Case 1:14-mj-00228-JMF Document 11 Filed 08/08/14 Page 17 of 21 -17730 F.3d at 1042 (“Because electronic devices could contain vast quantities of intermingled information, raising the risks inherent in over-seizing data . . . law enforcement and judicial officers must be especially cognizant of privacy risks when drafting and executing search warrants for electronic evidence.” (citations omitted)). Discussing the serious risk to privacy in searches involving an individual’s personal files, the Supreme Court stated as follows: We recognize that there are grave dangers inherent in executing a warrant authorizing a search and seizure of a person’s papers that are not necessarily present in executing a warrant to search for physical objects whose relevance is more easily ascertainable. In searches for papers, it is certain that some innocuous documents will be examined, at least cursorily, in order to determine whether they are, in fact, among those papers authorized to be seized. . . . In [these] kinds of searches, responsible officials, including judicial officials, must take care to assure that they are conducted in a manner that minimizes unwarranted intrusions upon privacy. Andresen v. Maryland, 427 U.S. 463, 482 n.11 (1976). At the same time, searches for electronic data present unique challenges for law enforcement officials tasked with prosecuting crimes and gathering evidence relevant to criminal investigations. Indeed, the practical realities of searches for electronic records may require the government to examine information outside the scope of the search warrant to determine whether specific information is relevant to the criminal investigation and falls within the scope of the warrant. Given