Is a catch-all phrase sufficient to restrict the scope of a search warrant?

MultiRegion, United States of America

The following excerpt is from United States v. Khan, No. CR-S-10-175 KJM (E.D. Cal. 2013):

crime being investigated, the catch-all phrase was not attached to any specifically described crime and so provided no context to inform interpretation of the catch-all phrase. See also United States v. Adjani, 452 F.3d 1140, 1148 (9th Cir. 2006) (finding warrant sufficiently specific to restrict discretion of agents when it limited search of computer for evidence of extortion).

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