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United States v. Bridges, 344 F.3d 1010 (9th Cir. 2003)
There was probable cause to search the defendant’s office based on the information in the application that documented his efforts to provide illegal tax advice to various clients, including undercover agents. The search warrant in this case, however, was overly broad. It listed, among the items to be seized, “All records . . . documents . . . computer hardware and software . . .” Though this list was detailed, it was too expansive. There was simply no boundary to what could be seized. In addition, the warrant did not specify the crimes that were the subject of the search (nor did the warrant incorporate the application) so there was no limitation in that manner. Though the application was detailed, the warrant was not. All evidence should have been suppressed. (No discussion of Leon).
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