Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 1 of 65 EXHIBIT Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 2 of 65 A0 93 Rev 1 1 13 Search and Seizure Warrant UNITED STATES DISTRICT COURT for the District of Maryland In the Matter of the Search of Brie y describe the property to be searched or identify the person by name and address 16-0 19 7sz Premises at Lillian Lane Laurei MD 20723 and the persons 0 Shaun Bridges Ariana Esposito SEARCH AND SEIZURE WARRANT To Any authorized law enforcement of cer An application by a federal law enforcement of cer or an attorney for the government requests the search of the following person or property located in the District of Maryland Baltimore Division identify the person or describe the property to be searched and give its location See Attachment A2 I nd that or any recorded testimony establish probable cause to search and seize the person or property described above and that such search will reveal tdentz z the person or describe the property to be seized See Attachment 32 YOU ARE COMMANDED to execute this warrant on or before 7 1201 no to exceed 14 days 3 in the daytime 6 00 am to 10 00 pm Cl at any time in the day or night becausi good cause has been established Unless delayed notice is authorized below you must give a copy of the warrant and a receipt for the property taken to the person from whom or from whose premises the property was taken or leave the copy and receipt at the place where the property was taken The of cer executing this warrant or an of cer present during the execution of the warrant must prepare an inventory as required by law and return this warrant and inventory to Timothy J Sullivan Magistrate Judge f United States Magistrate Judge at Pursuant to l8 U S C 3103a b I nd that immediate noti cation may have an adverse result listed in 18 U S C 2705 except for delay of trial and authorize the of cer executing this warrant to delay notice to the person who or whose property will be searched or seized check the appropriate box for 10 days nozto exceed 30 3 until the facts justifying the later speci c date of Date and time issued qu Lol I a PM Judge is City and state Baitimore MD Timothy J ullivan Magistrate Judge Printed name and title Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 3 of 65 - 16- 019 7TJS A0 93 Rev 11 13 Search and Seizure Warrant Page 2 Return Case No Date and time warrant executed Cepy of warrant and inventory left with Inventory made in the presence of Inventory of the property taken and name of any person s seized Certification I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the designated judge Date Executing o r cer s signature Printed name and title Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 4 of 65 A0 93 Rev 01 09 Search and Seizure Warrant UNITED STATES DISTRICT COURT for the District of Maryland In the Matter of the Search of Brie y describe the property to be searched or identi z the person by name and address Case NO SEARCH OF INFORMATION ASSOCIATED WITH TJS STORED AT PREMISES CONTROLLED BY MICROSOFT SEARCH AND SEIZURE WARRANT To Any authorized law enforcement of cer An application by a federal law enforcement of cer or an attorney for the government requests the search of the following person or property located in the Western District of Washington identify the person or describe the property to be searched and give its location See Attachment Property to be Searched attached hereto and incorporated by reference The person or property to be searched described above is believed to conceal identify the person or describe the property to be seized Items as described in Attachment B attached hereto I nd that the 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 February 6 2016 not to exceed 10 days at in the daytime 6 00 am to 10 pm at any time in the day or night as I nd reasonable cause has been established Unless delayed notice is authorized beiow you must give a copy of the warrant and a receipt for the property taken to the person from whom or from whose premises the property was taken or leave the copy and receipt at the place where the property was taken The of cer executing this warrant or an of cer present during the execution of the warrant must prepare an inventory as required by iaw and return this warrant and inventory to United States Magistrate Judge Dutv maulstrate Judue name I nd that immediate noti cation may have an adverse result listed in 18 U S C 2705 except for delay of trial and authorize the of cer executing this warrant to deiay notice to the person who or whose property will be 863113th or seized check the appropriate box Elfor days not to exceed 30 Duntil the facts justifying the later speci c date of Date and time issued Z h ZOI I0 I Judge signature City and state Baltimore MD Honorable Timothy J Sullivan Printed name and title Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page Rev 01109 Search and Seizure Warrant Page 2 Return Case No Date and time warrant executed Copy of warrant and inventory left with Inventory made in the presence of Inventory of the properw taken and name of any person s seized Certi cation I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the designated judge Date Executing of cer 3 signature Printed name and title Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 6 of 65 A0 106 Rev 04 10 Application for a Search Warrant UNITED STATES DISTRICT COURT for the District of Maryland In the Matter of the Search of Brie y describe the property to be searched or identz the person by name and address Case NO 1 6 1 8 SEARCH OF INFORMATION ASSOCIATED - 0 9 JS STORED AT PREMISES CONTROLLED BY MICROSOFT APPLICATION FOR A SEARCH WARRANT I a federal law enforcement of cer 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 identy j the person or describe the 1 - prggeeBAIfac Searched attached hereto and incorporated by reference located in the Western District of Washington there is now concealed identify the person or describe the property to be seized Items as described in Attachment B attached hereto The basis for the search under Fed R Crim P 41 c is check one or more Erevidence of a crime if contraband fruits of crime or other items illegally possessed if 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 I The search is related to a violation of Code Section Offense Description 18 U S C 641 theft of government property 18 U S C 1956 money iaundering 18 U S C 1343 wire fraud The application is based on these facts See attached Af davit of Gambaryan Approved as to B Evans AUSA HAUN PIN ATTY EVANS El Continued on the attached sheet if Delayed notice of days give exact ending date if more than 30 days 05 31 2016 is requested under 18 U S C 3103a the basis of which is set forth on the Applicant is signature Printed name and title Sworn to before me and signed in my presence Datej l WHW 7ft 10110 MW Judgei sqignature City and state Baltimore MD Honorable Timothy J Sultivan Printed name and title Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 7 of 65 A0 106 Rev 04l10 Application for a Search Warrant UNITED STATES DISTRICT COURT for the District of Maryland In the Matter of the Search of rcgibe the prgperot to baseggcherj' ori enti person name an a res Case No The premises located at-l Lillian LaneTJS Laurel MD 20723 and the persons of Shaun Bridges and 3 Ariana Esposito APPLICATION FOR A SEARCH WARRANT I a federal iaw enforcement of cer 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 identify the person or describe the preperty to be searched and give its location See Attachment A2 to Af idavit in Support of Search Warrant located in the District of Maryland Baltimore Division there is now concealed identi l the person or describe the property to be seized See Attachment 132 to Af davit in Support of Search Warrant The basis for the search under Fed R Crim P 41 c is check one or more Elf evidence of a crime Moontraband fruits of crime or other items illegally possessed Erproperty designed for use intended for use or used in a crime 3 a person to be arrested or a person who is unlawfully restrained The search is related to a violation of Code Section Offense Description 18 U S C 641 Theft of Government Property 18 U S C 1343 Wire Fraud 18 U S C 1956 8 922 9 Money Laundering Firearms Violations The application is based on these facts See Af davit in Support of Search Warrant Continued on the attached sheet El Delayed notice of 10 days give exact ending date if more than 30 days is requested under 18 U S C 3103a the basis of which is set forth on the attached sheet Applicant Signature gTaa'eaabaryaa sectarian taster Printed name and title Sworn to before me and signed in my presence 13$ me 72 20 Judge 54 htgnatw'e City and state Baltimore MD Timothy J Sullivan Magistrate Judge Printed name and title headquartered at One Microsoft Way Redmond WA 98052 6399 relating to the email address Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 8 of 65 16-0197sz 16 019aws AFFIDAVIT IN SUPPORT OF APPLICATION FOR SEARCH WARRAN TS I Tigran Gambaryan being rst duly sworn hereby depose and state as follows INTRODUCTION 1 I am a Special Agent with the Criminal Investigation Division of the Internal Revenue Service IRS-CI in the Northern District of California and have been since 201 i I am currently detailed to the IRS Cyber Crimes Unit CCU and the National Cyber Investigative Joint Task Force NCIJTF in Washington DC Prior to my employment I was as an auditor for Califomia s Franchise Tax Board where I investigated abusive tax shelters My training and experience includes but is not limited to investigations involving money laundering white collar fraud public corruption organized crime and violations of the Bank Secrecy Act and tax code Ihave developed a Specialty in cyber and digital currency crimes 2 I am an investigative or law enforcement officer of the United States within the meaning of Title 18 United State Code Section 2510 7 that is an of cer of the United States who is empowered by law to conduct investigations of and to make arrests for violations of federal law 3 I make this af davit in support of two separate warrants for different purposes rst I submit this affidavit in support of an application for a search warrant for certain records I controlled by the electronic communications service provider Microsoft Corporation Microsoft branstein gustaf@outlook com As set forth herein there is probable cause to believe that the records and information contained in this email account further described in Attachment A contain evidence instrumentalities contraband and or fruits of violations of 18 U S C 1343 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 9 of 65 wire fraud l8 U S C 1956 money laundering and or 18 U S C 641 theft of government property as further described in Attachment B Second this af davit is also submitted in support of an application for a search warrant for the residence of former Secret Service Agent Shaun Bridges and his wife Ariana Esposito located at - Lillian Lane in Laurel Maryland hereinafter as well as any electronic devices or evidence found in the PREMISES and or on the persons of Bridges and or Esposito A As set forth herein there is probable cause to believe that the locations further described in Attachment A2 contain evidence instrumentalities contraband and or fruits of the same violations identi ed above in this paragraph and further described in Attachment B2 as well as violation of 18 U S C 922 g rearms violations 4 The facts and information contained in this af davit are based on my'personal knowledge as well as observations of other law enforcement of cials involved in this investigation All observations that were not personally made by me were related to me by the persons who made them or by representatives of those persons This af davit does not contain each and every fact known to the government but only those necessary to support a finding of probable cause 5 I have set forth facts that I consider are suf cient to establish probable cause to believe that the locations described in Attachments A and A2 will contain evidence and or instrumentalities of violations of 18 U S C 1343 Wire Fraud 641 Theft of Government Funds 1956 Money Laundering and or 18 U S C 922 g Firearms Violations This af davit is intended to show merely that there is suf cient probable cause for the requested - _warrants and does not setforth all of myknowledgeaboutthismatter - _a r WNW and one'di's tfict'tliat contains abourt of competent Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 10 of 65 JURISDICTION 6 This af davit is made in support of an application for a search warrant pursuant to 18 U S C 2703 a 2703 b 1 A and 2703 c 1 A to require Microsoft to disclose to the United States records and other information pertaining to the subscriber s and or customer s associated with the email account branstein gustaf@outlook com including the contents of communications 7 This court has jurisdiction to issue the requested warrant seeking records and information from Microsoft because it is a court of competent jurisdiction as de ned by 18 U S C 2711 Under Section 2711 3 A i a court of competent jurisdiction is a district court of the United States that has jurisdiction over the offense being investigated 1 As discussed below although former Secret Service Agent Shaun Bridges was prosecuted and sentenced in the Northern District of California for obstruction of justice and money laundering stemming from his theftofbitcoins during the course of his participation in a federal criminal investigation there is a new investigation into additional and as of yet uncharged criminal conduct for whichjurisdiction may lie in either the District of Maryland and the Northern District of California and agents on both coasts are working'on the instant investigation 8 This af davit is also made in support of an application for a search warrant under Federal Rule of Criminal Procedure 41 to search the PREMISES and the persons of Shaun Bridges For these reasons a court in the Northern District of California would also be a court of competent jurisdiction from which to seek a warrant for the electronic records In my training jurisdiction In this case given that a search warrant is being sought for physical premises and items physically located in the District of Maryland I seek the warrant for the electronic records out of Maryland in the interests of a conservation of judicial and investigative resources 3 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 11 of 65 and his wife Ariana Esposito for evidence instrumentalities contraband and or fruits of violations of 18 U S C 922 g rearms violations and or 18 U S C 1343 wire fraud 18 U S C 1956 money laundering and or '18 U S C 64l theft of government property on things such as cellulartelephones thumb drives etc as further described in Attachment B2 Since the PREMISES are located in Maryland as are the persons of Bridges and Esposito the District of Maryland has jurisdiction to issue a search warrant authorizing the requested search warrant BITCOIN BACKGROUND 9 Bitcoin is a form of decentralized convertible virtual currency that exists through the use of an online decentralized ledger system While Bitcoin mainly exists as an intemet-based form of currency it is possible to print out the necessary information and exchange Bitcoin via physical medium The currency is not issued by any government bank or company but rather is generated and controlled through computer software operating via a decentralized network To acquire bitcoins a typical user will purchase them from a Bitcoin seller or exchanger It is also possible to mine bitcoin by verifying other users transactions Bitcoin isjust one form of digital currency there are a signi cant number of other varieties of digital currency lO Bitcoin exchangers typically accept payments of at currency currency which derives its value from government regulation or law or other convertible virtual currencies in order to obtain bitcoins When a user wishes to purchase bitcoins from an exchanger the user will typically send payment in the form of at or other convertible virtual currency to an exehanger usually via wire or ACH for the corresponding number of bitcoins based on a uctuating exchange rate The exchanger often for a commission will then typically attempt to broker the purchase 4 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 12 of 65 with another user of the exchange that is trying to sell bitcoins or in some instances will act as the seller itself If the exchanger can place a buyer with a seller then the transaction can be completed 11 When a user acquires bitcoins the bitcoins are sent to the user s Bitcoin address This is somewhat analogous to a bank account number which is comprised of a case-sensitive string of letters and numbers amounting to atotal of 26 to 35 characters The user can then conduct transactions with other Bitcoin users by transferring bitcoins to their Bitcoin addresses via the internet 12 Little to no personally identi able information about the payer or payee is transmitted in a Bitcoin transaction Bitcoin transactions occur using a public key and a private key A public key is used to receive bitcoins and a private key is used to allow withdrawals from a Bitcoin address Only the Bitcoin address of the receiving party and the sender s private key are needed to complete the transaction which by themselves rarely re ect any identifying information 13 All Bitcoin transactions are recorded on what is known as the block chain Block chain is essentially a distributed public ledger that keeps track of all Bitcoin transactions incoming and outgoing and updates approximately six times per hour The block chain records every Bitcoin address that has ever received a bitcoin and maintains records of every transaction and all the known balances for each Bitcoin address 14 Digital currencies including Bitcoin have many known legitimate uses However much like cash bitcoins can be used to facilitate illicit transactions and to launder criminal um -- -_proceeds -given- the- ease with which they can be__used tohmove moneys demonstrated herein however in some circumstances bitcoin payments may be traced to accounts at traditional nancial institutions using the block chain 5 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 13 of 65 SAN FRANCISCO PROSECTION 0F CORRUPT FEDERAL AGENTS 15 Beginning in 2012 the government had multiple investigations into the Silk Road marketplace an underground black market that allowed vendors and buyers to conduct illegal transactions over the internet One of these investigations was conducted in the Southern District of New York the other investigation was conducted out of Baltimore in the District of Maryland Shaun Bridges former Special Agent for the US Secret Service US SS Baltimore Field Office and Carl Force former Special Agent for the DEA BaltimOre eld officer were assigned to the Baltimore investigation and were not part of the New York investigation The New York and Baltimore investigations were conducted independently of each other 16 In 2012 Bridges was assigned to and had signi cant responsibilities related to the Baltimore Division s Silk Road investigation In this capacity Bridges was the computer forensics and technical expert on the Baltimore Silk Road Task Force In his capacity as a member of the Baltimore Silk Road Task Force Bridges had signi cant exposure to and developed expertise in the digital currency known as Bitcoin My investigation has also revealed that he developed expertise in anonymizing tools such as TOR The Onion Router and mixers and tumblers to be discussed later in this af davit 17 In 2012 former DEA Special Agent Carl Force also had significant responsibilities related to the Baltimore Division s Silk Road investigation In fact Force was the lead undercover federal agent in communication with Ross Ulbricht who was later convicted in the SDNY of running the Silk Road Case Document 137-2 Filed 06 30 16 Page 14 of 65 18 Bridges and Force abused their positions as federal agents and engaged in a scheme to defraud a variety of third parties the public and the government for their own nancial enrichment On or about March 17 2015 then-Special Agent Bridges became the target of a criminal investigation in the Northern District of California in connection with the Silk Road investigation He was placed on administrative leave and then resigned the following day March 18 On March 25 2015 Bridges was charged with wire fraud and money I laundering stemming from his theft of bitcoins from the Silk Road investigation by the United States Attorney s Of ce for the Northern District of California NDCA On June 15 2015 Bridges signed an agreement to plead guilty to money laundering and obstruction of justice in the US District Court for the NDCA On August 1 2015 Bridges pleaded guilty to money laundering and obstruction of justice On December 7 2015 Bridges was sentenced to 71 months incarceration three years supervised release and $1 127 275 80 in forfeiture and restitution Bridges has been out of custody on court ordered conditions of release since March 2015 The government has moved for his remand at his plea and sentencing Bridges is scheduled to self surrender at FCI Berlin on January 29 2016 19 Like Bridges Force also abused his position as a federal agent in a wide variety of ways for his own nancial enrichment Force was also a target of a federal investigation in the Northern District of California in connection with the Silk Road investigation Like Bridges Force was charged with federal offenses including extortion money laundering and wire fraud in the NDCA On July 1 2015 Force pleaded guilty to these offenses in the NDCA and was sentenced inchtober 201 5-to a a term ofsupervisedrelease and restitution and forfeiture Unlike Bridges Force has been in continuous federal custody since his arrest in Spring 2015 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 15 of 65 NOVEMBER 2014 BITSTANIP SEIZURE 20 The initial focus of the NDCA corruption ' investigation regarding the Baltimore Silk Road Task Force was Carl Force By May 2014 the NDCA investigative and prosecutorial team was aware that Force had approximately $200 000 worth of bitcoins sitting in an account at Bitstamp a digital currency exchange based in Slovenia and the UK Given the ongoing NDCA criminal investigation the government and Force through his attorneys entered a Written agreement to permit Bitstamp to freeze Force s bitcoins pending resolution of the government s investigation of Force Bitstarnp did so The expectation was that in the event the NDCA case proved those funds were tied to criminal conduct by Force and represented criminal proceeds the government would move to have them seized and forfeited 21 No later than summer of 2014 Bridges was aware of the government s investigation into Carl Force 22 In November 2014 the US Attorney s Office for the District of Maryland working with then Special Agent Bridges and with another member of the Baltimore Silk Road Task Force sought and obtained a seizure warrant out of the District of Maryland for following property at Bitstarnp hereinafter the November Bitstamp warrant 1 cash 2 funds in a bank account and 3 16066488 bitcoins from various Bitstamp accounts The affidavit in support of the warrant claimed that certain Bitstamp account owners did not supply basic account holder information by identifying their name address phone number and instead only supplied email addresses Bridges was the af ant on the warrant and executed it against Bitstamp on or about 23 At the time of the execution of the seizure warrant the bitcoins at issue in the November Bitstamp warrant alone were worth approximately $600 000 This figure represents Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 16 of 65 the value on November 18 2014 when the bitcoin rate was approximately $372 3 77 US Dollars per bitcoin multiplied by 1606 6497 24 Among the Bitstamp customers accounts that were seized pursuant to the warrant was the account of former DEA agent Carl Force which contained approximately $200 000 worth of bitcoins the same funds that the NDCA and Force s defense attorneys had agreed in writing would be frozen by Bitstamp pending the outcome of the NDCA criminal investigation Although there were approximately 5072 Bitstarnp email addresses associated with accounts that were the subject of the seizure warrant most of those accounts contained very nominal amounts and funds in Force 5 Bitstamp account represented by far the largest portion of funds at issue in the November Bitstamp warrant and approximately twenty ve percent of the total amount of bitcoin seized 25 On approximately December 3 2014 Bitstarnp complied with the November Bitstamp seizure warrant and sent the bitcoins to the bitcoin address XthP7NcecDbr5jj9 hereafter referred to as the Sij wallet which based on my understanding of the bitcoin protocol was a wallet created by Bridges as the af ant on the warrant This digital wallet created to hold the forfeited funds contains the wallet address or identification ending in VSjj9 and a discreet privacy key which was established to protect the newly created wallet from theft or intrusion In order to transfer bitcoins out of the wallet the private key is required Bridges saved this information containing the wallet identi cation and private key associated with the Bitstamp digital wallet to a compact disc CD It was determined through interviews of personnel that Bridges was the only Baltimore Agent that had the expertise to create the private key for the seizure wallet Additionally a review of evidence inventory documents show that Bridges secured the CD containing the private key on December 2 2014 No other personnel is listed on the inventory documents as accessing the CD from the time Bridges wasnaeaverea iif' December 2015 described further below Once saved to a CD Bridges entered it into evidence and secured in the Baltimore Field Of ce evidence vault However based on my training 9 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 17 of 65 and experience in digital currency cases know that even though this CD was logged into evidence Bridges could have made duplicate CDs containing the private key data required to transfer the bitcoins out of the Bitstamp wallet Importantly no one at Bitstamp would have had the private key needed to transfer the bitcoin out of the wallet 26 Meanwhile upon being served with the November Bitstamp warrant Bitstamp contacted the prosecutors and agents in NDCA case and apprised them of the District of Maryland s seizure warrant a seizure warrant which had not been shared with the government prosecutors or agents in NDCA or known tothe NDCA investigative team 27 By Fall 2015 various Bitstamp account owners whose accounts were the subject of the November Bitstamp warrant disputed the legality of that warrant Subsequently pursuant to a court order dated September 11 2105 Case No in the US District Court for the District of Maryland the was directed to return 125 3 8885781 bitcoins worth approximately $30 616 69 at the time of the order to Bitstamp for reimbursement to the affected Bitstamp clients Separately as part of his plea agreement Force agreed to administratively forfeit the approximately $200 000 of the seizure that represented his Bitstamp account BRIDGES HAD ACCESS TO THE BITCOINS SEIZED PURSUANT TO THE NOVEMBER BITSTAIVIP WARRANT AFTER HE RESIGNED AND WAS CHARGED WITH CRINIES 28 The corruption investigation initially focused on Car Force However due to certain facts and the government s analysis of the blockchain for various bitcoin transactions at issue in that case the NDCA investigation ultimately expanded to include other s on the Baltimore Silk Road task force including Bridges 29 In fact by late March 2015 Bridges was charged with a variety of crimes alongside Force including obstruction money laundering and wire fraudfln to 7 i I having used a cooperating witness login and password credentials to access various Silk Road vendors accounts and transfer bitcoins out of those wallets and into a wallet that he controlled 10 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 18 of 65 Ultimately Bridges liquidated those funds into US dollars into a personal account that he controlled In other words Bridges stole the lDdS out of the various vendors accounts made it appear as if the cooperating witness had done so and then transferred them to an offshore digital currency exchange 1n Japan Mt Gox Between March and May 2013 those funds were liquidated from Mt Gox to an account Bridges had set up with Fidelity 1n the US 1n the name of Quantum LLC a shell company Bridges had established for the purpose of effectuatin his fraud Two days after his last withdrawal from Mt Gox Bridges actually served as the afflant on a separate seizure warrant directedat Mt Gox - A 30 Initially Bridges indicated a desire to self-surrender and to cooperate with the government in its investigation into the Silk Road Task Force However Bridges was untruthful in his early interactions with the NDCA investigators and prosecutors and as a result he unusable as a cooperator Therefore in April 2015 the government and Bridges lawyer set about plea discussions and a plea was nalized in or about late June 2015 31 Meanwhile on or about April 8 2015 the Asset Forfeiture Branch of the US Secret Service contacted the NDCA team and alerted them that former-Special Agent Bridges had access to the private key of the wallet associated with the November Bitstarnp seizure namely the wallet ending in Sjj9 NDCA having had no role in the November seizure warrant and having had no controi over the fruits or diSposition of that warrant which at that point was subject to a valid federal court order - was not in a position to undo the seizure However on April 8 2015 it advised the Asset Forfeiture Branch of the need to move the funds out of the existing 5ij wallet to which Bridges still had access and into another new wallet to which Bridges did not have access The con rmed that it would do so 32 The matter was left-to the Baltimore Division and the US SS Asset Forfeiture I branch to 66i 1 1etet amdv from the Wallet-over which Bridgesmliaduacc'e-SS f6 a Ew Wall foxfei which he did not have control Unfortunately the failed to effectuate this move Thus despite that Bridges had been charged in a criminal case for stealing bitcoin and transferring it to 11 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 19 of 65 his own personal account and was in the process of negotiating a guilty plea for that conduct Bridges retained his ability to access yet other funds the funds at issue in the November Bitstarnp seizure THEFT OF THE GOVERNMENT FUNDS FROM THE NOVENIBER WARRANT 33 As stated above various Bitstamp account owners disputed the legality of the November Bitstamp seizure on which Bridges had served as the af ant Pursuant to a court order Case No 14-2651 SAG in the US District Court for the District of Maryland dated September 11 2015 the was directed to return 125 38885781 bitcoins to Bitstamp for reimbursement to the affected Bitstamp clients On December 14 2015 when the attempted to transfer these bitcoins back to Bitstamp the discovered that the total amount of bitcoins 16066497 in the wallet ending in 5jj9 and established by Bridges had been moved without authorization to another wallet with the address of hereinafter h8D5 The records reflect that the bitcoinswere moved and thus stolen on or about July 28 2015 This theft occurred after Bridges has signed a plea agreement with the government pleading guilty to the theft of bitcoins 34 To date the investigation has revealed that Bridges was the only individual known to have possessed and or have had access to the private key needed to move the bitcoins that were the subject of the November Bitstamp seizure out of the wallet Although it is possible that other government employees had such access at present the only individual that is conclusively known to have access was Bridges As stated below approximately one dozen other employees have been interviewed and reported that they did not have such access 12 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 20 of 65 35 The NDCA investigative and prosecutorial team was alerted to this theft on or about December 15 2015 Based on this information I Conducted a blockchain analysis of the 5jj9 wallet the recipient address for the funds that Bridges originally seized from Bitstamp pursuant to the November Bitstarnp warrant Based on this analysis on July 28 2015 at 2 24 UTS the entire balance of the 5ij wallet or 1 606 6497 bitcein was sent to the h8D5 address I linked h8D5 to a bitcoin exchange through tools such as WalletExplorer cem WalletExplorer com is a clustering tool that allows for open-sourced search of the bitcoin bloekchain WalletExplorer com also detects when a bitcoin user deposits or withdraws bitcoins through certain services such as bitcoin exchanges bitcoin payment processors bitcoin mining pools or dark web underground marketplaces 36 Whoever established the h8D5 electronic wallet used an account at an unregistered bitcoin exchanger that operates outside the United States i know based on my training and experience that operates without appropriate anti-money laundering and know your customer policies of their customers including customers in the United States which is why they are one of the exchanges of choice for many engaging in criminal conduct 37 Based on the blockchain analysis I conducted described in the paragraphs above on or about December 16 2015 my co case agents contacted customer support in order to obtain additional information for the user that on or about July 28 2015 deposited the aforementioned 1 606 6497 bitcoins from the wallet ending in 5jj9 to the wallet ending in 38 On December 17 2015 emailedrecords associated with the transfer of 1606 6497 bitcoin from the wallet address ending in 5jj9 to the wallet address ending in h8D5 The records revealed that the account in question was established on July 28 2015 and that 13 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 21 of 65 on July 28 2015 a deposit bitcoin was made to the Bitcoin exchange The records further revealed that seventeen 17 withdrawals were thereafter made from and transferred out of the account Bach withdrawal from was in the amount of 100 bitcoin currently worth approximately $3 9 000 except for the last withdrawal made on September 24 2015 which was for the remaining amount of 6 6497 bitcoin By September 24 2015 all 1606 6497 bitcoins were transferred completely out of the account 39 I conducted additional blockchain analysis and learned that the Bitcoin wallet addresses contained in the'account records provided were then anonymized by using a Bitcoin tumbler A tumbler as the name suggests is used to tumble funds by disguising them and making it dif cult to track where the bitcoins originated It is a tool frequently used by money launderers and others engaged in criminal activity Additionally the logs contained the Internet ProtOcol IP addresses of the unidenti ed user s that connected to when a transfer was executed The IP addresses have also been anonymized by using a service known as The Onion Router TOR Thus I believe whoever was accessing the account was using TOR 40 Part of the December 17 2015 response from was that the subject account was registered to an individual associated with the email address branstein gustaf@outlook com records also indicated that had veri ed this email address 41 The information provided by did not contain personal identi ers but it did confirm that on July 28 2015 an individual or individuals with access to 5jj9 deposited 1 606 6497 into deposit address ifhiiDS for the bene t of the user associated with the branstein gustaf@outlook corn account I know this because only an individual with private key level access to 5jj9 would be able to move funds from this address The user 14 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 22 of 65 branstein gUStaf@outlook com utilized numerous TOR exit node B s and a transaction history for incoming and outgoing transactions was provided by I analyzed the account history associated with branstein gustaf@outlook com and determined that between July 28 2015 and September 29 2015 the user of this account liquidated this account through a series of withdrawals to the following addresses #1765195313 -6 6497 BTC Withdrawal BTC to address 24 09 15 #1762869539 -100 BTC Withdrawal BTC to address 23 09 15 #1758659810 -100 BTC Withdrawal BTC to address 21 09 15 #1756545817 -100 BTC Withdrawal BTC to address 20 09 15 #1754015944 -100 BTC Withdrawal BTC to address 19 09 15 #1751508892 100 BTC Withdrawal BTC to address 18 09 15 #17484989297 -100 BTC Withdrawal BTC to address 17 09 15 #1746405859 -100 BTC Withdrawal BTC to address 16 09 15 #1743976434 -100 BTC Withdrawal BTC to address 15 09 15 4 0 #1647541890 -100 BTC Withdrawal BTC to address 12 08 15 L #1644646075 -100 BTC Withdrawal BTC to address 11 08 15 4 #1641585943 100 BTC Withdrawal BTC to address 10 08 15 OJ #1636258844 -100 BTC Withdrawal BTC to address 08 08 15 A h #1627614158 -100 BTC Withdrawal BTC to address 06 08 15 l #1624829195 -100 BTC Withdrawal BTC to address 05 08 15 #1621659974 -100 BTC Withdrawal BTC to address 04 08 15 l '4 #1618505986 -100 BTC Withdrawal BTC to address 03 08 15 Based on this information I utilized additional clustering tools in order to determine whether these transactions were funneled through bitcoin services that would identify the user 1 determined that the bitooins withdrawn from the account registered to branstein gustaf@outlook com were deposited into a biteoin tumbling Service called SharedCoin SharedCoin works through a serious of transactions that mix coins with those of other individuals as well as coins belonging to SharedCoin This masks where the coins came from or were sent to SharedCoin works through a serious of transactions 5 to 205 mixing chins witha stream of transactions from other users as I well as internal coins that are held by SharedCoin Based on the complexity of these transactions 15 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 23 of 65 I worked with an expert in the eld of blockchain analysis and determined that at least 438 9714 bitcoins from the original coins that were taken from 5jj9 were eventually deposited into on December 15 2015 Note that this was after Bridges had entered his guilty plea and was still out of custody on release conditions As late as January 11 2015 these coins were still being actively laundered through SharedCoin 42 Microsoft which is responsible for outlook email accounts was served a Grand Jury subpoena on December 18 2015 for the subscriber information associated with the branstein gustaf@outlook com email address The email address was the only information contained in the records that could readily lead to the identity of the unidenti ed individual s who stole the 1606 6497 bitcoin because does not comply with US Treasury Bank Secrecy Act reporting requirements as legitimate Bitcoin exchanges do As a result does not require Know Your Customer data KYC is the process of a nancial institution bitcoin exchanges in this case of verifying the identity of its clients before establishing an account Since does not comply fully with KYC laws and regulations and appears to have required only an email address for verification no subscriber information was contained in the logs As a result the agencies investigating this theft DOJ-OIG and FBI Wish to obtain the content if any contained within the branstein gustaf@outlook corn email account that resides on Microsoft servers in order to help to identify the subject s that stole the 1606 6497 bitcoins from the on July 28 2015 As of today s values 1606 649 bitcoin is worth over $7 00 000 43 information thatwouldhelp identify the individual s associated with the aforementioned email account includes subscriber data Internet Protocol IP addresses address book entries sent and received email messages and draft email messages that are saved in the 16 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 24 of 65 account but never transmitted to another email account Microsoft and other email providers log IP addresses that are used at the time the account was established as well as when the user connects to Microsoft servers to send and receive email messages As a result the account may contain IP addresses that were not anonymized by TOR or other anonymity services unlike the IP addresses associated with the records Furthermore even if the unidenti ed individual responsible for the theft of Bitcoin use TOR or other anonymity services to mask their IP address vulnerabilities in the services could still leak the user s original address Identi cation of an IP address can sometimes lead to records that can help reveal the identity of the user s or location or address where the user s was located THEFT OF THE GOVERNMENT FUNDS FROM THE CALLAHAN GOVERNNIENT SEIZURE 44 In a separate incident on November 5 2014 then Secret Service Agent Bridges administratively seized 50 44 bitcoins worth approximately $20 000 at the time of the seizure from Tom and Amanda Callahan of Hurlock Maryland the Callahan seizure The Callahan seizure stemmed from a warrant by the Maryland State Poiice Dorchester County Maryland Narcotics Task Force in which Bridges participated for the Callahan residence in Hurlock Maryland During the execution of that search warrant 50 44 bitcoins were identi ed and seized 45 On November 5 2014 the proceeds of the Callahan seizure 50 44 bitcoin were transferred to wallet address hereinafter zfme The transfer to the zfrne wallet was presumably made by or at the-direction of federal law enforcement of cers involved in the Callahan seizure which included Bridges as the digital l7 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 25 of 65 currency expert and fellow Baltimore Silk Road Task Force Members however it is at this point undocumented in the case les who created the zfme wallet 2 46 Importantly there is and was no record of the zfme address in seizure files All that is listed in the original wallets addresses seized from the Callahans The following original addresses associated with the seized wallets were listed Wallet 10 59647a405d 1 2 1 SustEe rct7nUmaj ch Wallet 10 02be0310b2 3 1 4 5 47 Shortly after the 50 44 bitcoins were seized the Asset Forfeiture Branch determined that the funds could not be administratively seized Specifically on December 8 2014 the US SS Asset Forfeiture Branch wrote in an email to Bridges that After discussing the seizure with the Of ce of Chief Counsel they decided that the particular facts of the case will not allow the Secret Service to proceed with the administrative seizure process That decision was reached because OCC determined that there was not probable cause for wire fraud or mail fraud violations Title 18 U S C 1960 is not one of the core violations that the Secret Service has jurisdiction over and under Title 18 U S C 1956 any laundering appears to be predicated on drug offenses Therefore without any additional instances of fraud under the Secret Service Administrative 7 The affidavit in support of the seizure warrant states that Amanda Callahan Woluntarily transferred the contents of the Bitcoin addressed listed above to the agents and those contents presently are held in the custody of the US Secret Service 18 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 26 of 65 Statutes this seizure could not be pursued administratively However it could still be possible to forfeit the property through the AUSA or at the state level 48 Therefore on or about December 29 2014 then Special Agent Bridges sought a civil seizure warrant from the District of Maryland It is unclear currently whether he worked with the US Attorney s Of ce for the District of Maryland to obtain this seizure warrant A civil seizurewarrant for the 50 44 seized from the Callahans was issued by Magistrate Judge Timothy J Sullivan on December 29 2014 The warrant listed in its Attachment A the following addresses and made no mention of the zfme wallet address but instead contained the following addresses Wallet 10 '59647a405d 1 2 SustEefxct'inUmaj ch Wallet 10 02bec3 1cb2 49 Given the December 2015 discovery of the theft of the bitcoins at issue in the November Bitstamp seizure the US SS recently checked on the status of the bitceins that were the subject of the Callahan seizure warrant to wit Wallet 10 59647a405d 1 thES 2 1 SustEefxet7nUmaj ch Wallet 10 02bec3lcb2 3 4 5 IGEB aXsoQ vP7ng5 50 When these addresses were queried on the blockchain the results showed that all of the funds were transferred on November 5 2014 to the aforementioned zfme 9 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 27 of 65 wallet address This zfrne address did not engage in any additional activity until September 10 2015 when the entire balance was zeroed out and transferred to a series of other addresses It appears as if this like the November Bitstarnp seizure was the subject of yet another theft ADDITIONAL FACTS RELATED TO SHAUN BRIDGES Bridges Theft of Silk Road Bitcoins IS Similar to The Newly Discovered Bitstamp Thefts 51 I am currently investigating other seizures if any in which Bridges and or other members of the Baltimore Silk Road Task Force participated in an effort to determine whether any of those funds also have been stolen It has been reported to me that the November Bitstamp theft and the Callahan theft described above are not the only thefts and that there may be thefts of other digital currency seizures that happened outside of Maryland It should be noted that on the dates of the two additional thefts that have been discovered to date the July 28 2015 theft of the funds at issue in the November Bitstarnp warrant and the September 10 2015 theft of the funds at issue in the Callahan seizure former DEA Special Agent Carl Force was in custody in San Francisco California and had no access to a computer The same is not true of Bridges 52 As demonstrated above Shaun Bridges had access to the wallet and private key needed to access the wallet from which the funds at issue in both the November Bitstamp warrant and the Callahan Warrant were stolen My DHS-OIG counterparts have interviewed approximately one dozen employees of the US SS and to date have learned that Bridges was the only individual who had access to the private key that controlled the wallet from which the bitcoins that were the subject of the November warrant were stolen As stated to my knowledge Bridges was the only individual who possessed or had access to the private key needed to move the bitcoins 20 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 28 of 65 that were the subject of the November Bitstamp seizure out of the wallet An investigation into who if anyone aside from Bridges had access to the Callahan seizure wallet is underway 53 As discussed above Bridges was charged with wire fraud obstruction of justice and money laundering in connection with his theft of bitcoins during the course of the Silk Road investigation - United States v Bridges The facts of the thefts at issue in that case are very similar to the facts at issue in the instant investigation into the new thefts bitcoins to which Bridges had access through his position as a law enforcement agent 2 were stolen 3 then moved around from one address to another in an apparent effort to conceal and 1aunder and 4 offshore eXchanges were used Bridges pleaded guilty to obstruction of justice and money laundering and admitted the following facts as part of his plea agreement On or about January 25 2013 I devised a scheme to defraud and to obtain money and property through false and ctitious representations I an administrator account on the Silk Road website belonging to another individual and not intended for me or my personal use to obtain access to that site I am aware and agree that the government could prove that Silk Road was a website where illegal goods were posted for sale including narcotics and that payments were accepted on the site in Biteoin I used the administrator account to reset passwords of vendor accounts and other accounts to give me access to those accounts and any bitcoin in the accounts Ithen moved a total of approximately 20 000 bitcoin from various Silk Road vendor accounts into a walle over which I exercised control The value at the time the bitcoin was stolen was approximately $350 000 On January 26 2013 I moved the bitcoin into an account at Mt Gox a digital currency exchange based in Japan On January 27 2013 I attempted to lull the manager of the Silk Road site Ross William Ulbricht a lc a Dread Pirate Roberts elk a by telling him that I too had had bitcoin stolen from me This communication took place by interstate wire I agree that the government could prove that Ulbricht was in the Northern District of California on that date and that I was in Maryland Between March and May of 2033 I converted the bitcoin into US currency and caused wire transfers of money totaling approximately $820 000 from the accounts at Mt Gox into a Quantum International Investments LLC account I controlled at Fidelity On June 2 2014 I transferred funds from that Quantum Fidelity account into an account in thejdint names of myself and a person known to the parties Speci cally I conducted the following nancial transactions Date Amount Description of Financial Transaction 3 6 13 $98 511 08 Wire transfer from Mt Gox to Quantum Fidelity account 3 8 13 Wire transfer from Mt Gox to Quantum Fidelityaccount 3 13 13 $99 968 62 Wire transfer from Mt Gox to Quantum Fidelity account 3 18 13 $99 968 74 Wire transfer from Mt Gox to Quantum Fidelity account 3 19 13 $99 968 64 Wire transfer from Mt Gox to Quantum Fidelity account 4 5 13 $99 968 08 Wire transfer from Mt Gox to Quantum Fidelity account 4 16 13 $99 969 34 Wire transfer from Mt Gox to Quantum Fidelity account 21 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 29 of 65 4 26 13 $99 969 32 Wire transfer from Mt Gox to Quantum Fidelity account 5 7 13 $25 559 37 Wire transfer from Mt Gox to Quantum Fidelity account 6 2 14 $225 000 Wire transfer from Quantum Fidelity account to PNC Bank in joint name I knew that the funds in each of the above transactions were the proceeds of wire fraud and I carried out each of those transactions with the intent both to promote my ongoing wire fraud scheme and to conceal and disguise the nature location source ownership and origin of those illegal proceeds During the time that I devised and carried out this fraud and money laundering scheme I was a Special Agent with the United States Secret Service and a member of the Eiectronic Crimes Task Force and the Baltimore Silk Road Task Force which was actively engaged in investigating Silk Road its vendors and buyers and Dread Pirate Roberts and for which there was an ongoing Grand Jury investigation in the District of Maryland I agree that the Baltimore Silk Road Grand Jury investigation was an official proceeding As a United States Secret Service Special Agent I heid a position of public trust and I abused that position I further agree that my activities obstructed in uenced and impeded the Baltimore Grand Jury related to its Silk Road investigation as well as its resulting case in the District of Maryland against Ulbricht by among other things obstructing and impeding the ability of the investigation to fuily utilize a cooperator s access to Silk Road after my fraud 2 causing the Task Force and the Grand Jury to spend time and effort to investigate the thefts from Silk Road thatI committed 3 creating additional incentive for Ulbricht to attempt to hire someone to kill a cooperator whom Uibricht suspected of committing thefts I had in fact committed and 4 obstructing in uencing and impeding the Grand Jury s investigation into Ulbricht in the District of Maryland I agree that I acted corruptly in obstructing in uencing and impeding the Grand Jury s Silk Road investigation I agree that by May of 2014 there was also an active San Francisco-based Grand Jury investigation into potential misconduct by Drug Enforcement Administration DEA Special Agent Carl M Force IV and that the San Francisco Grand Jury subsequently began to investigate my conduct 1 further agree that the San Francisco Grand Jury investigation was an of cial proceeding On May 28 2014 I was interviewed by a Special Agent with the Federal Bureau of Investigation FBI and I intentionally misled that agent On November 13 2014 I was interviewed by a Special Agent from the Department of Justice Of ce of Inspector General and I intentionally misled that agent as well During January and February of 2015 I censulted with another employee of the United States Secret Service both before and after that employee had an interview on the subject ofthis investigation with Special Agents from the Department of Homeland Security Of ce of Inspector General DHS BIG and the FBI I met with that employee before and after the employee s interview and we discussed the subject of the interview and agreed to tell a false consistent story regarding searches conducted on a database controlled by the Financial Crimes Enforcement Network F On April 2 2015 in the Northern District of California I also misrepresented certain facts to agents with the FBI DHS 01G Department of Justice Of ce of Inspector General and Internal Revenue Service Criminal Investigations with respect to the full scope of the database searches I understand and agree that each of the interviews and actions described in the preceding paragraph were in corinection with the San Francisco Grand Jury investigation I further agree that by corruptly encouraging another Secret Service employee to tell a false story to federal agents and by lying to federal agents myself I obstructed in uenced and impeded the San Francisco based Grand Jury investigation into my own criminal conduct and that of former DEA Special Agent Carl M Force IV 54 In contrast to the 2013 conduct at issue in 15-cr-319-RS where Bridges knew that he had not covered his tracks well enough the perpetrator of the thefts in 2015 knew to Use 22 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 30 of 65 anonymizing sources such as tumblers and TOR so that the blockchain analysis would be of lesser if any value 55 Bridges signed a Plea Agreement with the government to factual basis conduct on June 15 2015 but due to his attorney s schedule he did not enter his guilty plea before Judge Seeborg in San Francisco until on or about August 31 2015 Although the government sought Bridges remand at the change of plea hearing given certain facts based on learning that morning of the fact he had tried to change his name described lrther below Judge Seeborg allowed Bridges to remain out on pretrial release with conditions and directed Bridges to cease efforts to change his name 56 The government sought Bridges remand thereafter on two additional occasions rst when it learned that Bridges had tried to report law enforcement credentials as stolen described further below The government s motion for remand was ultimately denied but an additional condition that Bridges not access a computer was imposed on or about October 15 2015 Second the government also sought remandat the time of sentencing given Bridges stated mental issues and given that he had been sentenced to a prison term of 71 months imprisonment Judge Seeborg denied the government s request to remand Bridges at sentencing and permitted Bridges to remain out of custody albeit on strict conditions of release As such Bridges was not in custody on July 28 2015 or on September 10 2015 when the two thefts described above occurred 57 During Bridges time as a federal agent he was a specialist in tumblers and also in the use of TOR and other anonymizing services 23 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 31 of 65 58 The thief s of the bitcoins at issue in the November Bitstamp warrant used TOR and a tumbler presumably to cover their tracks I am still investigating whether TOR and bitcoin tumblers were used in connection with the theft of the Callahan funds 59 As stated above the bitcoins at issue in the November Bitstamp warrant were stolen on or about July 28 2015 the account to which they were moved was established on or about July 28 2015 and the Microsoft account associated with the account Gustaf Branstein was established on or about July 27 2015 PayPal A ctivigg 60 Bridges established a PayPal account in 2002 PayPal has recently reported to law enforcement that transactions that PayPal nds suspicious were conducted in 2015 using Bridges account Speci cally Bridges account appears to have engaged in a number of sales as a merchant to third parties for computer hardware and computer equipment At least two credits to Bridges PayPal account in September 2015 totaling approximately $6 000 were disputed by different third parties to PayPal In other words it appears as though third parties complained to their credit card companies and PayPal was forced to rebate the charges However when PayPal went to debit the mds from Bridges PayPal account that account was empty PayPal records indicate that Bridges subsequently transferred those funds to the PayPal account belonging to his wife Ariana Esposito 61 Investigation to date has also revealed that on or about June 26 2015 Bridges PayPal account was used in an apparent attempt to buy a document from a merchant in Germany that sells birth certi cate and related documents Specialiy his PayPal account was debited $149 from a merchant called Germany-Service with a description of birth certi cate international form with an apostille An apostille is a highly recognized official notary A search of Germany 24 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 32 of 65 Service s website reveals that they specialize in providing birth certi cates The charge was returned on Bridges PayPal account the next day June 27 2015 fer reasons that I am investigating This was approximately one month before the Gustaf Branstein account was established at Microsoft and also approximately one month before the perpetrator of the November Bitstamp warrant funds established a account using the email address in the name of Gustaf Branstein Bridges Odd Behavior On March 18 2015 62 On March 18 2015 Bridges was informed that he was being placed on administrative leave for the conduct-that led to the charges in United States v Bridges RS3 - 63 On March 18 2015 Bridges left for lunch carrying a duf e bag that appeared to be lled and weighted down _S_e_g Exhibit 1 attached herewith stills of photographs of CCTV surveillance photos from Baltimore on March 18 2015 Bridges returned from lunch without the bag Even though at that time Bridges was not informed of his suspension given certain communications I am aware of in the case it is possible that Bridges lawyer informed Bridges that he was under investigation Additionally an inspection of Bridges government vehicle that afternoon did not uncover the aforementioned bag 64 That same morning of March 18 2015 another Special Agent observed Bridges at the undercover workstation Bridges was complaining that someone had changed the undercover computer s password and added that he was trying to access some case les on another side of the computer The other agent observed that in his training and experience this could 3 He Was apparently already aware by this point that he was under investigation in connection with the conduct that led to but had not yet been formally placed on administrative leave by the U888 25 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 33 of 65 indicate that there was a separate partition or storage area on the computer that Bridges was trying to access 65 In the afternoon of March 18 2015 after Bridges was informed that he was being placed on administrative leave for the conduct that led to the charges in United States v Bridges 15 19-RS Bridges stated that he wanted to take personal items be had in the of ce home and repeatedly asked other personnel not to follow him around the of ce while he did this First Bridges went to the Electronic Crimes Special Agent Program ECSAP Lab and placed personal items into boxes 66 After gathering personal items from the ECSAP Lab Bridges asked his supervisor if he could access his Dell laptop computer to copy electronic receipts of personal items he had purchased from internet merchants However instead of copying receipts Bridges began copying a Microsoft Outlook folder entitled Bitstamp Upon noticing what Bridges was copying his supervisor secured the laptop and did not allow Bridges rrther access 67 Bridges took a break to speak with his attorney and when he returned from speaking with his attorney Bridges advised that he was resigning effective immediately After personnel transported Bridges to his mother s residence Bridges US SS escort found what looked like two external hard drives while looking through the items Bridges placed in his vehicle Both drives were marked Bridges with one also stating Evidence drive The evidence drive was actually a hard drive enclosure that was empty and contained no harddrives It is believed that the hard drives that were contained in the enclosure were already taken by Bridges earlier in the day-when Bridges was observed on CCTV security cameras departing with the duf e-bag Exhibit 1 which Bridges never returned with when he arrived back at the eld office As stated above the Bitstarnp private key was stored as evidence in the Baltimore evidence vault having 26 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 34 of 65 been originally provided to the vault by Bridges I believe that Bridges may have made a backup of the key needed to access the Bitstamp wallet and that these hard drives that were contained in the enclosure marked Evidence drive may have contained just that The hard drives and contents of the duffle bag are believed to be located at the premises to be searched unless Bridges or one of his associates has hid or destroyed them Bridges Efforts to Change His Name And Seal Such Change From The Public Record 68 On or about June 28 2015 Bridges petitioned a Maryland state court to have his named changed from Shaun Wesley Bridges to Calogero Esposito Esposito is his wife s last name His justi cation for the change was past incidents of identity theft and an interest in connecting with his self identi ed ancestral heritage Importantly Bridges motion also contained a motion request to shield the information Bridges motions were denied and Bridges re petitioned the Court two additional times neglecting to mention that he had been arrested and was scheduled to plead guilty to federal charges in connection with his original bitcoin theftin United States v Bridges 15 cr 3 1 9-RS 69 The government brought this to Judge Seeborg s attention within a day of learning of this information which happened to coincide with the change of plea date of August 31 2015 Bridges proffered explanation was that he was concerned about the U S Of ce of Personnel Management data breach and that was why he was trying to change his name 70 In my training and experience as a nancial crimes investigator one of the reasons that those convicted of nancial crimes try to change their names and or identities is to procure - new identity documents often to establish new accounts with nancial institutions Such institutions may then be used to liquidate criminal proceeds Furthermore from my training and experience I know that individuals normally maintain records of their nancial activity in their 27 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 35 of 65 residence including receipts for expenditures by cash and check bank records and other' nancial documents Based on my training and experience as well as my consultations with other Special Agents with whom I work I am aware that individuals maintain evidence for long periods of time for several reasons First to any individual the evidence may seem innocuous nancial credit card and banking documents travel documents receipts client lists documents re ecting purchases of assets personal calendars telephone and address directories Checkbooks photographs utility records ownership records letters and notes tax returns and nancial records escrow les telephone and pager bills keys to safe deposit boxes packaging materials computer hardware and software To law enforcement however such items may have signi cance and relevance when considered in light of other evidence Second the individual may no longer realize he she still possesses the evidence or may believe law enforcement could not obtain a search warrant to seize the evidence Third the individual may operate under the belief that he she has deleted hidden or further destroyed computer related evidence which in fact may be retrievable by a trained forensic computer expert FACTS DEMONSTRATING THAT ARIANA ESPOSITO IS WILLING TO HELP BRIDGES CONCEAL HIS CRINIINAL CONDUCT Esposito Relationship With 71 Ariana Esposito was Bridges girlfriend during the timeframe in which Bridges committed his crimes to which he pleaded guilty in United States v Bridges to wit theft of bitcoins from an account that did not belong to him and subsequent laundering of those criminal proceeds At the time of the investigation she was his girlfriend The two did then and continue to live together 28 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 36 of 65 72 Esposito was also listed as a joint account holder on the PNC bank account which received $225 000 in criminally derived proceeds Orh er Conduct 73 As stated above PayPal identi ed as suspicious certain chargeback activity involving Bridges PayPal account in September 2015 When it went to recover the funds from Bridges PayPal account it learned that Bridges had transferred funds to a PayPal account belonging to Ariana Esposito 74 At Bridges sentencing on December 7 2015 Bsposito testi ed in support of her husband The bottom line is that Esposito is an individual who has demonstrated that she supports Bridges They live together Bridges tried to change his name to her name i e Esposito during the aforementioned name change I know from my training and experience that criminals often use their loved ones including spouses or signi cant others to help commit their crimes and also to help conceal their crimes This can be unwitting on the part of the signi cant other or purposeful and deliberate I believe that due to Bridges sophistication with law enforcement techniques and the fact that he knew he was under investigation and would be closely watched it is likely that he used and or was assisted by a third party such as Esposito to assist him in covering his tracks with any other criminal activity in which he was engaged to include the aforementioned theft of the November Bitstamp warrant Bridges Emirts to Transfer Guns to Esposito 75 On April 1 2015 as part of the court ordered conditions for his pretrial release in 15 cr-319-RS Bridgessurrendered four rearms to theDepartment of Homeland Security DHS Of ce of Inspector General 01G Bridges stated that the surrender of his weapons was voluntary that he could still legally possess the weapons and that he intended to find a third party to assume 29 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 37 of 65 ownership 'of the weapons A agent provided Bridges a business card with contact information for when a suitable party was located and explained that the weapons would be transported to and secured at a facility On May 28 2015 the NDCA received an email from the law of ces of Rosen Bien Galvan Grunfeld LLP Attached to the email was a Firearm Bill of Sale showing that Bridges sold the weapons seized by DHS-OIG to his wife Ariana Esposito on March 29 2015 for Notably the bill of sale was dated with a date when Bridges was on a cross country ight Bridges never informed DHS-OIG that he had found a third party Esposito to assume ownership of the weapons when he surrendered them on April 1 2015 76 Local gun records that were recently discovered however show that Bridges did not voluntary surrender all rearms and that he may still be in possession of an item under the Gun Control Act GCA 18 U S C 921 to wit a regulated silencer that he never surrendered to DHS-OIG Under the GCA the silencer is de ned as a rearm 18 U S C 921 a On or about June 28 2014 Bridges purchased the GCA regulated silencer Sure re 308 caliber from _of Select Fire Incorporated I Holsum Way Glen Burnie MD The silencer was purchased legally and Bridges completed the required Department of Justice Bureau of Alcohol Tobacco Firearms and EXplosives paperwork ATP Form 4473 On the form Bridges listed his residence the PREMISES to be searched as - Lillian Lane Laurel MD 77 Under 18 U S C 922 g which prohibits possession of a rearm or ammunition by a prohibited person it is illegal for a convicted felon or persons awaiting trial on felony charges to possess a silencer It is believed that the prohibited silencer is currently located at the Bridges Esposito residence 30 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 38 of 65 ADDITIONAL PROBABLE CAUSE RELATING TO EMAIL ACCOUNT 78 As described in the preceding paragraphs there is probable cause to believe that the email account branstein gustaf@outlook corn was used to steal seized government assets and linked to the account where the stolen bitcoins were transferred into As a result there is probable cause to believe that the branstein gustaf@outlook com contains evidence of wire fraud and theft of government funds and money laundering in violation of 18 U S C 641 1343 and 1956 Information that Microsoft has provided in response to a Grand Jury subpoena indicated that the aforementioned email account was created on or about July 27 2015 just one day before the wallet was established 79 Based on your af ant s training and experience I know that individuals who conspire with others to commit wire aud launder currency and theft use e-mail in the furtherance of their criminal activity Here I know that the individual s at a minimum used this email address to establish an account with and that the individual s established the email address the very day before the account was created and that the email address was used by to verify the account holder 80 On or about December 17 2015 your af ant sent a preservation request to Microsoft for the branstein gustaf@outlook com email account In general an email that is sent to or from a Microsoft subscriber is stored in the subscriber s mail box on Microsoft servers until the subscriber deletes the email If the subscriberdoes net delete the message the message can remain on Microsoft s servers inde nitely Even if the subscriber deletes the email it may continue to be available on a Microsoft s servers for a certain-period of time Therefore I believe that content of messages sent from the branstein gustaf@outlook com accounts may still be maintained on Microsoft s servers 31 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 39 of 65 81 In my training and experience I have learned that Microsoft provides a variety of on line services including electronic mail email access to the public Microsoft allows subscribers to obtain email accounts at the domain name outlookcom like the email account listed in Attachment A Subscribers obtain an account by registering'with Microsoft During the registration process Microsoft asks subscribers to provide basic personal information Therefore the computers of Microsoft are likely to contain stored electronic communications including retrieved and retrieved email for Microsoft subscribers and information concerning subscribers and their use of Microsoft services such as account access information email transaction information and account application information In my training and experience such information may constitute evidence of the crimes under investigation because the information can be used to identify the account s user or users 82 In my training and experience email providers generally ask their subscribers to provide certain personal identifying information when registering for an email account Such information can include the subscriber s fuli name physical address telephone numbers and other identi ers alternative email addresses and for paying subscribers means and source of payment including any credit or bank account number In my training and experience such information may constitute evidence of the crimes under investigation because the information can be used to identify the account s user or users Based on my training and experience I know that even if subscribers insert false information to conceal their identity I know that this information often nevertheless provides clues to their identity location or illicit activities 83 - - Inamy training and experience email providers typically retain certain transactional information about the creation and use of each account on their systems This information can include the date on which the account was created the length of service records of log-in 122 32 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 40 of 65 session times and durations the types of service utilized the status of the account including whether the account is inactive or closed the methods used to connect to the account such as logging into the account via the provider s website and other log les that reflect usage of the account In addition email providers often have records of the Internet Protocol address address used to register the account and the 1P addresses associated with particular logins to the account Because every device that connects to the Internet must use an IP address address information can help to identify which computers or other devices were used to access the email account 84 In my training and experience in some cases email account users will communicate directly with an email service provider about issues relating to the account such as technical problems billing inquiries or complaints from other users Email providers typically retain records about such communications including records of contacts between the user and the provider s support services as well records of any actions taken by the provider or user as a result of the communications In my training and experience such information may constitute evidence 'of the crimes under investigation because the information can be used to identify the account s user or users 85 As explained herein information stored in connection with an email account may provide crucial evidence of the who what why when where and how of thecriminal conduct under investigation thus enabling the United States to establish and prove each offense-element or alternatively to exclude the innocent from further suspicion From my training and experience I know that the-information stored in connection with an email account can indicate who has used or controlled the account This user attribution evidence is analogous to the search for indicia of occupancy while executing a search warrant at a residence For example email 33 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 41 of 65 communications contacts lists and images sent and the data associated with the foregoing such as date and time may indicate who used or controlled the account at a relevant time Further information maintained by the email provider can show how and when the account was accessed or used For example email providers typically log the IP addresses from which users access the email account along with the time and date By determining the physical location associated with the logged IP addresses investigators can understand the chronological and geographic context of the email account access and use relating to the criminal activity under investigation This geographic and timeline information may tend to either inculpate or exculpate the account owner Additionally information stored at the user s account may further indicate the geographic location of the account user at a particular time location information integrated into an image or video sent via email Finally stored electronic data may provide relevant insight into the email account owner s state of mind as it relates to the offense under investigation For example information in the email account may indicate the owner s motive and intent to commit a crime g communications relating to the crime or consciousness of guilt deleting communications in an effort to conceal them from law enforcement ADDITIONAL PROBABLE CAUSE RELATING TO PREMISES PERSONS AND DEVICES 86 As stated above both Bridges and Esposito s PayPal accounts have been active in the period of time to include the summer and fall of 2015 times during which the thefts that I am now investigating occurred 87 I know from my training and experience that PayPal accounts are accessed with electronic devices that connect to the internet such as cellular telephones computers andfor ipads 34 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 42 of 65 Therefore there is probable cause to believe that Bridges and or ESposito have in their possession an electronic device or devices that may be used to connect to the internet 88 I further know that on or about June 26 2015 as stated above Bridges PayPal account showed evidence that Bridges had attempted to order a birth certi cate from Germany- Service Again this was something that was done online I know in my training and experience that individuals often keep electronic devices in their residence and or on their persons depending on the size of the device This is particularly true for cellular telephones which are effectively computers It is also true of small storage devices such as a thumb drive 89 The crimes that are the focus of the instant investigation those enumerated in Attachments and B2 are crimes that in my training and experience are often committed online I know from my training and experience that individuals who commit crimes oniine often do so using computer and other electronic devices in the privacy of their own homes This is especially true where as here Bridges is not permitted to leave his residence under the terms of his court ordered supervision in lS-cr-319-RS In addition I am aware that Esposito is no longer employed by the Maryland State Troopers or in training at their academy and I am aware of no other employment There is therefore probable cause to believe that such electronic device s will be found in the PREMISES or on Bridges or Esposito s person 90 In this case that is especially true as Bridges does not have a place of employment indeed if he is following newly added court ordered conditions of release by Magistrate Judge James on October 15 2015 he is on lockdown at his home with a curfew Thus this is not a case where theinstrumentalities'and or evidence should be'found for example on a computer at a public library or at a workplace Personnel with the Pretrial Services Department advises that Bridges location monitoring shows he has been at his residence 35 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 43 of 65 91 As described above and in Attachment B2 -this application seeks permission to search for records electronic or otherwise that might be found on the PREMISES in whatever form they are found One form in which the records might be found is but-is not limited to data stored on a computer s hard drive or other storage media Thus the warrant applied for would authorize the seizure of electronic storage media or potentially the copying of electronically stored information all under Rule 92 I submit that if a computer phone electronic device or storage medium of any kind is found on the PREMISES there is probable cause to believe those records will be stored on that device computer or storage medium for at least the following reasons 93 Based on my knowledge training and experience I know that computer les or remnants of such les can be recovered months or even years after they have been downloaded onto a storage medium deleted or viewed via the Internet Electronic files downloaded to a storage medium can be stored for years at little or no cost Even when les have been deleted they can be recovered months or years later using forensic tools This is so because when a person- deletes a le on a computer the data contained in the le does not actually disappear rather that data remains on the storage medium until it is overwritten by new data 94 Therefore deleted les or remnants of deleted les may reside in free space or slack space that is in space on the storage medium that is not currently being used by an active le for long periods of time before they are overwritten In addition la computer s operating system may also keep a record of deleted data in a swap or recovery le 95 Wholly apart om user generated les computer storage media in particular computers internal hard drives contain electronic evidence of how a computer has been used what it has been used for and Who has used it To give a few examples this forensic evidence can 36 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 44 of 65 take the form of operating system con gurations artifacts from operating system or application operation le system data structures and Virtual memory swap or paging les Computer users typically do not erase or delete this evidence because Special software is typically required for that task However it is technically possible to delete this information 96 Similarly les that have been viewed via the Internet are sometimes automatically downloaded into a temporary Internet directory or cache A 97 Based on actual inspection of other evidence related to this investigation including but not limited to Spreadsheets nancial records and invoices I am aware that computer equipment was used to generate store and print documents used in the theft money laundering and wire scheme that I am investigating Thereis reason to believe that there is a computer system in some form is currently located on the PREMISES 98 As further described in Attachment B2 this application seeks permission to locate not only computer les that might serve as direct evidence of the crimes described on the warrant but also for forensic electronic evidence that establishes how computers were used the purpose of their use who used them and when There is reason cause to believe that this forensic electronic evidence will be on any storage medium in the PREMISES because 99 Data on the storage medium can provide evidence of a le that was once on the storage medium but has since been deleted or edited or of a deleted portion of a le such as a paragraph that has been deleted from a word processing Virtual memory paging systems can leave traces of information on the storage medium that show what tasks and processes were recently active Web browsers -e mailw programs and chat programs store configuration information on the storage medium that can reveal information such as online nicknames and passwords Operating systems can record additional information such as the attachment of 37 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 45 of 65 peripherals the attachment of USB ash storage devices or other external storage media and the times the computer was in use Computer file systems can record information about the dates les were created and the sequence in which they were created although this information can later be falsi ed 100 As explained herein information stored within a computer and other electronic storage media may provide crucial evidence of the who what why when where and how of the criminal conduct under investigation thus enabling the United States to establish and prove each element or alternatively to exclude the innocent from further suspicion In my training and experience information stored within a computer or storage media registry information communications images and movies transactional information records of session times and durations internet history and anti-virus spyware and malware detection programs can indicate who has used or controlled the computer or storage media This user attribution evidence is analogous to the search for indicia of occupancy while executing a search warrant at a residence The existence or absence of anti- virus Spyware and malware detection programs may indicate whether the computer was remotely accessed thus inculpating or exculpating the computer owner Further computer and storage media activity can indicate how and when the computer or storage media was accessed or used For example as described herein computers typically contains information that Io g computer user account session times and durations computer activity associated with user accounts electronic storage media that connected with the computer and the IP addresses through which the computer accessed networks and the internet Such information allows investigators to understand the chronological context of computer 'or electronic storage media access use and events relating to the crime under investigation Additionally some information stored within a computer or electronic storage media may provide crucial evidence 38 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 46 of 65 relating to the physical location of other evidence and the suspect For example images stored on a computer may both show a particular location and have geolocation information incorporated into its le data Such file data typically also contains information indicating when the le or image was created The existence of such image les along with external device connection logs may also indicate the presence of additional electronic storage media a digital camera or cellular phone with an incorporated camera The geographic and timeline information described herein may either inculpate or exculpate the computer user Last information stored within a computer may provide relevant insight into the computer user s state of mind as it relates to the offense under investigation For example information within the computer may indicate the owner s motive and intent to commit a crime internet searches indicating criminal planning or consciousness of guilt running a wiping program to destroy evidence on the computer or password such evidence in an effort to conceal it from law enforcement 101 A person with appropriate familiarity with how a computer works can after examining this forensic evidence in its proper context draw conclusions about how computers were used the purpose of their use who used them and when 102 The process of identifying the exact les blocks registry entries logs or other forms of forensic evidence on a storage medium that are necessary to draw an accurate conclusion is a dynamic process While it is possible to specify in advance the records to be sought computer evidence is not always data that can be merely reviewed by a review team and passed along to investigators Whether data stored on a computer is evidence may depend on other information - stored on the computer and the application of knowledge about how a computer behaves Therefore contextual information necessary to understand other evidence also falls within the scope of the warrant 39 Case Document 137-2 Filed 06 30 16 Page 47 of 65 103 Further in nding evidence of how a computer Was used the purpose of its use who used it and when sometimes it is necessary to establish that a particular thing is not present on a storage medium For example the presence or absence of counter-forensic programs or anti- virus programs and associated data may be relevant to establishing the user s intent 104 I know that when an individual uses a computer to obtain unauthorized access to another users account over the Internet the individual s computer will generally serve both as an instrumentality for committing the crime and also as a storage medium for evidence of the crime The computer is an instrumentality of the crime because it is used as a means of committing the criminal offense The computer is also likely to be a storage medium for evidence of crime From my training and experience I believe that a computer used to commit a crime of this type may contain data that is evidence of how the computer was used data that was sent or received notes as to how the criminal conduct was achieved records of Internet discussions about the crime and other records that indicate the nature of the offense 105 Necessity of seizing or copying entire computers or storage media In most cases a thorough search of a premises for information that might be stored on storage media often requires the seizure of the physical storage media and later off-site review consistent with the warrant In lieu of removing storage media from the premises it is sometimes possible to make an image copy of storage media Generally speaking imaging is the taking of a complete electronic picture of the computer s data including all hidden sectors and deleted les Either seizure or imaging is often necessary to ensure the accuracy and completeness of data recorded on the storage media and to prevent the loss of the data either from accidental or intentional destruction This is true because of the following 40 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 48 of 65 106 The time required for an examination As noted above not all evidence takes the form of documents and files that can be easily viewed on site Analyzing evidence of how a computer has been used what it has been used for and who has used it requires considerable time and taking that much time on premises could be unreasonable As explained above because the warrant calls for forensic electronic evidence it is exceedingly likely that it wiil be necessary to thoroughly examine storage media to obtain evidence Storage media can store a large volume of information Reviewing that information for things described in the warrant can take weeks or months depending on the volume of data stored and would be impractical and invasive to attempt on site 107 Technical requirements Computers can be con gured in several different ways featuring a variety of different operating systems application software and con gurations Therefore searching them sometimes requires tools or knowledge that might not be present on the search site The vast array of computer hardware and software available makes it dif cult to know before a search what tools or knowledge will be required to analyze the system and its data on the Premises However taking the storage media off-site and reviewing it in a controlled environment will allow its examination with the proper tools and knowledge 108 Variety of forms of electronic media Records sought under this warrant could be stored in a variety of storage media formats that may require off site reviewing with specialized forensic tools 109 Nature of examination Based on the foregoing and consistent with Rule - the warrant lam applying for would permit seizing imaging or otherwise copying storage media that reasonably appear to contain some or all of the evidence described in the warrant and would authorize a later review of the media or information consistent with the 41 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 49 of 65 warrant The later review may require techniques including but not limited to computer-assisted scans of the entire medium that might expose many parts of a hard drive to human inspection in order to determine whether it is evidence described by the warrant 110 Because Bridges shares the PREMISES as a residence with Ariana Esposito his wife it is possible that the PREMISES will contain storage media that are predominantly used and perhaps owned by persons other than Bridges or jointly owned In addition for the reasons contained herein it is believed that ESposito is at a minimum aware of her husband s recent criminal activity if not outwardly serving as an accomplice of those crimes or an accomplice after the fact Thus if it is possible that the things described in this warrant could be found on any of those computers devices or storage-media the warrant applied for would permit the seizure and review of those items as well and they are included in Attachment BZ CONCLUSION 111 Based on the foregoing I request that the court issue the proposed search warrants I believe that the facts described in the preceding paragraphs establish probable cause to believe that there exists on the computer systems controlled by Microsoft in the PREMISES and on Bridges and Esposito s persons that there exists evidence of violations of 18 U S C 1343 Wire Fraud 641 Theft of Government Funds 1956 Money Laundering and 922 g Firearms Violations 42 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 50 of 65 f16 0197us REQUEST FOR SEALING I I 1 6 0 19 8133- 112 I further request that all papers in support of these application including the affidavit and search warrants be seaied until further order of the respective Court These documents discuss an ongoing criminal investigation the details of vvhich are neither public nor known to all of the targets of the investigation Accordingly there is goodcause to seal these documents because their premature disclosure may seriously jeopardize that investigation It should be noted that an af davit containing many of the foregoing details has been provided to Judge Seeborg under seal and ex parte in support of the government s opposition to terminate electronic monitoring for Shaun Bridges Respect illy submitted Tigran Gambaryan Special Agent IRS CI Cyber Crimes Unit Subscribed and sworn to before me on January 27 2016 HONORABLE TIMOTHY J SULLIVAN UNITED STATES MAGISTRATE JUDGE 43 Case Document 137-2 Filed 06 30 16 Page 51 of 65 ATTACHMENT A Place to Be Searched This warrant applies to information associated with the email account branstein gustaf@outlook com that is stored at premises owned maintained controlled or operated by Microsoft Corporation which is headquartered at One Microsoft Way Redmond WA 98052-6399 44 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 52 of 65 1 6-3 0 19 8 ns ATTACHNIENT Particular Things to be Seized and Procedures to Facilitate Execution of the Warrant 1 Information to be disclosed by Microsoft Inc the Provider to facilitate execution of the warrant To the extent that the information described in Attachment A is within the possession custody or control of the Provider including any emails records les logs or information that has been deleted but is still available to the Provider or has been preserved pursuant to a request made under 18 U S C 2703 f on January 6 2015 the Provider is required to disclose the following information to the government for each account or identi er listed in Attachment A a The contents of all emails associated with the account from the date of the account s creation to the present including stored or preserved copies of emails sent to and from the account email attachments draft emails the source and destination addresses associated with - each email the date and time at which each email was sent and the size and length of each email b All records or other information regarding the identi cation of the account to include full name physical address telephone numbers and other identi ers records of session 7 times and durations the date on which the account was created the length of service the IP address used to register the account log in IP addresses associated with session times and dates account status alternative email addresses provided during registration methods of connecting log les and means and source of payment including any credit or bank account number c The types of service utilized 45 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 53 of 65 1 6- 0 d All records pertaining to communications between the Provider and any person regarding the account including contacts with support services andrecords of actions taken The Provider shall deliver the information set forth above via United States mail courier or email to Special Agent Todd McI-Iale Department of Homeland Security OIG 45 Hardy Court Suite 224 Gulfport MS 39507 email Todd McHale@oig dhs gov H Information to be seized by the government All information described above in Section I that constitutes fruits contraband evidence and instrumentalities of violations of 18 U S C 1343 Wire Fraud 641 Theft of Government Funds and 1956 Money Laundering and those violations involving the unidenti ed individual and or any additional co conspirators including for each account or identi er listed on Attachment A information pertaining to the following matters 1 Communications and records related to the the trade transfer and sale of Bitcoin and any nancial accounts at any type of nancial institution or currency exchange 2 Information relating to who created used or communicated with the email account including records about their identities and whereabouts 3 Evidence indicating how and when the email account was accessed or used to determine the geographic and chronological context of account access use and events relating to the crime under investigation and to the email account owner 8 Evidence indicating the email account owner s state of mind as it relates to the criminal activity under investigation 9 The identity of the person s who created or used the user ID for the email account including records that help reveal the whereabouts of such person s and 10 Identi cation of co conspiratcrs accomplices and aiders and abettors in the commission of the above offenses Government procedures for warrant execution The United States government will conduct a search of the information produced by the Provider and determine which information is within the scope of the information to be seized 46 Case Document 137-2 Filed 06 30 16 Pagev54 of 65 Speci ed in Section II That information that is within the scope of Section II may be copied and retained by the United States Law enforcement personnel will then seal any information from the Provider that does not fall within the scope of Section II and will not further review the information absent an order of the Court 47 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 55 of 65 16-0197sz ATTACHMENT A2 Premises and Persons to Be Searched The premises known as - Lillian Lane Laurel MD 20723 is a residential detached single family home The street house number is prominently displayed in black numbers below the mailbox on a wood post at the foot of the driveway The dwelling is a two story colonial house with multi-color brown tan and gray stone and tan siding a single wood with a natural nish front door there are vertical side windows on each side of the front door black lamps with clear class are on both sides of the front door over the front door is a small awning with a black metal roof slate gray asphalt shingle roof on the rest of the house five windows on the front of the house all with white trim and no shutters The concrete front walk way turns toward the garage side and ends at the asphalt driveway There is an attached two car garage on the south facing side left side if facing the front of the house of the house The east facing outside wall of the garage is made of stone and has four windows with white trim The garage door is white with white trim and it is surrounded by siding To the side and above the garage door are five windows one on the rst story and four on the second story all with white trim on siding The north facing side of the house Right-side is made of siding and has one small window on the rst oor one on the second oor and one on the wall of the exposed basement all windows have white trim The basement appears to be made of poured concrete The electric and gas meters are also on the north facing side right-side of the house In the back of the house there are six windows on the second story six on the rst story and two on the exposed basement There are sliding doors on the rst story and exposed basement in the back of the house It is the rst house on the left hand East side as you enter and travel north on the Lillian Lane cul- de sac Additionally the front of the premise faces and is across the street from a house with a 48 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 56 of 65 lie-01971213 red brick front Your af ant knows Shaun BRIDGES is the owner through Maryland MVA records and the Maryland Department of Assessment and Taxes property records Additionally in the driveway of the premise there was a red 2002 Toyota Takoma with Maryland tags 391 1 18 MVA vehicle registration records con rm that Shaun Wesley BRIDGES is the registered owner As further stated in the af davit and Attachment B2 the premises to be searched also includes the persons of Shaun Bridges and Ariana Esposito to locate any of the material enumerated in B2 49 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 57 of 65 - 16-0197TJS ATTACHIVIENT BZ Particular Things to be Seized All documents records and property Whether in the form of printed documents or stored in electronic or digital form on any storage device that constitute evidence or fruits of 1 8 U S C 641 Theft of Government Property and or 18 U S C 1343 Wire Fraud 18 U S C 1956 I I Money Laundering and or 18 U S C 922 g Firearms Violations involving SHAUN BRIDGES and others on the Baltimore Silk Road Task Force including but not limited to the following items 1 Any information related to Bitcoin thefts or other nancial thefts 2 I All computers iPads hard drives or other electronic storage media or devices 3 All bank records checks credit card bills federal and state tax returns account information or other financial records 4 Items belonging to or originating from the US Department of Homeland Security DHS and other governmental agencies and departments 5 Cell phones PDAs and other communication devices capable of sending and receiving text messages and online communications 6 Currency in the form of any denomination to include but not limited to digital currency printed money coins checks money orders etc in any form and 7 Stolen government property to include the following a records in paper land electronic form b computers and computer equipment c Law enforcement equipment 8 Firearms ammunition and or silencers Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 58 of 65 16-0 1971113 16-0198TJS EXHIBIT 1 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 59 of 65 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 60 of 65 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 61 of 65 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 62 of 65 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 63 of 65 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 64 of 65 Case 3 15-cr-00319-RS Document 137-2 Filed 06 30 16 Page 65 of 65 This document is from the holdings of The National Security Archive Suite 701 Gelman Library The George Washington University 2130 H Street NW Washington D C 20037 Phone 202 994-7000 Fax 202 994-7005 nsarchiv@gwu edu
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