2093, SW 006 W2TUC STATE OF FLORIDA) 1STHUUDICIAL CIRCUIT ) SEARCH WARRANT (GOOGLE LLC) COUNTY OF SARASOTA ) THIS ORDER IS ISSUED PURSUANT TO SECTION, 92.605, FLORIDA STATUTES. A RESPONSE IS DUE WITHIN 20 BUSINESS DAYS OF RECEIPT OF THIS ORDER UNLESS A LONGER TIME PERIOD IS STATED HEREIN. IN THE NAME OF THE STATE OF FLORIDA, to all and singular the SheriffS and their Deputies, the Director of the Florida Highway Patrol and his Troopers, the Cosnmissioner of the Florida Department of Law Enforcement and his Designees, the. Director of the Florida Fish and Wildlife Conservation Commission and his Officers, and Constables, Municipal Police Officers and State Auomey's Itivestigators all acting within their juri&diction; WHEREAS, I have received affidavit for search warvant, on this date tnade before me by the Affiant, Detective/Officer A. Cox 1746, who has prepared same in his/her capacity as a law enforcement officer; and WHEREAS, the stated! Detective/Officer having been placed under oath and having swom to the facts as stated therein, and having examined the said facts set forth in support of said application for search Warrant, and the facts contained therein which are now incorporated herein by reference and made a part of this Warrant, and; WHEREAS, said fucts so made known to me by such affidavit as set forth, have caused me to certify and find that there is probable cause te-belicve-that the Hrs of the Bate of-— Florida relative to prohibiting Sexual Battery (Mentally Incapacitated), controlled by Florida State Statute 794.011(4)(b), has been violated by Christian Ziegler, and the officer has reason to believe and does believe that evidence connected with the crime is currently located within the below identified Google account, A’ user account identified by Unique Google ID: [email protected] This account is under the control of: Google LLC. Attention: Custodian of Records Google LLC. 1600 Amphitheatre Parkway Mountain View, CA 94043 Email: [email protected] THEREFORE, the Court having found that Google is an out-of state.corporation that provides electronic communication services or remote computing services to the public and pursuant to Florida Statutes § 92:605 and § 934.23, as well as the United Filed 11/17/2023 03:07 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL918617738 03:27:26 pm, 12-01-2023 4n8 States Code 18 U.S.C, § 2708, und California Statute § 1524.2, a Judge of the Circuit Court of Florida has jurisdiction to issue a search warraat for a Google account, Consequently these presents are to eoitunand you, with the proper and necessary assistance, cither inthe day time or inthe night time, as the exigencies ofthe situation may demand or require or on Sundays, or holidays, to enter the said Google account described above, and diligently séarch said account and seize as evidence any of the following: PROPERTY TO BE PROVIDED BY GOOGLE LLC, 1. Stored electronic communications or files associated with the user accounts identified ‘48 Google User ID: [email protected], and any related accounts conceming the same account subscribers or users, since creation of such aceount until the date of production, including but not limited to: 4, content and hedder information of email or other messages and any’ attachments; 1b. user contact information, group contsct information; ©. IP logs, and instant messages if any, whether drafted, sent, received, opened or unopened, reed or unread; and/or forwarded; and 4. any buddy lists or contact lists, calendars, transactional data, account passwords or identifiers, and/or any-othet files related to that account; 2. Records conceming the identity of the user of the above-listed user account(s); consisting of name, postal code, country, e-mail address, date of account creation, IP address at account sign-up, logs showing IP address, and date stamps for account accesses, 3, Any photo prints linked to of associated with the above-listed user account(s). The photo prints are to include a compilation of all photos and or videos uploaded by the user that have not been deleted, along with all photos and videos uploaded by any user that has the user togged ia them. 4, Any additional video and/or images uploaded or downloaded to the account with any associated inctadata, timestamps, and IP addresses associated with the upload or download, as well as any traiisactional logs that show user interaction with the videostimages. 5. Stored Android backups; 6. Stored web bookmarks, web history, and autofill data that are stored under this account; 7. Files stored in the Google Drive related to this account, to include shared folders thet axe accessible by this account; 8. Files stored ini the Google Photos related to this account, to include shared folders that are accessible by this account with any associated metadata (EXIF), timestamps, IP addresses associated with the upload or download, any transactional logs diat show user interaction with the videos/images;1861738 03:28:21 pm, 12-01-2023 5128 9, Google Hangonts conversation content and history associated to this account; 10. Any additional Google Accéunt or Google Play acéount, to include; céount information, and account history; 11, Any location history including global positioning éoordinates; 12, Google wallet/checkout service information; and 13, Installed application, device make(s), model(s) and intemational mobile identification number (IMEI) or mobile equipment identifier nuraber (MEID) for Google account. YOU ARE FURTHER DIRECTED to bring the property so seized before a court having jurisdiction to be disposed of and dealt with according to law and make roti of ‘your doings under this warrant to me or to miy designated clerk, and give proper receipts for any property taken hereunder, and deliver a copy of this warrant to the person at whom directed, GIVEN UNDER MY HAND AND SEAL THIS DAY 14/15/2023 SIGNATURE/ELECTRONIC SIGNATURE03:28:51 pm, 12-01-2023 6128 tice EP IN THE CIRCUIT COURT OF THE 12" JUDICLAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA 918617738 APPLICATION FOR COURT ORDER/SEARCH WARRANT COMPELLING PRODUCTION OF GOOGLE RECORDS Ine: A Criminal investigation Case No, 23-048937 A user account identified by: Unique Googie ID: Email: christiaamzicgler@gmail,com This account is under the control of: Google LLC. Attention; Custodian of Records Google LLC. 1600 Amphitheatre Parkway ‘Mountain View, CA 94043 Email: USLawEnforcement@googlé:com BEFORE ME, a Judge of the Circuit Court, personally or by sworn attestment appeared Detective/Officer A. Cox #1746, a duly sworn law enforcement officer of the Sarasota County Sheriff's Office, State of Florida, who after being first properly sworn, makes application for an order compelling Google to search for, and obtain, and to provide information and data in the above described Google accoiint to the appficant ‘Detective/Officer listed above, who states under oath that he/she has sufficient grounds to believe and does believe that the Inws of the State of Florida have been violated by Christian Ziegler, to-wit: The laws prohibiting Sexual Batiery (Mentally Incapacitated) controlled by Florida State Statute 794,011(4)(b), has been violated, nid the officer ias reason to believe anid does believe that eviderice connected with the crime is currently loceted within the below identified Google account, ‘THE DESCRIPTION OF THE USER ACCOUNT is as follows; A user account identified by Unique Google ID: Email: [email protected] GROUNDS FOR ISSUANCE: ‘The following grounds for issuance of the Order Compeiling Production of Google Records, as required by Florida Statutes exist, to-wit: the evidence sought is relevant to. proving the above described offerise has been committed and such evidence is contained918617738 03:29:41 pm, 12-01-2023 728 within the Google account described above. See Florida Statute 933.02(3). Google, is an out-of-state corporaticin that provides electronic communication services or remote ‘computing services fo the public. Your Affiant seeks to seize the below-described evidence pursuant to Florida Statute § 92.605 and § 934.23, as well as the United States Code 18 U.S.C. 2703, and Catifornia Statute § 1524.2, which compel out-of-state electronic communication service or remote computing service that provides such services to tie public to provide information requested pursuant to search warrants, court ordets or subpoenas issued in the State of Florida, FACTS STATED IN SUPPORT OF APPLICATION: ‘Your Affiant has sufficient reasonable grounds to believe that the above-named crime has een committed and that evidence in the form of electronic communication and or data held or possessed by Google may be discovered for the following reasons: 1, Your Affiant hias bee employed with the Sarasota Police Department since April 2015. Your Atfiant is assigned to the Criminal Investigation Division unit and has been in this unit for 4 years. specializing in Crimes against Children and all other crimes against ‘persons or property. Your Affiant-is tasked with conducting computer-related investigations and examining digital evidence. ‘THE FOLLOWING FACTS SUPPORT YOUR AFFIANT’S PROBABLE ‘CAUSI 1. 01 10/0423, vier cope he had been sexually asputed by Christian Ziegler on 10/02/23. The vietim was treated and examined at Sarasota Memorial Hospital where a sexual It ‘occurred at the victim’s apartment 2: On 10/05/23, Detectives began the investigation which revealed the following, The victim and Christian Ziegler have kriown each other for twenty yeats. On 10/02/23, the victim and Christien Ziegler agreed to have a sexual encounter thet included ‘Christian’s wife Bridget Ziegler. When the victim learned that Bridget could not ‘make it, she changed her mind and cancelled with Christian, On 10/02/23, the victim ‘opened her apartment door to walk her dog and Christian was standing outside in the hallway. Christian entered the apartment, bent the victim over the bar stool and. vaginally penetrated her with his penis, The victim advised Christian did not wear a condom, and he stated “I’m leaving the same way I came in.” The victim said she, Christian and Bridget were sexually involved one timo over a yar ago at their house. ‘The vietim stated that when Christian éaine over, she was 1ict in a place to consent Tequila all day. The viet} because it was her day off and sh advised she called her tit sist and told her she was raped, imrhediately went to the vietim’s house, 3. Detectives interviewed bo con x sister called her and told her she was raped but did not tell her who did ‘aid her sister (victim) was very emotional. and distraught.918617738 1. 03:30:52 pm, 12-01-2023 ‘On 10/24/23, Detective viewed the video surveillance footage from. the victim apartment complex. The video captured Christian Ziegler arriving in his gray Ford ‘ruck bearing FL., ag SRQGOP on 10/02/23, at 1429 hours. Christian immediately centered the apartment complex, is seen coming off the elevator and driving away in ‘the parking lot at 1507 hours. Christian was wearing dark shorts and a red shirt, ‘As patt of the investigation, Detectives performed a digital extraction on the victim's cell phone. Detectives located several digital messages from Christian to the victim ‘on 10/02/23 starting at 0729 hours, In the messages Christian told the victim to go to Instagram. The vietio said Christian liked 10 use Instagram because he conecals tie messages tsing vanish mode, {In another message hie asked the vietim for Ker address and told her they were driving, fafound referring to him and Bridget. Christian continued sonding the victim messages, but she did not respond in a timely manner, When the victim finally responded she asked who Was coming. At 1412 Christian said “Prob just me this time now: Was ready at 1:30.” Christian was referring to Bridget beinig ready at 1:30. At 1424 hours, the vietim responded “Sorry I was mostly in for her” referring to Bridget. On 10/27/23, Deteétives learned that Christian was trying to coiitact the vietiin by sending her messages via Instagram. Detectives and the victim began communicating with Christian via controlled/recorded messages. The following is a summary of the communication: * Victim: P'm not okay with what happened the other day between us. ‘© Christian: On, Thet's not good, You are my friend. Known ya for like twenty years now. Lol. Note: Christian goes on to talk about how long they have been Friends, ‘© Victim: Yeah I know bit that was not cool and you didn’t bring her and then did that to me. ‘© Clristizin: Shie was in, Then couldn't because tio Fésponse. She said in next time. But I understand. Your my friend I actually like you as a person, so sorry you got upset, but I can leave you alone if you prefer. Note: Christian then tried to change the conversation to getting his hair cut. © Victim: I don’t know if can do that anymore after what you did to ine last time it freaked me out. ‘© Christian: Ok. Well, Sorry. Not the fitention. Lwant yoti to be happy and not have Grama, You have dealt with enough BS, Note: Christian again tried to change the subject by talking about getting a hiiteut, Victim: I have not beén able to work sincé you came over. Chistian: Tam pretty loyal to my friends. Tried to call. Hard fo text. How can I help? Victim; 1 really can’t even talk to you tight now. 8128918617738 03:31:49 pm, 12-01-2023 9128 During the messaging, Christian continuously asked how he could help, and the victim responded, “You caused this. You can’t help mé.” Christian repeatedly referred to the ‘victim as his friend in an effort to minimize the situation, he would defléct by trying to change the subject when confronted. «Victim: I'd prefer you to tell me why you think what you did was okay? * Christian: Where ru? Wanna meet and chat? Worried about you. You are my fiend, Victim: Hell no not after what you did to me, Do you not understand -am terrified of you? Christian responded that he had to go soon, Christian then began calling the victim. The calls were audio recorded, Tin the first phone call the victim told Christian he hurt her when he came over. Christian said he did not think that was the case and if she was upset, he did not need her upset. Christian tried to change the subject, and the victirh asked why he did that. Christian suid he was not trying to start any issues, and she knows who he is. Christian asked the victim ifshe wanted him to leave her lone. The victim said she needed him to know that he hust ‘her. Christian responded by saying he would leave her alone. In the second controlled phione call, the vietitn called Christian back, When he afiswered the phone, the victim asked him why he forced her to have sex with him when she never ‘wanted to, Christian said he has never done that then said he had to go because some guy ‘was giving him a heed time, Charistian asked the victim if'she wanted him to call her later and she said no, In the third controlled phone call. Christian called the victim. Christian started asking the victim what she was going through. The victim told Christian he sexually assaulted her. Christian said, “Those are big words, please don't, o I dida’t. You invited me in, that’s it, Idid not at al, ard I never wait you to feel that way.”* Christian went on to say the ‘vietimn was his friend and asked her what she needed, Christian asked the victim if she needed financial help or anything else. Christian asked the victim what the issue was. The ‘victim responded twice that he was the issue, Christian told the victim she was his friend, sind he apologized for whatever is going on. Christian said he did not necd any drama, and hie did not want to create any issues for her, and if she was upset with him, he would Teave her alone. Christian told the victinn she was a good pérson, and he ‘vould leave her alone. The victim asked Christian to help her understand why he came over. Christian xesponidcd that he thought she wanted him to come over. The victisu said no, I told you not to. Chistian said that’s not true, The victim asked Christian to acknowledge that he lias been using her all these years. Chiistian said he was not going to acknowledge that, and he asked her if she'was recording him: Christian said the victim was trying (0 get him on record saying something. Christian once again asked the victim what he could do to help her, The vietim told Christian to leave her alone. End of call.918617738 03:32:51 pm, 12-01-2023 4, On 11/01/23, Detectives interviewed Bridget Ziegler. Bridget confiriied that she new the victim through her husband. Bridget confirmed having a sexual encounter with the victim-and Christian: over a year ago and that it only happeried one time. 9. On 11/02/23, Detectives interviewed Christian Ziegler with his allomey preset. Christian advised he had consensval sex with the vietim, and that he took a video of the encounter on 10/02/23 of the victim. Christian said he initially deleted the video, but since the allegation, he uploaded the video to his Google Drive. Which we have not been able to locate upon a digital extraction. 10, Based on the above information, I believe a search warrant for the content stored on Google’s servers for data relating to the Gmail addres christ zal a ‘will lead to locating evidence of the'crime, and will authenticate the date, time, and location of when the video was created. H1, Google is, a web service provider that provides users the ability to communicate with other users by various means; this includes the ability to email, post videos, and past photographs for others to view and to keep privately stored: meséaging services to communicate directly between users; and sharing of media between users, among. other services. 12. Your Affiant knows from experience that items can be synced to multiple electronic dovices including mobile devices, by the installation and use of the application Google Drive. Specifically, Google Drive is a cloud-based storage service that cchables users to store and access files online. The service synes stored documents; photos, and more across all the user's devices, including mobile devices, tablets, and PCs. These files can be saved on a folder and synced across any device that Google Drive is installed on, thus allowing the user to access these files on any device at any time 13, Your Affiant knidws from experience that Google Drive is one of Google’s cloud- based storage services that allows customers to access videos, photos, and documents from their mobilé devices aid Mac or Windows personal computers. It also cnables customers to back up the data within the Google Drive folder which as a result allows the information and data from the customer's device stored by Google to be available offline. 14, Your Affiant knows from training and experience that iPhones, iPads, Androids, and Apple iPhone 15 Pro Max are devices that can have Google Drive installed. Specifically, Auidroid based devise have Google Drive installed automatically when the device is purchased and activated. 15. Your Affiant knows from triining and experience that searches and seizures of electronic communications evidence may require the seizire of most, o all comminications currently stored fo be processed later, Fuitheritiore, you A ffiait believes that there is no way.to minimize or narrow the focus of the items beingrequested herein and this data can only be nerrow after you Affiant hes an opportunity to search all of the data being stored within the aforementioned Google Drive account, 16. Becatise the out-of-state electronic communication service or remote computing service provider has no reasonable means to distinguish evidence of the crimes froin any other records contained within the sought-afler account, your Affiant seeks to ‘compel the service provider to seize a copy of all records pertaining to the account and provide the entirety of the records to your Affiant., Once your Affiant has obtained those records, your Affiant and/or other representatives of his/her agency shall conduct ani actual search of the items obtained from the out-of state electronic ‘or remote computing service provider in order to soit the ions attigulated above and specifically sought herein, which ‘may be intermingled with innocent or innocuous documents or records. ‘On the basis of the foregoing facts, Affiant believes the following evidence may be found: INFORMATION AND DATA SOUGHT BY LAW ENFORCEMENT PROPERTY TO BE PROVIDED BY GOOGLE LLC. 1, Stored electronic comimuttications or files associated ivith the user ascounts identified as Google User 1D: Emall: [email protected] and any related accounts conceming the same account subscribers or users, siice creation of sucht account until the date of production, including but not limited to: ‘2. content and header information of emsil or other messages and any attachments, b._ user coritact information, group contact information; ©. IP logs, and instant messages if any, whether drafted, sent, reecived, opened ‘or unopened, read or unsead, and/or forwarded; and d._ any buddy lists or contuct lists, calendars, transactional data, account: ‘passwords or identifiers, and/or any othes files related (o that account; 2. Records concenting the'identity of the user of the above-listed user accounts); consisting of name, postal code, cotintry, é-mail address, date of account creation, IP address at account sigt-up, logs showing IP address, and date stamps for account accesses: 3. Any photo prints linked to or associated with the above-listed user a¢count(s). The photo prints are to include a compilation of all photos and or videos uploaded by the ‘user that have nit boen deleted, alonig with all photos and videos uptoaded by any user that has the user tagged in them, 4, Any additional yideo and/or images uploaded or downloaded to the account with any associated metadata, timestamps, and IP addresses associated with the upload or918617738 10, we 13, 03:34:53 pm, 12-01-2023 12128 download, as well as any transactional logs that show user interaction with the videos/images. Stored Android backups; Stored web bookmarks, web history, and aitofill data that are stored under this account, les stored in the Google Drive related to this account, to include shared folders that are aceossible by this aecount; Files stored in the Google Photos related to this acount, to inehudé shared folders that are accessible by this account with any associated metadata (EXIF), timestamps, IP addresses associated with the upload or download, any transnctional logs that show User interaction with the videos/images; Google Hangouts conversation content and history associated to this account; Any additional Google Account or Google Play accouint, to include; account informations, and account history’ ‘Any location history incfuding global positioning coordinates; Google wallevcheckout service information; and . Installed application, device make(s), model(s) and intemational iiobile identification’ number (IMEI) or mobile equipment identifier number (MEID) for Google account. WHEREFORE, your Affiant respectfully requests that a Search Warrant be issued commanding all arid singular the Sheriffs and their Deputies, the Director of the Florida Highway Patrol and his Troopers, tke Commnissioner of the Florida Department of Law Enforeement anid his designees, Constables and Municipal Potice Officers and Siote ‘Attomey’s Investigators acting within their jurisdiction, with proper and necessary assistance, to search the above described Google accouat in a manner consistent with ES. S. § 92.605 and California Penal Code §15.24.2, by delivering said warrant via facsimile or U.S, mii to an authorized legal representative Of Google, and to séize any and all of the aforesaid property found by virtue of stich Search Warrant and to list the property seized-on a return and inventory, to be filed within this Judicial Circuit within ten days of this date. F gle ob Detective Angela Cox!#1746 Affiaat / Signature Blectronic Signature918617738 03:35:40 pm, 12-01-2023 13128 STATEOF FLORIDA) COUNTY OF SARASOTA ) The foregoing instrument was acknowledged before me this |3tlvday of November 2023, by the individual whose name and signature appear above, and who is persomally known to me and wha did take an oath, Detective Maria Llovio #1312 Signature/Blecteonic Signature. Law Enforcement Officer Notary Public, State of Florida918617738 03:35:57pm, 12-01-2023 148 RETURN TO SEARCH WARRANT RECEIVED THIS WARRANT on the. sth aut Mor ia AD.,20Q and EXECUTEDthesameonthe [Sth _dayot_ W/bvembel AD., 20¢%3, by READING THIS WARRANT TO, and delivering a true COPY hereof toone SPD | (or by leaving a COPY at the premised}-and seizure of the item(s) described previously. Upon the completion of said SEIZURE, a WRITTEN INVENTORY OF THE PROPERTY seized was delivered to the aforementioned PERSON (or such a copy was left at the premises). A TRUE and CORRECT LIST of the item(s) seized is set forth in the following INVENTORY: a ter iF L ye la Cay . the officer by whom this WARRANT was executed, DO SWEAR thal the above INVENTORY contains a TRUE AND DETAILED ACCOUNT of all the PROPERTY seized by me on said WARRANT. a. a AFFIAN (SEAL) BEL SWORN TO AND SUBSCRIBED BEFORE ME THIS THE __| yi day of Navendae AD. 208918617738 03:36:34 pm, 12-01-2023 15128 2222 SB WO IL NE fo Chose, IN THE CIRCUIT COURT OF THE 12” JUDICLAL CIRCUIT IN AND FOR: SARASOTA COUNTY, FLORIDA. SEARCH WARRANT (CELLULAR TELEPHONE) IN THE NAME OF THE STATE OF FLORIDA, to all and singular the Sheriff and ‘their Deputies, the Director of the Florida Highway Patrol and his Troopers, the. ‘Commissiorier of the Florida Department of Law Enforcement and his Special Agents, the Director of the Florida Fish and Wildlife Coriservation Commission and his Officers, and Constables, Municipal Police Officers and State Attomey’s Investigators all acting within their jurisdiction, WHEREAS, Ihave received affidavit for search warrant, on this date made before ine by the Affiant, Detective Angela Cox #1746 who has prepared same in his/her capacity.as a law enforcemient officer; and WHEREAS, the Detective/Officer having been placed under oath and having swom to the facts as stated therein, and having examined the said facts set forth in support of said application for search warrant, and the facts contained therein which are now incorporated herein by reference and made a part of this Warrant, and; WHEREAS, said facts so made knowh to ine by such affidavit as set forth, have. ‘caused me to certify and find that there is probable cause to believe that the laws of the State of Florida relative to: Sexual Battery pursuant to Florida Statute 794.01 1(4)(b) “Mentally Incapacitated” have been violated by Christian M. Ziegler, W/M, DOB 05/27/1983 and that evidence of the crime is currently located at or within the below described cellular telephone(s). ‘THE DESCRIPTION AND LOCATION OF THE CELL PHONE(S) TOBE SEARCHED is as follows: Cellular phone belonging to Christian Ziegler, telephone number 202-731-7213. The cellular device is currently located in the custody of. Christian Ziegler. The aforesaid location is within the jurisdictional boundavies of Sarasota County. THEREFORE, these presents are to command you, withthe proper and necessary aésistance, inchiding off-site forensic cellular telephone analyst experts, either in the daytime or in the nighttime, as the exigencies of the situation may demand or require or on Sundays, or holidays, to search the said cellular telephone(s) described above, and seize as evidence any of the following: EVIDENCE SOUGHT: Filed 11/03/2023 02:52 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL918617738 03:37:30 pm, 12-01-2023 16128 1, All data regarding the target device identity information including the assigned phone ‘umber, serial number, make, model, IMEI, carrier, and owner information.” 2, All data regarding text communication including SMS, MMS, and 3" party application communication whether incoming, outgoing, and drafts including’any associated metadata. 3. Alldata regarding contacts including any associated logs and metadata, 4, All data regarding call log history, including incoming, outgoing, missed, and dialed and any associated metadata, 5. All data regarding images, videos, and audio files, including any associated metadata, 6, All-data regarding web history, including web sites visited internet searches, web bookmarks, internet cookies, downloaded data, and any associated metadata 7. All data regarding emiils whether incoming, outgoing and drafts and associated metadata. 8. All date regarding GPS-locations, location information, longitude and latitude data, cell tower locations, Wi-Fi connections, Bluetooth connections, hot-spot connections, including any associated metadata, 9. All data regarding docuiments, installed applications, autofill data, user accounts, passwords, PINs, notes, pattern locks, financial transaction rétords, credit card numbers, including any associated metadata. 10. In order to successfully complete a forensic extraction from a mobile device, it may be necessaty to repair the device, replace the display screen, replace the chassis, replace the battery, and repair or replace switches anid other components that are Hecessary to make the device operational. It may be necessaty to employ advanced forensic processes to bypass locked display screens and other data access restrictions. ‘Advanced processes may include, but are not limited to, brute-force attack methods, third party proprietary services and methods, destructive and potentially destructive processes such as gaining root and/or super-user level access, and employing methods such as JTAG, ISP and chip-off in order to extract data. 2 while seach wana being Sout des ot coe ine pod or dt testo, des nt a sublet man iin, he aso sss th 4 Amendment pricy sequent. Sec Le Soles, Bicoos, 970 24987, 98 m7" Ci 1982), abated an ae aneds by Cleseond ed Sia, 53 Us. 12 2000), Libel v, Wandion, 2013 WT. 6634249. (io 2013) Unis Sis. Kemall 2010 WL 1491873 ED. Tean 2010), an Units Sas v, Oa, 2008 WE. 247034 (WD. ‘Ten, 2008), Becanses forensic seh of cel pov does not alec wz of search pater, ut instead feiss of aries using ae oF more specie dees ib exet al el phone it~ lading deleted ers ~ and spay sain ‘punaesedale foal cesighed by tcreorof he exastion seivar, de vesctionscanet be ued the frese exaeation ‘tll pane. Adate resietion ako impractical because dls associated with dled les at ave bee estore during 8 ‘cen ection a ollnines ovate,918617738 03:38:30 pm, 12-01-2023 11. The executing law enforcement officer(s) may enlist the aid of a law enforcement computer forensic laboratory and/or certified digital forensic examiner(s) in the searching, viewing, photographing, recording, copying, forensic imagining, and analysis of all of the information described. 12, Digital items listed in this warrant may have associated content thatis stored remotely ‘ona server(s) at a third-party electronic service provider. If seized, Law enforeement ‘will return with a second warrant request to search these items. If any of the same be found in said object, you ate hereby authorized, with proper and necessary assistance (to include forensic computer analyst experts), to seize and secure same, to make retumn of your doings under this Warrant within ten (10) days of the date hereof. Youmay conduct an offsite forensic examination for the data listed in this warrant. You are likewise to give proper receipt for said property, and to deliver a copy of this Warrant to the person from whom the iterh was taken, or the person in charge of the item, or in the absence of any such persoa, to leave a copy of this Warrant in the place where said properly was found. ‘This Warrant authorizes the seizure of electronic storage media and/or the seizure ‘or copying of clectionically stored information. ‘This Warrant further authorizes a later review of the media or information. The 10-day timeframe for executing the wariant ii accordance with the provisions of Section 933.05, Florida Statutes, refers to the seizure or ‘onsite copying of the media or information, and not to any later off-site copying or review. GIVEN UNDER MY HAND AND SEAL THIS DAY 11/1/2023 CIGUULT susan 1214 aUvIELAL CIRCULT SIGNATURE/ELECTROMC SIGNATURE1861738 03:38:15pm, 12-01-2023 1818 IN THE CIRCUIT COURT OF THE 12” JUDICIAL CIRCUIT IN AND FOR, SARASOTA COUNTY, FLORIDA SEARCH WARRANT AFFIDAVIT & APPLICATION (CELLULAR TELEPHONE) BEFORE ME, a Judge of the Circuit Court, peisonally or by sworn attestment appeared Affiant Detective Angela Cox. Your affiant is a duly som law enforcement officer of the Sarasota Police Department, State of Florida, who after being first properly swom, deposes and says that he has probable cause to believe and does believe that the laws of the State of Florida have been violated, t0-wi ‘The laws prohibiting Sexual Batiery. controlled by Florida State Statute 794.011(4)(b) “Mentally incapacitated” have been violated by Christian M. Ziegler, W/M, 05/27/1983, ‘That the officer has reason to believe afd does believe that evidence comneéted with the ‘crime is currently located within the below described cellular telephone. ‘THE DESCRIPTION AND LOCATION OF THE CELLULAR TELEPHONE(S) TO BE SEARCHED: ‘The cellular phoné belonging to Christian Ziegler, telophione number 202-731-7213 and any and all digitally stored data on the device, ‘The cellular device is currently located in the custody of Christian Ziegler. ‘The afotesaid location is within the jurisdictional boundaries of Sarasota County. GROUNDS FOR ISSUANCE: ‘The following grounds for issuance of a Search ‘Warrant, as required by Florida Statutes exist, to-wit: Florida Statutes provides that a warrant to search an item, structure, o: conveyance other than a’ dwelling may be issied when any property constitutes evidence relevant to proving that a felony has been committed. See Florida Statute 933.023). PROBABLE CAUSE FOR ISSUANCE: ‘Your Affiants have probable cause to:believe that the above-named crime has been committed and that evidence may be discovered for the following reasons: 1. Your Affiant has been employed with the Sarasota Police Department since April 2015, ‘Your Affiant is assigned to the‘Criminal Investigation Division unit and has been in918617738 2 6 03:40:06 pm, 12-01-2023 19128 this unit for 4 years, specializing in Crimes against Children and all other crimes against persons or property. 0n 10/04/23, the victin AM ceported she had been sexually assaulted by Christian Ziegler‘on 10/02/23. The victim was treated and examined at Sarasota Memorial Hospital where a sexual assault ki pleted. The sexual assault come! thevcie' ara On 10/05/23, Detectives began the investigation which revealed the following. The victim and Christian Ziegler have known each other for twenty years. On 10/02/23, the victim and Christian Ziegler agreed to have a sexual encounter that included Chuistian’s wife, Bridget Ziegler. When the victim learned that Bridget could not ‘make it, she chenged her mind and cancelled with Christian. On 10/02/23, the vietim ‘opened her apartment door to walk her dog and Chistian was standing outside in the hallway. Christian entered the apartment, bent the vietim over the bar stool and vaginally penetfated her with his penis. The victim advised Christian did not wear a condom, and he stated, “I’ni leaving the same way T came in.” The victim said she, Cristian and Bridget were sexually involved one time over a year ago at their hous ‘The victim stated that when Christian came over, she was not in a place to consent because it was her day off and st dking Tequila all day. The vicgy Advised she called her twin a told her she was a immediately went to the victim's house. Detectives interviewelfAAEEE who con; hae she was raped but didnot tell her who did. vvery emotional and distraught. ister called her and-told her sister (victim) was. On 10/24/23, Detective viewed the video surveillance footage from the victim's apartment complex. The video captured Christian Ziegler arriving in his gray Ford truck bearing FL tag SRQGOP on 10/02/23, at 1429 hours. Chistian immediately entered the apartment complex. He is seen coming off the elevator and driving away in the parking lot at 1507hours. Chuistian was-wearing dark-shorts and a red shirt, As part of the iivestigation, Detectives performed a digital extraction on the victim's cell phone. Detectives located several digital messages from Christian to the victim ‘on 10/02/23 starting at 0729 hours. In the messages, Christian told the victim to go to Instagram. The victim.said Christian liked to use Instagram because he conceals the ‘messages using vanish mode. In another message, he asked the victim for her addrass.and told her they were driving found referring to hirh aiid Bridget, Christian continued sending the victim messages, but she did not respond in a timely mannes. When the victim finally respondéd she asked who was coming. At 1412 Christian said, “Prob just me this time now. Was ready at 1:30." Chistian was referring to Bridget being ready at 1:30, At 1424 hours, the vietim responded, “Sorry { was mostly in for her” referring to Bridget.918617738 03:41:09 p.m, 12-01-2023 20128 8. On 10/27/23, Detectives leamed that Chuistian was trying to contact the victim by sending fier messages via Instagram, Detectives and the victim began coinmunicating with Christian via controlled/recorded messages. The following is a summary of the communication: Victim: I'm not okay with what happened the other day between us. Christian: Ob. That’s not good, You are my friend, Known ya for like twenty years now: Lol. Note: Christian goes on to talk abouit how long they have been, friends. ‘+ Victim: Yeah I know but that was not cool and you didn’t bring her and then did that tome, Christian: She was in. Then couldn’t because né response. She said in next time. But I understand. Your my friend I actually like you as a person, so sorry you got upset, but I can leave you alone if you prefer. Note: Christian then tried to change the conversation to getting his hair cut. ‘© Victim: I don’t know if | can do that anymore after what you did to me last ime it freaked me out. * Christian: Ok. Well, sorry. Not the intention, I want you to be happy and not have drama. You have dealt with enough BS. Note: Christian again tried to change the subject by talking about getting @ haircut. Victim: I have not been able to work since you aime over. Christian: I am pretty loyal to my fiends. Tried to call, Hard to text. How can 1 help? * Viet : J really can’t even talk to you right now, Dating the messaging, Christian continuously asked how he could help, and the victim responded, “You caused this. You can’t help me.” Christian repeatedly referred to the victim as his friend in an effort to minimize the situation, he would deflect by trying to change the subject when confronted. ‘Victim: I'd prefer you to tell me why you think what you did was okay? Christian: Where ru? Wanna meet and.chat? Worried about you. You are my friend. ‘Victim: Hell no not after what you did to me, Do'you not understand Lam’ terrified of you? Christian responded that he liad to go soon, (Christian then began calling the victim. The calls were audio recorded. In the first phone call the victim told Christian he hurt her when he came over. Christian said he did not think that was the case and if she was upset, he did not need her upset. Christian tried to change the subject, anid the victim asked why he did that. Christian said he was not trying to start any issues, and she knows who he is. Christian asked the victim if she wanted him to leave her alone. The victim said she needed him to know that he hurt her. Christian responded by saying he would leave her alone.918617738 03:42:03 pm, 12-01-2023 2118 Inthe second controlled phérie call, the viciim called Christian back. When he answered the phone, the victim asked him why he forced ber fo have sex with him when she never ‘wanted to. Christian said he has never done that then said he had to go because some guy ‘was giving him a hard time. Christian asked the victim if she wanted him to call her later and she said no, In the third controlled phone call, Christian called the victim. Christian started asking the victim what she was going through. The vietim told Christian he sexually assaulted her. Christian said, “Those are big words, please don’t, 110 J didn’t. You invited me:in, that’s it, I did not at all, and I never want you to feel that way.” Christian went on to say the vietim.was his friend and asked her what she needed. Christian asked the victim if she needed financial help or anything else. Christian asked the victim what the issue was. The victim responded twice that he was the issue, Christian told the victim she was his fiend, and he apologized for whatever is going on. Chistian said he did not need any drama, and he did not want to create any issues for her, and if she was upset with him, he would ‘eave her alone. Chitistian told the victim she was a good person, and he would leave her alone, The victim asked Chistian to help her understand why he came over. Chistian responded that he thought she wanted him to come over. The victim said no, I told you not to, Christian said that’s not true, The victim asked Christian to acknowledge that he has been using her all these years. Christian said he was not going to acknowledge that, ‘and he asked her if she was recording him, Christian said the victim was trying to get him on record saying something. Christian once again asked the victim what he could do to help her. The victim told Christian to leave her alone. End of call. 9, Ori 11/01/23, Detectives interviewed Bridget Ziegler. Bridget confirmed that she knew the victim through her husband, Bridget confirmed having a sexual cncounter ‘with the vietim and Christian over a year ago and that it only happened one time. 10. Based on the above information, Affiant has reason to believe that evidence of the crime will be found within the cellular phone device belonging to Christian Ziegler telephone number 202-731-7213. 11. Your Affiant knows fiom other investigations that it is common for'a suspect, in advance of criminal activity, to communicate about their motives and plans via text message, phone calls, emails, or through other communication ‘programs/applications/platforms; and also to utilize an electronic device's access to the internet fo research infomation that may play a role in the person's plan or motive for the crime to be committed. 12, Your Affiant also knows froin other investigations it is common fot a suspect, post crime, to communicate about their recently committed criminal activity with other suspects or accomplices via text message, phone calls, emails, or through other communication programs/applications/platforms, and also to utilize an electronic device's access to the internet to research information that may assist the suspect in disposing of evidence, a path of flight/getaway from the crime and/or to coordinate a918617738 03:43:08 pm, 12-01-2023 22128 niceting location with other suspects in order to discuss the recently committed crimes in an attempt to thwart law enforcemeits efforts, 13, Your Affiant knows through his training and experience as a criminal investigator that individuals who participate in such crimes communicate via cellular telephones, text messages, calls, emails, etc, 14, Your Affiant also knows cellular devices such as iPhones/Androids continuously scan their environment for the best signal, which generally comes from the closest cell site and thus records and stores the phone's location. 15, Additionally, your Affiant knows that cellular devices such as an iPhones/Androids also have the ability to and routinely do store satellite-based location data within the phone:when a user opens-certain applications, sends messages over cellular data or does ather tasks on the iPhones/Androids. 16. Two-way communication is a term used to express any form of sent or received ‘communication between two electronic devices. This includes, but is not limited to the following: e-mails text messages, data messages, picture messages, dialed phone calls, incoming phone calls, and missed phone calls. 17, Text messages are a vernacular term for two-way communication between mobile device systertis which contain words, symbols, pictures, and files. Text messages include SMS (short message service), MMS (multimedia messaging service), iMessage, Data Messaging, and various other applications which express communi mi across visible letters between electronic devices. IMéssage is the most. ‘common way to communicate between iPhones, which is data based in internet activity. 18, With my training and experience; your affiant knows cellular telephones, and the stored data, may be important to a criminal investigation because they may contain evidence or fiuits of the crime. 19, Databases within the phone can be integrated and correlated to each other raking it. ‘unvealistic to simply remove certain data sections of a cellular phone to extract ‘evidence sought during a data extraction. It is not feasible, with the nature of current. technology, to only extract specific sections of a cell phone during a cell phone data ‘extraction and guarantee all the sought evidence is properly and completely extracted. 20. Based on the aforementioned facts, your A ffiant believes that probable cause exists to show Christian Zieglet’s cellular phone, an AT&T carrier, #202-731-7213 which is currently in Christian Ziegler’s custody, contains valuable evidence relevant to the subject matter of this warrant.918617738 03:44:04 pm, 12-01-2023 23728 ‘THE ROLE OF CELLULAR TELEPHONES IN CRIMINAL ACTS: ‘A cellular telephone is a long-range, electronic device used for mobile voice or data communication over a cellular network of specialized base stations known as cell sites. The cell sites are interconnected to the public switched telephone rietwork (PSTN), which is most commonly associated with fixed/stationary telephones that were ini use for the majority of the twentieth century. ‘A smartphone is a cellular telephone that las Wi-Fi end céllular connectivity. It can shoot videos, take photographs, play music, send, and receive email, browse the Webvinternet, send text messages, and receive voicemail. Smartphones are also used for banking, as well as scheduling appointmeats through their calendar operations. Other smartphone functions — video games, GPS navigation, social networking, etc, ~ can be enabled by downloading application programs, ‘A typical smartphone feature is the contact/name and address book, an internal database used for storing entries called contacts. Each contact entry typically consists of a few standard fields (eg,, first name, last name, company name, address, telephone number, e-mail address, fax number, and mobile phone number), Most smartphones store the details in alphabetical order of the individuals" names, Additionally, the contact/name anid address book of @ suspéct’s cell phone can provide information relevant and material to a criminal investigation. Such information can include leads relating to the names of individuals associated with the suspect, who ‘may themselves: (a) know of the suspect’s role in the offense(s) under investigation, and/or (b) have participated in the offense(s). Affiant'also knows that smartphones and the data stored in same may be important to a ctiminal investigation in two distinct ways: (1) the objects themselves may. be contéaband, evidence, instrumentalities, or fruits of crime, and/or (2) the objects inay be used as storage devices that contain contraband, evidence, instrumentalities, or fruits of crime it the form of electronic data. In. this case, the warrant application requests permission to search and Scizo electronically stored data and images as the stored data and images constitute evidence of a criine. Fu:thermore, I know that if location data is enabled on a cell phone, @ unique set of metadata is assigned, This metadata is able to show the Origin, eapture time, and real time GPS location in which a photograph or video is taken, or from where a midssage is sent. ‘Additionally, this location-based metadata would show an approximate location where the cell phone was at a given date and time depending on the defendant's usage of the phone. Based on the Affiant’s training and experienee, it is common for a suspect to use his or her smartphone to make and/or receive calls while in the area of a crime that he or she is committing,918617738 03:45:05 p.m, 12-01-2023 Based on Affiant’s training and experince, the text message feature of a smartphone has proven inevensingly popular in recent years, “Text messaging” or “texting” is the practice of sending short text messages from cellular telephiones or similar devices to their intended recipients. According to a September 2010 report by the Pew Research Center, as of May 2010, 72 percent of adults in the United States who own cell phones tse their phones’ “texting” features. See: Cell Phones and American Adults by clicking HERE. That same report notes that “{aldults who text typically send and receive a median of 10 texts a day; teens who text send and receive a median of 50 texts per day.” ‘Affiant has further leained that whien a’srnartphone user “deletes” data of his or her smartphone, the data is not actually erased, but is instead retained in the smartphone’s ‘memory until overwritten when additional memory space is needed by the device. This ‘process leaves deleted data retrievable by digital evidence experts, sometimes fong after thedata has been deleted. The afotementioned crimes are still under investigation and the évidence sought may corroborate information already known and/or provide: additional leads for further investigation. NECESSITY TO REMOVE CELLULAR TELEPHONE ‘TO CONDUCT & THOROUGH SEARCH “This affidavit also requests permission to seize the cellular telephone hardware that may contain the stored data if t becomes necessary for reasons of practicality to remove the hardware and conduct a scarch off-site... believe that,:in this case, the cellular telephone is a container for evidence and an instrumentality of the crime under investigation. Based upon my knowledge, training, and experience, I know that searching and seizing information from a cellular telephone often requires agents to seize the object to be searched later by a qualified computer expert in a laboratory or other controlled environment, This is true because of the following: (1) The-volume of evidence. Cellular telephones can store the equivalent of ftundreds of ‘pages of information. Searching this vast amount of information is a very time- consuming task. This sorting process can take an extended period of time and require special cellular telephone software, and it would be impractical and invasive to attempt this kind of data search of-sit. 2) Technical Requirements. Searching a cellular telephone for criminal evidence is a highly tectinical process requiring expert skill and a properly controlled environment. Data search protocols are exacting scientific procedures designed to protect the integrity of the evidence and to recover even “hidden,” erased, compressed, password-protected, fr encrypted files. Because cellular telephone evidence is vulnerable to inadvertent or intentional modification or destruction, a controlled environment may be necessary to complete an accurate analysis. Data recovery techniquies used with forensic examination 24128918617738 03:46:07 pm, 12-01-2023 25:28 of cellular telephones have been proven effective in recovering data tong after its creation, transmission, or receipt. (3) Necessity to Establish a Timeline. Its important in investigations of this manner to place the suspect with the cellular telephone at the time of the offense. Since this evidence must frequently be proven circumstantially, the forensic examiiner may need to compile a timeline of cellular telephone fies that were altered by the phone's use at or near the time of the offensé. An analysis of sich files may provide evidence that the suspect was utilizing his or her cellular telephone in the appropriate time frames. This is analogous to reviewing a suspect’s telephone records to prove he was at home at the time of the offense. In light of these cénicems, your Affiant hereby requests the Court's permission to search the cellular telephone that is believed to contain some or all of the evidence described in ‘the warrant, and to conduct an off-site search of the cellular telephone for the evidence described below. EVIDENCE SOUGHT: 1. All data regarding the target device identity information including the assigned phone number, serial number, make, model, IMEI, catrier, and owner information, ' 2, Ail data regarding text communication including SMS, MMS, and 3" party application communication whether incoming, outgoing, and drafts including any associated metadata. 3. All data regarding contacts including any associated logs and metadata. 4, All data regarding call log history, including incoming, outgoing, missed, and diated and any associated metadata, 5. All data regarding images, videos, and audio files, including any associated metadata. 6. All data regarding web history, including web sites'visited internet searches, web bookmarks, internet cookies, downloaded data, and any associated metadata. 7, Al data regardinig emails whether incoming, outgoing dnd drafts and associated metadata. * nite the sate wary being ough es ot contain ns ped ode esto, does ons ase tnaon, ‘which satisfies the Amendment pticlriy regime. See ii Site Buca, 970 F, 20937, 98.7 ("Ce 1902) amas oe eh sands by Chews Uried States, 531 U.S. 12 (2000), Ltr Wooden, 2013 WL. 6634249 (ND, (Ohi 013), Un Sate Kermel, 7010 WL 491873 (ED, Term, 2010), and United Stes x-Caden, 2008 WL 2367074 (WD. ‘Ton, 2008), Beeautesfrese seach ofl plo dos tt iveve the us of snc pasices, bt sted reuies amine ese eavor sor speilied devices tetra l cell phon dl including deed lems a0 soy sme na ‘ana nat designed by te erro the esrction soflvae, doe retin canal be ed nthe arene exarsaon ‘fa esl pone. Ade wetcton ko inpacicl beau the die msl with dscted fs Tin ave Baa restored Seg. 2 ‘ices exaction a flestines eave918617738 03:47:03 pm, 12-01-2023 26:28 8. All data regarding GPS locations, location information, longitude and latitude data, cell tower locations, Wi-Fi connections, Bluetooth connections, hot-spot connections, including any associated metadata. 9. All data regarding documents, installed applications, autofill data, user accounts, passwords, PINs, notes, pattern locks, financial transaction records, credit card numbers, including any associated metadata. 10. In order to successfully complete a forensic extraction from a mobile device, it may ‘be necessary to repair the device, replace the display screen, replace the chassis, replace the battery, and repair or replice switches and other components that are ccessary to make the device operational. It may be necessary to employ advanced forensic processes to bypass locked display screens ind other data access restrictions. Advancéd proceéses may include, but are not limited to, brute-force attack methods, third party proprietary services and methods, destructive and potentially destructive, processes such a3 gaining root afid/or super-uset level access, and employing methods such as ITAG, ISP and chip-off in order to extract data. 1. The executing law enforcément officer(s) niay enlist the aid of a law enforcement computer forensic laboratory andor certified digital forensic examiner(s) in the searching, viewing, photographing, recording, copying, forensic imagining, and ‘analysis of all of the information described. 12, Lalso know that digital items listed in this warrant may have associated content that is stored remotely on a server(s) at a third-party electronic service provider. If seized, I will retum with a second warrant request to search these items. On the basis of the foregoing facts, Affiant belicves the above-described evidence may be found. WHEREFORE, your Affiant respectfully requests that a Search Warrant be issued commanding all and singuler the Sherifis and their Deputies, the Director of the Florida ‘Highway Patrol and his Troopers, the Commissioner of the Florida Department of Law Enforcement and his Special Agents, the Director of the Florida Fish and Wildlife ‘Conservation Commission and his Officers, Constables, Municipal Police Officers and State Attorney's Investigators all acting within their jurisdiction, either in the day time or night time, asthe exigencies of the occasion may demand or require, or on Sunday, oF holidays with proper and necessary assistance, including using forensic cellular telephone analyst experts off-site to search the above described celfular telephone(s), and seize as evidence any of the above mentioned items or any other evidence relating to the sibject matter of this warrant that could be used in further violation of, or has been used in violation Of the iaws of the State of Florida in otder that evidence may: be procured to be-used in the prosecution of the Criminal Laws of the State of Florida.918617738 03:48:04 pm, 12-01-2023 27128 ‘Affiant / Signature Electronic Signature STATE OF FLORIDA) COUNTY OF SARASOTA ) The foregoing instrumnent was acknowledged before me this 01 day of November, 2023, by the individual whose name and signature appear above, and who is personally known to ine and who did take an oath, Debosve Whar” L310, Signature/Electronic Signature Law Enforcement Officer Notaty Public, State of Florida918617738 03:48:24 pm, 12-01-2023 RETURN TO SEARCH WARRANT RECEIVED THIS WARRANT onthe _O/ day of, Woven ber” AD.,20.23,andEXECUTEDthesameonthe OR dayof_Aévember AD., 2023, by READING THIS WARRANT TO, and delivering a true COPY hereof toone _CHai'stiew Ziegler COPY at the premises), and seizure of the item(s) described previously. Upon the completion of said SEIZURE, a WRITTEN INVENTORY OF THE PROPERTY seized was delivered to the aforementioned PERSON (or such a copy was Iéft at the premises). A TRUE and CORRECT LIST of the item(s) seized is set forth in the following INVENTORY: (Pre 16 Bleck ir Color _(or by leaving a \ Anse core , the officer by whom this WARRANT was executed, DO SWEAR that the above INVENTORY contains a TRUE AND DETAILED ACCOUNT of all the PROPERTY seized by me on said WARRANT. Paphe Gy AFFIANT (SEAL) & ete Der. ctor SWORN TO AND SUBSCRIBED BEFORE ME THISTHE ___-OQ__day of Movember, AD., 208.3. 281728