the government any e-mails. Strictly read, it instead asks for extensive non-content records about the account as well as “address books, contact and buddy lists, pictures, and files.” Application at 15. However, under the subheading of “Information to be seized by the government,” Attachment B states that the government will “seize” relevant “[r]ecords, e-mails, and other information . . .” Id. at 16 (emphasis added). The Court believes that this confusion was caused by poor drafting. Compare Application at 15-16 (repeating sections beginning “All records or other information stored . . .” and “All records pertaining to communications between Apple . . .”) with Searching and Seizing Computers and Obtaining Electronic Evidence in Criminal Investigations at 261. After all, the affidavit discusses specific e-mail conversations as the reason for seeking the warrant; it would be illogical for the government to then not seek these e-mails. While it is evident from closely reading the Application and its attachments what the government is really after, it is equally evident that the government is using language that has the potential to confuse the provider—in this case Apple—which must determine what information must be given to the government. See In the Matter of the Application of the United States of America for an Order Authorizing Disclosure of Historical Cell Site Information for Telephone Number [Redacted], 1:13-MC-199, 1:13-MC-1005, 1:13-MC-1006, 2013 WL 7856601, at *4 (D.D.C. Oct. 31, 2013) (Facciola, M.J.) (“Generic and inaccurate boilerplate language will only cause this Court to reject future § 2703(d) applications.”). This Court should not be placed in the position of compelling Apple to divine what the government actually seeks. Until this Application is clarified, it will be denied. III. Analysis A. The Court’s Previous Actions Regarding Overly Broad Search Warrant Applications 4

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