a.
All records pertaining to communications between Apple and any person
regarding the account, including contacts with support services and
records of actions taken;
b.
All records or other information regarding the identification of the
accounts, to include full name, physical address, telephone numbers and
other identifiers, records of session times and durations, the date on which
each account was created, the length of service, the types of service
utilized, the Internet Protocol (IP) address used to register each account,
log-in IP addresses associated with session times and dates, account status,
alternative email addresses provided during registration, methods of
connecting, log files, and means and [sic] of payment (including any credit
or bank account number);
c.
All records or other information stored by an individual using each
account, including address books, contact and buddy lists, pictures, and
files; 6
d.
All records pertaining to communications between Apple and any person
regarding the account, including contacts with support services and
records of actions taken; and 7
e.
All records or other information pertaining to including [sic], without
limitation, subscriber names, user names, screen names, or other identities,
mailing addresses, residential addresses, business addresses, email
addresses and other contact information, telephone numbers or other
subscriber number [sic] or identity, billing records, credit card or bank
account and information about the length of service and the types of
service the subscriber or customer utilized, and any other identifying
information, whether such records or other evidence are in electronic or
other form.
II. Information to be seized by the government
All information described above in Section I that constitutes contraband,
evidence, fruits and instrumentalities of violations of 41 U.S.C. § 8702
(Solicitation and Receipt of Kickbacks) and 18 U.S.C. § 371 (Conspiracy),
between [December], 2013, and the present, including the following:
a.
Records, emails, and other information referring or relating to a
government investigation involving any or all of the following: [Specific
names of individuals and corporations are redacted].
Application at 15-16.
II.
Drafting Errors and The Scope of the Government’s Request
It is evident from the sealed affidavit that the government is really after e-mails from
December to the present. Nothing in Attachment B, however, explicitly requests that Apple give
6
7
This paragraph is a repeat of the request after the colon in the initial paragraph.
This paragraph is also listed twice in the original Application.
3