seisure warrent documents for ripco bbs.txt

1000 HOWTOs for various needs [WINDOWS]

The warrant alleges violations under Title 18, USC, Sections
1343, 1030, 1029, 1962, 1963, and 371.
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  --------------(Begin Barbara Golden's Affidavit)-----------------

State of Illinois    )
                     )    SS
County of Cook       )


                                    AFFIDAVIT

     1.   I, Barbara Golden, am a Special Agent of the United States
Secret Service and have been so employed for the past fourteen years; the
past three years as a Special Agent.  I am present assigned to the
Computer Fraud Section of the United States Secret Service in Chicago.  I
am submitting this affidavit in support of the search warrants for the
residence of Bruce Xxxxxxxxxxx xxxx North Lawndale, Chicago, Illinois
(including the detached garage behind the house) and his business address
at xxxx North Clybourn, Chicago, Illinois.
     2.  This affidavit is based upon my investigation and information
provided to me by Special Agent G. Kirt Lawson of the United States Secret
Service in Phoenix, Arizona and by other agents of the United States
Secret Service.  I have also received information from Sergeant Abigail
Abrahams of the Illinois State Police.
     3.  Additionally, I have received technical information and
investigative assistance from Roland Kwasny of Illinois Bell Telephone
Corporate Security.

                              VIOLATIONS INVOLVED

     4.  This warrant is requested to recover unauthorized and illegally
used access codes posted on the RIPCO BBS by computer hackers and to
develop evidence of their illegal use of those codes in violation of
federal criminal laws, including:

                                - 1 -

     a.  18 USC 2314 which provides federal criminal sanctions against
individuals who knowingly and intentionally transport stolen property or
property contained by fraud, valued at $5,000.00 or more, in interstate
commerce.
     b.  18 USC 1030(a)(6) provides federal criminal sanctions against
individuals who, knowingly and with intent to defraud, traffic in
interstate commerce any information through which a computer may be
accessed without authorization in interstate commerce.
     c.  Other federal violations involved in this case may include Wire
Fraud (18 U.S.C. 1343), Access Device Fraud (U.S.C. 1029) and other
violations listed and described on page 15, 16, and 17 of the attached
affidavit of Special Agent Lawson.

                                LAWSON AFFIDAVIT

     5.  The attached affidavit of Special Agent Kirt Lawson is
incorporated herein in its entirety and is attached as Attachment 1.
Lawson's affidavit is based upon a two year undercover investigation  of
the United States Secret Service involving an undercover bulletin board
located in Phoenix, Arizona.  Essentially, Lawson's affidavit and my
investigation establish probably cause to believe:
     a.  Bruce Xxxxxxxxxxx, using the computer hacker handle "Dr. Ripco",
has been operating the RIPCO BBS in Chicago since approximately
December 10, 1983.

                                - 2 -

     b.  During the time period named in the Lawson affidavit unauthorized
access codes were posted on the RIPCO BBS by various computer hackers.
     c.  The access codes posted on the RIPCO BBS have been determined by
Special Agent Lawson to be valid access codes which are being used without
authorization of the true authorized user of the access codes.  Moreover,
in many cases the access codes have been reported stolen by the true
authorized user(s).
     d.  Special Agent Lawson's investigation has further determined that
the access codes posted on the RIPCO BBS are not concealed from the system
administrator of the BBS and could be seen by the system administrator
during an examination of the BBS.

     6.  I have personally worked with S.A. Lawson on computer crime
investigations and known him to be a reliable agent of the Secret Service
and an expert in the field of telecommunication investigations.
     7.  I personally received the attached affidavit on May 1, 1990 and
have verified with S.A. Lawson that it is in fact his affidavit and have
verified with S.A. Lawson that it is in fact his affidavit and that it
accurately reflects his investigation.  I have verified information with
respect to his investigation with Special Agent Lawson as recently as May
7, 1990.

                                - 3 -


                            UPDATED PROBABLE CAUSE

     8.  On May 1, 1990, I personally observed that the surveillance
cameras described on pages 32 and 33 of Lawson's affidavit still
appear to be in operation.  (The antennas and surveillance cameras
located at the Clybourn address are reflected in the photographs
attached as Attachment 2.)
     9.  On May 4, 19900, I personally updated the status of the
telephone lines at the Clybourn address with Roland Kwasny of Illinois
Bell Telephone.  Kwasny advised me that those telephones continue to
be in active service at this time.

                              ITEMS TO BE SEIZED

     10.  On pages 36 to 39 of his affidavit S.A. Lawson describes the
items to be seized at the search locations.


                            Locations to be Searched

     11.  The complete description of the business location to be searched
on Clybourn Street is contained on page 30 of S.A. Lawson's affidavit.
(Photographs of that location are in Attachment 2.)  I have personally
observed the resident to be searched on Lawndale on May 1, 1990.  The
photographs attached to this affidavit as Attachment 3 truly and
accurately show the residence known as xxxx North Lawndale, Chicago,
Illinois, as of May 1, 1990.

                                - 4 -


                        EXAMINATION OF COMPUTER RECORDS

     13.  Request is made herein to search and seize the above described
computer and computer data and to read the information contained in and on
the computer and computer data.

        14.  The following attachments are incorporated herein by reference:
Attachment 1 - Affidavit of S.A. Lawson (39 pages): Attachment 2 -
Photographs of the Clybourn address (2 pages); Attachment 3 - Photographs
of the Lawndale address (1 page).


                                         (signature)
                                         Special Agent Barbara Golden
                                         United States Secret Service


Sworn and Subscribed to before
me this 7th day of May, 1990.


(signature)
James T. Balog
UNITED STATES MAGISTRATE


                                - 5 -

                ** (End Barbara Golden's Affidavit) **

++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

               ** (Begin G. Kirt Lawson's affidavit) **

++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++


State of Arizona    )
                    )    SS
County of Maricopa  )


                                  AFFIDAVIT

     1.  Your affiant G. Kirt Lawson has been a Special Agent of the U.S.
Secret service for eighteen years and in the course of his employment has

investigated over 100 cases involving credit card fraud, theft, computer-
related crime, and other offenses.   I have training from the Secret
Service in the investigation of computer fraud, have attended six or more
seminars on investigative procedures from AT&T and the Secret Service, and
have lectured on computer crime for the IEEE (an international
professional group of electrical engineers) and Bellcore (the research /
security organization owned by the regional Bell operating companies.)
Within the last year, I have assisted the Arizona Attorney General's
office with the execution of three computer-crime search warrants, and the
Austin, Texas field office of the Secret Service with the execution of
another computer-related search warrant.  Over the last two years, I
have assisted numerous state, local, and federal law enforcement
agents in half a dozen U.S. cities by providing information and
technical assistance which has led to the execution of over a dozen
search warrants in computer crime cases nationwide.

                                - 1 -


                            SOURCES OF INFORMATION

     2.  Your affiant has also received technical information and
investigative assistance from the following experts in the field of
telecommunication fraud and computer crime:
     a.  R.E. "Sandy" Sandquist,, Regional Security Manager, U.S. Sprint
Communications Company, who has been so employed since 1987, and was
previously employed by General Telephone (GTE) as a special agent,
technical investigations since 1983.  He has investigated cases of
communications fraud involving computer hackers, computer bulletin board
systems (see Definitions section below), and the abuse of voice mail
message computers, involving over 100 systems.  He has assisted law
enforcement search teams in the execution of search warrants, and has
trained many state, local and federal agents in the investigation of
computer and communications crime.
     b.  Stephen R. Purdy, Special Agent, U.S. Secret Service, currently
the Assistant to the Special Agent In Charge of Fraud Division of the
Computer Diagnostic Lab in Washington, D.C.  He is a member of the Federal
Computer Investigations Committee, and is currently its Co-Chair.  He has
helped to design training programs in computer crime and
telecommunications fraud investigations for the Federal Law Enforcement
Training Center in Glynco, Georgia.  He also developed and instructs in
the Secret Service's training program in computer fraud investigations.

                                - 2 -

     c.  George Mehnert has been a Special Agent with the Arizona Attorney
General's office for more than twelve years; for the last three years, he
has been responsible for special projects including the investigation of
computer crime.  He has taken courses relating to computer hardware and
software programs from various industry sources and a local college, and
has worked with computer hardware and software, including communications
equipment and analysis tools, in investigative matters for more than six
years.  Mehnert has instructed numerous state and local law enforcement
agencies in the methodology of executing search warrants involving
computers, and in the investigation of computer crimes.  He recently
published of article on this subject in a law enforcement periodical.  In
the past two years, Mehnert has been involved in thirty warrant searches
relating to the seizure of computer of communications-related evidence.
     d.  In addition to the above, affiant has also received technical
assistance and information from the following communication industry
sources: Steve Matthews, Telenet;  Leila Stewart, MCI;  Sue Welch, MCI;
Toni Ames, U.S. West;  Connie Bullock, ComSystems (a long-distance
carrier);  Karen Torres, MidAmerican Communications Company;  Richard
Petiollo and Richard Kopacz, AT&T;  Hank Kluepfel and David Bauer,
Bellcore (a research/security company owned by the Bell Regional Operating
Companies);  Marty Locker, International Telephone and Telegraph (ITT),
and credit industry sources:  Valerie Larrison, American Express;  MaryAnn
Birkinshaw, TRW:  Michelle Mason, CBI (TRW and CBI are national card
bureaus).

                                - 3 -


                          DEFINITIONS AND EXPLANATIONS


     3.  Computer hackers:  individuals involved in the unauthorized
intrusion into computer systems by various means.  They commonly identify
themselves by aliases of "hacker handles" when communicating by voice or
electronically with other hackers.  Because they normally communicate
through electronic bulletin board systems in several states, and because
they often conduct their hacking activities against victims at many
locations outside their local calling area, computer hackers typically use
long-distance carrier customer authorization codes without the permission
of the individuals or corporations to which they are assigned, in order to
achieve "free" long distance telecommunications (over standard voice
lines, or over data-communications services).  Search warrants executed in
hacker cases routinely produce evidence of theft of communications
services, and often product of possession, use, and/or distribution of
credit cards as well.
     4.  Electronic Bulletin Board System (BBS):  an electronic
bulletin board is a computer operated as a medium of electronic
communications between computer users at different locations.
Users access the BBS by telephone from distant locations (often
their residences), using their own computers and communication
devices (modems).  Typical functions of a BBS include (1) providing
storage for a software library; (2) allowing users to "download"
(copy to their own computers) various files or software programs;
(3) allowing users to

                                - 4 -

exchange and store messages by "electronic mail"; and (4) publishing
of text files and tutorials, which contain information or instructions
on various subjects of interest to the users.  Although many BBS's are
operated as commercial services to the public (large services such as
Compuserve and The Source may offer many more functions than those
listed above), thousands of BBS's are privately operated by
individuals who run them from their residences, or by special-interest
clubs.  It is common for a BBS to have several sections or
"conferences" on the system, to which a particular level of access is
required:  many users might have access to lower-level sections, while
only some users would be permitted to access the highest-level
sections (many sysops --defined below-- "voice validate" a prospective
user, using a telephone call to screen users and determine whether