Part 4 Of The Ald. Danny Solis Federal Investigation Affidavit 4s345t

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 1 of 43 PageID #:136

expenditures by sol,rs associatedwith the 25'nward Regular Democratic organz5-ation are, in fact, personal expenditures. Additionally,

intercepted conversations suggest that sol,rs and his wife are renting subject Location 4, which suggests that financial documents, including the apartment lease and other records, will be l-ocated at this location. For example, ofi or about March 2G, zoLs, at approximately 11:55 a.m. (call #i87B), sor,rs placed an outgoing call on Target Phone 2 Lo a representative of the property developer behind The Roosevel-t Co1lect,ion, where subject r,ocation 4 is located.

ouring the carl,

the representative informed solrs that a two bedroom, two bathroom apartment may become available in ,Ju1y. so1,rs informed the representative that he was looking L,o rent right now and may purchase a property as an investment Iater. sol,rs arso said t.hat he had a unit in River City (Subject lJocation 3) . In another intercepted calr on or about June 19, 2015, at approximat,eLy 2z4L p'm- (call- #13375), solrs placed an outgoing call on Target phone 2 to "Roxy" at the Roosevelt Colrection. During the caI1, Roxy informed solrs that she had received his application, proof of income, and a copy of his identification in connection with his rentar of an apartment at the Roosevelt Colrection. During the caIr, sol,rs informed Roxy that he would arrange to have his bank automatically transfer rent for the apartment on a certain day v.

Subject Location

5

151. As described inAttachmenL E-1, subject r,ocation 5 is the business premises of the copper Tan and spa, where sol,rs received

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Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 2 of 43 PageID #:137

prostitution

services, as described above in paragraphs 59 Lhrough

T5,EsandSg.BasedonsurveillanceandnewsreportsrelatedLo which a Chicago Police Department raid on the Copper Tan and Spa, video occurred on or about.Tuty 31-, 20L3, Subject Location 5 has surveillance equipment, which may provide evidence of soLIS's visiL' of payment for soLIS's visit, and' the identities of the individuals who provided. services to soLIS and his companions ' which is available L62 . Ad.ditionallY, according to its websit,e, at www.coppertanspa.com, the business accepts mosL credit cards'

the

meLhod.

Basedonmyt.rainingandexperj-ence,Iknowthatbusinessesthat in accept credit cards maintain records of credit card Lransactions order to receive pa)rment from the lender for the services rendered' including such businesses often maintain other financial records, receipts, checks, bank and savings and loan records of deposit, money sLaLements and ot,her bank records, credit card statemenLs, ord,ers, cashier, s checks, books, cancelled checks, certificaLes of deposit, Ioan records, customer information,

amd income

and exPense summaries.

1-63. Additionally, businesses such as the copper Tan and spa ofLen maintain appointment books, calendars, client lists, details of services rendered, the names of masseuses t'hat a client utilizes' and other records of client visits,

services rendered and conLact

i-nformation.Alltheforegoinginformationwillconstitute location' evidence of visits by soLIS and his companions to Lhis

LlZ

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 3 of 43 PageID #:138

vi.

Target Phone

2

1-64. As further described inAttachment F-1, Target Phone 2 is

the cel1u1ar telephone used by SOLIS in the intercepted conversations and text messages discussed above regarding the Subject Offenses.

165. Based upon my training

and experience, f know that information stored within a cel-lular phone may provide crucial evidence of the "who, what, why, when, where, and how" of the criminal

conduct under investigation,

t,hus enabling the United States to

establish and prove each element or alLernatively, Lo exclude the innocenL from further suspicion. fn my training and experience, the information stored within a ceIl phone can indicaLe who has used or controlled t.he cell phone. This t' attribution" evidence is analogous to the search for "indicia of occupancy" while executing a search warranL at a residence. In this case, establishing SOLIS,s use of Target Phone 2 wilI,

identification

other things, establish his voice in wire j-nterceptions made over Target Phone 2. In among

addition, s lists, inst.anL messaging logs,

and communications

(and the data associated with the foregoing, such as date and time) may

indicate

who used

or controlled the cel-I phone at

a

relevant time.

Further, such stored electronic data can show how and when the ce}1 phone and its related were accessed or used. Such "timeline" information allows investigators to understand the chronological context of cell phone access, use, and events relating to the crime

113

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under invesLigation. This "timeline" information may tend to either

inculpat.e or exculpate the cel1 phone owner. 166. Cellu1ar phones may contain relevanL evidence of the

Subject Offenses, including text messages made or received from Target Phone 2 t.hat are located in the memory of Target Phone 2, which messages may provide information regarding the identities of, and t.he methods and. means of operation and communication used by, Lhe

participanls in the Subject Offenses. Moreover, d"igital photographs located in t.he memory of Target Phone 2 may contain images of participants involved in Lhe Subject OffehEes. Moreover, digital photographs stored in Target Phone 2 may contain images of SOLIS, SOi,IS's associaLes (including persons involved in or knowledgeable

about the Subject Offenses), places frequented by SOLIS leading up

Subject Offenses, and locations instrumentalities used in committing the Subject Offenseg. t67. In addition, based on my training and experience, f

to

and during

the

and

know

that information stored within a cell phone may indicate the geographic location of t.he ce}I phone and at a particular t.ime (e.g., IocaLion integrated into an image or video senL via email or text message to include both metadata and Lhe physical location displayed in an image or video). Stored electronic data may also provide relevanL insight into the cell phone owner's sLate of mind as it relaLes to the offense under invesLigation. For example, informaLion in the cetl phone may indicaLe Lhe owner's motive and intent to commit a crime (e.g., communications relating to the

714

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 5 of 43 PageID #:140

crime),orconsciousnessofguilt(e'g"deletingcommunicationsin anefforttroconcealthemfromlawenforcement).Unlessthisdata isdestroyed,bybreakingthecellphoneitselforbyaprogramthat within the ce11 phone' deletes or over-writes the data contained

such

datawillremainstored.withinthecellphoneindefinitely. enforcement officer 1-68. Through experience as a law

and

throughtheexperienceofotherlawenforcementofficersasconveyed tome,Ihave].earnedthatindividualsinvolvedincriminaloffenses commonlyusecellulart.elephonesasameanstocOmmunicate.As d.et.ailedabove,SoLlsusedTargetPhone2tocommunicaLewithanumber to the subjeet offenses' of individuals regard.ing and in connection often sLore telephone Individuals involved in criminal 0ffenses also

numbersandnamesornicknamesoffellowconspiraLorsont'heir telephonesand'thet,elephonesalsoreflectrecentcallhistory. Finally,individualsoftenusetextmessaginganddigital photographsinfurtheranceoftheircriminalactivitythataresLored oncellularterephones.Because,asexplainedabove,Target.Phone there was Lelephonic 2 ts associated with solrs, because in the subj ect offenges ' communication between participanLs involved andbecause,inmyexperienceandintheexperienceofotheragenLs' defend.antsusetelephonestoco-Conspirators,thereis described further in probable cause to believe Target Phone 2 ' Att'achmentF-].,containsevidenceoftheSubjeetoffenses. Specifics Regarding Searches of Computer vaa. Systems.

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Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 6 of 43 PageID #:141

L6g. Based upon my training and experience, and the training and experience of specially trained computer personnel whom I have

Consulted, searches of evidence from Compulers commonly require agents to or copy information from the computers and their components, or remove most or all computer items (computer hardware, computer software, and computer related documentation) to be processed later by a qualified computer expert in a laboratory or other controlled environment. This is almost always true because of

the following: a.

Computer storage devices can

store the equivalent of

of pages of information. Especially when the wants Lo conceal criminal evidence, he or she often stores it with deceptive file names. This reguires searching authorities to examine all the

t.housand.s

stored data to determine wheLher it is included in the warrant. This sorting process can take days or.weeks, depending on the volume of data sLored, and it wouId. be generally impossible to accomplish this

kind of data search on site. b.

Searching computer systems for criminal evidence is

a highly technical process reguiring expert skill and a properly conLrolled environmenL. The vast array of computer hardware and software available requires even computer experts to specialize in to know before a some systems and applications, so it is difficult search which expert should analyze the system and its data. The search

of a compuLer system is an exacting scientific procedure which is designed to protecL the integrity of the evidence and to recover even

116

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hidden, erased, compressed, protect.ed, or encr)r'pt,ed f i1es. since computer evidence is exLremely vulnerabre Lo t.ampering or destruction (which may be caused by mal-icious code or norma]

activities

of an operating system), the controlled environment of a laboratory is essential to its complete and accurate analysis. L7o. rn order to fu1Iy retrieve data from a computer system, the analyst needs all storage media as werl- as the computer. The analyst needs arr the system software (operating , systems or interfaces, and hardware drivers) and any applications software which may have been used to creat.e the data (whether stored on hard disk drives or on external media). L71-. In order to gain access to data from a computer system and

t.o fulry analyze t,hat data, an analyst may need to have access to

the following information or equipment: (a) s, encrlption keys, and other access devices that may be necessary to access the computer equipment; (b) documents or ot.her items demonstrating the presence or absence of computer software that. would al1ow others to

cont,rol the items, and presence or absence of security software designed to detect such malicious software,. (c) document.s or other items d.emonst.rating t.he attachment of oLher computer hardware or storage media; and (d) counter forensic programs and associated data that are designed to eliminate data. l'72. fn addition, a computer, its storage devices, peripherals, and Internet connection interface may be instrumenLalities of the

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Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 8 of 43 PageID #:143

crime (s) and are subject to seizure as such if Lhey contain contraband

or were used to carry out criminal activity'

vLll-.

Procedures To Be FolLowed In Searching Computers and Electronic Storage Devices.

L73. The warrant sought by this Application will not authorize the ,'seizure,, of computers and related media within the meaning of Rule 41(c) of the Federal Rules of Criminal Procedure. Rather the

warrant sought by t.his Application will authorize the removal of compuLers and related media so that they may be searched in a secure environmenL. where practicable, however, agents will image the computers and related media on-site-

L't4. With respect to t.he search of any computers or electronic sLorage devices seized from the locations identified in Attachment. A-1, B-1, C-1, D-1, E-1, and F-l- hereto, the search procedure of

electronic dat.a conLained in any such computer may include the following techniques (the following is a non-exclusive fiit, and the government may use oLher procedures thaL, Iike those listed below, minimize the review of information not within the list of items to be seized as set forth herein): examination of ,lI a.

\

of the data contained in such

compuLer hardware, computer software, and/or memory storage devices

to determine whether t.hat. data falls within the items to be seized as set forth herein;

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Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 9 of 43 PageID #:144

b.

searching for and attempting to recover any deleted,

hidden, or encrypted data to determine whether t.hat data falls within

the rist of items to be seized as set forth herein (any data that is encrypted and unreadable will not, be returned unless law enforcement personnel have determined that the data is not (1) an

instrumentality of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4) otherwiseunlawfullypossessed, or (5) evidence of the offenses specified above);

c.

surveying various

file

directories

and the

individual files they contain to determine whether they include data falling within the list of items to be seized as set forth herein; d.

opening or reading portions of files

in order to

determine whether their contents fall within the items to be seized

as set forth herein; e.

scanning storage areas to discover data falling

within the list of items to be seized as set' forth herein, to possibly recover any such recently deleted data, and Lo search for and recover deriberately hidden files falling within the list of items to be seized; an.d/or f.

performing key word searches through aII storage

media t.o determine whether occurrences

of language contained in

such

storage areas exj-st, that are }ikely to appear in the evidence described in At,tachments A-2 , B-2, C-2, D-2, E-2, and F-2. g.

Any computer systems and

removed from the premises

electronic st,orage devices

during the search wil-1 be returned to the

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Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 10 of 43 PageID #:145

premises within a reasonabte period of t.ime not to exceed.30 days,

or unless otherwise ordered by the Court.

rv.

coNcl.usroN 1,75

.

Based on

the above informat.ion, I respectfully submit t.hat

there is probable cause to believe that evidence, instrumentalities, and fruits of the Subject Offenses are 1ocated within t.he Subject Premises. By this affidavit and application, r request that the Court issue a search warrant authorizing the search of the Subject Premises f or the it.ems described in Attachments A-2, B-2, C-2, D-2,

E-2, and F-2. FURTHER AFFIANT SAYETH NOT.

Steven SpeciaT Agent

Federal Bureau of Investigation

Sworn to before me and subscribed in my presence

this 27th day of May,

201-6

es Magistrate Judge

t20

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ATTACHMENT A-1

DESCRIPTIONoFPREMISESToBESEARCHED Tl:.eofficelocatedattL1NorthLaSallestreet,Rooms04'chicago'Il1inois' which is the rioor.

city Hall office

a of Alderman DANIEL SOLIS' The office is behind

name and office that states "Committee on Zortrtrg." The office bears SOLIS's

nnmber, 304. The entrance to the office is depicted below:

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ATTACHMENT A.2

I.IST OF ITEMS TO BE SEIZED Evidence and instru.mentaij.ties concerning

rriolaiicn of Title 18,

United-

States Cod-e, Seciions 37L,666,1343, L346,1349, and 1951, as follo.rrs:

1.

Campaign financral records including financial d-onations, in-krnd

contributions and expenditure records, reports, ledgers and receipts;

2.

Information related to fundraising acti..zities including ments,

photographs, invitations, letters

or records of contributors and/or attendees at

fundraising events;

3.

Lists, spreadsheets or other records of potential or actual campaign

contributors including, but not limited to, contributors with potential matters before

the Chicago City Council or a representative body or committee thereof;

4.

Calendars, schedules and communications of staff ;

5.

Letters and correspondence concerning matters which have appeared

or may likely appear before the Chicago City Council or a representative body or committee thereof, including the Zoning Committee, actions Daniel Solis has taken on those matters, as well as benefits received by Daniel Solis from any other party;

6.

Credit card statements, bills, payment records/ledgers or receipts;

7.

Emplc).ee Faj/nrent recorci-s,

a- f, i.its 1099 c r'Lrl)..

tr

incl,rrie IF.S rel-orting dccumenis

su-ct,

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 13 of 43 PageID #:148

B.

Documents concerning occupancy of the Subject Premises (described

in Atiachment A.-1), such as u'uiJity and telephone bi,lis, mail enize1opes, or

a,ddresseci

correspondence; a"nd

9.

Computers, electronic devices and removal:le media siorage devices

ivhich may contain information reiaied- to the above items.

10.

With respect to any computer equipment or other electronic devices:

a.

s, eacryption keys, and other access devices that

may be necessary to access the computer equipment.

b-

Documents or other iterns demonstrating the presence or

absence of computer software

that would allow others to control the

items, and presence or absence of security software designed to detect such malicious software.

Documents or other items demonstrating the attachment of other computer hardware or storage media.

d. '

Counter forensic programs and associated data that are

designed to eliminate data.

11. Items in the paragraphs

above

that are stored in computer

including media capable of being read by a cornputer (such as exiernal cor:eputer hard driires, melriorjr .qricl..s, and ;ha:u

are

ca-Fa-bls

cf anal:,:i n;. :rei.ting,

media,

a-nd

iniernal

thumi: d-rives), and electroric



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Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 14 of 43 PageID #:149

electronic or magnetic computer impulses or data (such as cellular telephones and PDAs), shall be searched in accordance with tlne aitached Addendum.

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ADDENDUM TO ATTACHMENT A.2 Pui:suani io Ruie a1(eX2XB) of the Federal Bules of Criminal Procedure, ihis "r,rarrant a-uthonzes ihe remo,zal of el"ecironic siatage raedia and co;oying of electrcnicaliy sioi:ed- information fou-nd in the premrses described in A'ciachmen,c I!-1 so ihai ihe}, m2;' be revie-rrred in a secure en-rironm.ent foi: rnforma'cion coasisl:en,i vrith the ',rra::r'ani. That revie'w shall be conducied pursuan'c to the foliox,ing

pi'otocol:

The review of electronically stored information and electronic storage meclia removed from the premises described in Attachment A-1 may include the ioilowing techniques (the following is a non-exclusive list, and. the government may use other procedures that, like those listed below, minimize the review of information not within the list of items to be seized as set forth herein):

a'

examination of ali the d.ata contained in such computer hardware, computer software, and/or memory storage devices to determine whether that data falls within the items to be seized as set forth in Attachment A-2;

b.

searching for and attempting to recover any deleted, hidden, or encrypted data to determine whether that data falls within the list of items to be seized as set forth in Attachment A-2 (any data that is encrypted and unreadable will not be returned unless law enforcement personnel have determined that the data is not (1) an instrumentality of the offenses, (2) a fruit of the criminal activity, (B) contraband, (4) otherwise unlawfullypossessed, or (5) evidence of the offenses specified above);

surveying

file directories and the individual files they contain

to

determine whether they include data falling within the list of items to be seized as set forth in Attachment A-2; and d.

opening or reading portions of files, and performing key word searches of r'iles, in order to determine rvhether 'cheir contents fall rcithin ihe iterns 'uo be seized as se'c for'uh in Atta,climen.i A-2.

Tire gc.,rerr.rrr€l1i, :^ri]i r.eculn e.r:!t, elecircnrc si,crt,p,:e iescriJ;eC .ir .ar:t:-c,:rr,.,ent, ,ll- -1 rt,;i il_r,i n -! 3 C,:-.rS rl...t. 'l-1. i,r;: -1,^i ^-ilr--.i-..,.': P"f,: j-l':),.t r t:('' .r-r-{'a:a:itses

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removed eiectronic storage media contains coniraband

or

instrumentality of crime, or unLess otherwise ordered by the Court.

constitutes

an

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ATTACHMENT 8.1 DESCRIPTION OF PREMISES TO BE SEARCHED The office located

at

1645 South BIue Island Avenue, Chicago, Iilinois, which

is the 25ih Ward office for Alderma"n DANIEL SOLIS and the location of Citizens for Danny Solis and the 21thWard Reguiar Democratic Organi zation. The entr.ance

to the office located at 1645 South Biue Island Avenue is depicted in the attached photograph:

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r_':"a

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 19 of 43 PageID #:154

ATTACHMENT 8.2

LIST OF ITEMS TO BE SEIZED Evidence and instrumentalities concerning

violation of Title 18, United

,states cod-e, sections 371, 666, 1943, 1rB4G,lz4g, anri 1g51,

1.

a-s

follows:

Campaign financiai records including financial d-onations, in-kind-

contributions and expenditure records, reports, ledgers and receipts;

2-

Information related to fundraising activities including ments,

photographs, invitations, letters

or records of contributors and/or attendees at

fundraising events;

3.

Lists, spreadsheets or other records of potential or actual campaign

contributors including, but not limited to, contributors with potential matters before

the Chicago City Council or a representative body or committee thereof;

4.

Calendars, schedules and communications of staff ;

5.

Letters and correspondence concerning matters which have appeared

or may likely appear before the Chicago City Council or a representative body or committee thereof, includ.ing the Zoning Committee, actions Solis has taken on those matters, as well as benefits received by Daniel Solis from any other party;

6.

Credit card statements, bills, payment records/ledgers or receipts;

7.

Employee payrnent record.s, to include IRS reporting documents such

as iorms 1099 or rrlr2:

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 20 of 43 PageID #:155

8.

Documents concerning occupancy of the Subject Premises (cLescribed in

Attachment B-1), such as utility and teiephone biils, mail envelopes, or addressed correspondence; and

I'

Computers, etrecti:onic de',zices and remo..zable media storage

d-evrces

which ma-y contain information related to the abo.re items.

10.

With respect to any compuier equipment or oiher electronic devices:

a.

s, encrJ4ption keys, and other access devices that

may be necessary to access the computer equipment.

b.

Documents or other items demonstrating the presence or

absence of computer software

that would allow others to control the

items, and presence or absence of security software designed to detect such malicious software.

c.

Documents or other items demonstrating the attachment

of other computer hardware or storage media.

d.

counter forensic programs and associated data that are

designed to eliminate data.

11.

Items in the paragraphs above that are stored in computer media,

including media capable of being read by a computer (such as external

and"

internal

computer hard drives, memory sticks, and thumb drives), and electronic devices

ifhat are cairal:le of analirzing, cr:eating;, riisrtaying,

con-,zertinE,

cr

ira-nsrnitr,iup-

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 21 of 43 PageID #:156

electroni.c or magnetic computer impulses or data (such as cellular telephones

PDAs), shall be searched in accordance with the attached Addendum.

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ADDENDUM TO ATTACHMENT 8.2 Put:suant to Rule a1(e)(2XB) of the Federai Rules of Criminal procedure, th.is wa.i:rant authorizes the remo.ral of elecrronic storage media and copyrng cf elecci:onicaliy s'tored informaiicc fou::d in the premises described j-n Atl,a,chnei,rt B-_l sc i'iia''; tbey rne,y be rerzie-wed in a secure e&'/1i'oriment for informa-'bicn consis,uen.i ''riiLh the '/:'ra-ria-11t" That r'evie w sha-ll be co-ad-uc'ue ci i:u-r-span'r ic ihe folicwirip

prcbocol:

The revievr of electronicaliy s'uored infoi'matior and electronic stor.age media removed from the premises described in Attachment B-1 may inchde the ioilo-r,ring iechniques (the following is a non-exclusive list, and the government rnay use other procedures that, like those listed below, minimize the rerriew of information not v'zithin the }ist of items to be seizecl a-s set forth herein):

a.

examination of all the data contained in such computer hardware, computer software, and/or memory storage devices to determine whether that data falls within the items to be seized as set forth in AttachmentB-2;

b.

searching for and attempting to recover any deleted, hidden, or encrypted data to determine whether that data falls within the list of items to be seized as set forth in Attachment B-2 (any data that is encrypted and unreadable will not be returned unless law enforcement personnel have determined that the data is not (1) an instrumentality of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4) otherwise unlawfully possessed, or (5) evidence of the offenses specified above);

surveying file directories and the individual files they contain to determine whether they include data falling within the list of items to be seized as set forth in Attachment B-2: and d.

opening or reading portions of files, and performing l<ey word searches of files, in order to determine whether their contents fall within the items to be seized as set forth in "Aitachment B-2.

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ATTACHMENT C.l DESCRIPTION OF PR,EMISES TO BE SEARCHED The apartment located at 800 South Wells Street, lJnit 522, Chicago, Illinois.

The apartment is located within a multi-unit building known as River residence is located on the "RR" level of River

City. And

City.

address placard

The

with ,nit

number "522" is affixed to the wall adjacent to the entrance. The entrance to Unit

522 is a solid entrance door with a silver colored door knocking device attached.

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ATTACHMENT C-2

LIST OF ITEMS TO BE SEIZED Evidence and instrumentalities concerning

violation of Title 1g. United

states code, sections 371, 666, 1848, 1846, LB4g, and

. 1'

lgbl,

as follows:

Items reiating to DANIEL SOLIS's personal finances, loans

and

expenditures, to include:

a.

Books, records, journals or other records oforiginal entry;

b.

Ledgers and other records of assets, liabilities, or capital

balances;

c.

Records

of income or

expenses including invoices and

receipts;

d.

records oflessors or lessee;

e.

records of receipts or disbursements;

f.

ing information;

g.

bank statements, check s, or canceled checks;

h.

duplicate d.eposit tickets;

i. j.

bank reconciliations; books, certificates

of

deposit, money ord.ers, or

cashier's or official checks;

tr..

r'ecold,g of 1:ai,rcl| or er-,;;lclree

earlings;

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 25 of 43 PageID #:160

l.

records ofbartering activity such as exchanges ofproperty

or.services;

m.

financial statements or copies of tax returns;

n.

docurne,ts and items co,celning economic and other

benefits received by Daniel soris from any other party;

2'

Credit card statements, bills, payment records/ledgers or receipts;

3'

Documents concerning occupancy of the Subject Premises (described

in Attachment C-1), such as utility and telephone bills, mail envelopes, or addressed correspondence; and

4'

Computers, electronic devices and removable media storage devices

which may contain information rerated to the above items.

5'

With respect to any computer equipment or other electronic devices:

a.

s, encr5rption keys, and other access devices that

may be necessary to access the computer equipment.

b.

Documents or other items demonstrating the presence or

absence of computer software

that

would" allow others

to control the

items, and presence or absence of security software designed" to detect such malicious software.

Documents or other iterns demonstrating the attach*re,t o

f, o.i lir: r" co

ntp i,t c. L ir i,,i,d.,.i, a.i e

o:_. s t,o

r a p e ri: e c}

a-.

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 26 of 43 PageID #:161

d.

counter forensic programs and associated data that are

designed to eliminate data.

6.

Items

in the paragraphs above that are storecl in

computer

media, including media capable of being read b5, a computer (sucir as external and

internal computer hard drives, memory sticks, and thumb drives), and electronic devices

that are capable of

anaryzing, creating, displaying, converting, or

transmitting electronic or magnetic computer impulses or data (such as cellular telephones and PDAs), shall Addendum.

be searched" in

accordance

with the

attached

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 27 of 43 PageID #:162

Pursuant to Rule al(e)(2XB) of the Fecleral Rules of Crirninal pr.ocedure, this rva::rant authorizes the remorzal of electronic storage meclia and cop5ring of electronically stoled information for,rnd in the premises clescribe4 in Attachmen1 C-lso that they may be reviewed in il $lecure environment fcl. inforrnation with L'lie '"Varrant- TLrat re.rie.w shall be cr:nduc'i,ed pursualt to theconsistent foliov,,ing

protcc<;l:

The review of electronicall5, stored information and electronic stor.age me4ia removed from the premises describecl in Attachment C_1 ma5, include the iollowing techniques (the following is a non-exclusive list, and the governrnent may Llse other procedures that, iike those listed below, minimize the review of information not within the list of items to be seized as set forth herein): a.

examination of all the data contained in such computer hardware, computer software, and/or memory storage devices to determine whether that data falls within the items to be seized as set forth in Attachment C-2;

b.

searching for and attempting to recover any deleted, hidde,, or encrypted data to determine whether that data falls within the list of items to be seized as set forth in Attachment c-2 (any d"ata that is encrypted and unreadable will not be returned unless law enforcement personnel have determined that the data is not (1) an instrumentality of the offenses, (2) a fruit of the criminal activity, (B) contraband, (4) otherwise unlawfully possessed, or (5) evidence of the offenses .p".ifi.d above);

C.

d'

surveying file directories and the individual files they contain to determine whether they include data falling within the tist of items to be seized as set forth in Attachment C-2; and opening or reading portions of files, and performing key word. searches of files, in order to determine whether their contents falt within the iteins to ]:e seized as set, forth in Attachment C_2.

'Ii--te gc,,,'eL::r,.ei:t -,r,r:li rgi-,,1r.i,

._-,

.rj- elet.': ct,,iil ;iri-oriil-ge

ilr'C'!riiSst CCict',rl:i]i] ir,. rr,i.ia-CitlI:-C:.i i...]a,r,,1i1.,i;. ia) a:,-'' ' rj .-:l-'...ri-l .r.!.- i,c E;,-le 4,1 (c)i-j) cr, (3) :f ir..c ,iCcierr:_.,i lt'i,;ICl Oi

,"i:

edi

I..'

a

i.-1.

r'er:Lo1,'ed fi.,.1,:_.

ii:e

'.-'::-C':', -,--,:,,,,. . l. ,. .,....j .._. '...,.]. .:q.- 1..

aD ,l

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 28 of 43 PageID #:163

removed electronic storage media contains contraband instrumentality

or

of crime, o, unress otherwise ordered by the court.

constitutes

an

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 29 of 43 PageID #:164

ATTACHMENT D-l DESCRIPTION OF PREMISES TO BE SEARCHED The apartment located at 1135 South Delano Court, Unit 812 East, Chicago.

llliiiois.

The apartment is located within a multi-unit apartment complex knovrn as

Tlre Roosevelt Collection. As shown below, the numb er "BLZE" is shown next to the

entlance to the Subject Premises.

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 30 of 43 PageID #:165

ATTACHMENT D-2

LIST OF ITEMS TO BE SEIZED Euridence and

instrumentalities concerning violation

of Title 1g, Ulitecl

si,aies code, sections BT1, 666, 1z4B, ra46,l}4g, and 1g51, as follows:

1.

Items relating to DANIEL SOLIS'g personal finances, loans anrl

expenditures, to include

:

a.

Books, records, journals or other records oforiginal entry;

b.

Ledgers and other records of assets, liabilities, or capital

balances;

c.

Records

of income or

expenses including invoices and

receipts;

d.

records oflessors or lessee;

e.

records of receipts or disbursements;

f.

ing information, incruding

trial

balances or work

sheets adjusting, reclassifiring, closing, or reversing entries;

g.

bank statements, check s, or canceled checks;

h.

duplicate deposit tickets;

i. j"

bank reconciliations; books, certificates

of deposi,u, rllonej/ ord,ers, or

:asl,ier''s cr lfficia_i cLecLrr;

1...

:.,ec:i,,1-r,

:f pa..';:cii cr. eLiIlIc.).:: ear._,ii,r3;,..,;

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 31 of 43 PageID #:166

l.

records ofbartering activity such as exchanges ofpropertv

or services;

m.

financiai statements or copies of tax returns;

n.

documents and items concerning economic ancr otrrer

. 2'

benefits received by Daniel soris from any other party;

3'

Documents concerning occupancy of the Subject premises (described

Credit card statements, bills, payment records/ledgers or receipts;

in Attachment D-1), such as utility and telephone bills, mail envelopes, or addressed correspondence; and

4'

Computers, electronic devices and removable media storage devices

which may contain information related to the above items.

5'

With respect to any computer equipment or other electronic devices:

a.

s, encryption keys, and other access d.evices that

may be necessary to access the computer equipment.

b.

Documents or other items demonstrating the presence or

absence of computer software

that would alrow others to contror the

items, and presence or absence of security software designed to detect such malicious software.

c. :f

Docurnents or other items d,emonstrati*g the attachme,t

ci,her ccmputer harc vare cr storage n,ed-ia.

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 32 of 43 PageID #:167

d.

counter forensic programs and associated data that are

designed to eliminate data.

6"

Items

in the paragraphs above that are sior.ecl in comiruter

ileclia, including media capable of being read by a computer (such as externai a*cl inter:na} computer hard drives, memory sticks, and thumb drives), and electronic

clevices

that are capable of

analyzing, creating, displaying, converting, or

tlansmitting electronic or magnetic computer impulses or d.ata (such as cellular telephones and PDAs), shall Acldendum.

be searched in

accordance

with the attached

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 33 of 43 PageID #:168

ADDENDUM TO ATTACHMENT D.2 Pursuant to Rule 1(e)(2XB) of the Federal Rules of Criminal Procedure, this -warLant, authorizes the removal of eiectronic storage media and copying of eiect,.onicall5, 966r*6 information found in the premises described in Attachment D-1 so that, they may be revie,,ved in a secul"e environment for information consistent .r,il.ir the rvarlant. That revievr shall be conducted pursuant tc the foliowing irlotocol: The rerriew of electronically s'uored information and electronic storage media rernoved from the premises described in Attachment D-1 may include the following techniques (the foliowing is a non-exclusive list, and the government may use other plocedures that, like those listed below, minimize the review of information not rvithin the list of items to be seized as set forth herein): a.

examination of all the data contained in such computer hardware, computer softwilre, and/or memory storage devices to determine whether that data falls within the items to be seized as set forth in AttachmentD-2;

b.

searching for and attempting to recover any deleted, hidden, or encrypted data to determine whether that data falls within the list of items to be seized as set forth in Attachment D-2 (any data that is encrypted and unreadable will not be returned unless law enforcement personnel have determined that the data is not (1) an instrumentality of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4) otherwise unlawfully possessed, or (5) evidence of the offenses specified above);

C.

d.

surveying file directories and the individual files they contain to determine whether they include data falling within the list of items to be seized as set forth in Attachment D-2; and opening or reading portions of files, and performing key word sealches of files, in order to determine whether their contents fall rn,ithin the iiems to be seized as set forth in Attachrnent D-2.

'ILie Eo',rerrln:-ent ..trill retrr,:n ailjr eiect,. criic st,cra g.e nred-ia r'3riri.r reC ftin :,1-: ::r, ,r,;,.:l,l iei,rciiJ,.ed ii; r..t::ii,ii:,- l- D- 'l -,-,;..;i 3 . i-: cf lhe reil:c-,,a1 rur:i,.-r[.i:r. i;,.r -!'-,t r'c Eui.: ai(c)(2) ,:r l-e) :f rhe .f ',.Cie la,l E rii:r: ,:f rll iir lr r, P .--irr:, . r;,-,

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 34 of 43 PageID #:169

removed electronic storage media contains contraband or constitutes an instrumentality of crime, or unless otherwise ordered by the Court.

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 35 of 43 PageID #:170

ATTACHMItrNT E-l I]ESCRIPTION-OF' PR,EM:tSES TCI BE SMARCHE.!] 'L

l',e j,-',,i,,-!iie

ri''/3r.r1-.r--i-

s].lo',,,.+

,.:ril ]::._?c,.ir;=r

all

''f;ilF1,rt:-,_-

l'l:i:,'-zt:,, i-tlincii:. ir; ioc:iie,J

'f'Etn and ,ll::r-"'' lr;,_::,iill,,i

rn ilre frsL

ii,:rr.L

tl r

,,..i

r,.1,.;-s,1,i;i

J:elcrr, r,he sigil "Cc1;1:e.*'I'ar.t Ii,. Cl'.,a" liriiigs o.,e],"ilte fi:rsl, j-loo'.: .ii

i'Jeon iight,s ,-.ea-ding "ope1r," "lidassage," ancl "Facial" trrang

in

Lhe f:;ani, rr,rindorr,, cf

the business" The number "1052" appears over the entrance to the

business.

a

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 36 of 43 PageID #:171

ATTACHMENT E-2

LIST OF ITEMS TO BE SEIZED Evidence and instrui:rentalities concerning

s.iates code, sections

violation of Title 1g,

Uni,ied

sJl, 666, l}4z, 1846, lz4g, and lgb1, namely, i.tei's

evidencing visits

to the Subject Premises (as clefined in Attachment E-1) I:y Daniel solis and his comi:anions (to include Roberto caldero), to include the following items:

1.

Video surveillance equipment and recordings;

2'

Financial records, including receipts, checks, bank and savings an4

loan records of deposit, statements and other bank records, credit card statements, money orders, cashier's checks, books, cancelled checks, certificates of deposit, loan records, customer inform'ation, and income and expense summaries.

3'

Appointment books, calendars, client lists, details of services rendered,

the names of masseuses that a client utilizes, and other records of client visits, services rendered and information; and

4'

Computers, electronic devices and removable media storage devices

which may contain information related to the above items.

a

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 37 of 43 PageID #:172

Pursuant to Rule a1(eX2XB) of the Federal Rules of Criminal procedure, this authorizes the I'emo'za-l of electronic stora-ge media and copying of electrcnically siored infoi:n:a',,ion found in the pre:nises described in Ati;achment E-i so -bhat they ma5' be reviewed in a secure environmenL for information consistent 'wiih the war"rant. 'Ihat le.,,iev,z shall be conducted pursuani to the follorving protocol: -warran.-L

The review of electronically stored inforrnaiion and eiectronic storage media removed from the premises described in Attachment E-1 may include the following techniques (the following is a non-exclusive list, and the government may use other procedures that, like those tisted below, minimize the review of infbrmation not within the list of items to be seized as set forth herein): a.

examination of all the data contained in such computer hardware, computer software, and/or memory storage devices to determine whether that data falls within the items to be seized as set forth in AttachmentE-2;

b.

searching for and- attempting to recover any deleted., hidden, or encrypted data to determine whether that data falls within the 1ist of items to be seized as set forth in Attachment E-2 (any data that is encrypted and unreadable will not be returned unless law enforcement personnel have determined that the data is not (1) an instrumentality of the offenses, (2) a fruit of the criminal activiiR (B) contraband, (4) otherwise unlawfully possessed, or (5) evidence orihe offenses .p".iri.a above);

surveying file directories and the individual fites they contain to

determine whether they incrude data falring within the be seized as set forth in Attachment E-2; and

riit of items

to

opening or reading portions of files, and performing key word searches

d.

of file"s, in order to determine wheth"" ihui, contlnts fail within the iterns to be seized as set forth in A.ttachment E-2. 'l'l:, e

pl:rrris,:s pr-;-i,luani,

E

Ctief

ni:i,. e tt.t

les:ribei

r' I'rl.

i11

Jl,_,

rj c stcr a ge nr : Jiri i:e r.nc-,.,,:d frc rrr l;l,ie .r'i'u!.rirt E2 3'3 c,a-,,s cl .it,: t:e-,::rrc-.,a.l tinies,,,. .li: l1:icr:rl }ri:: -_f Cri:irri.r:.i 11::e :r,li€. rir::

?,ri'r;

el-3c.t,.ac

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 38 of 43 PageID #:173

ia 'l

removed electronic storage media contains contraband or constitutes an instrumentality of crime, or unless otherwise ordered by the Court.

i?

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 39 of 43 PageID #:174

ATTACHMENT F-1

DESCRIPTIONoFPR0PERTYToBESEARCHED The cellu-lar 'celephone bearing the numb er (3LZ) 2OB-A292, International

Mobile subscriber Identity Number

('IMSI")

310410840352309,

a

cellu-lar

to telephone on the system operatecl by the service provider AT&T', subscribed

"Daniel So1is, 6148 Rob Roy Dr., Oak Forest, IL 60452'"

1,

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 40 of 43 PageID #:175

ATTACHMENT F-2

LIST OF ITEMS TO BE SEIZED Erridence and instru.menia,liti.es concerning viola.tion S.i,a,tes Code. Seci;ions 37-1,,666,

of Tj.tle 18, United-

1343, 1346, 1349, and 1951, as follows:

Items indicating use or control of the cell phone, including contacis

1.

lists, instant messaging logs, call history, and communications (and ihe associated.

data

with the foregoing, such as date and time);

Z-

Comrnunications, including voicemails and text messages, relating to

the Subject Offenses as d"escribed in the affidavit of Special Agent Steven Noldin

submitted

in of the

application

for search warrant, including

communications, voicemails and text messages concerning the following:

a.

campaign financial records including financial donations, in-

kind. contributions and expenditure records, reports, ledgers and receipts;

b.

information related to fundraising activities including

and/or ments, photographs, invitations, letters or record"s of contributors attendees at fundraising events;

c.

lists, spreadsheets or other records of potential or

actual

potential campaign contributors including, but not limited to, contributors with

matters befor.e i1ir=re:'i'.

,uhe Chicago Cii5z Courncil

or a represen'raiive body or commitiee

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 41 of 43 PageID #:176

e.

communications concerning matters which have appeared or

may likely appear before the Chicago City Council or a representative body

or

committee thereof, including tne Zunrrrg Committee, as well as benefits received by

Daniel Solis from any other party;

.

f.

credit card statements, bi}ls, payment records/ledgers or

g.

employee payment records, to include IRS reporting d.ocuments

receipts;

such as forms 1099 or W2;

3.

Dig-ital photographs of co-conspirators

Offenses as described

or relating to the

Subject

in the affidavit of Special Agent Steven Noldin submitted in

of the application for search warrant; and

4.

Items indicating the geographic location of the cell phone and at a

particular time (e.g., location integrated into an image or video sent via email or

text

message

to include both metadata and the physical location displayed in an

image or video).

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 42 of 43 PageID #:177

ADDENDUM TO ATTACHMENT F-2 Pursuani to Rule 1(e)(2)(B) of the Federai RuLes of Criminal Procedure, this --;,zanant authorizes ihe remo.ra-l of electroni.c storage medi,a and copying of elec'ti:onica.!.1y storer} information fcund in ihe prernises desclibed irl Attachmeni F-1 sc 'blrat 'chey ria5r be reozielved in a secure environn:.ent foi infor'.,na'cion consi,steni .wi';h tite ,r,rarra-nt. Thai revie:r,, shall be conCucted- pu-i:st-lant to the foli,owing pro'cocoi:

The review of electronicallS, stored, information and- electronic storage media removed from the premises described in Attachment F-l may include the following techniques (the following is a non-exclusive list, and the government may Llse other procedures that, like those listed beLow, minj.mize the review of information not within the list of items to be seized as set forth herein): a.

b.

examination of all the data contained in such computer hardware, computer software, . and/or memory Storage devices to determine whether that data falls within the items to be seized as set forth in Attachment F-2; searching for and attempting to recover any deleted, hidden, or encrypted data to determine whether that data falls within the list of items to be seized as set forth in Attachment F-2 (any data that is encrypted and unreadable will not be returned unless law enforcement personnel have determined that the data is not (1) an instrumentality of the offenses, (2) a fruit of the criminal activity, (3) contraband, (4) otherwise unlawfully possessed, or (5) evidence of the offenses specified above);

surveying file directories and the individual files they contain to determine whether they include data falling within the list of items to be seized as set forth in Attachrnent F-2; and

d.

opening or reading portions of files, and performing key word searches of files, in order to determine whether their contents iall within the items to be seized as set forth in Atiachment F-2.

Tli.- pc,r:r:rry1,:i-tt ll,i.] ret'-r:'rtr z-fr.;,, e1ec,,rcr-ric s'icrag-e n,.eC.ia 1"1,1n,,r-'i frcrr :l'e ',;.iifii1;i 3C Ca:'i' c'l the ie jr-ic:rEr,l t-r-',Less, I, -,:)r-:!ii:te: descr'.Led llr ,{ir,ochr:€n: ir' l 'P,''-^re,:lrrt i:. tli': 2.11,)(?) :, ill -.,i --li, F: j:ra. P.i.ri'.r ',1 t--t-ir: ,:r:.1 1,i-rr.'l-:ue-r:.. r: P.,:!e

J

a

Case: 1:16-mc-00261 Document #: 1-3 Filed: 05/27/16 Page 43 of 43 PageID #:178

removed electronic storage media contains contraband instrumentality of crime, or unress otherwise ordered

or

by the court.

constitutes an