_________________________________________________________________

IN THE THIRD DISTRICT COURT - ALL DEPARTMENT

IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

_________________________________________________

AFFIDAVIT FOR SEARCH WARRANT

STATE OF UTAH )
:ss
County of Salt Lake )

The undersigned affiant, Detective Marc Bucher of Salt Lake City Police Dept., upon
an oath or written affidavit subscribed under criminal penalty, declares:

That your affiant has reason to believe:

THAT

On the premises known as :

AT&T Wireless, 11760 US Highway One, 6th Floor, North Palm Beach, FL 33408.
AT&T is also doing business at AT&T Wireless 611 S Main St., Salt Lake City,
UT 84111;

Sprint, 6480 Sprint Parkway, Overland Park, KS 66251. Sprint is also doing
business at 665 E 400 S, Salt Lake City, UT 84102;

T-Mobile, 4 Sylvan Way Parsippany, NJ 07054. T-Mobile is also doing business

at 613 E 400 S Ste. D, Salt Lake City, UT 84102;

Verizon Wireless, 180 Washington Valley Rd, Bedminster, NJ 07921. Verizon is

also doing business at 2274 S 1300 E, Ste G-14, Salt Lake City, UT 84106.

further described as cellular phone service providers and any other

technology-related business associated with this account.,

In the City of Salt Lake City, County of Salt Lake, State of Utah, there is now certain
property or evidence described as:

For each cell tower described in labeled Section 1, the Service Providers named
in this affidavit are required to disclose all records and other information (not
including the contents of communications) about all communications made

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 using the cell tower during the corresponding time frame(s) listed in Section 1,
including the records that identify:

A. The telephone call number and unique identifiers for each wireless device
in the vicinity of the tower ("the locally served wireless device") that registered
with the tower, including Electronic Serial Numbers ("ESN"), Mobile Electronic
Identity Numbers ("MEIN") Mobile Identification Numbers "MIN" Subscriber
Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network
Numbers ("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), and
International Mobile Equipment Identities ("IMEI");

B. The source and destination telephone numbers associated with each

communication (including the number of the locally served wireless device and
the number of the telephone that called, or was called by, the locally served
wireless device);

C. The date, time, and duration of each communication;

D. The "sectors" (i.e., the faces of the towers) that received a radio signal from
each locally served wireless device; and

E. The type of communication transmitted through the tower (such as phone call
or text message).

These records should include records about communications that were initiated
before or terminated after the specified time period, if part of the communication
occurred during the relevant time period identified in Section 1.

Section 1:
Cell Tower Locations, Dates and Times

1) The cellular towers that provided service to 701 E 2100 S, SALT LAKE CITY,
UT, 84106, United States, 40°43’32.58” N 111°52’14.65” W, on October 19,
2019 from 1500 hours to 1700 hours MDT (Mountain Daylight Time).

2) The cellular towers that provided service to 701 E 2100 S, SALT LAKE CITY,
UT, 84106, United States, 40°43’32.58” N 111°52’14.65” W, on October 31,
2019 from 1150 hours to 1320 hours MDT (Mountain Daylight Time).

3) The cellular towers that provided service to 905 E 2100 S, SALT LAKE CITY,
UT, 84106, United States, 40°43’32.12” N 111°51’54.39” W, on October 31,
2019 from 1310 hours to 1350 hours MDT (Mountain Daylight Time).

and that said property or evidence:

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 Was unlawfully acquired or is unlawfully possessed;

has been used or is possessed for the purpose of being used to commit or
conceal the commission of an offense; or

is evidence of illegal conduct.

Affiant believes the property and evidence described above is evidence of the crime
or crimes of Aggravated Robbery.

The facts to establish the grounds for issuance of a Search Warrant are:

Your affiant is a Salt Lake City Police Officer and has been a police officer for over
nine years. Your affiant is currently assigned to the Robbery & Violent Crimes
Unit. Prior to that, your affiant worked assignments in patrol, bike patrol, and as a
detective in the Salt Lake City Police Department’s Metro Investigations Unit and
the Property Crimes Unit. Your affiant has investigated crimes ranging from but not
limited to Murder, Aggravated Robbery, Aggravated Assault, Drug Investigations,
Burglary, and other persons or property-related crimes. Your affiant has attended
two police academies; Weber State Law Enforcement Academy and Salt Lake City
Police Department Police Academy. Your affiant has also received specialized
training related to current crime trends, crime recognition, and investigative
techniques. Your affiant is certified to write search warrants and has completed
all necessary associated trainings.

The facts in this affidavit come from your affiant’s personal observations, training
and experience, and information obtained from other agents and witnesses. This
affidavit is intended to show merely that there is sufficient probable cause for the
request warrant and does not set forth all of your affiant's knowledge about this
matter.

On 10/31/2019 at approximately 1320 to 1330 hours, two black male adults

entered the Stroud Jewelers located at 905 E 2100 S in Salt Lake City, UT. The
males initially looked around the store at the various pieces of jewelry in the
display cases while the owner of the store, hereafter referred to as ZS, was helping
another customer. Once the customer left the store, the two males spoke with ZS
and expressed an interest in spending money at his store and purchasing multiple
pieces of jewelry. One of the two males then left the store momentarily and went
out into the parking lot. This male returned moments later along with an additional
black male adult. One of the black male adults then forcefully grabbed ZS and
pushed him up against a wall, ordering him to open the display cases because
they were robbing him. When ZS didn’t immediately comply, the male produced a
handgun from his waistband and pointed it as ZS, then forced him to the ground,
again ordering him to comply.

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ZS complied while the black male adults, who proceeded to rob him and went
through the display cases, stealing whatever jewelry they could. During this time,
one of the suspects went to the back door located in the office area, and opened
the door, letting in a fourth black male adult who also assisted in stealing additional
items. The suspects took not only jewelry, but also accessed a safe in the office
area and stole large quantities of cash and loose diamonds. After gathering jewelry
and merchandise, the suspects ran from the store through the front and back
doors. ZS looked outside and saw the suspects enter a dark newer-model Dodge
Charger that was parked in a parking stall directly north of his business in the
shared parking lot between his business and the Walgreen’s located at 909 E
2100 S. The Dodge Charger had tinted windows and no license plates on it. Upon
getting into the Dodge Charger, the four black male adult suspects drove out of
the parking lot and continued westbound on 2100 S, then turned southbound on
800 E, where ZS could no longer see their vehicle. ZS called police at 1347 hours
to report what had just happened and officers responded to his business.

Your affiant also responded to the scene and spoke with ZS, who initially estimated
his loss to be around 70,000 dollars worth of merchandise, but acknowledged that
this amount would likely change upon completing a more-thorough inventory. ZS
expressed to your affiant that because of the dynamic nature of the robbery, he
couldn’t recall every description for each of the suspects but stated there were a
few details that stood out to him. ZS stated that the initial and primary suspect
he dealt with had a thicker or larger stature and that he was wearing an all-blue
Nike athletic jumpsuit; consisting of both shirts and pants being part of the same
blue jumpsuit. ZS recalled that the second male who was with him had a hoodie
sweatshirt on that was either partially or fully gray. ZS recalled one of the other
two men was heavily-tattooed. ZS described all the suspects as being in their 20s
or 30s.

Crime Lab personnel responded to the scene and processed it for fingerprint
and DNA evidence. Due to backlog, these items have not yet been analyzed by
the Crime Lab. Assisting officers and detectives also canvassed the area around
Stroud Jewelers for relevant evidence or video. Unfortunately, Stroud Jewelers did
not have a surveillance system and none of the surrounding businesses had video
or the video they did have didn’t capture any of the robbery or flight afterward.

During the time of the initial investigation on scene, your affiant was made aware
that just prior to this robbery taking place, officers were called to King’s Custom
Jewelry located at 701 E 2100 S, Salt Lake City, UT on a related call. This
jewelry store is only two blocks west of Stroud Jewelers. Officers had initially
responded here because the ownership believed a group of black male adults
were “casing” their store, or preparing to rob it, based on their suspicious actions.
Your affiant later met directly with the ownership of King’s Custom Jewelry and
learned what happened. The owner of King’s Custom Jewelry, hereafter referred
to as KK, informed your affiant that on 10/19/2019 between 1500 and 1700 hours,

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a black male adult wearing an all-blue Nike jumpsuit had entered his store and
inquired about having some custom jewelry made for him. This individual seemed
suspicious because KK and his staff could see that he exited a dark newer-model
Dodge Charger vehicle with no plates on it, which he didn’t park in their own
parking lot, but rather in the rear parking area of an adjacent business. KK and his
staff also observed that there were other male black adults that remained in the
vehicle while the male in the blue Nike jumpsuit came inside. This was suspicious
behavior that KK believed may be indicative of a robbery about to take place.

The male in the blue Nike jumpsuit eventually left the store but returned on
10/31/2019 around 1200 hours, wearing the same clothing, this time accompanied
by another male black adult wearing a gray and green hoodie sweatshirt. They
initially stopped by the store for a short time, left, and came back minutes later.
Again, KK and his staff noted that these two males arrived in a dark newer-model
Dodge Charger, and that they parked it a significant distance away from their
business, in the rear parking area of the business to the east. This again worried
KK and his staff that these suspicious actions were indicative of a robbery about
to take place. KK and his staff tried to act as though there were more employees
present in the back office area of their business, which KK believes may be a
reason that the suspects ultimately left shortly after 1300 hours and didn’t commit
the robbery of his store but instead chose to rob the Stroud Jewelers two blocks
east of his store just 20 to 30 minutes later.

Your affiant was able to obtain video footage from King’s Custom Jewelry that
showed the suspects and their descriptions as described by KK. Your affiant
was also able to locate video surveillance footage at the Beans and Brews store
east of King’s Custom Jewelry, which shows the four black males arriving in a
newer-model dark Dodge Charger and parking in the rear parking area of Beans
and Brews and then two of those males, the male in the blue Nike jumpsuit and
the other male wearing the gray and green hoodie, exit the vehicle and walk into
King’s Custom Jewelry.

Only limited views and descriptors are available for the suspects and the vehicle
they are observed driving. Some of these details are specific, but not sufficient by
themselves to establish a conclusive identity.

The day following the robbery, your affiant released images of the robbery
suspects to the media. The next week, your affiant received a call from an
organization called Jewelers Security Alliance (JSA), based out of New York City,
NY. JSA is a private organization that specializes in jewelry-related crimes and
tracks the occurrence of these crimes nationwide. JSA had observed the press
release your affiant had released, and immediately recognized the suspects as
being involved in a series of 8 different robberies out of California over the past
four months. JSA sent your affiant some photographs of the California robberies,

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and your affiant noted that it appeared to be the same individuals. Your affiant was
given contact information for the detectives working the California robbery cases.

Your affiant learned that a task force had been put together out of California to aid
in investigating these robberies. Your affiant was added to the contact list for this
task force and your affiant contacted two of the detectives leading that task force.
Your affiant received additional case surveillance, photographs, and police reports
from each jurisdiction out of California. Your affiant again reviewed the video and
photographs and further concluded that the suspects appeared to closely match
the appearance of the suspects in this latest Salt Lake City robbery. Your affiant
also noted that the modus operandi appeared to be very consistent with the other
robberies, as well.

As part of the investigation in California, the detectives in each of the

different jurisdictions applied for and received search warrants for the cellular
communication records associated with each cellular tower in the geographic
areas surrounding the locations of the robberies. This is frequently referred to as a
“tower dump” and is used to identify if a common cellular phone was at each of the
locations. Through your affiant’s years of experience in dealing with suspects of
violent crime, suspects will often communicate with co-conspirators, loved ones,
etc. while they are watching their target or preparing to commit a crime. It is also
common for suspects to communicate after the crime to verify their safety and/or
success in committing the intended crime. This information has been developed
through follow-up interviews and examination of their electronic devices, through
additional search warrants. The examinations show text messages, data usage,
and phone calls before and after crimes. Through my training and experience,
I have also observed that phones continually communicate with cell towers and
receive phone calls, text message, and data, even if their user is not actively
manipulating their electronic device. All this activity is monitored and stored by the
towers for billing and engineering reasons. Therefore this technique can be useful
when other reasonable leads have been exhausted.

This technique is best utilized when the occurrence of the crimes in question took
place at specific and different times and locations, as is the situation in the Salt
Lake City robbery and California robberies involving these same suspects.

Your affiant is aware that the detectives working on the robberies out of California
have received some cellular communication records back. Your affiant believes
it is necessary to obtain the requested cellular communication records related
to times and locations when the suspects were known to be in Salt Lake City,
specifically at the King’s Custom Jewelry and Stroud Jewelers, which times are
specifically listed in this affidavit. This information may then be used to identify
any common phone numbers found within the geographical area of the Salt Lake
City robbery compared to that of the California robberies.

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Your affiant further believes it is necessary to obtain these records with the
purpose of identifying the suspects. Evidence has shown that these suspects
have committed multiple violent robberies, all within the space of approximately 4
months, and there is a likelihood that these robberies will continue to occur unless
steps are taken to interdict their occurrence. The exact records requested are
found below in Section 1:

Section 1:

Cell Tower Locations, Dates, and Times

1) The cellular towers that provided service to 701 E 2100 S, SALT LAKE CITY,
UT, 84106, United States, 40°43’32.58” N 111°52’14.65” W, on October 19, 2019
from 1500 hours to 1700 hours MDT (Mountain Daylight Time).

2) The cellular towers that provided service to 701 E 2100 S, SALT LAKE CITY,
UT, 84106, United States, 40°43’32.58” N 111°52’14.65” W, on October 31, 2019
from 1150 hours to 1320 hours MDT (Mountain Daylight Time).

3) The cellular towers that provided service to 905 E 2100 S, SALT LAKE CITY,
UT, 84106, United States, 40°43’32.12” N 111°51’54.39” W, on October 31, 2019
from 1310 hours to 1350 hours MDT (Mountain Daylight Time).

Section 2:

Legal Background of State and Federal procedure

1. The State of Utah may use a court order or warrant under Utah Rule of Criminal
Procedure 40 and under federal code 18 U.S.C. § 2703(d) to require a provider
of electronic communication service to disclose records or other information
pertaining to a subscriber to or customer of such service, not including the contents
of any communications. Cellular service providers are providers of an electronic
communications service, as defined in 18 U.S.C. § 2510(15). Accordingly, the
State of Utah may use a court order or warrant issued under 18 U.S.C. § 2703(d)
to require the Service Providers to disclose the items described in Part II of
Attachment A, which constitute "record[s] or other information pertaining to a
subscriber to or customer of such service." 18 U.S.C. § 2703(c)(1).

2. The Court has jurisdiction to issue the proposed Order because it is "a court of
competent jurisdiction," as defined in 18 U.S.C. § 2711. See 18 U.S.C. § 2703(d).
Specifically, the Third District Court of Utah is a district court of the State of Utah
that has jurisdiction over the offense being investigated.

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3. A court order under§ 2703(d) "shall issue only if the governmental entity offers
specific and articulable facts showing that there are reasonable grounds to believe
that ... the records or other information sought, are relevant and material to an
ongoing criminal investigation." 18 U.S.C. § 2703(d). Accordingly, the next section
of the instant Application sets forth specific and articulable facts showing that
there are reasonable grounds to believe that the records and other information
described in Attachment A are relevant and material to an ongoing criminal
investigation.

Section 3:

Facts about Cell Towers

1. Many cellular service providers maintain antenna towers ("cell towers") that
serve specific geographic areas. Each cell tower receives signals from wireless
devices, such as cellular telephones, in its general vicinity. These cell towers allow
the wireless devices to transmit or receive communications, such as telephone
calls, text messages, and other data. The tower closest to a wireless device does
not necessarily serve every call made to or from that device.

2. In addition to a unique telephone number, one or more unique identifiers identify

each cell phone. Depending on the cellular network and the device, the unique
identifiers for a cell phone could include an Electronic Serial Number ("ESN"),
a Mobile Electronic Identity Number ("MEIN"), a Mobile Identification Number
("MIN"), a Subscriber Identity Module ("SIM"), a Mobile Subscriber Integrated
Services Digital Network Number ("MSISDN"), an International Mobile Subscriber
Identifier ("IMSI"), or an International Mobile Equipment Identity ("IMEI").

3. Cellular service providers routinely maintain historical cell-tower log information,

including records identifying the wireless telephone calls and communications
that used a particular tower. For each communication, these records may include
the telephone call number and unique identifiers for the wireless device in the
vicinity of the tower that made or received the communication ("the locally served
wireless device"); the source and destination telephone numbers associated with
the communication (including the number of the telephone that called or was
called by the locally served wireless device); the date, time, and duration of the
communication; the "sectors" (i.e., the faces of the towers) that received a radio
signal from the locally served device; and the type of communication transmitted
through the tower (such as phone call or text message).

4. Based on the above facts, there is reason to believe that the records desired in
this affidavit would identify which wireless devices were near the victim businesses
at the times of the robberies. This information will assist law enforcement in

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 identifying persons present near each of the robberies at the time of the robberies
and serve to eliminate or support any investigative actions to follow.

Pursuant to Rule 40(c) of the Utah Rules of Criminal Procedure, AT&T,

Sprint, T-Mobile and Verizon Wireless will be protected against unreasonable
interference and the search will be during daytime hours. Based on law
enforcement experience with AT&T, Sprint, T-Mobile and Verizon Wireless, your
affiant knows that in order to obtain the above requested information, a search
warrant is required rather than a subpoena This is because AT&T, Sprint, T-Mobile
and Verizon Wireless, and other cell phone carriers, require a probable cause
finding within the document. Therefore, the evidence desired cannot be obtained
through subpoena alone.

This affidavit has been reviewed by Attorney Morgan Vedejs of the SL County District
Attorney's Office, and it has been approved for presentation to the court.

WHEREFORE, your affiant prays that a Search Warrant be issued for the seizure of
said items in the daytime.

I declare under criminal penalty of the State of Utah that the foregoing is true
and correct.

Executed on: 17th day of December, 2019 @ 01:29 PM by /s/ Marc Bucher

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 _________________________________________________________________

IN THE THIRD DISTRICT COURT - ALL DEPARTMENT

IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

_________________________________________________

SEARCH WARRANT

No. 2029401

COUNTY OF SALT LAKE, STATE OF UTAH

To any peace officer in the State of Utah:

Proof by Affidavit made upon oath or written affirmation subscribed under criminal
penalty of the State of Utah having been made to me by Detective Marc Bucher of Salt
Lake City Police Dept., this day, I am satisfied that there is probable cause to believe

THAT

On the premises known as :

AT&T Wireless, 11760 US Highway One, 6th Floor, North Palm Beach, FL 33408.
AT&T is also doing business at AT&T Wireless 611 S Main St., Salt Lake City,
UT 84111;

Sprint, 6480 Sprint Parkway, Overland Park, KS 66251. Sprint is also doing
business at 665 E 400 S, Salt Lake City, UT 84102;

T-Mobile, 4 Sylvan Way Parsippany, NJ 07054. T-Mobile is also doing business

at 613 E 400 S Ste. D, Salt Lake City, UT 84102;

Verizon Wireless, 180 Washington Valley Rd, Bedminster, NJ 07921. Verizon is

also doing business at 2274 S 1300 E, Ste G-14, Salt Lake City, UT 84106.

further described as cellular phone service providers and any other

technology-related business associated with this account.,

In the City of Salt Lake City, County of Salt Lake, State of Utah, there is now certain
property or evidence described as:

For each cell tower described in labeled Section 1, the Service Providers named
in this affidavit are required to disclose all records and other information (not

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 including the contents of communications) about all communications made
using the cell tower during the corresponding time frame(s) listed in Section 1,
including the records that identify:

A. The telephone call number and unique identifiers for each wireless device
in the vicinity of the tower ("the locally served wireless device") that registered
with the tower, including Electronic Serial Numbers ("ESN"), Mobile Electronic
Identity Numbers ("MEIN") Mobile Identification Numbers "MIN" Subscriber
Identity Modules ("SIM"), Mobile Subscriber Integrated Services Digital Network
Numbers ("MSISDN"), International Mobile Subscriber Identifiers ("IMSI"), and
International Mobile Equipment Identities ("IMEI");

B. The source and destination telephone numbers associated with each

communication (including the number of the locally served wireless device and
the number of the telephone that called, or was called by, the locally served
wireless device);

C. The date, time, and duration of each communication;

D. The "sectors" (i.e., the faces of the towers) that received a radio signal from
each locally served wireless device; and

E. The type of communication transmitted through the tower (such as phone call
or text message).

These records should include records about communications that were initiated
before or terminated after the specified time period, if part of the communication
occurred during the relevant time period identified in Section 1.

Section 1:
Cell Tower Locations, Dates and Times

1) The cellular towers that provided service to 701 E 2100 S, SALT LAKE CITY,
UT, 84106, United States, 40°43’32.58” N 111°52’14.65” W, on October 19,
2019 from 1500 hours to 1700 hours MDT (Mountain Daylight Time).

2) The cellular towers that provided service to 701 E 2100 S, SALT LAKE CITY,
UT, 84106, United States, 40°43’32.58” N 111°52’14.65” W, on October 31,
2019 from 1150 hours to 1320 hours MDT (Mountain Daylight Time).

3) The cellular towers that provided service to 905 E 2100 S, SALT LAKE CITY,
UT, 84106, United States, 40°43’32.12” N 111°51’54.39” W, on October 31,
2019 from 1310 hours to 1350 hours MDT (Mountain Daylight Time).

and that said property or evidence:

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 Was unlawfully acquired or is unlawfully possessed;

has been used or is possessed for the purpose of being used to commit or
conceal the commission of an offense; or

is evidence of illegal conduct.

Affiant believes the property and evidence described above is evidence of the crime
or crimes of Aggravated Robbery.

YOU ARE THEREFORE COMMANDED:

to make a search in the daytime of the above-named or described person, vehicle,

item, and/or premises for the herein-above described property or evidence and if you
find the same or any part thereof, retain such property in your custody subject to the
direction of a prosecutor or an order of this Court.

Dated: 17th day of December, 2019 @ 02:31 PM /s/

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