Case 1:14-mj-00228-JMF Document 11 Filed 08/08/14 Page 14 of 21 -14Computers and other electronic storage media commonly contain such large amounts of information that it is often impractical for law enforcement to review all of the information during execution of the warrant at the search location. This rule acknowledges the need for a two-step process: officers may seize or copy the entire storage medium and review it later to determine what electronically stored information falls within the scope of the warrant. Fed. R. Crim. P. 41(e)(2) advisory committee’s note. Several courts have found the two-step procedure to be reasonable under the Fourth Amendment, provided that there is a valid warrant supported by probable cause. 9 See, e.g., United States v. Schesso, 730 F.3d 1040, 1046 (9th Cir. 2013) (upholding government’s seizure of electronic data for a subsequent offsite search where there was a fair probability that evidence would be found on the defendant’s personal computer and other electronic devices); United States v. Evers, 669 F.3d 645, 652 (6th Cir. 2012) (6th Cir. 2012) (“The federal courts are in 9 The D.C. Circuit has not directly addressed the propriety of the procedures for executing search warrants for electronic evidence outlined in Rule 41(e). In its challenge, the government argues that the D.C. Circuit case of United States v. Heldt, 668 F.2d 1238 (D.C. Cir. 1981), “does not reject the twostep process for execution of warrants for electronic evidence.” Govt.’s Challenge at 11-12 n.5. Although it is true that the Heldt case does not expressly reject the two-step process under Rule 41, the case is not applicable to the issues presented here -- namely, whether the government may remove all files and records from a location to perform a subsequent search off-site to identify which e-mails are items specified under the search warrant. The Heldt case involved an on-site search performed by law enforcement where certain documents were seized under the plain view exception. That was not a case where, as here, an entire set of files was seized for a subsequent off-site search to identify which items fall within the scope of warrant.