USA v. Patel
District Judge Katherine B. Forrest
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Patel worked at the Leukemia and Lymphoma Society (LLS) from 2006 to Oct. 2014. Between Sept. 2012 and Sept. 2014 Patel awarded LLS contracts to Pyramid Tech. Solutions Inc. in exchange for $274,000 in kickbacks paid by co-defendant Vadlamuti. On Dec. 5, 2016, Patel and Vadlamuti were indicted for conspiracies to commit honest services wire fraud, to violate the Travel Act, and to commit money laundering. District Court denied Patel's motion seeking return of emails seized from two email accounts. It rejected his claim the June 10, 2016, warrants issued under the Stored Communications Act authorizing seizure of all emails sent, received or created by the two accounts between Oct. 1, 2012, and June 10, 2016, violated the Fourth Amendment's particularity requirement by authorizing the government to seize every email written by him even months after he ceased being employed by LLS. The warrants authorized law enforcement to review records produced by Google Inc., Yahoo! Inc. and Microsoft Corp. to locate any evidence, fruits, and instrumentalities of five specific offenses and provided nine examples of documents covered by the warrant. Such "modicum of vagueness" did not render the warrants invalid.
