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This is an example search warrant to place a “lojack” type tracker on a vehicle.

This first
page has the language that would be used for the LOCATION, PROPERTY &
PERSONS pages of the search warrant & affidavit. The example also has the
statement of probable cause which is the justification for the tracker to be placed on the
inside of the vehicle. In this example the tracker is needed to identify “chop shops”,
however a tracker could be placed for different types of investigations, i.e., narcotics
ring, id theft ring, etc. A vehicle in a public place can have a tracker installed on the
exterior without a search warrant. Be sure to read this example before you simply cut
and paste it to ensure that its statements will be true for your Statement of Probable
Cause.

YOU ARE THEREFORE COMMANDED TO SEARCH:


Authorizing the installation and subsequent removal of a vehicle location tracking device in
a 1994 Honda Accord, beige in color, with a CA license plate of 4ZXV811 and VIN of
1HGCE18324A002590.

FOR THE FOLLOWING PROPERTY:


Vehicle monitoring and tracking locations for a period of (60) days from the date of
installation.
STATEMENT OF PROBABLE CAUSE

On March 05, 2008 at approximately 1200 hours, your affiant was contacted by Ofc. Arrestor of
the San Luis Beach PD. Ofc. Arrestor told me he had located a 2002 Cadillac Escalade, that had
been reported stolen to the LAPD/ Beach Front Division. Ofc. Arrestor told me the vehicle was
parked in a driveway, in the east/west alley, south of OceanWave Highway and east of Maple
Avenue. Ofc. Arrestor told me he was at the intersection of OceanWave Hwy and Maple Avenue
monitoring the alley, as it was the only way the vehicle could leave. Ofc. Arrestor also advised
me the stolen vehicle was being blocked by a tan or brown vehicle. Ofc. Arrestor asked if the
BeachFront Taskforce for Regional Auto theft Prevention (TRAP) Team would respond and
assist with the surveillance and investigation.

While your affiant was en-route to the location, your affiant could hear Ofc. Arrestor relay via
radio that the stolen vehicle was leaving the location. Ofc. Arrestor followed the vehicle and as it
approached 115th Street, the driver exited and began running away. The vehicle rolled into a
parked vehicle and came to a stop.
Ofc. Arrestor chased the suspect, who fled east into the yards of the residences along 115th
Street. As your affiant arrived at the location, Ofc. Arrestor was initiating a perimeter and San
Luis Beach PD patrol units began searching for the suspect. After a short period of time the
suspect, later identified as Adrian Guzman, was located hiding along the house at 1234 Main
Street.

Ofc. Arrestor identified Guzman as the same subject he had seen exiting the stolen Cadillac.
Ofc. Arrestor placed Guzman under arrest for violation of 10851 (a) VC and Guzman was
transported to San Luis Beach PD for booking.

During the course of the incident, a second subject, identified as Juan Martinez, was also taken
into custody. Martinez was seen leaving the alley at a high rate of speed in a 1994 Honda CA
license plate 4ZXV811. Ofc. Arrestor believed this was the vehicle that was blocking the stolen
Escalade in the driveway. San Luis Beach units stopped the Honda and contacted Martinez, who
did not possess a valid drivers license. Martinez also admitted to Sgt. Smith of the San Luis
Beach PD that he had recently been arrested for operating a chop shop.

Martinez was arrested for violation of 12500 VC and transported to San Luis Beach PD booking
and further questioning related to the Escalade.

Following the arrest of Adrian Guzman, your affiant proceeded to the corner of Maple Avenue
and 155th Street to examine the stolen Escalade. Your affiant could see the vehicles ignition had
been stripped and it appeared the vehicles tires and rims had been removed and replaced with a
“dummy”set.

Your affiant returned to the alley where the stolen vehicle had originally been located by Ofc.
Arrestor. With his assistance, we were able to identify the location where the Escalade had been
parked, as 3714 West OceanWave Highway.
Based on the events that had occurred, your affiant applied for and was granted a search warrant
for the location.

While at the location pursuant to the search warrant, your affiant located a set of 4 chrome rims
and Falken tires and a set of 4 DRIV chrome rims and Khumo tires. Believing one of these sets
may belong to the Cadillac Escalade, your affiant contacted the victim, Helpless and asked him
to describe his rims and tires. Helpless told me the rims were chrome with a “V” in the middle
and the tires were Falken “22 inch”. This fit the description of the tires your affiant had located.

Also seized from the rear of the location were 3 blue chrome rims with Michelin tires and 1
Image chrome rim, with a Toyos tire. Inside the rear shed, your affiant located a center console
to a Chevrolet Tahoe. Inside the console your affiant found an invoice to a Chevrolet Tahoe, CA
License plate 5NXV867. A record check indicated the vehicle had previously been stolen and
recovered in March of 2007.

Inside the trash barrel, which was located in the back yard, your affiant found two business cards
in the name of Mark Jones. I contacted Jones and asked him if he recently had his vehicle stolen
and he told me his Chevrolet Silverado was stolen on 2/28/08, while he was in San Miguel
Beach and the vehicle was recovered later the same day, in Santa Rosa Beach, CA.

Your affiant contacted Jesus Gonzalez, who rents the residence. Your affiant spoke with J.
Gonzalez regarding the stolen vehicle that had been at the location and all of the different
vehicle parts that we had located at the residence. Initially Gonzalez denied any wrongdoing in
the matter at hand, however; he later told me the following. Approximately two months ago,
Juan Martinez, known to Gonzalez as “Carlos”, which is Juan Martinez’s middle name,
approached Gonzalez at his home asking him to do some work on Martinez’s car. Gonzalez did
somebody work on Martinez’s vehicle and Martinez paid him.

Within the past couple of weeks Martinez has returned with two Chevrolet Silverado’s, that
Gonzalez believed to be stolen. The first time Martinez showed up, Gonzalez allowed him to use
his driveway to strip rims and tires from the vehicle. The second time Martinez showed up,
Gonzalez claimed he turned him away.
Gonzalez admitted to me he had bought a “Kicker” speaker box from Martinez for fifty dollars
and that he believed it was stolen.

The “Kicker” speaker box had been described as one of the items missing from Mark Jone’s
Chevrolet Silverado, which had been stolen and recovered on 2/28/08.

Gonzalez told me that he works at San Luis Beach Collision Center and is rarely home during
the day. He told me he has returned home on a few occasions to find vehicle parts that do not
belong to him, in his yard.

Gonzalez has no prior arrest record and there is no indication he is a member of the San Luis
Beach 13 Gang.

At the San Luis Beach PD Jail, I contacted Martinez. I advised Martinez of his Miranda Rights
and he told me he understood them. I asked him if he knew Guzman and he told me they were
both from San Luis Beach. I told Martinez that I believed he was with Guzman, just prior to
Guzman being arrested in the stolen vehicle. Martinez denied he was with Guzman and claimed
he was just at the gas station. I told Martinez his vehicle was seen parked behind the stolen
Escalade in the alley and Martinez denied it was him.

I asked Martinez if he had ever been arrested for operating a chop shop and he told me he had. I
asked him what was going on with the case and he told me he was not sure.

I concluded my interview with Martinez and believed there was insufficient evidence to charge
him with anything related to the stolen Escalade. He was later released from San Luis Beach PD.

On 3/5/08, Det. Ruiz arrived at the scene of the search warrant. Det. Ruiz informed me that he
knew Adrian Guzman and Juan Martinez to be known San Luis Beach 13 Gang Members. Dep.
Ruiz told me that Martinez and Guzman both lived on Felton Ave., in the City of San Luis
Beach.
On 3/5/08, I was contacted by Investigator Todd Morris. Inv. Morris advised me that on or
about January 7, 2008, detectives served a search warrant at Juan Martinez’s residence, located
at 10320 Felton Ave., in the City of San Luis Beach. Inv. Morris told me that three stolen
vehicles were recovered from the location, some in various states of disrepair.

Inv. Morris told me investigators have been attempting to conduct surveillance on several San
Luis Beach 13 Gang Members, whom they believe to be involved in the theft of and “stripping
of parts” of several vehicles. Inv. Morris told me that Juan Martinez is one of the subjects they
have been attempting to watch. Inv. Morris related that their efforts have been unsuccessful due
to the fact that the subjects use counter surveillance.

Due to the foregoing, it is your Affiant’s opinion that Juan Carlos Martinez is using the 1994
beige, Honda Accord, with CA license plate 4ZXV811 as a means of committing and assisting
with the commission of several vehicle related felonies,

It is your Affiant’s opinion that the installation of a monitoring device on the vehicle described
above will enable your Affiant and TRAP Detectives to track the vehicle to operating “chop
shops.” It will potentially provide Detectives with additional suspects and locations related to
this vehicle theft investigation. The monitoring device will ensure surveillance teams are not
detected.

Your Affiant request the Court approve a monitoring receiver- transmitter and antenna device to
be temporarily affixed to the vehicle described in this warrant. The device is to be covertly
installed inside the vehicle. Your Affiant requests day and night time monitoring, which will
enable your Affiant to monitor the vehicle at any time.

Your affiant is aware that the service of this search warrant in the normal manner will alert the
suspect(s) under investigation, as well as other as yet unidentified members of this auto theft
organization, that they are the objects of a police investigation. For this reason, your affiant
requests permission to serve this search warrant, in the discretion of the officers executing this
warrant, in a manner that would not alert the suspects that they are under police investigation.
Such service might include surreptitious entry, non disclosure of law enforcement agency
executing this search warrant, service of the warrant during nighttime hours, and not leaving a
copy of this search warrant. Your Affiant requests that this entire Search Warrant and Statement
of Probable Cause / Affidavit be sealed because disclosure could irremediably harm the ongoing
criminal investigation, in accordance with California Rules of Court Rule 243.1(d). Your Affiant
requests permission to re-enter the vehicle to remove or repair the device if it fails to transmit.
Your Affiant is requesting night time service due to the fact the device may need to be installed,
repaired or removed under the cover of darkness, so as to not be detected. Your affiant requests
such permission through the signing of this warrant by the magistrate.

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