Case 4:18-mj-00032-VLD Document 5 Filed 04/19/18 Page 1 of 19 PageID #: 41

UNITED STATES DISTRICT COURT

HLED
FOR THE DISTRICT OF SOUTH DAKOTA APR 1 9
SOUTHERN DIVISION
^iem"

In the Matter of the Search re: No

AFFIDAVIT IN SUPPORT OF
18-044-04
SEARCH WARRANT "REDACTED"

STATE OF SOUTH DAKOTA )

:SS
COUNTY OF MINNEHAHA )

I, Matthew J. Miller, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

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

the premises described in Attachment A as:

a. A residence and home office located at

Sioux Falls, South Dakota 57106.

b. A commercial property located at|

in Sioux Falls, South Dakota 57108.

2. Items to be seized at both addresses are described in Attachment B.

3. I am a Special Agent of the Federal Bureau of Investigation and have

served in that capacity for 25 years. During this time, I have received specialized

training in white collar crime investigation by attending various seminars and

classes specifically related to white coUar crime. I have also worked a substantial
 Case 4:18-mj-00032-VLD Document 5 Filed 04/19/18 Page 2 of 19 PageID #: 42

number of white collar crime eases during my 25 years with the FBI, ineluding

multiple cases related to mail fraud and wire fraud.

4. Information contained within this Affidavit is based on my investigation,

training and experience, as well as information developed and relayed to me by

other law enforcement officers. I have set forth facts that 1 believe are neeessaiy

to establish probable cause to seize instrumentalities, fruits, and evidence in

violations of 18 U.S.C. §§ 1341 (Mail Fraud) and 1343(Wire Fraud). The FBI has

been investigating what appears to be a scheme to defraud investors. The

investigation, as detailed below, has revealed that Paul Erickson has been

obtaining investor money to produce specialized wheel chairs via a company

known as "Investing vrith Dignity," to build retirement centers around the

eountiy through a company known as "Compass Care," and to build housing for

oil workers in the Bakken Oil Region of North Dakota. It appears Erickson has

obtained approximately $2.2 million from 76 investors, but has not used this

money toward the projects he indicated he would be using it for. This Affidavit

sets forth facts establishing probable cause that evidence, fruits, and

instrumentalities of the scheme "will be located in Erickson's home office located

on and at his Compass Care office located on

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RELEVANT STATUTES

5. The application for a Search Warrant, which this Affidavit Is offered in

support thereof, Is being applied to seize Instrumentalities, fruits, evidence, more

particularly described In Attachment B for violations of:

a. 18 U.S.C. § 1343, which makes It a crime to engage In a

scheme or artifice to defraud another, and obtain the money

and property of another, by false and fraudulent pretenses,

that involves a wire transmission and Interstate or foreign

commerce for the purpose of executing the scheme or artifice.

b. 18 U.S.C. § 1341, which makes It a crime to engage in a

scheme or artifice to defraud another and obtain the money

and property of another, by false and fraudulent pretenses,

that involves the use of the United States Postal Service.

PAUL ERICKSON AND BUSINESS ENTITIES

6. Paul Erlckson filed articles of Incorporation for "Investing with Dignity,

LLC" with the South Dakota Secretary of State's Office on September 20, 2010,

and provided an address of Sioux Falls, South

Dakota 57106. Erlckson was listed as the Registered Agent and Manager.

Investing with Dignity was dissolved with a Certificate of Administrative

Dissolution on April 20, 2015, but was subsequently reinstated on March 24,

2016, and Is currently In good standing.

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7. Paul Erickson filed articles of incorporation for "Compass Care, Inc."

with the South Dakota Secretary of State's Office on December 20, 1996, and

provided the address of operation to be A series of

address changes occurred and the most recent address filed with the Secretary

of State's Office on October 28, 2017, was

Sioux Falls, South Dakota 57108-2237. This filing showed Erickson to he the

President of"Compass Care, Inc."

BACKGROUND

8. Paul Erickson came to the attention of the FBI in 2016 when Joan

Sammon reported a fraud by Erickson. Sammon was selling parcels of land in

Williston, North Dakota, in the Bakken region for residential development. In

about 2015, Erickson contacted Sammon and wanted paperwork to evaluate the

possibility of investing in Sammon's land. Sammon emailed him paperwork

related to the property but Erickson did not invest. Later, however, Sammon

was contacted by a group of investors who indicated they had paid Erickson

$100,000 for an investment in the same land. Because Erickson did not have

an interest in the land (which was owned by Sammon), Sammon believed the

investors had been defrauded.

9. The FBI then obtained hank records in an attempt to leam of other

investors. 1 have reviewed the results of a financial analysis conducted by FBI

Special Agent Roahn Wynar. Wynar reviewed bank records subpoenaed from

Wells Fargo Bank for accounts held by Paul Erickson for the period of December
 Case 4:18-mj-00032-VLD Document 5 Filed 04/19/18 Page 5 of 19 PageID #: 45

2012 to October of 2017. An analysis of these records revealed multiple

individuals who have deposited money into Paul Erickson's bank account. This

analysis revealed money given to Erickson was not used to invest in real estate,

wheelchairs, or nursing homes. Instead, the money was used on flights, motels,
and other personal expenses incurred by Erickson. The list of depositors

discovered from bank records showed approximately 51 investors who gave

Erikson $720,400.

10. I have become aware of additional investors through my contact with

Brookings Police Detective Derek Powers who took a report in 2014 and

conducted an investigation into Erickson concerning investments into the

Bakken Oil region. Powers interviewed victims and also reviewed bank records.

His investigation revealed an additional ten investors who gave Erickson

$293,000.

11. I interviewed Todd Williams who invested $25,000 into a wheelchair

company (Investing with Dignity] being run by Erickson, which is further

described below. Williams provided a list of additional investors that was given

to him by Paul Erickson. This list contained 15 additional investors who gave

Erickson $622,530. In addition, Williams indicated Bob Elmen invested

$500,000 with Erickson and Brett Bozell invested $250,000 with Erickson.

12. In total, as of the time of this Affidavit, I am aware of approximately

78 investors who gave Erickson approximately $2.3 million. The FBI has
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conducted interviews of many of these investors and it appears Eriekson

obtained money from these investors for three primary businesses:

a. Investing with Dignity: Eriekson has obtained investor money

for the manufaeture of a speeialized wheelehair which allows

the user ofthe wheelehair to use the bathroom without getting

on and off the wheelchair.

b. Compass Care: Eriekson obtained money from investors to

build retirement homes around the eountiy.

e. Bakken Oil Fields: Eriekson obtained money to invest in real

estate and or build housing for oil workers in the Bakken

region in Williston, North Dakota.

My investigation has revealed that eaeh of these investment schemes

appears to be fraudulent, as further deserlbed below, and that each of these

companies are being mn out of one or both of the addresses listed in Attachment

A.

BAKKEN OIL FIELD INVESTMENT

13. The FBF has interviewed several investors in Erlckson's Bakken

housing projeet ineluding David Gillian, John Galbreath, and Loretta Waltner,

all of whom invested money with Paul Eriekson for real estate development in

the Bakken Oil Fields.

14. In each case, Eriekson described real estate he was aequiring in the

Bakken Oil Fields including housing for oil workers. Eriekson indicated the

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investor would receive an exceptionally high return. For example, Eriekson told

David Gillian he would receive a return of between 25 percent and 75 percent

within approximately one year. This motivated Gillian to wire transfer $100,000

from Virginia to Erickson's bank account in Sioux Falls, South Dakota, on

Februaiy 28, 2017. After complaining to Eriekson about a lack of return on his

investment, Gillian received $5,000 on March 29, 2018. 1 believe this was a

"lulling payment." That is, Eriekson provided Gillian with a small sum of money

in order to provide the illusion that Gillian's $100,000 investment was secure.

In reality, the bank records indicated that Gillian's $100,000 was not invested

in real estate or anything else. In fact, that money was used to pay routine

expenses and to pay off a previous investor. Congressman Marshall Sanford.

Some of Gillian's money went to Erickson's girlfriend, Maria Butina. Before

Gillian's investment, Erickson's bank account balance was approximately $110.

Within one month, all of Gillian's money was spent and none of that money was

used for real estate investment purposes.

15. Similarly, Eriekson convinced John Galbreath of Reston, Virginia, to

wire transfer $100,000 to him on May 30, 2017, by promising him a 50 percent

return within one year. Furthermore, Eriekson said he had a buyer ready to

purchase the housing he had built. This buyer was a group known as "Five

Guys." The FBI has interviewed members of the Five Guys who indicated that

they did not have any plans to make any purchases. Galbraeth has not received

any principal or any profits.

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16. I interviewed Loretta Waltner who invested approximately $58,000

with Erickson for real estate development in the Bakken region in 2014 and

2015. Waltner has been promised her money back several times but has not yet

received it.

17. SA Wynar's review of financial records has shown that none of this

money has been put into anything which appears to be related to real estate

investment.

18. The FBI contacted the Recorder for Williams County, North Dakota,

and determined that Paul Erickson has not purchased any land in the county.

The only filing for Paul Erickson in Williams County is a "Mineral and Royalty

Conveyance" filed in June of 2017, in which Erickson paid $10 to obtain the

rights to drill for oil in one section of land.

19. The documentation Erickson gave Gillian and Galhreth regarding their

investment showed an address of Sioux Falls,

South Dakota 57106.

20. The documentation Erickson gave Waltner showed an address of

Sioux Falls, South Dakota 57106, however, Erickson

also told Waltner in March of 2018 that the contract for one of her investments

was in his office located at in Sioux Falls.

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COMPASS CARE

21. The FBI Interviewed multiple Investors in Compass Care (a company

Erickson said he is involved in building smd or managing retirement homes),

including Vance Thompson, Loretta Waltner, and Todd Williams.

22. In the spring of 1999, Vance Thompson invested $500,000 based on

representations that he would make a 50 percent return on his money in 4 or 5

years and that the investment was a virtual guarantee. Erickson told Thompson

that Erickson had options on land for about 12 locations "already locked in."

Thompson paid Erickson by giving him a check.

23. In January of 2007, Loretta Waltner invested $1,000 in Compass Care.

Erickson provided Waltner with a document which indicated, "Compass senior

operations team oversaw 27,000 nursing homes, assisted living and apartment

beds in 26 states. No otfier assisted living company boasts that experience."

24. 1 interviewed Todd Williams whose father. Randy Williams, was a

minister. Upon retirement. Randy was hired by Paul Erickson to do marketing

and recruitment of potential retirement home residents. Todd Williams told me

that his father successfully recruited potential residents as well as investors

between 1999 and 2002, but was not paid by Erickson for his labor as Erickson

promised. Furthermore, Todd Williams' father did not see any evidence of any

retirement homes being constructed or acquired by Compass Care. Todd himself

invested $25,000 in 1999 and Erickson told him it would grow to $800,000 in

5-7 years. Todd made his investment by mailing a check to Erickson. As with
 Case 4:18-mj-00032-VLD Document 5 Filed 04/19/18 Page 10 of 19 PageID #: 50

all of Erickson's financial promises, his promise to Todd Williams included an

extremely high rate ofreturn well above standard investment opportunities. This
is, in my experience, characteristic of a high-yield investment fraud scheme.

25. The FBI reviewed public source databases and found no nursing
homes in the U.S. owned by or under the management of Erickson's Company.
The FBI located only two companies known as Compass Care: a nursing home
company for elderly residents known as "Compass Care, LLC," located in

Stamford, Connecticut, and a second nursing home company for people with

disabilities known as "Compass Care Ltd.," located in the U.K. Neither appear

to have any connection to Paul Erickson or the South Dakota Company known

as Compass Care.

26. Loretta Waltner told me that Erickson's Compass Care office was

previously located on 57th Street in Sioux Falls, South Dakota, but has since

moved to Sioux Falls.

27. In April of 2018, I personally observed the Compass Care office and

confirmed that it at A sign on the door

indicates it is the Compass Care office and I observed a computer, a filing

cabinet, an office chair and desk, and several boxes through an open window.

28. I received and reviewed documents from Vance Thompson and Loretta

Waltner, which show Erickson's Compass Care office to be at

in Sioux Falls, South Dakota.

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INVESTING WITH DIGNITY

29. The FBI interviewed multiple investors of "Investing with Dignity,"

including Kristen Hertog and Michelle Ward. Erickson represented to them that

Investing with Dignity had developed a unique wheelchair (the Dignity

Wheelchair) which allowed people using the wheel chair to go to the bathroom

without being lifted off of the chair.

30. 1 interviewed Reverend Greg Johnson, a Lutheran minister in

Brandon, and a childhood friend of Erickson. In 2005, Johnson and a friend

invented the Dignity wheelchair and obtained patents for it. The chair and

Johnson's company was at first known as J and L Products (later changed to

"Dignity Medical Devices" in 2007). In 2010, Johnson signed a contract Avith

Paul Erickson (dba "Investing AAdth Dignity") in which Erickson agreed to seek

out venture capital firms who might be willing to buy the patents for Johnson's

wheelchair. Erickson was unsuccessful and this arrangement ended in May of

2012 with a letter from Johnson's lawyer to Erickson. Subsequent to this letter

and unbeknownst to Johnson, Erickson began to raise money for the Dignity

wheel chair from investors. 1 believe this may reflect a pattern; that is, as with

Joan Sammon's property development, Erickson used Dignity's existing

literature as props to convince investors to give Erickson money based on the

false premise that Erickson was using the money for business development. In

reality, all of the money 1 am aware of was used to pay for Erickson's routine

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lifestyle expenses, pay for his girlfriend's college tuition (Maria Butlna), travel,
and also occasionally paid to previous Investors.

31. Specifically, on August 9, 2012, three months after his relationship

with Johnson ended, Erickson pitched Michelle Ward on an Investment In the

Dignity wheelchair which he now claimed as his own. Erickson told Ward her

Investment would pay 125 percent to 150 percent and guaranteed she would be

paid back the principal. Erickson also mentioned that Congressman Mark

Sanford had Invested In the Dignity wheelchair opportunity, a fact which helped
persuade her. Interestingly, Congressman Sanford told the FBI that. In fact, he

Invested In the Bakken scheme rather than In the wheelchair scheme. Based on

these representations. Ward wire transferred $15,000 from her account In

Virginia to Erickson's account at Wells Fargo Bank In Sioux Falls, South Dakota.

Since that time. Ward has received neither her principal nor any profits and

Erickson told Ward the delays were because the patents were stalled. Because

Erickson's relationship with Dignity was terminated approximately 5 yesirs

before this conversation with Ward, 1 believe that at the time Erickson mentioned

the stalled patents to Ward, Erickson knew the statement was false.

32. Similarly, in April of 2013, Erickson pitched Kristen Hertog to Invest

in the Dignity wheelchair. The pitch appealed to Hertog because her uncle

suffers from Multiple Sclerosis (MS) and Is confined to a wheel chair. Hertog

believed the product would help her uncle and others like him. Hertog, however,

was concerned because she was not a sophisticated Investor and told Erickson

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she did not have "any retirement savings." Erickson said he would double her

money in a year and she could then use her earnings to invest in a traditional

retirement account. Erickson also told her his investment was a "sure bet."

Based on these representations, Hertog gave Erickson a check for $5,000. Since

that time, she has received neither her principal nor any profit. In August of

2017, Hertog encountered Erickson in Sioux Falls and he told her that the

project had "gone up in smoke."

33. SA W5mar's analysis of bank accounts did not show any use of the

money to produce or create wheelchairs.

34. 1 have reviewed paperwork given to Ward and Hertog and both contain

|, in Sioux Falls, South Dakota as the address for

Investing with Dignity.

MAILINGS AND WIRINGS

35. I have interviewed victims in each scheme. In each case, the victim
/

has either wire transferred money or given checks to Erickson which were

deposited in his Wells Fargo Bank account.

36. 1 know from previous investigations about Wells Fargo Bank that

checks deposited in Wells Fargo Bank in Sioux Falls are cleared electronically

through the Federal Reserve Bank in Minneapolis, Minnesota, and involve

interstate wires.

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37. I have also Interviewed victims who have sent or received checks or

other materials In the United States Mall as a part ofthis scheme. Todd Williams
Indicated he sent a $25,000 check In the U.S. Mail to Sioux Falls for his

Investment In Compass Care In 1999.

38. 1 have also Interviewed victims who sent money to Erickson via
Interstate wire Including Galbreth, Gillian and Ward, previously mentioned.

USE OF COMPUTERS

39. I believe Paul Erickson makes use of computers In promoting his three
businesses. I base this belief on my observation of emails sent to Investors from

Erickson and on my observation of a computer In his Compass Care workspace.

40. 1 have reviewed emails received by Investors from Paul Erickson as a

part of promoting each of his three schemes. Among others, Erickson sent

emails to Todd Williams (a Compass Care Investor), Michelle Ward (an Investing

with Dignity Investor) and Joan Sammon (a Bakken real estate Investor).

41. I have observed, though an open window, a computer In the Compass

Care Office space located at In Sioux Falls.

LOCATIONS TO BE SEARCHED

42. Public source Database searches show Paul Erickson resides at

These data base searches (via Dunn and

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Bradstreet) also show "Investing with Dignity" and "Erickson Associates Inc." at

this address.

43. I have also spoken to Jaime Seherer of Lloyd Companies, the landlord

for this address, and she confirmed that Erickson Is currently residing there and

has been since about 2002.

44. South Dakota Seeretaiy of State filings for Eiickson's company known

as Investing with Dignity shows Sioux Falls,

South Dakota and shows a company known as Bridges LLC with Erickson listed

as the registered agent, at this address. The most recent filing was October 28,

2017.

45. As Indicated previously. Investors In the Bakken real estate scheme

(Investors Gillian, Galbreath and Waltner), Compass Care (Investors Thompson

and Waltner) and Investing Avlth Dignity (investors Ward and Hertog) all received

paperwork Indicating the company In which they Invested was headquartered at

I, Sioux falls. South Dakota.

46. 1 have reviewed Seeretaiy of State's filings and note that the current

address listed for Compass Care Is Sioux Falls,

South Dakota. The most recent filing was October 28, 2017.

47. In April of 2018, 1 have personally observed the Compass Care office

and confirmed that It Is at Sioux Falls, South

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Dakota. A sign on the door indicates it is the Compass Care office and I observed
a computer, an office chair, and several boxes through an open window.

48. I have reviewed public source databases which show

Sioux Falls, South Dakota as the address for "Compass

Care Inc."

49. 1 spoke to Jaime Soberer of Lloyd Companies, the landlord for this

address, and she confirmed that Erickson currently has a business at this

address.

50. As indicated previously, investor Waltner indicated Erickson told her

that paperwork concerning her Bakken investment was being stored in the office,

which she understood to mean in Sioux

Falls, South Dakota. Loretta Waltner also indicated she is familiar with the

as the office being currently used by Compass Care and

has personally observed the office to be located at that address. Therefore, I

believe there is evidence, fruits, and instrumentalities of wire fraud and mail

fraud specifically but not limited to business records related to Paul Erickson's

businesses at both of these locations.

RETURN AND REVIEW PROCEDURES

51. Pursuant to Rule 41 of the Federal Rules of Criminal Procedure, 1

understand and will act in accordance with the folloAving:

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a. Pursuant to Rule 41 (e) (2)(A) (i) an Agent is required to file with a

Court an Inventory return that is, an itemized list of the property

seized within fourteen days of the exeeution of the warrant.

b. Pursuant to Rule 41(e)(2)(B), Rule 41(e)(2)(A) governs the time within

whieh the eleetronieally stored information must be seized or eopied
on sight after the issuanee of the warrant not the later review of the

media ofinformation seized or the later off-site digital eopying ofthat

media.

e. Under Rule 41(f)(1)(B), the inventory return that is to be filed with

the eouit may be limited to a deseiiption of the physieal storage

media that was seized or eopied, not an itemization of the

information or data stored on the physieal storage media.

d. Under Rule 41(f)(1)(B), I may retain a copy of that information for

purposed ofthe investigation. Government tends to make and retain

a full image copy of the seized media, so that a copy of the evLdenee,

rather than the original evidence can be examined.

52. Computer hardwire, DVR devices, software, documentation,

passwords, and data security devises may be important to a criminal

investigation in two distinct respects: (1) The edits themselves maybe

instrumentahties, fruits, and/or evidence in a crime and/or (2) The Items may

have been used to collect and store information about a crime (in the form of

electronic data). Thus, Rule 41 of the Federal Rules of Criminal Procedure

permits the Government to search and seize computer hardware, software,

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documentation, passwords, and data security devises which are: (1)

Instrumentalities, fruits, and/or evidence of a crime and/or (2) Storage devices
for Information about crimes.

53. Based on my knowledge, training, experience, 1 know that searching

and seizing mformatlon from computer generated media such as compact discs,
often require search by qualified computer specialist In the laboratory or other
controlled environment. This Is true because computer storage devises can store
the equivalent ofthousands of pages ofInformation. Additionally, a suspect may
try to conceal evidence; he or she might also store It In random order with

deceptive file names. This may require searching authorities to examine all the

stored data to determine which particular files Is evidence or Instrumentalities

of the crime. This process maybe take weeks or months, depending on the
volume of the data stored, and often It would be Impractical to attempt this kind
of search on site.

54. Search team computers for criminal evidence Is a highly technical

process requiring expert skills and a properly controlled environment. For

I

example, on site and laboratory analysis by a qualified computer specialist Is

often required in order to properly retrieve and analysis electronically stored

(computer) data, to document and authenticate the data, and to prevent the loss
of data.

55. Based on the above facts, circumstances, and information, permission

Is requested to seize the computer systems, discs, or functionally - equivalent

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digital data storage devices (including computer systems and peripheral housing
data storage capability) and then image those items (a process which can take
several hours) even though there may be unrelated Information stored on them

and then return this equipment to the location so it can continue to be used for

legitimate business.

CONCLUSION

56. Based upon my experience all the factors have been indicative of

violation of federal criminal laws including 18 U.S.C. §§ 1341 (Mail Fraud) and

1343 (Wire Fraud).

57. 1, therefore, respectfully request that the attached Warrant be issued,

authorizing the search of the locations specified in the Attachment A and the

seizure of the items described in Attachment B.

1 do declare under the penalty of pequry that the foregoing is true and

correct.

Matthew J. IVftller, Special Agent

Federal Bureau of Investigation

Sworn to before me and subscribed in my presence on this 1 1 day of

April, 2018, at Sioux Falls, South Dakota.

Veronica Duffy
United States Magistrat^dudge

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ATTACHMENT A "REDACTED"

Property to be Searched

The property at Sioux Falls, South Dakota

57106, which is deseribed as a large, multi-unit apartment building and home
office.
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ATTACHMENT B "REDACTED"

Items to be Seized

1. Any and all books, records, papers, documents, emails, invoice,

receipts, ledgers, journals, accounting records, inspection reports,
correspondenees, bank records, and means of electronic storage relating in any
way to businesses involved in real estate, housing, retirement homes/nursing
homes, wheelchair or other medieal devices, oil exploration, oil drilling, and/or
evidence ofviolations of 18 U.S.C. §§ 1342(Mail Fraud)and or 1343(Wire Fraud),
and /or instruments of any nature and things which constitutes evidence of
these violations, or are contraband, the fruits, proceeds, or instrumentalities of
violations of 18 U.S.C. §§ 1341 and 1343 between Januaiy of 1997 to the
present. This evidence includes but is not limited to:
a. Contracts, bank records, internal or external correspondences,
marketing brochures, investor lists, maps, patent certificates, stock
certificates, financial institution records for accounts owned,
controlled, or aceessible by Paul Erickson or accounts in which he
may have a direct or indirect beneficial interest. These financial
records shall include, without limitation, account opening
documents, aceount statements, accounts correspondence,
caneelled ehecks, deposit and withdrawal slips, wire transferred
documents, signature cards, check registers, check stubs, savings
pass books, loan agreement/contracts, mortgage applications and
related documents, letters of eredit, bank drafts, money orders,
eashier's checks, debit advise, letter instructions regarding transfer
of funds, bank notices, credit memos, certificates of deposit, trust
accounts, brokerage accounts, safe deposit box and keys, personal
directories and phone lists of current and former employees as well
as wage and payroll records of current and former employees.
b. Any related business partner agreements or shareholder stoek
information related to any businesses belonging in some part to Paul
Erickson including documents reflecting the names of personal
aliases, corporate entities, shell corporations, partnerships,
relatives and associates.

c. Any and all ledgers and account books, financial net worth
statements, documents, paperwork, account summaries, relating to
investments or other monetary transactions. To include but not
limited to aceount print outs, ledgers, appointment books, client
lists, investor lists, billing agreements, tax returns, tax return
information, copies of tax returns, information returns, checks,
checkbooks, bank statements, reeeipts, bills, invoices, credit eard
receipts, credit card statements, travel card receipts, travel card
 Case 4:18-mj-00032-VLD Document 5-2 Filed 04/19/18 Page 2 of 2 PageID #: 62

statements, travel card correspondence, phone recordings, Skype or

other Internet recordings, contracts, leases, time cards,
correspondence, notes, cash receipts, and cash disbursements,
other business/financial records kept In the premises Including but
not limited to safes, filing cabinets, and boxes, computers, and/or
any other places documents can be stored.
d. Any and all documents reflecting, referring, and/or relating to the
ownership and/or location of real property. Including but not limited
to rental payments, business leases, land leases, billing leases,
options and exchange of title properties, owned and/or held by or
on behalf of Erlckson or any of his associated businesses including
land grants, trust deeds, claim deeds, or deeds held in trust,
purchase/sale agreements, depreciation or amortization schedules,
rental Income, and expense and related correspondence.
2. Electronic Media. Any and all of the above mentioned Information
and/or data stored In the form of magnetic or electronic coding on computer
media or on media capable of begin read by a computer or with the aid of
computer-related equipment. This media Includes floppy diskettes, fixed hard
discs, removable hard disk cartridges, tapes, laser disks, and other media which
are capable of storing magnetic coding.
3. Electronic devices. Any and all electronic devices which are
capable of analyzing, creating, displaying, converting or transmitting electronic
or magnetic computer Impulses or data. These devises Include computers,
computer components, computer peripherals, work processing equipment,
modem, monitors, printers, plotters, encr5q)tlon circuit boards, optical scanners,
external hard drives, and other computer-related electronic devices.
4. Electronically stored instructions. Any and all Instructions or
programs stored In the form of electronic or magnetic media which are capable
of being Interpreted by a computer or related components. The Items to be seized
Include operating systems, application software, utility programs, compilers.
Interpreters, and computer hardware or peripherals either directly Indirectly
capable of transmitting data via telephone lines, radio, or other means of
transmission.

5. Printed instructions. Any and all written or printed material which

provides Instructions or examples concerning the operation of a computer
system, computer software, and/or any related device and passwords.
6. Before reviewing data from the electronic storage media or electronic
stored Information seized pursuant to this warrant for purposes unrelated to this
Investigation, the government agrees to request another search warrant from the
court.