RE: Next steps

The team wanted to get you the below paragraphs reference begining the process for the "body search warrant" for MAXWELL to mitigate 3rd party residence, etc. and setting PC.

Vr

Vince

Forwarded message
From: (NY) (FBI)".
Date: Jul 1, 2020 12:34 PM
Subject: Maxwell and Borgerson connection
To: |(BS) (FBI)"

Cc:

It has been publicly reported that MAXWELL and BORDERSON are or were boyfriend and girlfriend. Since approximately October of 2018 MAXWELL and BORGERSON have had a shared joint bank account. Bank records show them to have a shared home address of 301 Summer Street Manchester MA. Accurint checks show both MAXWELL and BORGERSON to have a connection to 301Summer Street. MAXWELL often uses BORGERSON as a last name on certain records. AMAZON shows packages being delivered to either MAXWELL or BORGERSON up until March of 2020 at 301 Summer Street.

Between March and May of 2019 BORGERSON's bank records show him making multiple purchases at multiple locations between Hookset and Newbury New Hampshire.

M, let me know what else you need; I am at your service. I assume you'll take the lead with Amanda in drafting any SW, anticipatory or otherwise, to seize the defendant from premises owned by a third party. It looks like in the First Circuit a separate search warrant is required unless law enforcement reasonably believed at the time of entry that (1) the suspect resided at the location and (2) the suspect would be present. United States v. Young 835 F.3d 13, 20 (1st Cir. 2016). I can send you the regular SW forms we use if you need them.

Also, please advise if you think we will need a search warrant tonight, so I can alert Judge Johnstone. Her cut-off time last night on sending warrant materials was 9:00 p.m., but she would likely go another hour or so later if needed.

Thanks.

Thanks very much. Once the FBI is able to determine which building the phone is located in, we will seek a warrant to search that particular location. Would you please send me a go-by for a premises SW in your District?

The FBI is hoping to have the location identified tonight, but I do not have a clear sense of timing on that yet. Assuming we cannot get the warrant materials to the Judge in time to swear out the warrant tonight, do you know how early she would be available to swear it out tomorrow morning?

Thanks again for all of your help.

M, here are go-bys for residence and person. I will check on timing for swearing out tomorrow.