communications service to perform the searches. Under the government’s demand that it be given everything, the government leaves the Court with only two options: deny the warrants— thus depriving the government of needed information—or issue warrants that are repugnant to the Fourth Amendment. Neither is viable. Thus, having an electronic communication service provider perform a search, using a methodology based on search terms such as date stamps, specific words, names of recipients, or other methodology suggested by the government and approved by the Court seems to be the only way to enforce the particularity requirement commanded by the Fourth Amendment. D. The Government Must Return or Destroy Irrelevant Information The Court is particularly troubled that the Application does not specify what will occur with e-mails and other information that is, even by the government’s standards, not relevant. Will that information be returned, destroyed, or kept indefinitely? The “Secondary Orders” that have been routinely issued by this Court—and a significant portion of the Facebook Opinion— have required the government to destroy all contents and records that are not within the scope of the investigation as outlined in the search warrant. See Facebook Opinion, 2013 WL 7856600, at *7. While such a clause in a search warrant application is certainly necessary for its issuance by this Court, the government should not believe that it is sufficient. In this case, its absence is grounds enough for the Court to deny the Application. IV. Conclusion and Order By the Court’s count, it modified approximately twenty search and seizure warrants for electronic information during September and December 2013. It will no longer do so. Instead, any warrants that do not comport with the requirements of the Fourth Amendment will—like the present Application—be denied with an explanation of why they have been denied so that the 12