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DWB:sk
AO 106 (Rev. 04110) Application for a Search Warrant
2024R00256

UNITED STATES DISTRICT COURT

for the
District of Minnesota

IN THE MATTER OF THE SEARCH OF THE SEALED BY ORDER OF THE COURT

CELLULAR TELEPHONE ASSIGNED CALL
NUMBER (612) 402-8317 STORED AT Case No. 24-mj-456 (DLM)
PREMISES CONTROLLED BY T-MOBILE U.S.,
I C.

APPLICA TION FOR A SEARCH WARRANT

I, Emily Hamric, a federal law enforcement officer or an attorney for the government, request a search warrant
and state under penalty of perjury that I have reason to believe that on the following person or property:

See Attachment A, incorporated here.

located in the District of New Jersey, there is now concealed:

See Attachment B, incorporated here.

The basis for the search under Fed. R. Crim. P. 41(c) and 18 U.S.C. 2703(c)(I)(A) is (check one or more):
X evidence of a crime;
X contraband, fruits of crime, or other items illegally possessed;
X property designed for use, intended for use, or used in committing a crime;
a person to be arrested or a person who is unlawfully restrained.

The search is related to a violation of:

Code Section Offense Description

Title 18, United States Code, Section 201 Bribery of a Juror
Title 18, United States Code, Section 1503 Influencing or Injuring a Juror

The application is based on these facts:

See attached Affidavit

Continued on the attached sheet.

SUBSCRlBED and SWORN before me by reliable

electronic means (FaceTime and/or email) pursuant to Fed.
R. Crim. P. 41(d)(3) Emily Hamric, Special Agent
Federal Bureau of Investigation
Date: Printed Name and Title

Judge's Signature
City and State: St. Paul, MN The Honorable Douglas L. Micko
United States Magistrate Judge
Printed Name and Title
 UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
24-mj-456 (DLM)

IN THE MATTER OF THE SEARCH OF SEALED BY ORDER OF THE COURT

THE CELLULAR TELEPHONE
ASSIGNED CALL NUMBER
(612) 402-8317 STORED AT PREMISES
CONTROLLED BY T-MOBILE U.S.,
INC.

AFFIDAVIT IN SUPPORT
AN APPLICATION FOR A SEARCH WARRANT

Your affiant, Emily Hamric, being duly sworn, does state the following is true

and correct to the best of her knowledge and belief:

1. I make this affidavit in support of an application for a search warrant

under Federal Rule of Criminal Procedure 41 and 18 U.S.C. §§ 2703(c)(1)(A) for

information about the location of the cellular telephone assigned call number (612)

402-8317 (the "Target Cell Phone"), which is used by Abdimajid Mohamed Nur. T-

Mobile US, Inc., is the service provider the Target Cell Phone. The Target Cell Phone

is described herein and in Attachment A, and the location information to be seized is

described herein and in Attachment B.

2. I am currently a Special Agent with the Federal Bureau ofInvestigation

(FBI) and have been employed with the FBI in various roles since 2017.

3. As a Special Agent, my primary duties and responsibilities consist of

conducting investigations of individuals and businesses for possible violations of

federal laws. I am presently assigned to the FBI's Minneapolis, Minnesota field office

where I am a member of the Civil Rights and Public Corruption Squad. During my

employment as a Special Agent, I have conducted and participated in investigations

 of varying degrees involving wire fraud, fraud against the government, color of law,

civil rights, and other criminal acts.

4. I make this affidavit in support of an application for a search warrant

for records and information associated with certain cellular towers that is in the

posseSSIOn, custody, and/or control of T-Mobile, a cellular service provider

headquartered at 4 Sylvan Way, Parsippany, New Jersey, 07054.

5. Based on my training and experience, as well as the facts set forth in

this affidavit, there is probable cause to believe that the location information

described in Attachment B will constitute evidence of a crime-namely violations of

18 U.S.C. § 201 (bribery of a juror) and/or 18 U.S.C. § 1503 (influencing or injuring a

juror).

6. This affidavit is based on my personal knowledge, interviews of

witnesses, physical surveillance, information received from other law enforcement

agents, my experience and training, and the experience of other agents. Because this

affidavit is being submitted for the limited purpose of establishing probable cause to

secure a search warrant, I have not included each and every fact in this investigation

known to me and to others.

I. PROBABLE CAUSE

A. The Trial in United States v. Farah et al.

7. On September 13, 2022, a grand jury returned a 43-count superseding

indictment charging eight defendants-Abdiaziz Shafii Farah, Mohamed Jama

Ismail, Mahad Ibrahim, Abdimajid Mohamed Nur, Said Shafii Farah,

Abdiwahab Maalim Aftin, Mukhtar Mohamed Shariff, and Hayat Mohamed Nur-

2
with a number of crimes, including: one count of conspiracy to commit wire fraud, in

violation of 18 U.S.C. §§ 371 and 1343; eleven counts of wire fraud, in violation of

18 U.S.C. § 1343; one count of conspiracy to commit federal programs bribery, m

violation of 18 U.S.C. §§ 371 and 666; six counts of federal programs bribery, m

violation of 18 U.S.C. § 666; one count of conspiracy to commit money laundering, in

violation of 18 U.S.C. § 1956(a) and (h); twenty-two counts of money laundering, in

violation of 18 U.S.C. § 1957; and one count of false statement in a passport

application, in violation of 18 U.S.C. § 1542.

8. The indictment alleges that the defendants orchestrated and carried out

a scheme that defrauded the Federal Child Nutrition Program, a government aid

program designed to provide free meals to children in need. The defendants exploited

the Covid-19 pandemic to obtain, misappropriate, and launder tens of millions of

dollars in program funds that were intended as reimbursements for the cost of serving

meals and food to children. In all, the defendants fraudulently misappropriated more

than $40 million in Federal Child Nutrition Program funds.

9. On April 22, 2024, a trial of seven of these defendants-Abdiaziz Shafii

Farah, Mohamed Jama Ismail, Abdimajid Mohamed Nur, Said Shafii Farah,

Abdiwahab Maalim Aftin, Mukhtar Mohamed Shariff, and Hayat Mohamed Nur-

commenced in the District of Minnesota before the Honorable Nancy BraseL

United States v. Abdiaziz Farah, et al., 22 CR 124 (NEB).

10. The first week of trial, a jury was selected and seated. While the general

public did not have access to the personal information of jurors, counsel for the

3
government, counsel for the defense, and the seven defendants on trial had access to

this information.

11. On Monday, June 3, 2024, closing arguments were completed, and the

Court instructed and charged the jury. The jury began its deliberations on June 4,

2024. The jury reached a verdict on Friday, June 7, 2024. The jury found guilty

defendants Abdiaziz Shafii Farah, Mohamed Jama Ismail, Abdimajid Mohamed Nur,

Mukhtar Mohamed Shariff, and Hayat Mohamed Nur. It acquitted defendants

Said Shafii Farah and Abdiwahab Maalim Aftin.

B. Bribe Payment Delivered to Juror #52's Home

12. On June 2, 2024-the night before trial was set to conclude-at

approximately 8:50 p.m., a woman approached the home of Juror #52 and rang the

doorbell. A relative ofthe juror answered the door. The relative described the woman

as a black woman, possibly Somali, with an accent, wearing a long black dress. The

woman handed a gift bag to the relative and said it was a present for Juror #52. The

woman used Juror #52's first name. The woman told the relative to tell Juror #52 to

say not guilty tomorrow and there would be more of that present tomorrow. After the

woman left, the relative looked in the gift bag and saw it contained a substantial

amount of cash. When Juror #52 learned of the encounter, Juror #52 immediately

called 911 to report the incident. The Spring Lake Park Police responded. Juror #52

gave the bag of cash to the Spring Lake Park Police. The bag of cash contained 100-,

50-, and 20-dollar bills, totaling approximately $120,000. The FBI subsequently

interviewed Juror #52 and took custody of the bag of cash from the Spring Lake Park

Police.

4
5
 13. Among other things, Juror #52 told the FBI agent she drove her personal

car to the courthouse every day and parked in the Haaf Parking Garage near the

U.S. Courthouse.

6
 14. The home of Juror #52 is located in a short, dead-end street in

Spring Lake, Minnesota. The residential area only has approximately 10 homes and

is not a busy traffic thoroughfare.

C. Seizure of Cell Phones

20. On the morning on June 3, 2024, the Court, counsel for the government,

and counsel for the defendants learned of the attempt to bribe Juror #52.

21. After that information was disseminated to the parties, an FBI agent who

had been present for the entire trial observed defendants Abdiaziz Farah and Said

Farah act differently than they had throughout the trial. Both Abdiaziz Farah and

Said Farah appeared to be nervous, which was in contrast to their notably laid-back

manner throughout the preceding six weeks of the trial. The agent observed Said

Farah moving in and out of the courtroom quickly with his cell phone in hand. Said

Farah appeared to be making phone calls from the courtroom, which the agent had

not observed previously and which is generally frowned upon, if not outright

disallowed, in the courtroom.

22. In court proceedings that morning, the government moved to take custody

of the cell phones of the seven defendants-all of whom would have had access to

Juror #52's identifying information-to effectively "freeze" the scene. The Court

ordered that the defendants place their phones in airplane mode and surrender them

to law enforcement. The FBI agent observed Abdiaziz Shafii Farah continue to use

his phone for what appeared to be longer than necessary to place the phone in

airplane mode.

7
 23. The seven defendants surrendered their cell phones to the FBI that

morning. Later that day, Magistrate Judge Elizabeth Cowan Wright approved a

search and seizure warrant authorization law enforcement officers to search each of

the seven phones belonging to defendants. Law enforcement efforts to conduct those

searches are under way.

24. When FBI agents later attempted to review Abdiaziz Shafii Farah's cell

phone, they found that the cell phone screen displayed the factory settings as if it

were a brand-new phone being set up for the first time. Based on my training and

experience, this is consistent with the phone having been reset to factory settings,

which erases all content from the phone.

09 08

25. On June 3, 2024, the Court ordered all seven defendants detained.

D. The Search of Abdiaziz Shafii Farah's Residence

26. On June 4, 2024, Magistrate Judge Douglas L. Micko signed a search

warrant for Abdiaziz Farah's residence in Savage. Agents executed the search on the

morning of June 5. During the search, agents found a typed list ofthe jurors in United

8
 States v. Abdiaziz Shafii Farah et al. Juror #52's name appeared on the list, along

with the other 17 jurors. The list was hidden inside of a plastic water bottle.

27. Abdiaziz Farah's wife was present when agents arrived to search the

Farah residence. During the search, Abdiaziz Farah's wife asked to leave. Agents said

she was free to leave at any time. Prior to leaving, Abdiaziz Farah's wife went

upstairs to gather some personal items. Agents accompanied her to ensure the

integrity of the search scene. Abdiaziz Farah's wife went into a closet and grabbed

what appeared to be baby clothing. An FBI Agent asked to inspect the items that

Abdiaziz Farah's wife wanted to remove from the search scene. According to the

agent, Abdiaziz Farah's wife's eyes got wide as she handed the items to the FBI Agent.

Upon inspection of the items, the agent found $6,900 in cash. The cash was in a black

bag with polka dots that said "mama." The cash was in the form of $100 bills.

9
 E. The Fingerprint

28. The FBI submitted the Hallmark gift bag containing the bribe money

for fingerprint analysis. Fingerprint analysts found a fingerprint that matched with

a known print of Ladan Mohamed Ali.

29. Ladan Mohamed Ali is connected with a company that was involved in

the fraud scheme at issue in the trial of United States v. Abdiaziz Shafii Farah et al.

According to records obtained during the investigation, Ladan Mohamed Ali is a

signatory on an account at Think Mutual Bank in the name of Mro Produce LLC.

Based on the investigation, Mro Produce LLC is a purported food vendor that

10
 received millions of dollars from entities involved in the fraudulent scheme to obtain

federal child nutrition program funds.

30. Records of other Mro Produce bank accounts were admitted at trial in

United States v. Abdiaziz Shafii Farah et al. as Government Exhibits 0-203, 0-204,

and 0-205. Those records show that Mro Produce LLC received more than $1.6

million from entities involved in the charged fraud scheme from approximately

December 2020 through January 2022.

Entity Amount sent to Mro

Produce (a-pproximate)
Empire Cuisine & Market $859,008
Empire Enternrises $523,652
Bushra Wholesalers $184,559
ThinkTechAct Foundation $46,500
Total $1,613,719

31. During trial in United States v. Abdiaziz Shafii Farah et al., the

government introduced exhibits showing that defendants Hayat Nur and Abdimajid

Nur created fake invoices purporting to document the purchase of food from Mro

Produce LLC.

32. In an email admitted into evidence as Government Exhibit D-42, Hayat

Nur sent herself an email with the subject line "Master Document." In the body of the

email, Hayat Nur wrote "You can edit Master Document (DON'T SAVE IT AS

PDF)!!!!"

11
 From: Hayat NUl" <hayatnur861 @gmail.com>
To: Hayat Nur <hayatnur861@gmail.com>
Subject: Master Document
Date: Tue, 21 Dec 2021 23:15:21 -0600
Attachments: Master_ Document.docx;lnvoice_I.pdf

You can edit Master document (DON'T SAVE IT AS PDF)!!!!

33. Hayat Nur attached to the email one word document

(Master_Document.docx) and one pdf document (Invoice_1.pdf). Each document

contained a template of an Mro Produce LLC invoice.

MRO PROOUCE LLC

15S4COM()AVESTrl

v
rD!_ro
\.__r-prOduce
INVOICE

INVOICE OAT[
9132 10/01/2021

PRODUCT CASE UNJT PRICE TOTAL

Milk 750 SL40 $1800
Ne'GuikMillc. 20 S16.99 $339.80
Pot.1ltQeS 26 $22.00 $572.00
Onions II S23.00 $506.00
Tomatoes 2S $31.00 $77S.00
Apple 25 S32.00 $800.00
OrOinse $32.95
Banana "
21 $22.95
$625.05
$481.95
GoldFish 37' $11.00 $4114.00

Total: S10,013.80

34. Two weeks later, on January 4, 2022, Hayat Nur emailed her brother,

defendant Abdimajid Nur, an email with the subject line "Fwd: 5 Invoices." This email

was admitted at trial as Government D-44.

12
 From: Hayat N ur <hayatnur861 ~gmai l.com>
To: Abdi Nur <19anur@gmail.com>
Subject: Fwd: 5 Invoices
Date: Tue, 04 Jan 2022 13:41:53 -0600
Attachments: Invoice_2.docx; lnvoice_l.docx; Invoice_3.docx; ]nvoice_ 4.docx; Invoice_5.docx

--------- Forwarded message ---------

From: Hayat Nur <hay.atnur861@gmail.com>
Date: Wed, Dec 22, 2021 at 3:44 PM
Subject: 5 Invoices
To: Hayat Nur <hay.atnur86l@gmail.com>

35. Hayat Nur attached to her email a senes of five InVOICeSfrom Mro

Produce and created using her "Master Document" template.

AFRO PROOUCE liC Af'."RO PRODUCE uc

}U~ COM~ A'l'( He J

.SIohi:""""~"·'YJl)(!iJj

,lr:oo<o:i:lu:lC@!lla'l"'dCOll\

.....
;lropro<rxcllc"rrn;ll.com

INVOICE
rD!.rD
u_•..rOduce INVOICE
m~duce..
"
Bill TO- Ship TO:
Bill TO: Ship TO;

CASE UNrTPRICE
PRODUCT CASE UNIT PRICE TOTAl 150 52.40
Milk 810 52.99 52481.7 20 516.99
NesquikMHk 180 $17.5 $22.00
Potit~
Onions
Zl $22.00
$31S0
$506.00 "" S2JOO
531.00
Tomatoes
Aoole
20
18
$23.00
531.20
$460.00
$561.6 "
25
19
$32.00
$32-95
24 $32.00 $768
Orlln e 22 532.95 5724.9 21 $22.9$ S481.9S
B<mana 13 $22.95 374 SlLoa 5-&114.00
$527.85
GoldFish 28' 511.45 $3251,8
Tot~l: $10,013.50

Totilll:$12,53l.BS

13
 AFRO PROOUCE UC
AFRO PRODUCE uC
lJ.j.(OMO ..•.,.UtJ
Jli.UCOiVa .••.••..•.
HC}
Jrl!lrl'4t"".)'!NSSJNUS
sr.r"wl ..•.YI<ISJJ~US
~fr"l)loduc.e:k@am;tJ,~
~froon)!Jocl!k.jItIll •. tOlll
'Iv
rD!_••
Ult'rOdUte
INYOIa
ItlVOICE

Bill TO: Ship TO:

BIll TO: Ship TO:

TOTAl DUE Dut'DATE TEAMS ENCLOSED

$10 m,1S 10 1 21

PROOUel CAS. UNIT PRICE 'tmAL

sa, PflOOtJCT
M!l1I:

Ne5QUlkMilk
-~'60 - 517.5 - r!"'" 'ROO
"""
NC"·',.IlkM.1;.
~ASe
"5
3.
- UNITPRr~
IS2.99
517.5
~!~_:~~,sS-
Potatoes 25 522.00 SSSll $S2S
Onions
TOI'NItOP.l
,.
"
18
I <U.OO
531.20
$529
Po,",,,,,,,
Onkmi ,. 21 $22.00
.$21.5
I S594
"7•
Appll 532.00 S...,
$561.6
Tcm4lov.lo

" :S3UO I ~&552

S...,
O'''''Je
" $32 !IS $724,9 ~ 20 .S32OO
BI".J~
Gold ~bh
2.S 522 95 $573.15
Or:lI'l'e
Sa"_ana
~'" $32.'5
:S22.95
m.5
'70 5n.DO SZl7!..S
Goldl=lsl'I " 1:11L45
$573.7!a-

Tot:.l: 510,946.75 '" $<Jno.5S

Tof~I' H1.083.55

AfAOPflO!>U(_( uc

--
• aIiWOoI;
__ ""'t.A".I5J"~
1111

ct

&-tliO" TO

1~I_ostD

36. At trial, the government also introduced fake mVOlces purporting to

document the purchase of food from Afro Produce recovered from defendant

Abdimajid Nur's Google drive-including two different verSIOns of invoice number

"9133." These documents were admitted at trial as Government Exhibit G-342.

14
 AFRO PRODUCE llC
lS54CQM(lAIIC$":C1 AFRO PROOUCE LtC
SOinr;lluvi,Iv!N)SlalUS l),!>.c()t.!o..-vrSHl

.ltroprodu(el;c."m~iI.ccm
.••..
s...mrPaIlI.IA.'ollSIOill/S

"troP'()(!IK.~tI!lE"U~.(cm

rDlro "10':
\..!.t'roduce rDtro
INVOICE \_.-produce
INVOICE

Bill TO: Ship TO:

Bill TO: Ship TO:

I INVOICE I DATE I TOTAL DUE I DUE DATE r TERMS I ENaOSED I

19133 110/08/2021 1512.531.85 I INVOICE I DATE I TOTAL DUE IOUE OAT[ I TERMS I ENClOSED I
110/30/2021 I I I
9133 110/08/2021 I 512.531.85 110/30/2021 I I I

PRODUCT CASE UNIT PRICE TOTAL

Mi[1o. SOO 52.9.
~ODUCT CAse UNIT PRICE TOTAL
$1495
Ne~ujkMitk 90
Milk 830 52.99 $2481.7
$17.5 51575 Ne-scuikMitk
Potatoes 180 : $17.5 $3150
18 $22.00 $396 Potatoes 23 $22.00 5506.00
Onions IS $23.00 $34S Onions 20 $23.00 $450.00
Tomatoes 10 $31.20 $312 Tom.ltoe~ 18 531.20 S561.6
AopJe 20 $32.00 :S64D Ap~1e 24 $32.00 5768
Orange 20 $32.95 $659 Ora"lP"e 22 $32.95 5724.9
8alla"iI 20 522.91 $419 a"naniJ 23 SlB5 1527.85
Gold Fish 100 $11.45 $ Gold Fhh 28' 1111.'5 53251.8

Total; 512,531.85 TotOlI:512,531.85

37. Ladan Mohamed Ali received large checks from Afro Produce III 2021

and 2022. On August 30,2021, for example, Ladan Mohamed Ali received a $20,000

check from Afro Produce.

AFRO PRODuce LLC

2920 12'1'11 AVE S APT 2 2065
IIlItlNF.APOUS Ill" ~7"'~ Tl-l+!17ntlJN
no

38. Similarly, on December 10, 2021, Ladan Mohamed Ali received a

$10,000 check from Afro Produce LLC. The memo line indicated the payment was for

"consulting."

15
 AFRO PRODUCE LLC
2920 1'.!"tHAve S APT 2
MINtoIJ:APOI.IS
.~ MN 6&4Q7·-42$3
,f ';1../10 1l..6 ,,! tiite
2332
11-lml1J~:;

~I.°o~ L frQ_f}- N. JtL-J ~_.:.. '~, _. $ )0 000

1
_' -...:;.T.e..,;..'- --'(\-'--~..___=_~OOC...._.,....,i......__='ob:;;....:.;.......:.t..:..;:\a=v;$=, DQU~,$

BAN K OF AME RIC::'A...•.

. .,
~r--------~
'

39. On January 15, 2022, Ladan Mohamed Ali received a $10,000 check

from Mro Produce. The memo line indicated the payment related to her "salary."

40. Ladan Mohamed Ali also had a personal account at Think Mutual Bank.

On her account agreement dated June 28,2021, Ladan Mohamed Ali stated that her

employer was GarGaar Family Services, also known as Youth Leadership Academy.

Bank records show that Ladan Mohamed Ali received checks from GarGaarfY outh

Leadership Academy.

41. In December 2021, the Minnesota Department of Education found that

GarGaarfY outh Leadership Academy was "seriously deficient" and barred it from

participating in the federal child nutrition program. 1

See "State bars third major provider of meals to needy kids in Minnesota," Star
Tribune (March 9, 2022), available at https://www.startribune.com!state-bars-third-major-
provider-of- meals- to-needy -kids- in -minnesota/600 1545141?refresh =true (last accessed June
6,2024).

16
 F. Ladan Mohamed Ali Flew to Minnesota on May 30, Repeatedly
Drove Past Juror #52's House, and Flew Back to Seattle on
June 3

42. According to public records, Ladan Mohamed Ali currently resides in

Seattle, Washington.

43. According to records obtained from Delta Airlines, on May 28, 2024,

Ladan Mohamed Ali booked a round-trip flight from Seattle to Minneapolis-St. Paul

International Airport. The flight was scheduled to leave Seattle on May 30, 2024, and

return from Minneapolis on June 5, 2024.

44. According to records obtain from Delta Airlines, Ladan Mohamed Ali

flew into Minneapolis-St. Paul International Airport on May 30, 2023. She arrived on

Delta Airlines flight 364 from Seattle. Surveillance video obtained from Minneapolis-

St. Paul International Airport show Ladan Mohamed Ali arriving on a flight from

Seattle. Ladan Mohamed Ali appeared to be holding a cell phone as she departed the

jetway.

45. According to Enterprise Car Rental, on May 31,2024, Ladan Mohamed

Ali rented a Volkswagen Taos, bearing Texas license plate SHR 4372, at the

17
Enterprise Car Rental in Bloomington, Minnesota. Surveillance video obtained from

Enterprise Car Rental showed that Ladan Mohamed Ali picked up the car at

approximately 10:32 a.m.

46. On June 7, 2024, the government obtained a search warrant for the GPS

location information for the Volkswagen Taos Ladan Mohamed Ali rented from

Enterprise on May 31, 2024. The GPS data showed that Ladan Mohamed Ali's rental

car parked near the Jerry Haaf Memorial Parking Ramp in downtown Minneapolis

from approximately 4:55 p.m. to 5:51 p.m. on May 31,2024.

47. The Jerry Haaf Memorial Parking Garage is located at 424 South

Fourth Street-approximately one block from the federal courthouse at which trial

in United States v. Abdiaziz Shafii Farah et al. was conducted. Surveillance video

obtained from the parking garage showed that Ladan Mohamed Ali's rental car

(marked in red) was parked across the street from the Haaf Parking Garage. At

approximately 5:51 p.m., Juror #52 exited the Haaf Parking Garage. Juror #52's car

is marked in blue.

18
 48. Surveillance video showed Ladan Mohamed Ali's rental car back up and

then pull out to follow Juror #52.

49. The surveillance video showed that Juror #52 took a left-hand turn onto

South Fourth Avenue. Ladan Mohamed Ali's rental car followed Juror #52, taking a

left-hand turn across three lanes of traffic in order to follow the juror.

19
 50. According to the GPS data from Enterprise Rental Car, at

approximately 5:51 p.m., Ladan Mohamed Ali's rental car then drove to Juror #52's

house.

51. The license plate reader located at the end of Juror #52's block showed

that the Volkswagen Taos rented by Ladan Mohamed Ali drove past Juror #52's block

repeatedly between May 31 and June 2, 2024. FBI analysts created a "heat map"

showing the location frequency of the Volkswagen Taos's locations between May 31

and June 2, 2024. The heat map shows that the Volkswagen Taos frequently drove

past Juror #52's house.

52. Ladan Mohamed Ali's rental car passed by the license plate readers

located near Juror #52's residence approximately ten times between May 31 and June

2, 2024, including at approximately 9:00 p.m. on June 2, 2024-just a few minutes

after the bribe attempt was made.

20
 Date Time Capture Camera
May 31, 2024 6:15:36 PM Mounds View Blvd @ Lon~ Lake Rd - WB
May 31,2024 7:06:33 PM Mounds View Blvd @ Groveland Rd - EB
Mav31,2024 7:30:56 PM Mounds View Blvd (a) Countv H - 5B
June 1, 2024 12:35:37 PM Mounds View Blvd @ Groveland Rd - EB
June 1,2024 12:37:28 PM Mounds View Blvd @ Groveland RD- EB
June 1, 2024 2:10:21 PM Mounds View Blvd @ LonlZLake Rd - EB
June 1, 2024 2:48:33 PM Mounds View Blvd @ Groveland Rd - EB
June 1, 2024 2:50:58 PM Mounds View Blvd (@ Lon~ Lake Rd - EB
June 1,2024 2:53:17 PM Mounds View B.lvd @ County H - SB
June 1, 2024 8:08:19 PM Mounds View Blvd @ LOOllLake Rd - WB
June 1, 2024 8:36:17 PM Mounds View Blvd @ Groveland Rd - EB
June 1,2024 8:37:47 PM Mounds View Blvd @ Lon~ Lake Rd - EB
June 1, 2024 8:39:16 PM Mounds View Blvd @ County H - SB
June 1, 2024 8:39:39 PM Mounds View Blvd @ County H - 5B
June 1,2024 8:39:48 PM Mounds View Blvd @ Countv H - SB
June 1,2024 8:39:53 PM Mounds View Blvd @ Countv H - SB
June I, 2024 8:40:05 PM Mounds View Blvd @ Countv H - SB
June 2, 2024 4:47:37 PM Mounds View Blvd @ Long Lake Rd - WB
June 2,2024 9:00:37 PM Mounds View Blvd (a) Lon~ lake Rd - EB

53. Ladan Mohamed Ali was originally scheduled to return to Seattle from

Minneapolis on June 5, 2024. On the morning of June 3, 2024, the u.S. Attorney's

Office informed the court of the bribe attempt in open court during the trial in United

States v. Abdiaziz Shafii Farah et al. The government moved to take all seven

defendants into custody, and the Court ordered the defendants to turn their cell

phones over to the FBI case agent. That morning, news outlets around the country

reported on the bribe attempt. See, e.g., David A. Farenthold, A Mazda, a Gift Bag of

$120,000 and a Dismissed Juror, N.Y. TIMES,June 3, 20242; Fraud trial juror reports

getting bag of $120,000 and promise of more if she'll acquit, ASSOCIATED

PRESS,June

3, 2024, available at https:llapnews.com/article/minnesota-feeding-our-future-

pandemic-fraud-73610b59bb60bf33f2aa06063bb592d2 (last accessed June 7, 2024).

2 Available at https:llwww.nytimes.com/2024/06/03/us/jury-bribe-feeding-our-future-
fraud.html (last accessed June 7, 2024).

21
 54. Flight records show that on June 3, 2024, Ladan Mohamed Ali booked a

one-way flight leaving Minneapolis that afternoon. Flight records show Ladan

Mohamed Ali flew out of Minneapolis on a flight to Seattle on June 3, 2024--the day

after the bribery attempt and same day that news broke of the attempt to bribe Juror

#52. Ladan Mohamed Ali left at approximately 2:30 p.m. on Alaska Airlines flight

1430.

55. According to records obtained pursuant to a grand jury subpoena, Ladan

Mohamed Ali checked into the Hyatt Regency hotel in Bloomington, Minnesota on

May 30, 2024. Ladan Mohamed Ali checked out of the hotel on June 3, 2024--the

same day that news of the bribe attempt broke. Hotel records that Ladan Mohamed

Ali also stayed at the Hyatt Regency in Bloomington from May 17-19, 2024-during

the trial of United States u. Abdiaziz Shafii Farah et al.

50. On or about June 6, 2024, an FBI agent interviewed the general

manager ofthe Hyatt Regency hotel in Bloomington. Among other things, the general

manager said that there were packages left behind at the hotel for Ladan Mohamed

Ali that she never picked up prior to her departure. The general manager retrieved

22
the two abandoned packages from a backroom and tendered them to the FBI. Both

packages are in Amazon delivery packaging addressed to "Ladan Ali" at the Hyatt

Regency hotel in Bloomington.

"'''''I ~
i1 II
IA REM~C'f Hom BlOOMINGION
32!J~E 81ST Sf
~2S-2 97 MINHlAPDL'S ,MN
~I'!dSurrs

51. One of the abandoned packages contained cosmetic items. The other

package contained a LandAirSea model 54 GPS tracking device:

52. According to the LandAirSea website, available at https:11

https:llshop.landairsea.com/collections/featured-products-1/productsllandairsea-54

(last accessed June 8, 2024), the "54 GPS tracker provides accurate global location,

23
 real-time alerts, and geofencing" that enables the user to "track movement in real-

time." The tracker's "ultra-compact design" and "strong internal magnet create the

ultimate discreet tracker" that easily attaches to vehicles.

53. According to an incident report issued by the New Hope Police

Department, in December 2022, an officer pulled over a car displaying expired tags.

That officer determined that the driver, Ladan Mohamed Ali, had an active felony

arrest warrant for check forgery. The officer accordingly arrested Ladan Mohamed

Ali and asked if she could contact anyone to pick up her car so it would not be towed.

Ladan Mohamed Ali said she could contact Abdimajid Mohamed Nur. Abdimajid

Mohamed Nur is one of the defendants in United States v. Abdiaziz Shafii Farah, et

al.

G. The Search of Abdimajid Nur's Phone

54. As discussed above, on June 3, 2024, Magistrate Judge Elizabeth Cowan

Wright approved a search and seizure warrant authorizing law enforcement officers

to search each of the cell phones belonging to defendants. Although efforts to conduct

those searches remain under way, an initial review of Abdimajid Nur's cell phone

reveals that he performed multiple internet searches using the name of Juror #52,

including visiting the website https://www:truepeoplesearch.com. Abdimajid Nur

searched Juror #52 repeatedly between approximately April 27 and May 22, 2024. In

addition, Abdimajid Nur's internet search history shows that he searched for "jury

nullification." On or about April 28, 2024, Abdimajid Nur also searched using Google,

"how [much] did oj Simpson juror get paid." Abdimajid Nur additionally searched for

information about some of the law enforcement agents involved in the case. His

24
internet search history also includes searches for information about trackers and

hidden cameras.

55. On June 8, 2024, FBI personnel reviewed a folder in Abdimajid Nur's

cell phone titled "iCloudJRecently Deleted." Within that folder, there is a document

created on or about June 3, 2024. This document contains notes and instructions

seemingly intended for a juror, including instructions to vote not guilty as to all

counts and all defendants. It instructs the recipient juror to stand their ground and

not change their vote if pressured by other jurors. Specifically, it instructs the

recipient near the end of the document that "You alone can end this case. Always do

your best to convince other jurors to vote NOT GUILTY ON ALL COUNTS FOR ALL

DEFENDANTS." The instructions provide a list of arguments and talking points for

apparent use in convincing other jurors to vote not guilty. Portions of this document

from Abdimajid Nur's cell phone are excerpted below:

25
 Sody #1. Below are arguments to convince other jurors. REMEMBER your vote will be NOT GUILlY ON ttLL
COUNTS for all defendants 2. We are IITlmigrants: they Conl respe<t aM cale about us. 3. Go emm~nt
Late !n'les 'gation-AII agents did not swiftly acts on the case. JUI)' dOEsn't ha'o'e fuJI picture of what
happened on ·me 4. Misleading Information including the math 'I<f1ichwas done to fit the
Govemment narrabVe. 5. Lack of credible wItnesses( 3 years later). Nobod)' remembers anything about
what happened. 6. Assumed guilt from the beginmng of the case and didn·t even bother to in·ie.t'gate
ortalk to anyone at all just followed the money 7. No site "';sits, no surveillance and nothing was ever
tlone to visit any of tile locations. They Md over a year to do it but they didn·t at all. B. No one from
the main sponsor is jndtcted. 9. Oefendants as presented by 1he GO'/emm""t made millions and
millions outside of the food program. For eJ(ample over one million in just credit card sales alone of
tIleir bUSinesseslQ No one from MOE is indicted 11. Nobody from Slate government is indICted 12.
No experts including nutri1ionlst and even food experts were presented to jury to explain how the
food industry or food program works 13. Prejudice ~9ainst people of color. The Government kePI
attacking Somah ,ritnesses and asking lIlem If It'S true in 1I1eSomali culture to cheat, steal or lie whim
was very racIst. 14. The GOIWemment JU5t followed the money and didn't do any real Investigation to
better understand tile reimbursement program 1S. Hadith was a big ·me liar and nobody should
believe him. HIS maIO goal is to gel a deal from tile go,ernment and not go to prison. 16. Evidence
present.ed doesn't nat support the main facts of the case. Just pictures and me.al counts that were not
even verified and most of the witnesses did tlot even underst~nd 17. Most of tile data came from
cues whICh the defentlants don't !la". access to so It was flawed. lB. This is a reimbursement
program and it took months to receivE' payment. The defendan1s teo an enormous financial risk to
do this wo'" that they didn·t have alot of eJ<jlerience for. 19. The 90vemment ha(! options for other
remedies 10 collect money bacl( and don·! see Ihis as criminal case 20. The defendants are new to
program and never received any kind 01 support . .21.Slate leadefS and otller government entities
should have stopped payments and are responsible for such mess 22. All defendants are not guilty
beyond reasonabl. tloubt . The Government hasnt pro'Jen at al all a~d hasnt mel that burden at all.
23. Why .,I'Iy 'I,I'Iy " it al\Va~s people of color and Immigrants prosecuted for tile fault of otller people
Induding Kala Lomen and even the Governor. Where is Kara lome"? Where IS MOE finance people
',,"0 paid millions and millions of dollars. 24. Oefendants did a lot of worK including millions in food
and expenses so ",no Ille hell Cloesall tIlat to commit fraud.25. A lot of money ~ as spent on food and
other expenses but the govemment try 10 hIde them by creatJng their own categories especially in
hidden pivOI tables. 26. Defendants used their legal names, documents such as passports and drivers
license. 0 concealmenl and nothing is hidden so no Wile fraud or any money laundenng at all. They
created legal entf es With 'the state and federal government WIth no Intentions to hide at all. 27.
Spansor was re5IPorLlib1efor e\'ff)lthing. They received millions and millions of dollars 10 oversee this
but they didn t and the largest sponsor and Its staff members is not eyen indicted. 28. This case is not
about money or children and all they are trying is to inCite aoo In flame. The defendants ran for profit
entities, worj(ed hard anti earned the money rightfully. It's their money and they can spend y,I'Iatever
tIley Vlant ~rith it Irs not Illegal to spend your own money tIlat you so rightfull)' eamed. 29. The above
and many other reasons presented I firmly conclude NOT GUILTY on all counts for all 7 defendants.
The government has not pnoven its case beyond a reas.onable doubt al all. ot eyen dose at all. 30.
She really really needs to conVince all tile remaining jurors to marK NOT GUlLTV for all defendants and
all counts. 31. Stand your ground and don't change- your mind even if anyone pushes you to vote
Clifferenl. or GUILTY ON ALL COUNTS fOR ALL defenclanls. You alone can end this case. A1w~ys do
your besllO co~vi"(e other JUrors to VOle NOT GUILT\' ON ALL (OUNTS fOR ALL DEFENOANTS

H. The Video Recording of the Bribe Attempt

56. As discussed above, on June 3, 2024, Magistrate Judge Elizabeth Cowan

Wright approved a search and seizure warrant authorizing law enforcement officers

to search each of the cell phones belonging to defendants, including the phone

belonging to Said Shafii Farah.

57. During a reVIew of Said Shafii Farah's phone, agents found the

recording Individual B delivering the bribe money to Juror #52's house. According to

the data from the phone, Said Shafii Farah received the video on June 2, 2024, at

approximately 10:18 p.m.-a little more than an hour after Ladan Ali and

26
Abdulkarim Shafii Farah delivered the bribe money. Said Shafii Farah received the

video via a messaging app from "M." The message said, "watch and delete abti." As

noted above, in WhatsApp messages obtained during the execution of search

warrants in January 2022, Said Shafii Farah was regularly referred to as "abti."

58. The video recovered from Said Shafii Farah's phone shows Ladan Ali

walk up to Juror #52's house carrying the white gift bag containing the $120,000 in

cash. The video shows Ladan Ali approach the front door to Juror #52's house and

Juror 52's relative open the door. Ladan Ali then handed the gift bag containing the

bribe money to Juror #52's relative. The video then showed Ladan Ali run back to the

car after dropping off the gift bag containing the bribe money.

59. Said Shafii Farah received another message from "Af' on June 2, 2024,

at approximately 9:01 p.m., within minutes of the bribe attempt. The message said,

"Still posted outside of house abti."

I. The Indictment

60. On June 25, 2024, a grand jury returned an indictment charging five

defendants, including Abdulkarim Shafii Farah, with participating in the attempt to

bribe Juror 52. As alleged in the indictment, Abdulkarim Shafii Farah is the younger

brother of Abdiaziz Shafii Farah and Said Shafii Farah. According to records obtained

during the investigation into the Feeding Our Future fraud scheme, Abdulkarim

Shafii Farah received an IRS Form 1099 from Bushra Wholesalers in 2021.

Abdulkarim Shafii Farah was also listed as a site supervisor for the Somali

Community Resettlement site in Willmar, Minnesota-one of the sites involved in

27
the fraudulent scheme to receive federal child nutrition program funds at issue in

United States u. Abdiaziz Shafii Farah et al.

61. As alleged in the indictment, the following events happened on June 2,

2024:

a. At approximately 12:56 a.m. on Sunday, June 2, 2024, ABDIAZIZ

FARAH sent a message to SAID FARAH using an encrypted messaging app.

ABDIAZIZ FARAH told SAID FARAH to "[p]lease have the money ready by 10 please.

It's very important for everything we have."

b. On Sunday, June 2, 2024, ABDIAZIZ FARAH instructed

ABDlMAJID NUR to meet him at SAID FARAH's business, Bushra Wholesalers, to

pick up the bribe money.

c. On Sunday June 2, 2024, ABDlMAJID NUR drove to Bushra

Wholesalers to pick up the bribe money.

d. On Sunday June 2, 2024, SAID FARAH gave ABDlMAJID NUR

a cardboard box containing the money to bribe Juror 52.

e. On Sunday, June 2, 2024, LADAN ALI purchased two Hallmark

gift bags for use in delivering the bribe money to Juror 52.

f. After receiving the bribe money from SAID FARAH, ABDlMAJID

NUR met LADAN ALI in a parking lot in Bloomington, Minnesota. LADAN ALI got

into ABDlMAJID NUR's car. ABDlMAJID NUR then handed LADAN ALI the

cardboard box containing the bribe money he had received from SAID FARAH.

LADAN ALI took the bribe money from the cardboard box and put it into one of the

28
Hallmark gift bags for delivery to Juror 52. LADAN ALI left the cardboard box and

second gift bag in ABDlMAJID NUR's car.

g. Mter receiving the bribe money from ABDlMAJID NUR, LADAN

ALI met ABDULKARIM FARAH in a parking lot near Juror 52's house.

h. At approximately 5:30 p.m. on June 2, 2024, ABDULKARIM

FARAH and LADAN ALI drove to a nearby Target store to purchase a screwdriver.

ABDULKARIM FARAH used the screwdriver to remove the license plates from

LADAN ALI's rental car prior to the bribe attempt.

J. The Search of Abdulkarim Shafii Farah's Apartment

62. On June 17, 2024, Magistrate Judge Douglas L. Micko issued a warrant

to search Abdulkarim Shafii Farah's apartment located at 1201 Brook Avenue SW,

Apartment 205, in Minneapolis, Minnesota.

63. FBI agents executed the search warrant on the morning of June 20,

2024. During the search, agents recovered clothing matching the clothing that

Abdulkarim Shafii Farah appeared to be wearing on the night of the bribe attempt.

Specifically, on June 2, 2024, Abdulkarim Shafii Farah went into a Target store in

Mounds View, Minnesota, to purchase a screwdriver for use in removing the license

plate from the car prior to the bribe attempt. Surveillance video obtained from Target

showed Abdulkarim Shafii Farah purchase the screwdriver and leave the store

wearing a gray long-sleeved shirt and blue pants.

29
 64. During the search of Abdulkarim Shafii Farah's apartment, agents

found similar clothing. Agents also recovered at least $26,000 in cash during the

search of Abdulkarim Shafii Farah's apartment.

30
 65. The government has information that the Target Cell Phone is one of

the phone numbers that is used by Abdimajid Mohamed Nur.

66. The Target Cell Phone is associated with a phone number (612-402-

8317) that, in the weeks leading up to United States v. Abdiaziz Shafii Farah et al.,

Abdimajid Mohamed Nur provided to pretrial services as his contact number.

Further, in response to a search warrant executed during the investigation related to

United States v. Abdiaziz Shafii Farah et al., law enforcement received copies of email

communications in which Abdimajid Mohamed Nur tells others that that phone

number is his.

67. The carrier for Target Cell Phone number is T-Mobile.

II. AUTHORIZATION REQUEST

68. Based on the foregoing, I request that the Court issue the proposed

search warrant, pursuant to Federal Rule of Criminal Procedure 41 and 18 U.S.C.

§ 2703(c).

31
 69. I further request that the Court direct T-Mobile to disclose to the

government any information described in Attachment B that is within the possession,

custody, or control of T-Mobile. I also request that the Court direct T-Mobile to

furnish the government all information, facilities, and technical assistance necessary

to accomplish the collection of the information described in Attachment B

unobtrusively and with a minimum of interference with T-Mobile's services, including

by initiating a signal to determine the location ofthe Target Cell Phone on T-Mobile's

network or with such other reference points as may be reasonably available, and at

such intervals and times directed by the government. The government shall

reasonably compensate T-Mobile for reasonable expenses incurred in furnishing such

facilities or assistance.

FB~~amriC

Subscribed and Sworn before me by

reliable electronic means via FaceTime and
e-mail pursuanttoFed.R.Crim. P. 41(d)(3)
this __ day of June, 2024.

The Honorable Douglas L. Micko

United States Magistrate Judge

32
DWBsk
AO 93 (Rev. 12/09) Search and Seizure Warrant
2024R00256

UNITED STATES DISTRICT COURT

for the
District of Minnesota

IN THE MATTER OF THE SEARCH OF THE SEALED BY ORDER OF THE COURT

CELLULAR TELEPHONE ASSIGNED CALL
NUMBER (612) 402-8317 STORED AT PREMISES Case No. 24-mj-456 (DLM)
CONTROLLED BY T-MOBILE U.S., INC.

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 New Jersey:

See Attachment A, incorporated here.

The person or property to be searched, described above, is believed to conceal:

See Attachment B, incorporated here.

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.

YOU ARE COMMANDED to execute this warrant on or before July 9, 2024

(not to exceed 14 days)

_ in the daytime 6:00 a.m. to 10 p.m. X at any time in the day or night as I find reasonable
cause has been established.

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 the United States Magistrate Judge
on duty.

Date and Time issued:

Judge's Signature
City and State: St. PauL MN The Honorable Douglas L. Micko
United States Magistrate Judge
Printed Name and Title
AO 93 (Rev. 12/09) Search and Sei::.ure Warrant (page 2)

Return
Case No.: Date and time warrant executed: Copy of warrant and inventory le.ftwith:

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 designatedjudge.

Date:
Executing officer's signature

SUBSCRiBED and SWORN before me by reliable electronic Printed Name and Title
means (Face Time, ::oom, email) pursuant to Fed. R. Crim. P.
41 (d)(3)

U.S. Judge or Magistrate Judge Date

3
 ATTACHMENT A
Property to Be Searched

1. The cellular telephone(s) assigned call number 612-402-8317 whose

wireless service provider is T-Mobile US, Inc., a company headquartered at 4 Sylvan

Way, Parsippany, New Jersey, 07054.

2. Information within the possession, custody, or control ofT-Mobile about

the historical locations of the Target Cell Phone.

 ATTACHMENT B
Particular Things to be Seized

All information about the historical locations of the Target Cell Phone

described in Attachment A for the period March 1, 2024, through June 5, 2024, during

all times of day and night. "Information about the location of the Target Cell Phone"

includes all available E-911 Phase II data, GPS data, latitude-longitude data, and

other precise location information, as well as all data about which "cell towers" (i.e.,

antenna towers covering specific geographic areas) and "sectors" (i.e., faces of the

towers) that received a radio signal from the cellular telephone described in

Attachment A.

To the extent that the information described in the prevIOUS paragraph

(hereinafter, "Location Information") is within the possession, custody, or control of

T-Mobile US, Inc. ("T-Mobile") T-Mobile is required to disclose the Location

Information to the government. In addition, T-Mobile must furnish the government

all information, facilities, and technical assistance necessary to accomplish the

collection of the Location Information unobtrusively and with a minimum of

interference with T-Mobile's services, including by initiating a signal to determine

the location of the Target Cell Phone on T-Mobile's network or with such other

reference points as may be reasonably available, and at such intervals and times

directed by the government. The government shall compensate T-Mobile for

reasonable expenses incurred in furnishing such facilities or assistance.

Subscriber information pertaining to the cellular telephone described m

Attachment A, including subscribers' full names, addresses, shipping addresses, date

account(s) were opened, length of service, the types of service utilized, ESN(s)

(Electronic Serial Numbers) or other unique identifier(s) for the wireless device

associated with the account(s), Social Security number, date of birth, telephone

numbers, and other identifiers associated with the account(s).

This warrant does not authorize the seizure of any tangible property. In

approving this warrant, the Court finds reasonable necessity for the seizure of the

Location Information. See 18 U.S.C. § 3103a(b)(2).

2
 2024R00256

UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
Case No. 24-mj-456 (DLM)

IN THE MATTER OF THE SEARCH OF SEALED BY ORDER OF THE

THE CELLULAR TELEPHONE COURT
ASSIGNED CALL NUMBER
(612) 402-8317 STORED AT PREMISES PETITION OF THE UNITED
CONTROLLED BY T-MOBILE U.S.,
STATES FOR AN ORDER
INC.
SEALING SEARCH WARRANT,
AFFIDAVIT, RETURN,
PETITION AND ORDER FOR
SEALING

COMES NOW the United States of America by its undersigned attorneys and

in support of its Petition for an Order Sealing Search Warrant, Affidavit, Return, and

Petition in the above-captioned matter, states as follows:

1. On June 25, 2024, The Honorable Douglas L. Micko authorized the

search of the cellular telephone assigned call number (612) 402-8317 that is stored at

premises controlled by T-Mobile U.S., Inc.

2. The Affidavit of Special Agent, Emily Hamric, submitted in support of

the search warrant, sets forth facts regarding an ongoing investigation into violations

of Title 18, United States Code, Section 201, Bribery of a Juror, and Title 18, United

States Code, Section 1503, Influencing or Injuring Juror.

3. The search warrant documents presented to this Court for in camera

review include detailed and highly sensitive investigative information. Disclosure of

the information would jeopardize an ongoing investigation into alleged criminal

offenses and the privacy of individuals unlikely to be, and/or who may ultimately

not be indicted.

4. Nondisclosure of the search warrant documents is necessary to prevent

the ongoing investigation from being compromised. Immediate public filing of the

search warrant documents would, inter alia, compromise details about the nature,

extent, and scope of the investigation.

5. The search warrant documents contain identifying information of and

circumstances relating to an individual or individuals involved in criminal activity in

some way who may not be indicted in this case. Nondisclosure of the search warrant

documents at this stage is necessary to protect their identity and/or to minimize the

substantial risk that revelation of details set forth in the search warrant documents

could cause to their reputation.

6. The search warrant documents contain identifying information of and

circumstances relating to an individual or individuals involved in criminal activity in

some way who may not be indicted in this case. Nondisclosure ofthe search warrant

documents at this stage is necessary to protect their identity and/or to minimize the

substantial risk that revelation of details set forth in the search warrant documents

could cause to their reputation.

7. The Court's power to prevent disclosure of its files, especially for a

limited period of time, is well established. This general power has been recognized

by the United States Supreme Court.

It is uncontested, however, that the right to inspect and copy judicial

records is not absolute. Every court has supervisory power over some

2
 records and files and access has been denied where court files might
have become a vehicle for improper purposes.

Nixon u. Warner Communications, Inc., 435 U.S. 589, 598 (1978).

8. The Eighth Circuit has recognized the Court's specific power to restrict

access to search warrant documents like those at issue here:

We hold that the qualified first amendment right of public access

extends to the documents filed in support of search warrants and that
the documents may be sealed if the district court specifically finds that
sealing is necessary to protect a compelling government interest and
that less restrictive alternatives are impracticable.

In re Search Warrant for Secretarial Area Outside Office of Gunn, 855 F.2d 569,

574 (8th Cir. 1988).

9. The Eighth Circuit and district courts within the Circuit have

recognized that the circumstances surrounding ongoing investigations constitute

compelling government interests warranting the sealing of search warrant

documents. For example, the Eighth Circuit has approved sealing search warrant

documents that "describe [d] in detail the nature, scope and direction of the

government's investigation and the individuals and specific projects involved,"

resulting in "substantial probability that the government's on-going investigation

would be severely compromised if the sealed documents were released." Gunn, 855

F .2d at 574. Moreover, the Eighth Circuit has recognized that search warrant

affidavits permeated with references to individuals other than the subjects of the

search warrant and/or with information revealing the nature, scope and direction of

the government's ongoing investigation may be sealed not only because they present

compelling government interests justifying sealing, but also because less restrictive

3
alternatives to sealing are in such circumstances impracticable. Id.

10. Based upon the foregoing and all the files and proceedings to date, the

United States respectfully requests that this Court issue an Order Sealing the

Warrant, Application, Mfidavit of Federal Bureau of Investigations, Special Agent,

Emily Hamric, Return, this Petition, and the Sealing Order until the close of business

on June 25, 2025 unless a compelling interest is shown by the United States for a

continuation of the sealing.

Dated: June 25, 2024

Respectfully submitted,

ANDREW M. LUGER
United States Attorney

s/ Daniel W. Bobier
BY: JOSEPH H. THOMPSON
DANIEL W. BOBIER
HARRY M. JACOBS
MATTHEW S. EBERT
CHELSEAA. WALCKER
Assistant U.S. Attorneys

4
 2024R00256

UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
Case No. 24-mj-456 (DLM)

IN THE MATTER OF THE SEARCH SEALED BY ORDER OF THE

OF THE CELLULAR TELEPHONE COURT
ASSIGNED CALL NUMBER
(612) 402-8317 STORED AT PREMISES ORDER FOR SEALING
CONTROLLED BY T-MOBILE U.S.,
INC.

This Court, having reviewed the Petition of the United States herein, finds

that the United States has shown a compelling interest in the sealing of documents

in the above-captioned matter because:

a. Nondisclosure of the search warrant documents is necessary to prevent

the ongoing investigation from being compromised.

b. Nondisclosure of the search warrant documents is necessary to protect

the privacy of an individual who may ultimately remain unindicted.

This Court also finds that less restrictive alternatives to sealing are

impracticable or not appropriate.

It is therefore:

ORDERED that all documents filed in the above-captioned matter are hereby

sealed until the close of business on June 25, 2025.

 IT IS FURTHER ORDERED that these documents will be unsealed at the

above time unless further compelling interest is shown by the United States for

continuing this Order for an additional period of time.

Date The Honorable Douglas L. Micko

United States Magistrate Judge

2
 2024R00256

UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
Case No. 24-mj-456 (DLM)

IN THE MATTER OF THE SEARCH OF

THE CELLULAR TELEPHONE
ASSIGNED CALL NUMBER' SEALED BY ORDER OF THE
(612) 402-8317 STORED AT PREMISES COURT
CONTROLLED BY T-MOBILE U.S.,
INC.

APPLICATION FOR ORDER COMMANDING T-MOBILE U.S., INC. NOT TO

NOTIFY ANY PERSON OF THE EXISTENCE OF WARRANT

The United States requests that the Court order T-Mobile U.S., Inc. not to

notify any person (including the subscribers or customers of the account(s) listed in

the warrant) of the existence of the attached warrant until June 25, 2025.

1. T-Mobile U.S., Inc. is a provider of an electronic communication service,

as defined in 18 U.S.C. § 2510(15), and/or a remote computer service, as defined in 18

U.S.C. § 2711(2). Pursuant to 18 U.S.C. § 2703, the United States obtained the

attached warrant, which requires T-Mobile U.S., Inc. to disclose certain records and

information to the United States. This Court has authority under 18 U.S.C. § 2705(b)

to issue "an order commanding a provider of electronic communications service or

remote computing service to whom a warrant, subpoena, or court order is directed,

for such period as the court deems appropriate, not to notify any other person of the

existence of the warrant, subpoena, or court order." Id.

2. In this case, such an order would be appropriate because the attached

warrant relates to an ongoing criminal investigation that is neither public nor known

to all of the targets of the investigation, and its disclosure may alert the targets to
the ongoing investigation. Accordingly, there is reason to believe that notification of

the existence of the attached warrant will seriously jeopardize the investigation,

including by giving targets an opportunity to flee or continue flight from prosecution,

destroy or tamper with evidence, change patterns of behavior, or notify confederates.

See 18 U.S.C. § 2705(b)(2), (3), (5). Some ofthe evidence in this investigation is stored

electronically. If alerted to the investigation, the subjects under investigation could

destroy that evidence, including information saved to their personal computers.

3. WHEREFORE, the United States respectfully requests that the Court

grant the attached Order directing T-Mobile U.S., Inc. not to disclose the existence or

content of the attached warrant until June 25, 2025, except that T-Mobile U.S., Inc.

may disclose the attached warrant to an attorney for T-Mobile U.S., Inc. for the

purpose of receiving legal advice.

4. The United States further requests that the Court order that this

application and any resulting order be sealed until June 25, 2025. As explained above,

these documents discuss an ongoing criminal investigation that is neither public nor

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known to all of the targets of the investigation. Accordingly, there is good cause to

seal these documents because their premature disclosure may seriously jeopardize

that investigation.

Dated: June 25, 2024 Respectfully submitted,

ANDREW M. LUGER
United States Attorney

s / Daniel W. Bobier
BY: JOSEPH H. THOMPSON
DANIEL W. BOBIER
HARRY M. JACOBS
MATTHEW S. EBERT
CHELSEA A. WALCKER
Assistant U.S. Attorneys

3
 2024R00256

UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
Case No. 24-mj-456 (DLM)

IN THE MATTER OF THE SEARCH OF

THE CELLULAR TELEPHONE
ASSIGNED CALL NUMBER SEALED BY ORDER OF THE
(612) 402-8317 STORED AT PREMISES COURT
CONTROLLED BY T-MOBILE U.S.,
INC.

ORDER

The United States has submitted an application pursuant to 18 U.S.C. §

2705(b), requesting that the Court issue an Order commanding T-Mobile U.S., Inc.,

an electronic communications service provider and/or a remote computing service, not

to notify any person (including the subscribers or customers of the account(s) listed

in the warrant) of the existence of the attached warrant until June 25,2025.

The Court determines that there is reason to believe that notification of the

existence of the attached warrant will seriously jeopardize the investigation,

including by giving targets an opportunity to flee or continue flight from prosecution,

destroy or tamper with evidence, change patterns of behavior, or notify confederates.

See 18 U.S.C. § 2705(b)(2), (3), (5).

IT IS THEREFORE ORDERED under 18 U.S.C. § 2705(b) that T-Mobile U.S.,

Inc. shall not disclose the existence of the attached warrant, or this Order of the

Court, to the listed subscriber or to any other person, until June 25,2025, except that

T-Mobile U.S., Inc. may disclose the attached warrant to an attorney for T-Mobile

U.S., Inc. for the purpose of receiving legal advice.

 IT IS FURTHER ORDERED that the application and this Order are sealed

until June 25, 2025.

Date The Honorable Douglas L. Micko

United States Magistrate Judge

2
 2024R00256

UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
Case No. 24-mj-456 (DLM)

IN THE MATTER OF THE SEARCH OF SEALED BY ORDER OF THE

THE CELLULAR TELEPHONE COURT
ASSIGNED CALL NUMBER
(612) 402-8317 STORED AT PREMISES APPLICATION OF THE UNITED
CONTROLLED BY T-MOBILE U.S., INC. STATES FOR AN EXTENSION OF
TIME TO EXECUTE SEARCH
WARRANT

COMES NOW the United States of America, by its undersigned attorneys and

in support of an application for an Order extending the time by which T-Mobile U.S.,

Inc. must execute the search warrant:

1. On June 25,2024, The Honorable David T. Schultz issued the attached

search warrant authorizing the search of information maintained by T-Mobile U.S.,

Inc .. The search warrant commanded law enforcement to execute the search warrant

within 14 days of the issuance of the warrant pursuant to Federal Rule of Criminal

Procedure 41-i.e., by July 9,2024. The Affidavit of Federal Bureau ofInvestigations,

Special Agent, Emily Hamric submitted in support of the search warrant sets forth

facts regarding an ongoing criminal investigation. The factual allegations in this

application are also based on information provided from Federal Bureau of

Investigations, Special Agent, Emily Hamric.

2. Production by service providers such as T-Mobile U.S., Inc. pursuant to

search warrant routinely occurs outside Rule 41's 14-day period for execution.

Indeed, production often occurs more than 30 days after service of a warrant on the

service provider. Reasons for delay in production are outside the government's
control, and may include the complexity or volume of data requested in the warrant

itself, as well as the volume of other requests for information received by T-Mobile

U.S., Inc.

3. On June 26, 2019, a panel ofthe Eighth Circuit Court of Appeals issued

an opinion in United States v. Nyah, 928 F.3d 694 (8th Cir. 2019). The Eighth Circuit

addressed the question of when a warrant issued to Facebook was executed for

purposes of Federal Rule of Criminal Procedure 41: "The district court thought the

warrant was executed when the officers delivered it to Facebook," while "Nyah

counters that the warrant was not executed until the officers seized the evidence from

Facebook." Id. at 699. In dicta, the Nyah court observed that "the text of Rule 41

suggests that a warrant is not fully executed until officers have seized the property

that they are authorized to take" and "the authorized seizure of property under the

warrant constitutes part of the execution of the warrant." Id. The court, however,

concluded that it did not need to "definitively" determine whether the warrant was

"executed" within fourteen days after the warrant was issued because even if there

were a violation of Rule 41, there was no basis for suppression. Nyah, however,

recommends a remedy to any Rule 41 problem, which is to "simply obtain a fresh

warrant with a renewed period of fourteen days within which to execute the warrant."

Id. at 700.

4. Although Nyah does not contain a holding that a Rule 41 violation

occurs when providers like Facebook produce records in response to a search warrant

more than 14 days after the warrant is issued, Judge Colloton's opinion strongly
suggests such an interpretation. The United States disagrees with this

interpretation, and contends that, as the Sixth Circuit held in United States u.

Farrad, 895 F.3d 859, 890 & n.23 (6th Cir. 2018), a warrant directed to a service

provider is executed when an officer serves it on the provider. Nyah also conflicts

with the Eighth Circuit's earlier decision in United States u. Welch, 811 F.3d 275,

280-81 (8th Cir. 2016). In considering when the time limit for providing notice of a

search warrant under Fed. R. Crim. P. 41(f) began to run, the Welch court pinned the

timing of a warrant's execution to the date when officers served the warrant on the

provider (via installation of software on a server). Nevertheless, Nyah is the only

Eighth Circuit opinion to speak directly to when execution is complete under Rule 41,

and therefore the United States seeks to comply with it in an abundance of caution.

5. Recognizing both the Nyah court's suggestion that "execution" of a

warrant occurs only after the provider produces the records sought to the law

enforcement agent, and that prior experience has shown that production often occurs

after the 14-day requirement provided by Rule 41 has lapsed, the government hereby

moves for an Order pursuant to Rule 45(b)(1)(A) to extend the period of time for

execution "before the originally prescribed or previously extended time expires."

Accordingly, the government seeks an Order extending the period by which the

3
warrant must be executed from 14 days from the issuance of the warrant-July 9,

2024-until the government obtains the records produced by T-Mobile U.S., Inc. in

response to the warrant.

Dated: June 25, 2024 Respectfully submitted,

ANDREW M. LUGER
United States Attorney

s / Daniel W. Bobier
BY: JOSEPH H. THOMPSON
DANIEL W. BOBIER
HARRY M. JACOBS
MATTHEW S. EBERT
CHELSEA A. WALCKER
Assistant U.S. Attorneys

4
 2024R00256

UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
Case No. 24-mj-456 (DLM)

IN THE MATTER OF THE SEARCH OF

THE CELLULAR TELEPHONE SEALED BY ORDER OF THE
ASSIGNED CALL NUMBER COURT
(612) 402-8317 STORED AT PREMISES
CONTROLLED BY T-MOBILE U.S., INC. ORDER EXTENDING TIME TO
EXECUTE SEARCH WARRANT

The Court has reviewed the Application of the United States for an extension

of time to execute the accompanying search warrant. Although the Court does not

believe an extension is needed if the government executes the search warrant by

serving it on the provider within 14 days of its issuance, see United States v. Farrad,

895 F.3d 859,890 & n.23 (6th Cir. 2018) (stating that a warrant directed to a service

provider is executed when an officer serves it on the provider), the Court understands

the government's concerns about statements made in dicta in United States v. Nyah,

928 F.3d 694 (8th Cir. 2019).

Therefore, the Court finds that the United States has shown good cause for the

requested order. The United States must serve the above-captioned Search Warrant

on T-Mobile U.S., Inc. within 14 days of issuance. To the extent that "execution" of

the Search Warrant under Federal Rule of Criminal Procedure 41(e)(2)(A)(1) includes

production of records by T-Mobile U.S., Inc. in response to the Search Warrant, it is

ORDERED pursuant to Federal Rule of Criminal Procedure 45(b)(1)(A), that the date
by which law enforcement must execute this warrant is extended from July 9, 2024,

to the date the government obtains the records produced by T-Mobile U.S., Inc. in

response to the warrant.

Date The Honorable Douglas L. Micko

United States Magistrate Judge