Case Document 98-7 Filed 06/18/19 Page 1 of 56

Exhibit 

Case Document 98-7 Filed 06/18/19 Page 2 of 56

A0 106 (SDNY Rev. 01117) Application for a Search Warrant

UNITED STATES DISTRICT COURT

   

for the 
l' 
In the Matter of the Search of 
{Brie?y describe the property to be searched I
or fdenty?? the person by name and address) Case No. 31 17 on 548 (P AC)
See Attachment 3


APPLICATION FOR- A SEARCH AND SEIZURE WARRANT

I, a federal law enforcement of?cer or an attorney f01 the government, request a search wanant and state under
penalty of perjury that I have reason to believe that on the following person or propelty {ideas}? the person or describe the
property to be searched and give its location):

located in the Southern District of New York there is now concealed (Edema? the

person or describe the property to be seizec?:

See Attached Af?davit and its Attachment A

The basis for the search under Fed; R. Crim. P. 41(0) is (check one armor-e):
evidence of a crime; 
i3 contraband, fruits of crime, or other items illegally possessed;
property designed for?use, intended for use, or used in committing a crime;
a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:

Code Section?s) O??ense Description?)
18 U. S.C. 401- 793- Contempt of court; unlawful disclosure of ctassi?ed information; unauthorized computer
access obstruction ofjustice; smuggling contraband into prison; iliegal acts related to

1030; 1503; 1791; 2252A child pornography.
The application is based on these facts:

See Attached Affidavit and its Attachment A

51 Continued on-the attached sheet.

I21 Delayed notice of 30 days (give exact ending date if more than 30 days: is requested
under 18 3103a the basis of which IS set forth on the attached sheet.

 



t/anLoOl

 

pplicont hygnature


Jeffrey David FBI Speciat Agent

 

 

 

 

 

 

Printed game aiidt'ztle
Sworn to before me and signed in my presenceDate: 10/06/2013 11w item. 
. Judge? 5 signature
City and states, New York, NY . The Honorable Paul A. Crotty, uses.

Printed name and title



 

Case Document 98-7 Filed 06/18/19 Page 3 of 56

 

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

In the Matter of the Application of the United TO BE FILED UNDER SEAL

States of America for a Search and Seizure A A

Warrant for a Compact Disc Located at the 2 Agent Affidavit of
. Federal Bureau of Investigation?s New York Application for Search Warrant

Field Of?ce, 26 Federal Plaza, New York, New

York 3

SOUTHERN DISTRICT OF NEW YORK) 33.:
JEFF D. DONALDSON, being duly sworn, deposes and says:

I. Introduction

A. Affiant

1. I am a Special Agent of the Federal Bureau of Investigation assigned to the.

New York Field Office, and have been employed .by the FBI since 2010. I am currently assigned
to? a squad responsible for counterespionage matters and have. worked in the ?eld of
counterintelligence from 2010 to present. In the course of my duties as a Special Agent, I am
responsible for investigating offenses involving espionage and related violations of law, including
unauthorized retention, gathering, transmitting or losing classi?ed documents or materials;
unauthorized removal and retention of classi?ed documents or materials; illegally acting in the
United States as a foreign agent; other national security offenses; and the l-making of false
statements. As a result of my involvement in espionage investigations and investigations involving
the unauthorized disclosure or retention of classi?ed information, as well as my training in
.counterintelligence operations, I am familiar with the tactics, methods, and techniques of United
States persons who possessor have possessed a United States Government security clearance and

may choose to harm the United States by. misusing their access to classi?ed information. I am also



 

 

Case Document 98-7 Filed 06/18/19 Page 4 of 56

familiar, though my training. and experience with the use of computers in criminal activity and the
forensic analysis of electronically stored information.

2. I make this Af?davit in support of an application pursuant to Rule 41 of the Federal
Rules of Criminal Procedure for a warrant to search and seize materials contained on?a compact
disc currently in the possession of the Federal Bureau of Investigation in New York, New 2
York (the As described in additional detail below, on October 3, 2018, law enforcement
officers searched the Metropolitan Correctional Center pursuant to a search warrant
signed by the Court on October 2, 2018 (the Search Warrant?). The MCC Search Warrant
and underlying af?davit are attached to this application as Exhibit A and are incorporated by
reference, including the de?nedterms identi?ed therein.

3. Pursuant to the MCC Search Warrant and a subsequent search warrant-obtained on
October 3, 2018, law enforcement of?cers reviewed documents (the ?Schulte Cell Documents?)
collected from a cell formerly inhabited by Joshua Adam Schulte, among others. Among the
Schulte Cell Documents was a document that listed multiple potential passwords for three
messaging accounts Account-J,? Account-2,? 
Account-3,? together the Accounts?). On October S, 2018, an FBI Special Agent
who?is not a member of the Schulte prosecution team accessed the Accounts and
downloaded their contents onto the CD. This search warrant seeks authorization for law
enfOrcement of?cers on the Schulte prosecution team to review the CD and seize any evidence of
the Subject Offenses, de?ned below.

4. This Af?davit is based upon my personal knowledge; my review of documents and
other evidence; my conversations with other law enforcement personnel; and my training,

experience and advice received concerning the use of computers in criminal activity and the



 

Case Document 98-7 Filed 06/18/19 Page 5 of 56

forensic analysis of electronically stored information. Because this Af?davit is being submitted
for the limited purpose of establishing probable cause, it does not include all the facts that I have
learned during the course of my investigation. Where the contents of documents and the actions,
statements, and conversations of others are reported'herein, they are reported in substance and in
part, except where otherwise indicated.

B. The CD to Be Searched

5. The CD is a' silver and white compact disc bearing the marking ?2018.105? and
The CD is Currently located at the New York Field Of?ce, 26 Federal
Plaza, New York, New York.

C. The Subject Offenses

6. For the reasons detailed below, I believe that there is probable cause that the Schulte
Documents contain evidence, fruits, and instrumentalities of Title 18, United States Code, Sections
401 (contempt of court), 793 (uniawful disclosure of classi?ed information), 1030 (unauthorized
computer access), 1503 (obstruction of justice), 1791 (smuggling contraband into a federal -
detention facility) and 2252A (illegal acts related to child pornography); as well as conspiracies
and attempts to violate these provisions and aiding and abetting these offenses (the ?Subject
Offenses?). I

II. Probable Cause and Request to Search

7. Based on my training, experience, and participation in this investigation, as well as

my conversations with others, I have learned, among other things", that:
I a. On October 3, 2018, I and other law enforcement of?cers executed the
MCC Search Warrant. Prior to the search, MCC of?cials had removed the Schulte Cell
Documents, among other things, from Schulte?s former cell and stored them in an of?cial office

at the MCC.



Case Document 98-7 Filed 06/18/19 Page 6 of 56

I b. . Among the Schulte Cell Documents is a document that reflects the names 
of the Accounts, as?well as potential passwords for the Accounts (the
?Password Document?). The. Password Document is attached as Exhibit B.

c. The Accounts are email accounts housed by a foreign
service provider known as ProtonMail Secure Message, which according to its website is based in
Switzerland. Account-1 is the account named annon1204@protoninail.com;

Account-2 is the account named presumedguilty@protonmail.com; and 
Account-3 is the account named ?eej asonbourne@pretonmail.eom.

d; As?re?ected on the Password Document, the names of Account-
1 and Account-3 appear without ?@protonmail.com.? Nevertheless, the Government
previously identi?ed Account?.1 through pictures tram the CS Account, two of which.
are included in this affidavit. In addition, the name of Account-3 appears on the
password document below Account?1, which supported that Account-3 is
a ProtonMail account. Moreover, on another one of the Schulte Cell Documents the name of

Account-3 appears just above ?@protonmail.com.? Below the nameof 
Account?3 are a series of what appear to he draft Twitter messages that purport to be from third?
parties with knowledge of Schulte?s alleged innocence. (Twitter is a social media messaging
service that allows users to post messages known as .?tweets? onlinei) 

. 8. Based on my training, experience, and participation in this investigation, as well as
my review of documents in the CS Account, which belongs to a prisoner who While at the MCC
observed and documented Schulte and'Omar Amanat using the Contraband Cellphones, have

learned, among other things, that:



Case Document 98-7 Filed 06/18/19 Page 7 of 56

The Schulte Cellphone was used to send messages using .

Account-1 to third parties. The below image re?ects one of those communications:

3 it (if; 3 ti N- 

Wam-wuw

.

.mmw

 

b. Another image from the CS Account appears to Show that 
Account-1 Was used to receive potentially classi?ed'infonnation from another email account
believed to be used by Schulte. The image below, dated September 18, 2018, appears to depict a
September 1, 2018 message ?om Conj Khyas to Account-.1.1 The message contains
no body text and attaches a large (14.8 megabytes) ?le whose full title is not displayed. The
displayed title is ?Schulte _Ha . ?Notespdf,? which appears to be a reference to the information

contained in the Pro Se Bail Motion.

 

1 On October 3, 2018, the Government obtained a search warrant for the Conj Khyas account. The
search warrant was served on the provider and the Government is awaiting the returns.

5

1

Case Document 98-7 Filed 06/18/19 Page 8 of 56

 

9. Based on my training, experience, and participation in this investigation, as well as

'my review of the Schulte Cell Documents, I have learned, among other things, that:
a. Schulte discussed setting up and using the Accounts to send
potentiaily classi?ed information to third parties. For example, Schuite stated: -

. i. thoughtl convinced him [Schulte?s father] to setup a protonrnail
email acct for me to upload the articles,? which is potentially a reference to the Schulte Articles;
11. ?Create new protonmail: 
Account-2] . . . migrate wordpress to protonmail.? According to the website
WordPress.com, WordPress ?ailows you to build a website that meets your unique needs. Start a

biog, business site, portfolio, online store, or anything else you can imagine.?



Case Document 98-7 Filed 06/18/19 Page 9 of 56

?The way is clear. I . will set up a wordpress of
and From here, I will stage
my information war: . The presumption of innocence blog will contain my 10 articles . . 

iv. . ?Yesterday I started cleansing the phone in the process setup a
new protonmail which I transferred the wordpress too 

b. Schulte also discussed potentially disclosing classi?ed information to
foreign countries if the Government do es not pay him restitution for allegedly falsely accusing him
of crimes. For example, Schulte stated: . ?If govt doesn?t?pay me $50 billion in restitution 
prosecute the criminals who lied to the judge and presented this BS case then I will visit every
country in the world and bear witness to the treachery that is the USG [United States Government].
1 will look to breakup diplomatic relationships, close embassies, and US occupation across the
world ?nally reverse US 

10. Based on my training, experience, and participation in this investigation, as well as
On my conversations with others, including an FBI Special Agent who is not a member of the
S'chulte prosecution team (the ?Wall Agent?), I have learned, among other things, that:

a. On October 5, 2018, the Wall Agent used the passwords on the Password
Document to access the Accounts. 

b. Once the Wall Agent accessed Accounts, the Wall Agent
downloaded the contents of the Accounts to the CD.

. Evidence, Fruits, and Instrumentalitie?s on the CD
11. Based on my training, experience, and participation in this investigation, I know 
that inmate phone calls at federal detention facilities, like the MCC, are recorded. Thus, inmates

at times attempt to smuggle contraband electronic devices into the MCC, such as the Contraband

3

Case Document 98-7 Filed 06/18/19 Page 10 of 56

Cellphones, in order to covertly communicate with others while in prison. I also know that inmates
will use such electronic devices to access emails accounts, like the Accounts, that will

allow them to communicate discreetly, including about criminal conduct. As a result, the fact that
Schulte setup and used the Accounts to send or receive communications, on its own,
demonstrates that the account likely contains communications evidencing crimes, including the
Subject Offenses.

12. Based onthe foregoing, and based on my training and experience, i know that
Schulte has used the Contraband Cellphones to, among other things, access Account-
1. I also l<now that Schulte discussed using the Accounts, including 
Account-2, to load documents created by WordPress. I also know that Schulte referenced
Account~3 on at least two pages of the Schulte Cell Documents, and on one page
drafted purported messages below the name of Account-3. As a result, there is
probable cause to believe that the Accounts contain evidence, fruits, and
instrumentalities of the Subject Offenses, as more fully described in Section II of Attachments .
and A-2 to the requested warrants. For example, there is probable cause to believe that the
Accounts will contain evidence of communications involving Amanat and Schulte?s
attempt to manufacture evidence in advance of Amanat?s sentencing. Similarly, there is probable
cause to believe that the Accounts will also contain evidence of communications
Schulte had over the Contraband iPhones, which?like the Pro Se Motion and the Schulte
Articles?are likely to contain classi?ed information or information protected by the Schulte

. Protective Order. Moreover, I submit that there is probable cause to believe that the 
Accounts will also contain evidence of potential child pornography offenses and obstruction of

justice. In particular, Schulte has made certain allegations in his Pro Se Bail Motion with respect



Case Document 98-7 Filed 06/18/19 Page 11 of 56

to the child pornography crimes with which he is charged, which constitute evidence of the charged
offenses.
13.. Based on the foregoing, I believe the Accounts are likely to contain,
among other things, the following information:
a. Evidence of the identity(ies) of the user(s) of the Accounts and
the Contraband Cellphones, as well as other coconspirators in contact with the Contraband
Cellphones; 
b. Evidence relating to the geolocation of the users of the 
Accounts at times relevant to the Subject Offenses; 
c, Evidence relating to the participation in the subject Offenses by the?CS,
schuitc, Amanat, and others using or in communication with the Accounts;
d. Evidence concerning ?nancial institutions and transactions used by the
users of the Accounts in furtherance of the Subject Offenses;
e, Communications evidencing crimes, including the Subject Offenses; .
f. Evidence of and. relating to computers or other online accounts and facilities
(such as additional-email addresses) controlled or maintained by the user(s) of the Contraband
Cellphones or Accounts; and I
I g. Passwords or other information needed to access any such computers,
accounts, or facilities. .
14. Based on the foregoing, I believe there is probable cause to search the 

including the'contents of the seize the information identified in the

foregoing paragraph.

5

Case Document 98-7 Filed 06/18/19 Page 12 of 56

IV, Conclusion and Ancillary Provisions
- 15. Based on the foregoing, I respectfully request the court to issue awarrant to search
and seize the items and information speci?ed in Attachment A to this Af?davit and to the Search
and Seizure Warrant. I
16. In light of the con?dential nature of the continuing investigation, I respectfully
request that this Af?davit be maintained under seal until the Court orders otherwise.
mkotw?
JEFF D. 

Special Agent
Federal Bureau of Investigation

Sworn to before me on
this 6th day of October 2018?

THE HONORABLE PAUL A 
UNITED STATES DISTRICT HUI)

SOUTHERN DISTRICT QE YURK

.1 ll?i"

10



Case Document 98-7 Filed 06/18/19 Page 13 of 56

Attachment A
1. Identi?cation of the CD to Be Searched 7

The CD is a silver and white compact disc bearing the marking ?2018.105? and ?650-
The CD is currently located at the New York Field Office, 26 Federal Plaza,
New York, New York.-' The CD contains the contents of three email accounts
Account-d,? Acconnt~2,? and Account-3,? together the
Accounts?).

The Accounts are email accounts downloaded to the CD from a
foreign service provider known as ProtonMail Secure Message, which according to its website is
based in Switzerland. Account-1 is the account named annon1204@protonmail.com;
Account-2 is the account named presumedguilty@protonmail.com; and 
Account-3 is the account named 

II. Execution of the Warrant

Law enforcement agents are permitted to execute the search warrant at any time in the day
or night. Upon the execution of this warrant, notice will be provided at or as soon as possible after
the execution of the search.

Items to Be Searched and Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses

The CD may be searched for the seizure of the following evidence, fruits, and
instrumentalities of: Title 18, United States Code, Sections 401 (contempt of court); Title 18,
United States Code, Section 793 (unlawful disclosure of classi?ed information); Title 18, United
States Code, Section 1030 (unauthorized computer access), Title 18, United States Code, Section
1503 (obstruction of justice), Title 18, United States Code, Section 1791 (smuggling contraband

into a federal detention facility) and Title 18, United States Code, Section?i52A (illegal acts

7

Case Document 98-7 Filed 06/18/19 Page 14 of 56

related to child pornography); as well as conspiracies and attempts to violate these provisions and.
aiding and abetting these offenses (the ?Subject Offenses?), ineluding:

a. Evidence of the identity?es) of the user(s) of the Accounts and
contraband cellphones in the Metropolitan Correctional Center (the ?Contraband Cellphones? as
well as other coconspirators in contact with the ?Accounts and/or Contraband
Cellphones;

I Evidence relating to the geolocation of the users of the 

Accounts at times relevant to the Subject Offenses; I -

0. Evidence relating to the participation in the Subject Offenses by Schulte,
Omar Amanat, and others using or in communication with the Accounts and/or
Contraband Cellphones; 

7d. Evidence concerning financial institutions and transactions used by the
users of the Accounts and/or Contraband Cellphones in furtherance of the Subject
Offenses; 

e. Communications evidencing crimes, including the Subject Offenses;

f. Evidence of and relating to computers or other online accounts and facilities
(such as additional email addresses) controlled or maintained by the. user(s) of the 
Accounts and/or Contraband Cellphones; and

g. Passvvords or other information needed to access any electronic devices like

the Contraband Cellphones or facilities like the Accounts.

8

Case Document 98-7 Filed 06/18/19

EXHIBIT A

Page 15 of 56

21 9

Case Document 98-7 Filed 06/18/19 Page 16 of 56

A0 106 (SDNY Kiev. 0111'?) Application for a Search Warrant

UNITED STATES DISTRICT COURT
for the

ieMAGd3??i

Case No. 81 1? Or. 548 (PAC)

In the Matter of the Search of

(Brie?y describe the pi'operg: to be searched
or iden??t- the person by name and address? 

See Attachment A

APPLICATION FOR A SEARCH AND SEIZURE WARRANT

. I, a federal law enforcement of?cer or an attorney for the government, request a search warrant and state under
penalty of petjury that I have reason to believe that on the following person or property (idena? thepmm; or describe the

property i'o be searched and givelt'fs location):

located in the Southern District of New York there is now concealed ?deno?- the

person or describe thepropm??v {o be omitted):

- See Attached Affidavit and its Attachment A

The basis forthe search under Fed. R. Grim. P. 41 is (check one or more): I
I1 evidence of a crime;
[El contraband, fruits of crime, or Other items ?iega?y possessed;
property designed fer use, intended for use, or used in committing a crime;
a person to be antested or a person who is unlaw?zlly restrained.
The search is related to aviolatidn of:
Code Section?s?) Desenjption(s)

13 401; 793; 1030; Contempt of court: unlawful discioSure of classi?ed information; unauthorizedcomputer
access; wire fraud: obstruction of justice; smuggling contraband into prison; illegal acts

1343; 1503; 1791; 2252A related to child pornography.
The application is based on these facts:
See Attached Affidavit and its Attachment A
Continued on the attached sheet. -
. is requested

Delayed notice of 30 days (give exact ending date if more than '30 days:
under 18 U.S.C. 3103a,_the basis of winch is set forth on the attached sheet, .
.


?Tx?t?ve
. 

I Swami?! 

.I

 

Jetff?y? aim-Donaldson}! 31:13.! '??eciai Agent
.



I Sworn to before me and signed inmy presence. "1 
. ?zed clam-t I
Date: . 4am - .933? 
.ift?lci?e hig?o?ire

City and state: New York, NY . The Honorable Paul A. Crotiy..U.S.D.J..
- . Printed name and #er -

 



Case Document 98-7 Filed 06/18/19 Page 17 of 56

Lama
G0


.53

@3



UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK



In the Matter of the Application of the United 5 TO BE FILED UNDER SEAL
States of America for a Search Warrant for the 

Premises Known and Described as 7 South Unit, .3 - Agent Af?davit in Support of
7 North Unit, Including the Cells Located In Application for Search Warrant

Those Units, and the Education Department?s 
Law Library on the Second Floor, located in 
Metropolitan Cone ctional Center, 1550 Park Row, 
New York, New York 10007, as well as Any 5
Closed Containers/Items Contented in the i
Premises 3



SOUTHERN DISTRICT OF NEW YORK) 83.:



 

JEFF D. DONALDSON, being duly sworn, deposes and says:

I. IntrOdnotion
A. Affiant
l. I am a Special Agent of the Federal Bureau of Investigation assigned to the

New York Field Of?ce, and have been employed by the FBI since 2010. I am currently assigned
to a squad responsible for counterespionage matters and have worked in the ?eld of .
counterintelligence from 2010 to present. In the course of my duties as a Special Agent, I am
responsible for investigating offenses involving espionage and related violations of law, including
unauthorized retention, gathering, transmitting. or losing classi?ed documents or materials;
unauthorized removal and retention of. classi?ed documents or materials; illegally acting in the
United States as a foreign agent; other national security offenses; and the making of false
statements. Asa result ofmy involvement in espionage investigations and mvestigations involving
the unauthorized disclosure or retention of classi?ed information, as well as my training in
counterintelligence operations, I am familiar with the tactics, methods, and techniques of United 

States persons Who possess, or have possessed a United States Government secmity clearance and



Case Document 98-7 Filed 06/18/19 Page 18 of 56

may choose to harm the United States by misusing their access to classi?ed infonnation. I am also
familiar, though my training and experience with the use of computers in criminal activity and the
forensic analysis of electronically stored information,

I make this Affidavit in support of an application pursuant to Rule 41 of the Federal
Rules of_ Criminal Procedure for a second warrant to search the premises speci?ed below (the
?Subject Realises?) for the items and information described in Attachment A. This Af?davit is
based upon my personal knowledge; my review of documents and other evidence; my
conversations with other law enforcement personnel; and my training, experience and, advice
received concerning the use of computers in criminal activity and the forensic analysis of
electronically stored information Because this Af?davit is being submitted for the lirnited I
purpose of establishing probable cause, it does not include. all the facts that I have leamed during
the course of my investigation. Where the contents of do cmnents and the actions, statements, and
comers ations of others are reported herein, they are reported in substance and in part, one opt where
mavens indicated. 

B. The Subject Premises 
3. The Subject Premises is particularly described as the 7 South Unit 7?

North Unit including the cells located in those units, and the Education Department?s
law library on the Second ?oor (the ?Law Library,? together with ?Unit-l? and ?Unit?l,? the
?Subj ect Premises?) located in Metropolitan Correctional Center, 150 Park Row, New York, New

York 10007.

C. The Subject Offenses

4. For the?reasons detailed below, I believe that there is probable cause that the Subject
Premises contain evidence, ?fuits, and instrumentalities of Title 18, United States Code, Sections 

401 (contempt of court), 793 (unIaW?ll disclosure of classified information); 1030 (unauthorized

2



Case Document 98-7 Filed 06/18/19 Page 19 of 56

computer access), 1343 (wire fraud), 1503 (obstruction of justice), 1791 (smuggling contraband

into a federal detention facility) and 2252A (illegal acts related to child pornography); as well as

conspiracies and attempts to violate these provisions and aiding and abetting these offenses, among
other statutes (the ?Subject bffenses?);

D, Terminology 

5. The term ?computer,? as used herein, 'is de?ned as set forth in 18 U.S.C.
1030(e)(1).

6. The teens ?records,? ?documents,? and "materials? include all infonnation
recorded in any?form, visual or oral, and by any means, whether in handmade form (including, but
not limited to, writings, drawings, paintings), photographic form (including, but not limited to,
micro?lm, micro?che, prints, slides, negatives, videotapes, motion pictures, photocopies) or
electrical, electronic or magnetic form (including, but not limited to, tape recordings, cassettes,
compact discs, electronic or magnetic storage devices such?as ?oppy diskettes, hard disks, -CD-
ROMS, digital video disks (DVDs), Personal Digital Assistants (PDAs), Mtdti Media Cards
mommy sticks, optical discs, printer buffers, smart cards, memory calculators, electronic
dialers, Bernoulli drives, or electronic notebooks, as well as digital data ?les and printouts or
readouts from any magnetic, electrical or electronic storage device), as well as the equipment
needed to record such information (including but not limited to cameras and Video recording and
storage devices). I
.11. Probable Cause and Request to Search

A. Overview

7. .As described in thither detail below, through this application, the Goveinment
seeks a warrant to search the Subject Premises for two iPhones one with 

and one with IMBI 354444064445994 (the ?Contraband iPhones?); a Samsung cellphone with
3 .



Case Document 98-7 Filed 06/18/19 Page 20 of 56

IMBI number 3d7073084445432 and/or Serial Number 1153161 QOJCD (the ?Schulte Cellphone,?
together with the Contraband iPhones, the ?Contraband Cellphones?); and copies of certain
documents twitten by Joshua Adam Schulte {the ?Soho-he Sehulte?Who has been,
indicted i'or, among other things, possession of child pornography and m?awfl? disclosure of
classi?ed information??nd another inmate, Omar Amauatmxarho Was convicted at trial of various
forms of fraud, including securities ?end?have been 118ng the Contraband Cellphones that were
smuggled into the 13406 to, among other things, fabricate evidence and disseminate information
that is either protected by a comtventered protective order or that is, classi?ed.
B. Background on Amanat and Schulte?s Detention at the MCC

8. Based on my training and experience, my participation in this intestigatiou, and
my convers ations with other. law enforcement agents and others, and my review of rep orts prepared 
. by others, including other FBI agents, Ihave learned, among other things, that: I

a. BetWee'ri in or about 2012 and November 2016, Schulte was employed by
the Central Intelligence Agency (the 

b. At the CIA, Scimite worked at a speci?c group (the Group?) that,
among other things, - developed computer applications that the CIA used to gather intelligence
abroad. I i

0. Ab part of his work, Schulte developed specialized skills in, among other
things, hacking computers and computer networks and secretly obtaining computers and
computer ?ehvorlrs. I .

d; In or about November 2016, Schulte resigned from the CIA, Prior to his

resignation, Schulte had disclosed to other CIA employees that he was angry at what he perceived

 

1 One of the Contraband iPhones was seized by the MCC on or about September 26, 2018.

4



Case Document 98-7 Filed 06/18/19 Page 21 of 56

to be his mistreatment by CIA management in connection with a dispute Schulte- had had with
another CIA employee; -

. e. Beginning on or about March 7, 2017 through in or aboutNovember 2017,
the website. wildleaksorg (?WilciLealcs?) published information ?'om?the CIA Group at which
Schulte previously worked (the ?Leah?). The Leak appears to be the largest unauthorized public
disclosure of CIA information in the history of the agency. i

f. (in or about 2017, the FBI arrested Schulte for, among. other
things, possession of child pornography, based on, in part, the discovery of approximately
10,000 images of apparent child pornography on a nersonal desktop computer used by Schulte.

. g. Schulte was initially released on bail on or about September 15, 2017, over
the Government?s objection. Schulte?s bail was revoked, however, in connection with his violation
of his bail conditions, in particular, restrictions on his use of computers or the Internet. Schulte?s
actions included, among other things, using an online network that allows for anonymous browsing
of the Internet. Schulte has been detained at the MCC since on or about December 14, 201?.

11. On or about June 18, 2018, the Government ?led a superseding indictment
that, in addition to containing the original child pornography charges, also charged Schnite with
violations of, among other statutes, Title 18, United States Code, Sections ?7 93 and 103 0, in
connection with the Leak, 

i. The Govenunent has produced to Schulte certain search warrant af?davits
(the ?Schulte Search Warrant Af?davits?) pursuant to a protective order entered by the Court on
or about September 13, 2017 (the ?Schulte Protective Order?). Based on the terms of the protective

order, Schulte and his. defense team Were not permitted to disclose the Schulte Search Warrant



Case Document 98-7 Filed 06/18/19 Page 22 of 56

Af?davits. or the information contained in them to anyOne not involved in the preparation of
Schulte?s defense.

9. - Based on in}? training and experience, my participation in this investigation, my
review of reports and other documents prepared by others, and my conversations vrith other law
enforcement agents and others, including an FBI agent involved in an eariier hivestigation and
prosecution of Anianat, I have learned, among other things, that:

a. On or about July 13, 2016, the Government filed a sitperseding indictrnent
chargin Amanat with wire ?raud, conspiracy to commit wire fraud, aiding and abetting hwestment
adviser fraud, and conspiracy to commit securities fraud;

b. I Amanat teas arrested that day and released on bail on or about July 22,2016.

I c. On or about December 26, 2017,- Arnanat was Convicted on all counts after

a jury trial before the Honorable Paul G. Gardephe. -

d. Amanat' has been detained at the MCC since on or about December 26, -

20 17. -

e. Amanat is currently scheduled to be sentenced on or about October 18, 2018
although that sentencing date may in adjourned because ofrequests by defense counsel for Arnanat
and his co?defendant, Kaleil Isaza Tnzman, for a, Fatico hearing. Isaza Tuzman was also convicted

on or about December 26, 2017 and is currently on bail pending sentencing.

f. Amanatis brother and co~defendant, Irf?an Amanat, is scheduled to proceed
to trial before Judge Gardephe on October 22, 2018, on charges of wire fraud, conspiracy to
commit. Wire fraud, aiding and abetting investment advisor fraud, and conspiracy to Commit

securities fraud.



Case Document 98-7 Filed 06/18/19 Page 23 of 56

10?. Based on my training and experience, my participation in this investigation, my
conversations with other law enforcement agents and others, and my review of reports and

recorded telephone conversations, I have learned, among other things, that:

a. Schulte and Amanat are cellmates at the MCC, and are hcnsed in Unit?1.2
b. - During recorded telephone conversations ?om the Schulte has
stated that he and Amanat are friends and that Sehulte is helping Amanat with a report that will

- help-to prove Amanat?s alleged innocence.

Schulte? Violation of the Schalte Protective Order and Discloswe of Classified .
Information While at the MCC

1 1. Based on my training and experience, my conversations with other law enforcement
agents and others, my participation in this investigation, and my review of reports and recorded

conversations, I have learned, among other things, that:

a. In or about April 2018, in recorded calls from the MCC, Schulte discussed 
with members of his family his desire to talk to members of the media about his case. Schulte also
. indicated that he had written several documents, Which he called ?articles,? that discussed his case
(the f?Schulte Articles?) and which he wante'd'to be disseminated to the media. It appears item the
calls that at least some of the Schulte Articles may have been provided to one or more members 

of the media.

b. In or about April 2018, in a recorded call from the MCC, Schulte spoke with
an individual who appeared to be a member of the media. During the call, Schulte discussed the

interrelation contained in one of the Sehuite Search Warrant Af?davits and why he felt that

 

2 I understand that based on some of the conduct described in this Af?davit, MCC officials may
move Schulte to another part of the. MCC so that he is no longer Amanat?s celhnate.

3 All conversations or documents'referenced in this Affidavit are described in substance and in
part. 



Case Document 98-7 Filed 06/18/19 Page 24 of 56

Momation Was inaccurate. When asked if the hifcnnation he was discussing was classi?ed,
Schulte responded that it was not classi?ed, but that it was protected by the ?protective order.?
Nevertheless, Schulte continued to disclose information found in one of the Schulte Search
warrant Affidavits. 

c. On or about 2018, the Washington Post and the New York limes
published articles about Schulte?s case, in which they indicated that their reporters had learned of
information contained in at least one of the Schulte Search Warrant Af?davits.

d. On or aboutMay 21, 2018, at the Govemment?s request, the Court held a

. conference to address Schulte?s violation of the Schulte Protective Order. During the hearing, the
Goverrnnent noted, among other things, that it had renewed recordings of calls Sehulte had

participated In from the MCC
e. I On or about June 20, 2013, at his arraignment on the superseding
indictment, Schulte submitted a handwritten pro se bail motion to the Court (the ?Pro Se Bail

-w xjs"

f. The day after Schulte submitted the Pro Se Bail Motion, the Government

 

informed Schulte?s counsel that the Pro. Se Bail Motion was undergoing a review by the 

determine whether it contained classi?ed information.

g. it appears that after the Government Schulte?s counsel about the

classi?cation review, Schulte may have sent the Pro Se Bail Motion to an attorney and his parents.

h. The CIA has reviewed the Pro Se Bail Motion and the Schulte Articles, and
has. determined that the Pro Se Bail Motion and at least one of the Schulte Articles contain

classi?ed infatuation.

 

4 The Schulte Documents are ore particularly described 1n Attachment at 119/ ,4 c, 

anti/+16 f/Ir?t/C/c? 

25"



Case Document 98-7 Filed 06/18/19 Page 25 of 56

D. Amanat?s Fabrication of Evidence During His Trial
12. Based on my training and experience, my participation in this investigation, and
my conversa?ocs with other law enforcement agents and others, including an FBI agent involved
in a prior hivestigatiOn and prosecution oi" Amanat, I have learned, among other things, the
following:
a. During his trial, Amanat sodght to introduce, among other things,
approximately ?ve emails (the ?Amanat Fabricated Emails?), four of which were admitted 'iaitially

several in redacted form.

b. . In response, during two hearings held outside the presenee'of the jury as
well as in a rebuttal case before the jury, the Govemment submitted evidence showing that the
Amanat Fabricated Emails had been faked by Amanat, incloding, atnong other things:

i. Evidence of discrepancies in header information, including time
stamps associated with the Amanat Fabricated Emails and other emails introduced at trial.
ii. Evidence that certain of the Amanat Fabricated Emails were not

found in certain email accounts or on electronic media used by the purported recipients of the

emails.

Evidence that the Amanat Fabricated. Emails were inconsistent with
other contemporaneous and ineulpatow communications involving Amanat.

iv. An between Amanat and his brother and co? 
defendant, Irfan Amanat, conceiving how to delete emails from a certain email account.

v. Expert testimony from an experienced FBI'Special Agent assigned

to a cyber squad that four of the five Amanat Fabricated Emails were fake andlor were not sent on
the date and time on which they appeared to have been sent.

0. As noted above, Arcana-t was convicted by the jury of all scents.
9 .



Case Document 98-7 Filed 06/18/19 Page 26 of 56

E. Schulte and Alnanat Arrange. to have Cellphones Smuggled into the; MCC
13. I have participated in an interview of an inmate at the MCC who was housed in
Unit-1 With Amanat and Schulte until recently (the During that interview, the CS reported
that, among other things: A
- a. For the past several nionths, the CS has been paid by Amanat to store and

charge the Contraband Cellphones.

b. The Conttaband Cellphones were smuggled into the MCC and protected.
from detection through a network of visitors to the facility, inmates, and correctional officers.

c. For a time, the CS was tasked with storing and charging the Contraband

Cellphones in the (33?s cell. Daring that time-period, the CS also knew the passwords for the

devices.

(1. At some point, Schulte decided that he no longer wanted the CS to know
the password for the Schulte Cellphone or to store it. Since around that time, the Schulte Cellphone

has been stored in other himates? cells.

e. Schulte told the CS that Schulte had implemented certain security protocols
with respect to the S-chulte Cellphone, such as changing the cellphone?s unique device identi?er
and enabling a function by which all the data on the Schulte cellphone would be deleted if

someone other than Schultc tried to access the phone.

f. Prior to Schulte?s retrieval of the Schulte Cellphone, the CS would regularly 

take of messages and recorded videos involving the Contraband Cellphonesfacing immigration and narcotics n'af?clcing charges, and is cooperating in the hope
of receiving a more lenient sentence and potentially immigration bene?ts. As described in this
Af?davit, the 03?s information has been at least partly corroborated by, among other things, a
seizure of at least one contraband cellphone. -

10?



Case Document 98-7 Filed 06/18/19 Page 27 of 56

subsequently stored those Screenshots in an email account the CS created (the Accdunt?).

Based on these messages and the conversations with Schulte and Arnanat, the CS understood

that, among other things:

i. Schulte and Athena?s were using the Contraband Cellphones in
connection with the creation of some sort of report that would be submitted to Amanat?s sentencing
judge (Judge Gardephe) to show that the Amanat Fabricated Emails were allegedly real.

i ii. The CS also recalled a commonication over at least one of the .
Contraband Cellphones relating to ?Vault which is the name used by, Wikiheaks for the Leak.
g. Amanat and Sehuite also discussed their need to have the Contraband
Cellphones with them when they accessed discovery at the Law Library.
h. During the interview, the CS consented to the search of the. CS Account,
and provided not only the name of the CS Account-but also the password for 11:.

14: Based on my participation in this investigation, conversations with other
participants in the investigation,and my review of reports prepared during the investigation, I have
learned, among other things, that: 

a. Unit?l and Unit?2 are on the same floor of the M00 and are connected by
a corridor.

b. . Although inmates from the two units are prohibited from interacting with
each ether in the corridor between Unit-ll and Unit; inmates are, at times, able to meet brie?v in

that space.

0. On or about on or about September 26, 2.018, MCC of?cials recovered one
of the Contraband iPhones ?'oin Unit-1. It does not appear, however, that the other Contraband

Cellphones have been recovered of?cials yet.

11



Case Document 98-7 Filed 06/18/19 Page 28 of 56

d. - The search for the other Contraband Cellphones is ongoing, and has.
included, among other things, searching multiple cells in Unit?l, including Schulte and Amanat?s

cell, and cells in proximity to their cell.

F. Evidence of Schulte?s and Amanat?s Illegal Activity ,Using the Contraband
Cellphones -

15. Based on my review of the CS Account, my participation in this investigation,
conversations with other participants in the investigation, and my review of reports prepared
during the investigation, I have learned, among other things, that:

a. The CS Account contains approximately 450 electronic files (including
videos and photographs) of the Contraband Cellphones. These files inel?de, among other things, A
video recordings of Schulte and Amanat using the Contraband Cellphones and screenshots (or
images) of . communications received and/or sent using the Contraband Cellphones in connection
with Sehdlt?e"s and Amanatis intended fabrication of evidence and/or dissemination of materials
protected by the Protective Qrdet or that appear classi?ed, including the Soholte Documents.

1). . Below are several still images taken from videos retrieved from the 

Account that show Schulte and Amanat using the Contraband Cellphones in the MCC: 
Video 1 (image 1!

l2





13

 

Case 1

Document 98-7 Filed 06/18/19 Page 29 of 56

Case Document 98-7 Filed 06/18/19 Page 30 of 56

Video 2 ?gage 1) . I .

 

Video ?2 glmage 27]

 

I 11 J-ra PP ., .

14

234

Case Document 98-7 Filed 06/18/19 Page 31 of 56

0. Below are images from the CS Accouht re?ecting communicationa using

the Contraband Cellphones: I

i. The image below frem one of the Contraband Cellphones appears
to be a dra? report prepared by?S'chulte and Amanat related to the fabricated emails Amanat?s

trial.

I: Inteoductipig

amgh forensic: and CEO o?my?bIWnEdns
was contactedand hired ?dinecgly y; 
provide an expedi;



 

15



Case Document 98-7 Filed 06/18/19 Page 32 of 56

ii. The imagebelow from one of the Contraband Cellphones appears

to he 'an email describing an excerpt from one of the Sehulte Articles:

 



Case Document 98-7 Filed 06/18/19 Page 33 of 56

I The image?below is a scree?shot of what appears to be an email sent 

over one of the Contraband CellphonesBail Motion

 

 

?Protonma?? is. an email service based abroad,

?SchulteHHa. . ._Notes.pdf? app ears to be a reference to the information contained in



Case Document 98-7 Filed 06/18/19 Page 34 of 56

.iv. The image below is a soreenshot of one of the Contraband

Cellphones that depicts, certain applieetions that have been downloaded to the phon heluding

?Secure Delete? and ?IShredder?:

 



Case Document 98-7 Filed 06/18/19 Page 35 of 56

G. Probable Cause Justifying Search of ESI

16. Based on the foregoing, and based on my training and experience, I know that
Amanat and Schulte have used (or are using) the Contraband Cellphones to, among other things,
create documents and communicate with others outside the MCC. Moreover, like individuals -
engaged in any other kind of activity, hidividnals who engage in the Subject Offenses store records 
relating to their illegal activity and to persons involved with them in that activity on electronic
devices such. as the Contraband Cellphones. Such records can include, for example ?lo gs of online
?chats? with co-conspirators; email correspondence; contact information of co?conspirators, I
including telephone numbers, email addresses, and identi?ers for instant messaging and social
medial accounts; stolen ?nancial and personal identification data, including bank account
numbers, credit card numbers, and names, addreSSes, telephone numbers, and social security?
numbers of other individuals; and/or records of illegal transactions using stolen ?nancial and
personal identification data. Individuals engaged in criminal activity often store such records in 
order to, among other things, (1) keep track of co-con?spiratorsi contact information; (2) keep a
record of illegal transactions for future reference; (3) keep an accounting Iof illegal proceeds for
purposes of, among other things, dividing those proceed-s with ctr-?conspirators; and (4) store stolen
data for fume exploitation, 

17. As a result, there is probable cause to believe that the Contraband Cellphones
contain some or all of the following: i

a. The phone numbers associated with the Contraband Cellphones, as well as 
call log information of phone numbers of incoming and outgoing, and missed or unanswered calls
to and ?'omthe Contraband Cellphones;

b. Address books and contact lists stored on the Contraband Cellphones or its

memory card(s);
19



Case Document 98-7 Filed 06/18/19 Page 36 of 56

c. Voicema?il messages, opened or unopened, related to the Subject Offenses;
d, Evidence concerning the identity or location of the owner(s) or risotto) of
the Contraband Cellphones; I
e. Evidence concerning the identity and/or location of the individual(s)
involved in the commission of the Subject Offenses;
f. Evidence of communications among, or concerning, participants in or
witnesses to the commission of the Subject Offenses; . I
g. Contact information of ?co-conspirators and witnesses to the of
the Subject Offenses, including telephone numbers, email addresses, and identi?ers for instant
- messaging and social media accounts;
11. Text, data, ?chats,? W8 (?Multimedia Messaging Service?) messages,
SMS (?Short Message Service?) messages, FaceTime messages, and. e?mail messages, any
attachments to those messages, such as digital photographs and videos, and any associated
inforination, such as the phone number or e-_rnail_ address from which the message was sent,
pertaining to the Subject Offenses;
A i. Digital photographs and videos related to the Subject Offenses;
j. Browsing history, websites visited, and interest searches conducted on the
Contraband Cellphones related to the Subject Offenses.
18. I Based on my training and experience, I also know that, where computers aroused
in furtherance of criminal activity, evidence of the criminal activity can often be found months or
even years after it occurred. This is typically two because:

0 Electronic ?les can be stored on a hard drive for years at little or no cost and users thus
have little incentive to delete data that may be useful to consult in the future.

20



Case Document 98-7 Filed 06/18/19 Page 37 of 56

- Even when a user does choose to delete data, the data can often be recovered months
or years later with the appropriate forensic tools. When a ?le is ?deleted? on a home
computer, the data contained in the ?le does not actually disappear, but instead remains
on the hard drive, in ?slack space,? until it is overwritten by new data that cannot be
stored elsewhere on the computer. Similarly, ?les that have been viewed on the internet
are generally downloaded into a temporary Internet directory or ?cache,? which is only
overwritten as the ?cache? ?lls up and is replaced with more recently viewed Internet
pages. Thus, the ability to retrieve ?'om a hard drive or other electronic storage media
depends less on - when the ?le was created or viewed than on a particular user?s
operating system, storage capacity, and computer habits.

a In the event that a user changes computers, the user will typically transfer ?les from
the old computer to the new computer, so as not to lose data. In addition, users-often

keep backups of their data on electronic storage media such as thumb drives, ?ash
memory cards, CDHROMs, or portable hard drives. 

19. Based on the foregoing, I respectfully submit there is probable cause to believe that
Schulte andAmanat are engaged in the Subject Offenses, and that evidence of this criminal activity-
is likely to be found in the Subject Premises and on the Contraband Cellphones,

Procedures for Searching ESI
A. Execation of warrant for ESI
20. Federal Rule of Criminal Procedure provides that a warrant'to search 
for and seize property ?may authorize the seizure of electronic storage media. or the seizure or
copying of electronically stored information . . . for later review.? Consistent with Rule 41, this
application requests authorization to seize any computer devices and storage media and transport

them to an appropriate law enforcement facility for review. This is typically necessary for a numb er

of reasons:

0 First, the volume of data on computer'devices and storage media is often impractical
for law enforcement personnel to review in its entirety at the search location.

4? Second, because computer data is particularly vulnerable to inadvertent or intentional
modi?cation or destruction, computer devices are ideally examined in a controlled
environment, such as a law enforcement laboratory, where trained personnel, using
specialized software, can make a forensic copy of the storage media that can be
subsequently reviewed in a manner that dees not change the underlying data.

21



Case Document 98-7 Filed 06/18/19 Page 38 of 56

I Third, there areso many types of computer hardware and software in use today that it
can be impossible to bring to the search site all of the necessary technical manuals and
specialized personnel and equipment potentially required to safely access the
underlying computer data. 

a Fourth, many factors can complicate. and prolong recovery of data from a computer
device, including the increasingly common use of passwords, or other
features or con?gurations designed to protect or conceal data on the computer, which
often take considerable time and resources for forensic personnel to detect and resolve.

B. Review of E81

21. Following seizure of any cellphones and/or the creation of forensic image copies, 
law enforcementpersonnel (who may include, in addition to law enforcement officers and agents,
attorneys for the government, attorney support staff, agency personnel assisting the government in
this investigation, and outside technical experts under government control) will review the E81

contained therein for infonnation responsive to the warrant.

22. In conducting- this review, law enforcement personnel may use-various techniques
to determine which ?les or other ESI contain evidence or fruits of the Subject Offenses. 'Such

techniques may include, for example:

I surveying directories or folders and the. individual files they contain (analogous to
looking at the outside of a ?le cabinet for-the markings it contains and opening a drawer
believed to contain pertinent ?les);

In conducting a ?le-by-?le review by ?opening? or reading the first few ?pages? of such
?les in order to determine their precise contents (analogous to performin a cursory
examination of each document in a ?le cabinet to determine its relevance);

- ?scanning? storage areas to discover and possibly recover recently deleted data or
deliberately hidden ?les; and

- performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of

the investigation?; and

 

5 Keyword searches alone are typically inadequate to detect all relevant data. For one thing,
keyword searches work only for text data, yet many types of files, such as images and videos, do
not Store data as searchable text. Moreover, even as to text data, there-may be information properly

22



Case Document 98-7 Filed 06/18/19 Page 39 of 56

- reviewing metadata, system information, con?guration ?les, registry data, and any
other information re?ecting how, when, and by wliom the computer was used.

23. Law enforcement personnel will make reasonable efforts to restrict their search to
data falling, 'Wittun the categories of. evidence speci?ed in the warrant. Dependiug on the
circumstances, hovvever, law enforceroent personnel may need to conduct a complete review of all
the 1381 from seized devices or storage media to evaluate its contents and to locate all data
responsive to the warrant. - - i

C. Return of E51

24. If the Government determines that the electronic devices are no longer necessary
to retrieve and preserve the data, and the devices themselves are not subject to seizure pmsuant to
Federal Rule of Criminal Procedure 41(0), the Government will return these items, upon?request.
Computer data that is or unreadable will not be returned unless law enforcement
persorrnel have determined that the data is not an instrumentality of the offense, (ii) a fruit of
tiie criminal activity, contraband, (iv) othemdse unlawfully posseSsed, or evidence of the

Subject Offenses.

 

subject to seizure but that is not captured by a keyword search because the information does not
contain the keywordsbeing searched.

23



Case Document 98-7 Filed 06/18/19 Page 40 of 56

IV. Conclusion and Ancillary Provisions

25. Based on the foregoing, I respectfu?y request the court to issue a warrant to search
and seize the items and information specified in Attachment A to this Af?davit and to the Search -

and Seizure Warrant. .

26. In light of the con?dential nature of the continuing investigation, I respectfully

request that thisAf?davit be maintained under seal until the Court orders otherwise.

WJVL

JEFF n. 
Special Agent
Federal Bureau of Investigation

Swotn to?before me on
this i-stcjiay of October 2018
a"

WW ..
THEHONORABLE PAUL A CRO my . -.

UNITED STATES DISTRICT JUDGE . 
SOUTHERN DISTRICT on NEW YORK 

24

244

Case Document 98-7 Filed 06/18/19 Page 41 of 56

Attachment A
I. Preiuises to be Searchedeubject Preluises
The premises to be searched (the ?Subject Premises?) is described as follows, and includes
. all looked and closed containers'found therein:
The Subject Premises 1s particularly described as the ?7 South Unit, 7 North Unit, including

the cells located 1n those units, and the Education Department? law libraly on the second
floor of the building, located 111 Metropolitan Correctional Center, 150 Park Row, New

York, New York 10007.

H. Execution of the Warrant

Law enforcement agents are permitted to execute the search Warrant at any time in the day
or night. Upon the execution of this warrant, notice will be provided at 61' as soon as possible after
the execution of the search.

111. Items to Be Searched and Seized
A. Evidence, Fruits, and Inst-rumentali?es ofthe Subject Offenses

The items to be searched and/or seized from the Subject Premises include the folloudng
evidence, fruits, and instrumentalities of: Title 18, United States Code, Sections 401 (contempt of
court); Title 13, United States Code, Section 793 (unlaw?il disclosure of classi?ed information);
Title 18, United States Code, Section 1030 (unauthorized computer access), Title 18, United States
Code, Section 1343 (Wire fraud), Title 18, United States Code, Section 1503 (obstruction of
justice), Title 13, United States Code, Section 1791 (smuggling contraband into a federal detention
facility) and Title 18, United States Code, Section 2252A (illegal acts related to child
pornography); as well as conspiracies and attempts'to violate these provisions and aiding and
abetting these offenses, among other statutes (the ?Subject Offenses?):

l. A .Samsung cellphone with 357073084445432 andfor Serial Number

R58161QOJCD (the ?Schulte Cellphone?).



Case Document 98-7 Filed 06/18/19 Page 42 of 56

2. An iPhone cellphone nrith MEI 35879305266516]. (?names?);
3. An iPhone cellphone with MI 354444064445994 (?iPhone?Z,? together with
iPhcne?l and'the Schulte Cellphone,the ?Contraband Cellphones").

Evidence pertaining to the smuggling in of the Contraband Cellphones.

5. Evidence concerning the identity or location of, and communications with, any co-
conspirators.
6. Any and all notes, documents, records, correslaondence, or materials, in any format

and medium (including, but not limited to, envelopes, letters, papers, 'e-Lmail messages, chat logs
and electronic measages, other digital data ?les and Web cache information, and handwritten
notes), pertaining to the unauthorized retention, gathering, and transmission of classi?ed
docmnents or materials, and the unauthorized removal and retention of classified documents or

materials, and, in particular, the documents bearing the following titles or descriptions:

a. Article 1: ?Presumption oflnnocenee: A petition for redress of grievances? 
in. Article 2: ?Preemption of Innocence: A loss of citizenship?
c, Article 3: ?Preemption of Innocence: Do you want to play a game?-

d. Article 4: ?Presumption-of Innocence: Detention is not punishment?-

e. Article 5: ?Preemption of Innocence: Innocent until proven Wealthy?
f. Article 6: ?Presumption of Innocence: Can you afford to be accused??
g, Article?iz ?Preemption of Innocence: A proposed solution?
h. Article 8: i?l?resurnption of Innocence: Origins?
Article 9: . . unalienable Rights, that among these are Life, Liberty and
the pursuit of Happiness?
2



Case Document 98-7 Filed 06/18/19 Page 43 of 56

 
   

7. Evidence of the Subject Offenses on the Contraband Cellphones, including:

a. The phone numbers associated oath the Contraband Cellphones, as Well as
cell log information of phone numbers of incoming and outgoing, and missed or unanswered calls
to and from the Contraband Cellphones; I 

b, Address books and contact lists stored on the. Contraband Cellphones or its
memory card(s);
c. Voicemail messages, opened or unopened, related'to the Subject Offenses;
I (1. Evidence eoncetning the identity or location of the owner(s) or user(s) of
the Contraband Cellphones; I I
e. Evidence - concerning the identity and/or location of the individna1(s)
involved in the commission of the Subject Offenses; I
- Evidence of communications among, or concerning, participants in or
witnesses to the commission of the Subject Offenses; I
g. Contact infoimation of co-eonspirators and Witnesses to the cemznission of
the Subject Offenses, including telephone numbers, email addresses, and identi?ers for instant
messaging and social media accounts; 
h. Text, data, ?chats,? MMS (?Multimedia Messaging Service?) messages,
SMS (?Short Message Sewice?) messages, FaceTime messages, and email messages, any
attachments to those messages, such as digital photographs and Videos, and any associated
information, such as the phone number or e-mail address from which the message was sent,
pertaining to the Subject Offenses;

i. Digital photographs and videos related to the Subject Offenses;
3



Case Document 98-7 Filed 06/18/19 Page 44 of 56

Browsing history, websites visited, and internet Searches conducted on the
Contraband Cellphones related to the Subject Offenses.

8. If law enforcement personnel seize the Contraband Cellphones, the. personnel will
search the device Within a reasonable amount of time, not to exceed 60 days from the date of
execution of the warrant. If, after such a search has been conducted, it is determined that a
computer or device contains any data listed in paragraphs 2 and3, the Government will retain the
computer or device. If it is determined that the. computer(s) or device(s) are no longer necessary
to retrieve and preserve the data, and the items are not subject to seizure pursuant to Federal Rule
of Criminal Procedure 41th), such materials and/or equipment will be returned within a reasonable
time. In any event, such materials and/or equipment shall be retcrned no later than 60 days from
the execution of this warrant, unless further application is made to the Court.

B. I Search and Seizure of Electronically Stored Information

The items to be searched and seized from the Stibject Premises also include any cellphones
that may contain any electronically stored inforniation ?falling within the categories set forth in
. Section .A of this Attachment above, including, but not limited to, desktop and laptop
computers, disk drives, modems, thumb drives, personal digital assistants, smart phones, digital
cameras, and scanners. - The items to be searched and seized from the Subject Premises also
includef

1. Any items or records needed to access the data stored On any seized or copied .
computer devices or storage media, including but not limited to any physical keys, 

device-am records of login credentials, pas swords, private keys, or similar information.



Case Document 98-7 Filed 06/18/19 Page 45 of 56

2. Any items or records that may facilitate a forensic examination of the computer
devices or storage media, including any hardware or softWare manuals or other information
concerning the con?guration of the seized or copied computer devices or storage media.

3. Any evidenCe concerning the persons with access to, control over, or ownership of -
the seized or copied computer devices or storage media.

C. Review of ESI

Following seizure of any computer devices, and storage media and/er the creation of
forensic image copies, law enforcement personnel (including, in addition to law enforcement
of?cers and agents, and depending on the nature ofthe ESI and the status of the investigation and
related proceedings, attorneys for the government, attorney support staff, agency personnel
assisting the government in ?this investigation, and outside technical experts under government.
control) are authorized to review the E81 contained therein for information responsive to the
warrant. I

In conducting this review, law enforcement personnel may use various techniques,
including but not limited to:

surveying various ?le ?directories" and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it-contains and opening a drawer
believed to contain pertinent ?les);

7- opening or cursorily reading the first: few "pages" of such ?les in order to determine
their precise contents;

- scanning storage areas to discover and possibly recover recently deleted ?les 

Ir Scanning storage areas for deliberately hidden ?les; 



Case Document 98-7 Filed 06/18/19 Page 46 of 56

a performing key word searches through all electronic storage areas to determine whether
occurrences of language contained in such storage areas exist that are intimately related
to the subject matter of the investigation; end I

a. making reasonable efforts to utilize eonibuter search. methodology to search only for
?les, documents, or other electronically stored information within the categories

identi?ed in this Attachment.



Case Document 98-7 Filed 06/18/19 Page 47 of 56

A0 93 (SDNY Rev. 0111?) Search and Seizure Warrant

UNITED STATES DISTRICT COURT

for the
Southem District of New York

1

Case No. 81 17 Cr. 548 (PAC)

In the Matter of the Search of . .

{Brie?y describe theprfoper'bl to be searched
or identify the person by name and address)

See AttachmentA 



SEARCH AND SEIZURE WARRANT

To: Any authorized law enforcement of?cer

An application by a federal law enforcement of?cer or an attorney for the government requests the search
- of the following person or property located in the Southern District of York
the person or describe the-peppery to be searched and give ifs Ioca?cn):
See Attachment A
The person or property to be searched, described above, is believed to conceal (ideno? fheperson or describe the property
to be seized):
See Attachment A

 

The search and seizure are related to tdoIationCs) of (imam statutmy citations):
Title 18 United States Code, Sections 401 (contempt of court) 7?93 (unlaw?sl disciosure of classi?ed information): 1030 {onauthorizeci computer access}. 1343
(wire fraud} 1593 (obstruction of justice) 1791 (smuggling contraband into a fedora! detention facility) and 2252A(i liege! acts related to child pornography}
I ?nd that the af?dayi?s), or any recorded testimony, establish probable cause to seal oh and seize the person or

property I .
YOUARE to execute this warrant on or before October 1-5 2018
(not to exceed 14 dayg

Ci in the dayti?ne 6:any time in the day or night as I find lessonable- cause has been
. established
Unless delayed notice is authorized below, you most give a cepy of the warrant and a receipt for the property

taken to the person from where, or 13mm whose premises, the property was taken, or leave the copy and receipt at the
i I I

place where the pr opelty was taken. I I 
The ember executing this wanant, or an of?cer present during the exeeu?oiI of?ie warrant, most prepaie an

hiventory as required by law and return this warrant arid inventory to ?ief ?ierh? (SI the Com?t AC

52f Upon its return this warrant and inventmy should be ?led undet seal by: the ofthe Cpurt
. . UuiHJIm?als

i

. I 
Elf I ?nd that immediate noti?cation may have an adverse result listed at 18 ill. 3 C. (eXcept for delay
of trial), and authorize the of?cer executing this warrant to delay notice to the per. ?so?a who 01' Whose property, will be
sear chad 01 seized (check the box) Effor 30 days (not to exceed 30). - 
Buntil, the facts justifying, 6 later spec fie Pdate of .

hit? it 
Date and tithe issued: m1; My 
G) [043?- Jzitige ?ssl?gmtme
New York. NY - The Honorabte Paul A. Crotty, U.S.D.J.

Printed name and ri?e



 

City and state:



 

 

Case Document 98-7 Filed 06/18/19 Page 48 of 56

A0 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)

 

Return
Case No.: Date and time warrant executed: - Copy of walraut and inventory left with:

. s1 17 Cr. 548 (PAC)
Inventory made inrthe presence of 

 

 

 

 

 

inventory of the property taken and name of any jaerson(s) seized:

 

Certi?cation

 

I declare under vpenalty of perj my that this inve?tory is correct and was returned along with the original Warrant
to the Court. 

 

Date: A
Executing e?icer ?s signature

 

Printed Harrie and?ii?e

 

 

252

Case Document 98-7 Filed 06/18/19 Page 49 of 56

Attachment A
I. Premises to be Searched?Subject Premises

The premises to be searched (the ?Subject Premises?) is described as follows, and includes

all looked and closed containers found therein:

The Subject Premises is particularly described as the 7 South Unit, 7 North Unit, including
the cells located in those units, and the Education Department?s law library on 'the second
?oor of the building, located in Metropolitan Correctional Center, 150 Park Row, New

York, New York 10007.

11. Execution ofthe Warrant

Law enforcement agents are permitted to execute the search warrant at any time in the day

or night. Upon the execution of this warrant, notice will be provided at or as soon as possible after

the execution of the search.

Items to Be Searched and Seized 

A. Evidence, Eruits, and Instrumentalities of the Subject Offenses

The items to. be Searched and/or seized from the Subject Premises include thefollowing
evidence, fruits, and instrumentalities of: Title 18, United States Code, Sections 401 (contempt of 
cou1t);Title 18, United States Code, Section 793 (unlawful disclosure of classi?ed information); 
I Title 18, United States Code, Section 10.30 (unauthorized computer access), Title 18, United States.
Code, Section 1343 (Wire ?end), Title 18, United States Code, Section 1503 (obstruction of
justice), Title 18, United States Code, Section 1791 (smuggling contraband into a federal detention
facility) and Title 18, United States Code, Section 2252A (illegal acts related to child
pornography); as well as conspiracies and attempts to 'violate these provisions and aiding and
abetting these offenses, among otherr'statutes (the ?Subject Offenses?): -

1. A Samsung cellphone with IMEI 357073084445432 and/or Serial Number

(the ?Schulte Cellphone?).



Case Document 98-7 Filed 06/18/19 Page 50 of 56

2. An iPhone cellphone with HVIEI 35 8793052665161 (?iPhone?l? 
3. An iPhone cellphone with IMEI 354444064445994 together with
iPhone?l and the Schulte Cellphone, the ?Contraband Cellphones?).

4. Evidencepertaining to the smuggling in of the COntraband Cellphones.

5. Evidence concerning the identity or location of, and communications with, any con
conspirators.
6. Any and all notes, documents, records, correspondence, or materials, in any format

and medium (including, but not limited to, envelopes, letters, papers, e-mail messages, chat logs
and electronic messages, other digital data ?les and web cache information, and handwritten
notes), pertaining to the unauthorized retention, gathering, and transmission of classi?ed
documents or materials, and the unauthorized removal and retention of classi?ed documents or

materials, and, in particular, the doesnients bearing the following titles or descriptions:

a. Article 1: ?Presumpti'oneof Innocence: A petition for redress of grieVances?
b. Article 2: ?Presumption of Innocence: A loss of citizenship?

c.l Article 3: ?Presumpticn of Innocence: Do you want to play a game?

d. Alticlc 4: ?Resumption-cf Innocence: Detention is not punishment?

e. Article 5 ?Presumption of Innocence: Innocent until proven Wealthy?
if. Article 6: ?Preemption of Innocence: Can you afford to be accused??
7g. Article 7: ?Bresumption of Innocence: A proposed solution?
h. Article 3: ?Presumpticn of Innocence: Origins?l
i. Article 9: . . unalienable Rights, that among these are Life, Liberty and

the pursuit of Happiness?

254

Case Document 98-7 Filed 06/18/19 Page 51 of 56

 

7. Evidence of the Subject Offenses on the contraband Cellphones, including:

a. - The phone numbers associated with the Contraband Cellphones, as well as
call log information of phone nUmbers of incoming and outgoing, and missed or unanswered calls

to and from the Contraband Cellphones;

b. Address books and contact lists stored on the Contraband Cellphones or its

a memory card(s);
c. I Voicemail messages, opened 01 unopened related to the Subject Offenses;
d. Evidence concerning the identity or location of the owner(s) or needs) of

the Contraband Cellphones;

Evidence concerning the identity and/or location of the individual(s)

I involved in the commission of the Subject Offenses, .

f. - Evidence of communications among, or concerning, participants in or
witnesses to the commission of the Subject Offenses;

g. Contact information of cc-conspirators and witnesses to the commission of:
the Subject Offenses, including telephone numbers, email addresses, and identi?ers for instant-
messaging and social media accounts;

h. ext, data, ?chats,? MMS (?Multimedia Messaging Service?). messages,
SMS (?Short Message Service?) messages, FaceTiIne 'messages, and e-mail messages; an};r
attachments to those messages, such as digital photographs and videos, and any associated

information, such as the phone number or e?mail address ?'om Which the message Was sent,

pertaining to the Subj ect Offenses;

i. . Digital photographs and videos related to the Subject Offenses;
3 



Case Document 98-7 Filed 06/18/19 Page 52 of 56

j. Browsing history, websites visited, and interact searches conducted on the
Contraband Cellphones related to the Subject Offenses.

8. If law enfo1cement personnel seize the Contraband Cellphones the personnel Will
search the device Within a reasonable amount of time, not to exceed 60 days from the date of
execution of. the warrant. If, after such a search has been conducted, it is determined that a
computer or device contains any data listed in paragraphs 2 and 3, the Government will retain the
computer or device. If it is determined that the computer(s) or deviee(s) are no longer necessary
to retrieve and preserve the data, and the items are not subject to seizure pursuant to Federal Rule
of Criminal Probedu?re materials andfor equipment will be returned within a reasonable
time. In any event, such materials andlor equipment shall be returned no later than 60 days from
the execution of this warrant, unless further appliCation is made to the Court.

B. Search and Seizure of Electronically Stored Information

The items to be searched. and seized from the Subject Premises also include any cellphones
that may contain any electronically stored information falling within the categories set forth in
Section lilA of this ?Attachment above, including, but not limited to, desktop and laptop
computers, disk drives, modems, thumb drives, personal digital assistants, smart phones, digital .
cameras, and scanners. The item's to be searched and seized from the Subject Premises also -
include: I

1. Any items or records needed to access the data'stored on any seized or copied
computer devices or storage media, including but not limited to any physical keys, 

devices, or records of login credentials, passwords, private keys, or similar information.



Case Document 98-7 Filed 06/18/19 Page 53 of 56

2. Any items or-records that may facilitate a forensic examination of the computer
device's or storage media, including any hardware or software manuals or other information
concerning the con?guration of the seized or copied computer devices or storage media.

3. Any evidence concerning the persons with access to, control over, or ownership of
the seized or copied computer devices or storage media. -

C. Review of ESI

Follovving seizure of any computer devices and storage media and/or the creation of
forensic image copies, law enforcement personnel (including, in addition to law enforcement
of?cers and agents, and depending on the nature of the E81 and the status of the investigation and 
related proceedings, attorneys for the attorney support staff, agency personnel
assisting the govemment in this investigation, and outside technical experts under goVernment
control) are authorized to review the'ESI contained therein. for information 'responsive'to the

warrant.

In conducting this review, law enforcement may use various techniqUes,

including but not limited to: 
I surveying various ?le ?-?di?rectories" and the individual ?les they contain (analogous to
looking at the outside of a tile cabinet for the markings it contains and opening a drawer
believed to contain pettinent ?les);
- opening or cursorily reading the ?rst few "pages,? of such ?les in order to determine
their precise contents;
I Scanning storage areas to discover and possibly recover recently deleted ?les;

a . scanning storage areas for deliberately hidden ?les;



 

Case Document 98-7 Filed 06/18/19 Page 54 of 56

a performing key word searches through all electronic storage areas to determine whether
occurrences of language contained in such storage areas exist that are i?timately relatecl
to the subject matter of the investigation; a'iid

0 making reasonable efforts to utilize computer search methodology to search only for

files, documents, or other electronically stored information within the categories

identi?ed in this Attachment.



 

Case Document 98-7 Filed 06/18/19 Page 55 of 56

EXHIBIT 



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