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On January 20, 2010, law-enforcement agents, acting pursuant tojudicial orders, performed video surveillance on a coffee shop located near the intersection of 47th Street and8th Avenue in Manhattan, New York

(the “Coffee Shop”). CHAPMAN was seated near the window ofthe Coffee Shop and had with her a bag (the “Tote Bag”). After approximately ten minutes, I observed a minivan pass bythe window ofthe Coffee Shop. Basedonmyconversationswith another law-enforcement agent, I know that Russian Government Official #1 has been observed driving the minivan, recognizedby its license plate, onanumber ofoccasions subsequent t o January 20, 2010. As part o f the surveillance operation, law-enforcement agents utilized a commercially available tool that can detect the presence of wireless networks. The agents detected the presence ofaparticular network (the“AD HOC NETWORK”) with two associated MAC

addresses (“MACADDRESSA”and”MACADDRESS B”). Based on my training, experience, and participation in this investigation, I believe that on January 20, CHAPMAN (from the Coffee Shop) andRussian Government Official #1 (from the minivan) used their laptop computers (which bore “MAC ADDRESS A” and- “MAC ADDRESS B”) t o create the AD HOC NETWORK andto usei ttocommunicate with one another.

b. On March 17, 2010, law-enforcement agents, acting pursuant tojudicial orders, performed video surveillance on a book store located in the vicinity ofGreenwichand Warren Streets i n Manhattan (the “Book Store”). CHAPMAN was inside the Book Store. At the same time, Russian Government Official #1 was across the street from the Book Store, carrying a briefcase. I observed CHAPMAN pull a laptop out ofthe Tote Bag. CHAPMAN stayed i n the Book Store for approximatelythirty minutes; Russian Government Official #1was in the vicinity of the Book Store (but outside) for approximately twenty ofthose thirty minutes. As part ofthe surveillance operation, law-enforcement agents utilized a commercially available tool that candetect the presence ofwireless networks. Law- enforcement agents were able todetect a particular MAC address - MAC ADDRESS A - at the time that CHAPMAN was observed powering on her laptop computer; law-enforcement agents were also able todetermine that the electronic device associated with MAC ADDRESS A created the AD HOC NETWORK. Approximately three minutes after the

creation ofthe AD HOC NETWORK, another electronic device with MAC ADDRESS B was detected joining the AD HOC NETWORK.

c. On April 7, 2010, law-enforcement agents, acting pursuant tojudicial orders, performed surveillance on Russian Government Official #1 starting from the point that he left his office in mid-town Manhattan. According to a law-enforcement agent who was

6B.

performing surveillance on Russian Government Official #1, i tappeared that Russian Government Official #1 noticed the presence ofthe surveillance teamand returned to his office. As part ofthe surveillance operation, law-enforcement agents utilized a commercially available tool that candetect the presence of wireless networks. On this occasion; the agents detected the presence o f MAC ADDRESS A, but not MAC ADDRESS B. Based on my training, experience, andparticipation in this investigation, I believe that on April 7, Russian Government Official #1set outto communicate covertly with CHAPMAN, who was using a laptop computer that bore MAC ADDRESS A - but that he (Russian Government Official #1) abortedhiseffortsto communicate with CHAPMAN because hedetected the FBI’s surveillance ofhim.

d. On April 21, 2010, May 5, 2010, June 9, 2010, andJune 16, 2010, law-enforcement agents, acting pursuant tojudicial orders, observed CHAPMAN in the vicinity of Russian Government Official #1. On each ofthese four occasions, law-enforcement agents discerned the ‘presence o f MAC ADDRESS A and MAC ADDRESS B using the commercially- available tool described above, and were able todetermine that after the electronic devices associated with MAC ADDRESS A and MAC ADDRESS B joined the AD HOC NETWORK, the electronic devices transferred data between, each other.