Exhibit A - Search Warrant — USA v. Ilori et al (Dkt. 26.1)

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U.S. District Court for the Southern District of New York · No. 1:21-cr-00746-MKV · Doc. 26-1 · 2022-05-12 · Docket on CourtListener

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AO 93  (Rev. 1/13) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
__________ District of __________
In the Matter of the Search of
)
)
)
)
)
)
(Briefly describe the property to be searched
 or identify the person by name and address)
Case No. 21-MJ-1153
SEARCH AND SEIZURE WARRANT
To: 
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
District of
(identify the person or describe the property to be searched and give its location):
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized):
YOU ARE COMMANDED to execute this warrant on or before
(not to exceed 14 days)
u in the daytime 6:00 a.m. to 10:00 p.m.
u at any time in the day or night because good cause has been established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to 
.
(United States Magistrate Judge)
u Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C. 
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
u for
days (not to exceed 30)
u until, the facts justifying, the later specific date of
.
Date and time issued:
Judge’s signature
City and state:
Printed name and title
      Eastern District of New York
(1) THE PERSON OF ADEDAYO ILORI (DATE OF BIRTH DECEMBER 26, 1978) AND THE AREA 
WITHIN HIS IMMEDIATE REACH, INCLUDNG ANY PERSONAL EFFECTS LOCATED THEREIN; 
AND (2) THE PREMISES KNOWN AND DESCRIBED     AS 44-41 PURVES STREET, APARTMENT 
1805, LONG ISLAND CITY, NEW YORK, INCLUDING ANY CLOSED AND    LOCKED CABINETS 
AND CONTAINERS FOUND THEREIN
Eastern
New York
See Attachments A-1 and A-2
See Attachment B
October 21, 2021
✔
the Duty Magistrate Judge
✔
✔
30
Brooklyn, New York
Hon. Peggy Kuo
U.S.M.J.
October 7, 2021      9:25 pm
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AO 93  (Rev. 1/13) Search and Seizure Warrant (Page 2)
Return
Case No.: 21-MJ-1153
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.
Date:
Executing officer’s signature
Printed name and title
USAO_00006494
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10/8/21 @ approx 10:15 AM 
Adedayo ILORI 
DOJ OIG SSA Gary POPADOWSKI
Gary iPhone 
Black/Blue Motorola phone 
Black/Gray Samsung phone 
Misc. debit cards and account cards 
Parking receipt 
Apartment access device and key 
Gift cards 
FedEx office cards 
Blue iPhone

 
 
ATTACHMENT A-1 
 
Premises to be searched 
 
The person of ADEDAYO ILORI, date of birth December 26, 1978, and the area within his 
immediate reach, including any personal effects located therein.  ILORI has a dark skin 
complexion.  He has a close shaved haircut.  A photograph of ILORI is seen here. 
 
 
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ATTACHMENT B 
 
ITEMS TO BE SEARCHED AND SEIZED 
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses  
The items to be seized from the SUBJECT PREMISES and Subject Person include the 
following evidence, fruits, and instrumentalities of violations of Title 18, United States Code, 
Sections 1028A (aggravated identity theft); 641 (theft of Government funds); 1014 false 
statements to a financial institution; 1343 (wire fraud); 1344 (bank fraud); and 1956 (money 
laundering (the “Subject Offenses”) for the time period from March 2020 up to and including the 
present,  described as follows: 
 
1. 
Evidence concerning the occupancy or ownership of devices on ILORI’s person. 
2. 
Evidence concerning communications relating to the Subject Offenses, including 
but not limited to communications with concerning bank fraud and identity theft. 
3. 
Evidence, including communications, photographs, videos, images, and other 
content and information, of bank fraud and identity theft. 
4. 
Evidence of the identities and/or location of co-conspirators involved in the Subject 
Offenses.   
5. 
With respect to any devices seized; 
 
a. the phone number(s), email addresses, or other accounts associated with the 
Devices; 
b. address books and contact lists; 
c. log information of phone numbers of incoming and outgoing calls; 
d. other caller-identification information, including names, phone numbers, and 
addresses; 
e. items, records or information relating to the identity or location of the owner(s) 
or user(s) of the Devices;  
f. items, records or information relating to the identity or location of, and 
communications with, any co-conspirators;  
g. evidence of user attribution showing who used or owned the Devices at the time 
the records and items described in this warrant were created, edited, or deleted, 
such as logs, phonebooks, saved usernames and passwords. 
h. timeline data and data relating to the geographic location of the user of the given 
Devices; 
i. contact information pertaining to potential co-conspirators,  
j. text, MMS (i.e., multimedia messaging service), SMS (i.e., short message 
service), WhatsApp or other application messages, and email messages 
(collectively, “text messages”), any attachments to those text messages, such as 
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digital photographs and videos, and any associated information, such as the 
phone number from which the text message was sent, pertaining to the Subject 
Offenses, as set forth above. 
k. opened and unopened voicemail messages,  digital photographs, video, or audio 
recordings pertaining to the Subject Offenses, as set forth above. 
 
B. Search and Seizure of Electronically Stored Information 
The items to be seized pursuant to this warrant also include any computer devices and 
storage media that may contain any electronically stored information falling within the categories 
set forth in Section III.A of this Attachment above, including, but not limited to, cellphones and 
smart phones.  In lieu of seizing any such computer devices or storage media, this warrant also 
authorizes the copying of such devices or media for later review.   
The items to be seized also include: 
1. 
Any items or records needed to access the data stored on any seized or copied 
computer devices or storage media, including but not limited to any physical keys, encryption 
devices, or records of login credentials, passwords, private encryption keys, or similar information. 
2. 
Any items or records that may facilitate a forensic examination of the computer 
devices or storage media, including any hardware or software manuals or other information 
concerning the configuration of the seized or copied computer devices or storage media. 
3. 
Any evidence concerning the identities or locations of those persons with access to, 
control over, or ownership of the seized or copied computer devices or storage media. 
C. Unlocking Electronic Devices  
During the execution of the search of the Subject Person, law enforcement personnel are 
authorized to press the fingers (including thumbs) of ADEDAYO ILORI to the biometric sensor 
of any electronic devices recovered from ILORI’s person, or hold any such device in front of the 
face of ADEDAYO ILORI, and hold ADEDAYO ILORI’s face, for the purpose of attempting to 
unlock the device via biometric feature in order to search the contents as authorized by this warrant 
 
D. Review of ESI 
Following seizure of the Subject Devices and/or the creation of forensic image copies, law 
enforcement personnel (who may include, in addition to law enforcement officers and agents, 
attorneys for the government, attorney support staff, agency personnel assisting the government in 
this investigation, and outside technical experts under government control) are authorized to 
review the ESI contained therein for information responsive to the warrant. 
 
In conducting this review, law enforcement personnel may use various techniques to locate 
information responsive to the warrant, including, for example:  
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• surveying various file “directories” and the individual files they contain (analogous to 
looking at the outside of a file cabinet for the markings it contains and opening a drawer 
believed to contain pertinent files); 
 
• opening or cursorily reading the first few “pages” of such files in order to determine 
their precise contents; 
 
• scanning storage areas to discover and possibly recover recently deleted files or 
deliberately hidden files; 
 
• performing key word searches through all electronic storage areas to determine whether 
occurrences of language contained in such storage areas exist that are intimately related 
to the subject matter of the investigation; and 
• reviewing metadata, system information, configuration files, registry data, and any 
other information reflecting how, when, and by whom the computer was used. 
Law enforcement personnel will make reasonable efforts to search only for files, documents, or 
other electronically stored information within the categories identified in Sections IV.A and IV.B 
of this Attachment.  However, law enforcement personnel are authorized to conduct a complete 
review of all the ESI from seized devices or storage media if necessary to evaluate its contents and 
to locate all data responsive to the warrant. 
 
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