storage media or the seizure or copying of electronically stored information. Unless otherwise specified, the warrant authorizes a later review of the media or other information consistent with the warrant.’”) (citing Fed. R. Crim. P. 41(e)(2)(B)). Under this approach, “the initial section of the warrants authorizing the electronic communications service provider to disclose all email communications (including all content of the communications), and all records and other information regarding the account is too broad and too general.” In re Applications for Search Warrants for Information Associated with Target Email Accounts/Skype Accounts, Nos. 13–MJ– 8163, 13–MJ–8164, 13–MJ–8165, 13–MJ–8166, 13–MJ–8167, 2013 WL 4647554, at *1 (D.Kan. Aug. 27, 2013) (“In re App.”). Despite the Court raising its concerns and urging the government to adopt a different approach, the government continues to ask for all electronically stored information in e-mail accounts, irrespective of the relevance to the investigation. To ameliorate these problems with respect to Alexis’s Facebook account, the Court modified the search warrant to ensure that no third-party communications were turned over to the government, see Facebook Opinion, 2013 WL 7856600, at *3, and to require that the government destroy “[a]ll records and content that the government determines are NOT within the scope of the investigation.” Id. at *7. While those minimization procedures satisfied the Court in that particular case, it warned the government to “adopt stricter search parameters in future applications” or the Court would be “unwilling to issue any search and seizure warrants for electronic data that ignore the constitutional obligations to avoid ‘general’ electronic warrants.” Facebook Opinion, 2013 WL 7856600, at *8. The Court recommended several different approaches, including key word searches, using an independent special master to conduct searches, or segregating the people who are performing the search from those who are conducting the investigation. Id. As the present 6