complete the analysis within (90) days of receipt of the data

25

from the service provider, absent further application to this court.

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28

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41.

Based upon my experience and training, and the experience and training

2

of other agents with whom I have communicated, it is necessary to review and seize

3

all posting that identify any poster of the subject posting and any postings sent or

4

received in temporal proximity to incriminating electronic mails that provide context

s

to the incrimination mails.

6

42.

All forensic analysis of the imaged data will employ search protocols

7

directed exclusively to the identification and extraction of data within the scope of

8

this warrant.

9

IV.

REQUEST FOR SEALING AND PRECLUSION OF NOTICE

10

43.

Although John Earnest has been arrested by state authorities, he is

11

unaware of the scope and nature of law enforcement's investigation into his

12

activities. Additionally, law enforcement is still investigating whether he acted

13

alone, or conspired with others or was inspired by others. As such, there is reason

14

to believe that that disclosure of the affidavit and warrant will result in destruction

15

of or tampering with evidence or otherwise seriously jeopardize the investigation.

16

Accordingly, it is requested that this warrant and its related materials be sealed until

17

further order of the Court. In addition, pursuant to Title 18, United States Code,

18

Section 2705(b), it is requested that this Court order Ch.net to whom this warrant is

l9

directed not to notify anyone of the existence of this warrant, other than its personnel

20

essential to compliance with the execution of this warrant until October 28, 2019,

21

absent order from the Court.

22

V.

CONCLUSION

23

44.

Based on the foregoing, your affiant submits that there is probable

24

cause to believe that violations of federal criminal law, namely, violations of federal

25

law, namely, intentional obstruction, by force or threat of force of persons in the free

26

exercise of religious belief, resulting in death, in violation of 18 U.S.C. § 247(a)(2),

27
28

14

 1

willfully causing bodily injury to persons through the use of a firearm because of the

2

actual or perceived religion of said persons, resulting in death, in violation of 18

3

U.S.C. § 249(a)(l), and damage to religious property, in violation of 18 U.S.C. §

4

247(a)(l), have occurred, and that evidence of said violations, as described in

5

Attachment B will be found within the subject posting and all the postings of all of

6

the individuals who responded to the subject posting and/or commented about his

7

posting.

8
9
1o

I declare under penalty of perjury under the laws of the United States that the

11

foregoing is true and correct.

12
13

Michael J. Rod

14

FBI, Special Agent

15
16

Sworn to before me this

17

_z±:1day of April __ 2019

18
19
20
21

ED STATES MAGISTRATE JUDGE

22
23
24
25
26
27
28

15

 File (hide): 24426db8le67b3d

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search for shooter

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ATTACHMENT A

This warrant applies to information associated with Schan posting with ID�
IV\

�

� s==�bout the posting, owned, maintained, controlled, or if

posting an

operated by Sch.net, 9120 Double Diamond Parkway, Suite 5901, Reno, NV S9521.

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�p� lt >'-- �

4e267a and No. 13192921 and all postings by individuals wftti restiendeel to said

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ATTACHMENT B

All information, including but not limited to, IP address and metadata
information, related to Schan posting with ID 4e267a and No. 13192921 and all postings
,

by individuals

c�

�
v;r�G�d to said posting and/or oemni:ente«
about said posting,

as