Full opinion text
ORDER ANTOON, District Judge. The Defendants in this case have been charged in a 71-count Third Superseding Indictment with crimes involving employment and harboring of aliens and tax evasion. This Order addresses the Defendants’ motions to suppress evidence seized during a wide-scale search and seizure operation that was conducted in November 2002. Having considered the parties’ written submissions and oral argument, as well as the evidence and testimony presented at a nine-day evidentiary hearing, the Court concludes that the Defendants’ motions shall be granted in part and denied in part. Some, but not all, of the seized evidence shall be suppressed. I. Background Defendants Jesse Maali (“Mr. Maali”) and M. Saleem Khanani (“Mr. Khanani”) are businessmen who own and operate several businesses together in the Orlando, Florida area. Mr. Maali and Mr. Khanani also are each involved in other businesses independent' of one another, that is, in which the other of them has no interest. Among the businesses in which they are both involved are Defendants Big Bargain World, Inc. and SS Mart, Inc., entities which in turn own several “Big Bargain World” (“BBW”) stores that sell retail merchandise, primarily to tourists. Mr. Maali and Mr. Khanani are also the sole officers and shareholders of Sports Domi-nator, Inc., a BBW spinoff that sells sports-related retail merchandise in “Sports Dominator” stores. Defendant David Portlock (“Mr. Portlock”) is an accountant who has performed accounting services for Mr. Maali, Mr. Khanani, and their businesses; his accounting business also has many other clients who are in no way connected with this case. On November 6, 2002- — the same day that an Indictment was filed under seal against most of the current Defendants — • United States Magistrate Judge James G. Glazebrook authorized search warrants for thirteen locations: seven BBW stores; two Sports Dominator stores; a BBW corporate office/warehouse; the office of Mr. Portlock; the office of Maali Enterprises; and the residence of Mr. Maali. Additionally, on November 14, 2002, after searches of the first thirteen locations had begun, United States Magistrate Judge David A. Baker authorized a search warrant for a fourteenth location — a Shurgard storage unit that had been rented by Mr. Portlock. These search warrants were issued after the magistrate judges had been presented with a 59-page, 93-paragraph “Master Affidavit” (Khanani Ex. 14) sworn to by Agent Donald Buechner of the Immigration and Naturalization Service (“INS”), now known as Immigration, Customs, and Enforcement (“ICE”). The fourteenth warrant was also supported by an additional affidavit attested to by DEA Special Agent Timothy Jones. (See Government’s Ex. 14). In the Master Affidavit, Agent Buechner described an investigation by a multi-agen-cy task force of Mr. Maali and his businesses that had been underway since 1999. Agent Buechner stated that based on that investigation, there was probable cause to believe that searches of thirteen sites would lead to evidence of violation of federal law, including but not limited to: Title 8, United States Code, Section 1324(a)(l)(A)(iv), (encouraging or inducing undocumented aliens to come to, enter, or reside in the United States): Title 8, United States Code, Section 1324(a)(l)(A)(v)(I) (conspiracy to violate); Title 8, United States Code, Section 1324(a)(l)(A)(v)(II), (aiding and abetting the commission of any 1324(a)(1)(A) offense); Title 8, United States Code, Section 1324(a)(l)(A)(iii), (harboring aliens); and Title 26, United States Code, Sections 7201 and 7206, (Evasion of Employment Tax and False Employment Tax Returns). (Master Aff. at 2 ¶ 3). In the Master Affidavit, Agent Buechner recounted the task force’s investigation of the subject businesses, the employment of aliens by some of those businesses, and the manner in which the aliens were paid so as to avoid both detection by immigration officials and employment taxes. The task force investigators had determined through analysis of records and from conversations with cooperating informants that aliens had been employed at BBW stores “during the period January 1, 1999 through October 2002, ... and an elaborate scheme was used to hide payments to those aliens and disguise them as legitimate business transactions.” (Master Aff. at 4 ¶ 10). The payments were hidden through the establishment and use of four “shell company” accounts which were funded by proceeds from the retail sales of the businesses — proceeds which were disguised as operating expense payments to supposed vendors. The Master Affidavit lists by name more than fifty employees who were determined either never to have been authorized to work at Big Bargain World, not to have been authorized during at least part of their employment, or to have been paid from the shell company accounts but not reported as employees to the Florida Department of Revenue or the IRS. (Master Aff. at 8-25 ¶¶ 18-20). Also listed as to these employees are dates of birth, country of citizenship (where known), dates of entry into the country, and the amounts of payments received by them. (Master Aff. at 8-25 ¶¶ 18-20). At least six of the employees paid through the four shell company accounts were listed as employees of Sports Dominator on Sports Domi-nator’s Florida unemployment tax returns for 2000 and 2001. (Master Aff. at 47 ¶ 73). The Master Affidavit states that while “legitimate” employees of the businesses were paid regular wages through payroll bank accounts by a payroll company used by the businesses, between 1999 and 2001 unauthorized aliens were paid through a separate system using the accounts of the four shell companies — entities named T & S Printing, Florida Freight, Rainbow Merchandising, and Center Care Maintenance. (Master Aff. at 6-7, 8 ¶ 17). The shell company accounts had been established in 1999 by two BBW employees, Defendants Khan Aslam and Saeedullah Awan, who were under the direct control of Mr. Maali and Mr. Khanani. (Master Aff. at 6-7 ¶ 14). During 1999, 2000, and 2001, checks were written from the accounts of these shell companies to pay the unauthorized aliens’ wages. (Master Aff. at 5 ¶ 12). However, in June 2001 — shortly after grand jury subpoenas were served on the banks that held the shell companies’ accounts — the payments from these accounts stopped, and after that date the aliens were instead paid with cash. (Master Aff. ¶¶ 12, 16). Additionally, shortly after the grand jury subpoenas were served, three of the shell company accounts were closed, and activity in the fourth shell company account ceased. (Master Aff. at 7 ¶ 16). These four “shell companies provided no discernable service to their owners and were set up exclusively to conceal the criminal activity.” (Master Aff. at 6 ¶ 14). The shell company accounts were funded by sales and rental income from Mr. Maali and Mr. Khanani’s businesses; the Master Affidavit states that “[bjetween February 1999 and May 2001, approximately $2.25 million of Maali and Khanani sales and rental income was used to fund the four shell companies’ accounts, which were in turn used to pay the unauthorized alien and other employees working at Big Bargain World stores, the corporate office, and the warehouse.” (Master Aff. at 7 ¶ 15). The disguising of payments as expenses was achieved as follows. Funds received from sales of merchandise were deposited into “depository accounts,” and then transfers were made to expense accounts; as funds were needed to pay unauthorized alien employees, checks were written on expense accounts payable to one or more of the four shell companies, who then wrote checks to the unauthorized employees'. (Master Aff. at 28 ¶ 25). The funds that were deposited into the four shell company accounts came from eight different bank accounts controlled by Mr. Maali and Mr. Khanani, including accounts in the names of Defendants Big Bargain World, Inc., SS Mart, Inc., Denim Unlimited, Inc., Jeans Unlimited, Inc., and Barakat Corporation. (Master Aff. at 28-29 ¶ 25). The checks were signed by Mr. Maali or Mr. Khanani. (Master Aff. at 29 ¶ 25). Many-of the aliens’ paychecks were then cashed at the BBW stores. (Master Aff. at 29 ¶ 25). The wages that were paid through the four shell company accounts were not reported on employment tax returns filed with the State of Florida or the IRS. (Master Aff. at 29 ¶ 27). The four shell companies did not file any employment tax returns for 1999, 2000, or 2001, and none of the companies who contributed funds to the four shell accounts reported the unauthorized aliens on their employment tax returns. (Master Aff. at 29 ¶ 27). Thus, “the cost of the taxes associated with those wages were evaded.” .(Master Aff. at 29 ¶ 27). The Master Affidavit further states that “[i]n addition to the Big Bargain World and SS Mart employment tax returns therefore being false, the corporate tax returns for those entities would also be false if the payments were deducted as other types of operating expenses.” (Master Aff. at 29-30 ¶ 27). The use of the four shell company accounts also enabled the aliens to be shielded from detection by the INS; proper reporting on the employment tax returns would have put them at risk of detection due to the use of false social security numbers. (Master Aff. at 30 ¶ 28). ■ The Master Affidavit also reports that in 1998 the Department of Labor- (“DOL”) had investigated “the payment of employees at three Big Bargain World stores.” (Master Aff. at 5 ¶ 13). At the end of that investigation, “Big Bargain World, represented by [its] accountant David Portlock, admitted not paying [its] employees proper overtime, and submitted proper payment.” (Master Aff. at 5 ¶ 13). As part of the DOL investigation, Mr. Portlock and another accountant “were provided verbal and written instructions on the proper calculation and payment of overtime, child labor laws, and the proper completion of I-9 forms”- — forms that employers are required “to, fill out on every employee prior to the start of employment.” (Master Aff. at 5-6 ¶ 13). The Master Affidavit notes that two confidential informants (“Cls”) had provided information to the task force. Both of these Cls were former BBW employees who were not authorized to work in this country during at least part of the time they were employed there. (Master Aff. ¶¶ 29, 31, 37). Neither of the Cls had filled out an 1-9 form upon hire or completed the social security number box on their applications. (Master Aff. ¶¶ 29, 37). As to at least one of the Cls, Mr. Khanani was aware of the lack of work authorization. (Master Aff. ¶¶ 29, 31). Agent Buechner also noted that he had arrested other unauthorized aliens who had formerly worked at BBW, and those aliens had stated that they had not filled out 1-9 forms upon hire either. (Master Aff. at 33 ¶ 38). According to CI-1, BBW did not deduct social security taxes, federal income taxes, or state deductions from unauthorized aliens’ salaries. (Master Aff. at 32 ¶ 33). CI-1 also reported that the employees were told that if INS came to the store, a PA announcement, “Pick up line 7,” would be made; there was really-no line 7, and this was merely a signal regarding the presence of INS. (Master Aff. at 32 ¶ 34). The illegal “[ejmployees were then supposed to pretend to be customers, or to go to a nearby restaurant.” (Master Aff. at 32 ¶ 34). BBW also, according to CI-1, provided letters for the illegal employees to present to apartment complexes so that they could rent apartments. (Master Aff. at 32 ¶ 34). CI-1 also described a practice at BBW whereby sales were rung up until a designated total was achieved at a particular register; after that total was reached, the register was not used any more during that shift. (Master Aff. at 32 ¶ 36). Registers were cleared at the end of each shift, and the practice was reversed at the next shift. (Master Aff. at 33 ¶ 36). CI-1 believed that not all sales receipts were being reported so that sales taxes could be avoided. (Master Aff. at 33 ¶ 36). The Master Affidavit also recounts surveillance that the task force had conducted, (Master Aff. at 34-38 ¶¶ 39-50), and describes documents that had been recovered from trash receptacles at several of the sites for which search warrants were sought. (Master Aff. at 37-42 ¶¶ 51-68). For example, envelopes addressed to Mr. Portlock, Barakat Corporation, BBW, and others were recovered from the trash at Maali Enterprises (Master Aff. at 37-38); blank business checks with the name “T & S Printing” (one of the four shell companies) and documents of BBW, Sports Do-minator, Jeans Unlimited, Denim Blues, and Barakat Corporation were found in the trash at the BBW warehouse at 5858 Lakehurst Drive (Master Aff. at 38-40); an advertising brochure for Dunkin Donuts, TOGO’S, and 31 Baskin Robbins— other of Mr. Maali’s businesses — was also found at the 5858 Lakehurst warehouse (Master Aff. at 40 ¶ 61); a copy of Mr. and Mrs. Maali’s 2001 From 1040 tax return was found in the trash at Mr. Portlock’s office at 7345 Sand Lake Road (Master Aff. at 42 ¶ 67); and an envelope addressed to Big Bargain World, Inc. at 6454 International Drive from PayChex was recovered from the trash receptacle at Mr. Maali’s residence (Master Aff. at 42 ¶ 68). Agent Buechner explained that “[t]he financial documents related to Big Bargain World, SS Mart, Sports Dominator, Denim Unlimited, Jeans Unlimited, and Barakat Corporation are essential to determine whether the corporate income and employment tax returns filed with the State of Florida and IRS are true and correct, and determine the amount, if any, of taxes evaded through the scheme.” (Master Aff. at 43 ¶ 70). Additionally, “[t]he records are also needed to determine the source of the cash used to pay the illegal aliens and others after the four shell companies’ accounts were closed, and to further identify illegal alien employees that the Cls were not aware of.” (Master Aff. at 43 ¶ 70). The Master Affidavit concludes with 6$ pages describing a request for permission to search for and seize computers from the thirteen sites (Master Aff. at 51-57 ¶¶ 82-91). Agent Buechner explained that the government sought to seize computers and related equipment “in order to properly search the contents of those devices.” (Master Aff. at 56 ¶ 89). Agent Buechner then requested the issuance of search warrants for the thirteen described premises and “authorization to seize the items detailed in Attachment B” to the Master Affidavit. (Master Aff. at 59 ¶ 93). As noted earlier, this Master Affidavit was presented to a magistrate judge on November 6, 2002, and the magistrate judge issued warrants for thirteen sites that same day. After searches of those sites had begun on November 14, 2002, the fourteenth warrant was sought and obtained from another magistrate judge. Each of the warrants provides that based on the Master Affidavit of Agent Buechner (and, in the case of the fourteenth warrant, based also on the affidavit of DEA Agent Timothy Jones, which incorporates by reference Buechner’s Master Affidavit), U.S. Marshals and other authorized federal officers were commanded to search the named premises and to search for and seize the property listed in Attachment B, “which is contraband and/or evidence of the commis-r sion of a criminal offense, concerning violations of Title 8, United States Code, Section 1324(a)(1)(A) and Title 26, United States Code, Sections 7201 and 7206.” (Khanani Exs. 1-13; Government’s Ex. 14). Each warrant had two attachments: Attachment A, which describes the individual site to be searched and which varies from warrant to warrant; and Attachment B, which was the same as to each warrant except for the fourteenth warrant and which is identical to Attachment B to the Master Affidavit. Attachment B is comprised of three paragraphs. Paragraph A of Attachment B provides in part as follows: A. Items and information to be seized shall include the records, documents, and property described in Paragraph C found at the below-listed premises, for the time period 1997 to present relating to the employment and harboring of illegal aliens. The items and information being sought are financial documents and records of the entities[ ] Big . Bargain World, SS Mart, Sports Domi-nator, Denim Unlimited, Jeans Unlimited, Barakat Corporation, Florida Freight and Distributors, Center Care Maintenance, T & S Printing, and Rainbow Merchandising; as well as the individuals Jesse Maali, Saleem Khanani, Khan Aslam, and Saedullah Awan .... The rest of Paragraph A is a list of the first thirteen search sites. Paragraph B of Attachment B provides a definition of “documents” and “records” as used therein. Finally, Paragraph C of Attachment B lists eighteen categories of property to be seized from the thirteen locations, including but not limited to financial records, employee records, and computer equipment. Searches pursuant to all fourteen warrants were conducted on November 14, 2002. The execution of the searches involved approximately 200 law enforcement officers from several different law enforcement agencies, including but not limited to the FBI, DEA, INS, the Orange County Sheriffs Office. Most of the searching agents had not previously been involved in the task force investigation. However, the search team members were briefed the day before and the morning of the search; during those briefings copies of the Master Affidavit and search warrants were provided to the searchers. On the day of the searches, hundreds of boxes of documents were seized, as were nearly a hundred computer hard drives. Other items besides documents and computers were also seized. The seized items were then stored at a facility that the FBI rented specifically for that purpose at an office park in Maitland, Florida. The seized computer hard drives were copied or “mirrored” and the hard drives were returned to the Defendants approximately one week after the searches. Many of the documents and other items seized have also since been returned. It is undisputed that many of the items that were seized are neither relevant to the investigation nor responsive to the warrants, including records of other businesses and some personal items belonging to employees or family members of the Defendants. However, the parties do dispute the appropriate remedy for the overly broad seizure and whether some items that have not yet been returned by the Government should be ordered returned. II. Discussion The Fourth Amendment to the United States Constitution provides; “The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.” In their motions to suppress, the Defendants seek suppression of all seized evidence based on several portions of this provision. The Defendants challenge both the search warrants themselves and the manner in which the searches and seizures pursuant to those warrants were carried out. They argue that the search warrants were facially invalid because they were unconstitutionally overbroad and lacking in particularity, and they assert that the agents who executed the warrants seized items that were beyond the scope of even the overbroad warrants. The Defendants argue that the invalidity of the warrants was not cured by good-faith reliance on the warrants by the searching officers, and the Defendants aver that the manner in which the search was conducted and the seizure of numerous items beyond the warrants’ terms mandates wholesale suppression of all evidence seized — even evidence admittedly within the terms of the warrants. Additionally, Mr. Khanani argues that the search of an office at 6458 International Drive was completely unauthorized because no warrant was obtained for that location. The motion filed by Mr. Maali and the corporate Defendants further seeks return of improperly seized property. After brief mention of the threshold issue of the Defendants’ standing as to the fourteen search locations, the substantive issues raised with respect to the searches will be addressed in turn. A. Standing In his motion, Mr. Khanani asserts that he has standing to object as to all of the search locations except for the Maali Enterprises office and the Maali residence. The Government contends, however, that Mr. Khanani and all of the other Defendants except Mr. Portlock also lack standing as to Mr. Portlock’s office and storage unit, and the Government argues that Mr. Portlock has standing only as to those two locations. Mr. Portlock makes arguments as to sites beyond his office and storage unit, but he apparently concedes that he has standing only as to his office and storage unit and states that his arguments about the other sites go to show the flagrant disregard of the warrants as a whole. (See Doc. 306 at 3-4). In any event, it is clear that with respect to each of the fourteen sites there is at least one Defendant who has standing to object as to the search thereof. Thus, no further discussion of the issue of standing is necessary. B. The Specificity of the Warrants The Defendants raise several challenges to the sufficiency of the warrants. Although the Defendants do not contend that probable cause for issuance of the warrants was totally lacking, they argue that the warrants provided for seizure of items beyond the scope of the narrow probable cause showing made in the Master Affidavit and that the warrants did not particularly describe the things to be seized as required by the Fourth Amendment. The Defendants assert that the eighteen categories in Attachment B to the warrants and Master Affidavit include every possible type of business or personal financial record of the Defendants and that several of the categories do not bear any relationship to the crimes alleged to have been committed. The Defendants also argue that there was a lack of specification as to what type of evidence would be found at each of the fourteen locations, and they further aver that the warrants improperly called for seizure of each category of record without requiring examination of the records to determine whether the record pertained to the employment tax or INS violations for which probable cause had been provided. The Defendants contend that this overbreadth and lack of particularity rendered the warrants “general warrants” improperly authorizing the wholesale seizure of records. Additionally, the Defendants challenge the warrants’ computer-seizure provisions. Finally, Mr. Portlock asserts that the fourteenth warrant is deficient for lack of a specific date, and Mr. Portlock also challenges the sufficiency of the probable cause allegations of the Master Affidavit as to his office and storage unit. The issuing magistrate judge’s determination that probable cause exists for a search warrant is entitled to deference. Indeed, the Supreme Court has “repeatedly said that after-the-fact scrutiny by courts of the sufficiency of an affidavit should not take the form of de novo review. A magistrate’s ‘determination of probable cause should be paid great deference by reviewing courts.’ ” Illinois v. Gates, 462 U.S. 213, 236, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983) (quoting Spinelli v. United States, 393 U.S. 410, 419, 89 S.Ct. 584, 21 L.Ed.2d 637 (1969)); see also Massachusetts v. Upton, 466 U.S. 727, 732-733, 104 S.Ct. 2085, 80 L.Ed.2d 721 (1984) (finding error by appellate court “in failing to grant any deference to the decision of the Magistrate to issue a warrant,” noting that “ ‘[a] grudging or negative attitude by reviewing courts toward warrants’ is inconsistent with the desire to encourage use of the warrant process by police officers and with the recognition that once a warrant has been obtained, intrusion upon interests protected by the Fourth Amendment is less severe than otherwise may be the case”) (quoting United States v. Ventresca, 380 U.S. 102, 108, 85 S.Ct. 741, 13 L.Ed.2d 684 (1965)); United States v. Nixon, 918 F.2d 895, 900 (11th Cir.1990) (“The issuing magistrate is to make a ‘practical, common-sense decision’ about whether the ‘totality of the circumstances’ indicate that there is probable cause that the sought-for evidence will be obtained. The standard for our review of the magistrate’s determination is ‘simply to ensure that the magistrate had a “substantial basis for ... con-clud[ing]” that probable cause existed.’ We have also said that the practical nature of the magistrate’s decision justifies ‘great deference’ upon review and calls for upholding the magistrate’s findings even in marginal or doubtful cases.”) (quoting Illinois v. Gates, 462 U.S. 213, 238-39, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983), and United States v. Lockett, 674 F.2d 843, 845 (11th Cir.1982)) (alterations in original); United States v. Betancourt, 734 F.2d 750, 754 (11th Cir.1984) (“[Pjrobable cause exists ‘if facts within the magistrate’s knowledge and of which he had reasonably trustworthy information would warrant a man of reasonable caution in the belief that a crime was committed and that evidence is at the place to be searched.’ A magistrate’s decision that probable cause exists is conclusive absent arbitrariness.”) (quoting United States v. Strauss, 678 F.2d 886, 892 (11th Cir.1982)); United States v. Miglietta, 507 F.Supp. 353, 357 (M.D.Fla.1980) (“In reviewing the affidavit to ascertain whether it furnished probable cause for the warrant sought, it is given a ‘common sense and realistic’ interpretation. A magistrate’s factual conclusions in determining probable cause are entitled to considerable deference.”) (citations omitted). Examination of the sufficiency of the affidavits and warrants must be conducted with these deferential standards in mind. 1. Breadth and, Particularity “In order for a search to be reasonable, the warrant must be specific. Specificity has two aspects: particularity and breadth. Particularity is the requirement that the warrant must clearly state what is sought. Breadth deals with the requirement that the scope of the warrant be limited by the probable cause on which the warrant is based.” Does I Through IV v. United States (In re Grand Jury Subpoenas Dated December 10, 1987), 926 F.2d 847, 856-57 (9th Cir.1991) (citations omitted); see also United States v. Weinstein, 762 F.2d 1522, 1530-31 (11th Cir.1985) (discussing both overbreadth and lack of particularity). Both of these aspects of specificity are challenged here. In their overbreadth argument, the Defendants contend that the warrant called for the seizure of items that were not related to the crimes for which probable cause was provided in the affidavit, and in their particularity argument they assert that the warrant’s terms were so vague as to provide insufficient guidance to—and to leave improper discretion to—the searching agents. “The scope of the warrant, and the search, is limited by the extent of the probable cause.... [Pjrobable cause must exist to seize all the items of a particular type described in the warrant,” and “[tjhus, the concept of breadth may be defined as the requirement that there be probable cause to seize the particular thing named in the warrant.” In re Grand Jury Subpoenas, 926 F.2d at 857 (citations omitted); cf. United States v. Abbell, 963 F.Supp. 1178, 1185 (S.D.Fla.1997) (“A magistrate judge’s decision to issue a search warrant is necessarily guided by the information presented regarding the specific offense which was allegedly committed. In essence, the nature of the offense is the foundation upon which the need for the search is conducted.”). The Defendants argue that the items listed in Attachment B to the Master Affidavit and the warrants amount to nearly every financial record of the entities at issue. Additionally, they particularly challenge categories 6, 7, and 8 of Attachment B; these categories, which have been quoted in full in footnote 9, supra, pertain to loan records, monies held in foreign accounts, and credit card records. However, the Government emphasizes that a “paper puzzle” had to be assembled to piece together the fraud and that in a case like this one documents which would be seemingly innocuous in isolation could well be revealed to constitute a small part of a large fraudulent picture when viewed in conjunction with other evidence. The Government asserts that these “records are relevant to the ownership of the businesses, and to tracing the fruits and in-strumentalities of the charged crimes.” (Doc. 305 at 4). The Government is correct in noting that in complex financial fraud cases, the need to assemble a “paper puzzle” has been recognized and breadth in warrant provisions has been tolerated. See United States v. Wuagneux, 683 F.2d 1343, 1349 (1982). For example, in United States v. Travers, 233 F.3d 1327, 1330 (11th Cir.2000), the Eleventh Circuit agreed with the characterization of the district court that the breadth issue was a “close call” where the search warrant allowed for the seizure of “all documents involving real estate, litigation, property, mailings, photographs and any other material reflecting identity, and anything reflecting potential fraud.” The court noted that the ease “involve[d] a complex scheme to commit financial fraud concerning real property” and because “[a] wide variety of documents were relevant to prove this scheme ..., the agents applied for and received a warrant which cut a wide swath through [the defendant’s] papers and documents.” 233 F.3d at 1330. Additionally, in United States v. Abbell, 963 F.Supp. 1178 (S.D.Fla.1997), the court rejected the defendants’ attack regarding the nexus between the probable cause allegations and the documents as to which seizure was authorized by the warrants. The court noted that firsthand knowledge or observation of the interior of a to-be-searched office' “is desirable but not required,” and stated that the fact that a warrant attachment contains an extensive listing is not sufficient by itself to render a warrant overbroad. 963 F.Supp. at 1195. In Andresen v. Maryland, 427 U.S. 463, 96 S.Ct. 2737, 49 L.Ed.2d 627 (1976), the Supreme Court had rejected the defendant’s argument that the list in the warrants of documents to be seized rendered the warrant overly general, discussing the “paper puzzle” referenced in Wuagneux: Under investigation was a complex real estate scheme whose existence could be proved only by piecing together many bits of evidence. Like a jigsaw puzzle, the whole “picture” of petitioner’s false-pretense scheme with respect to [the real estate lot at issue] could be shown only by placing in the proper place the many pieces of evidence that, taken singly, would show comparatively little. The complexity of an illegal scheme may not be used as a shield to avoid detection when the State has demonstrated probable cause to believe that a crime has been committed and probable cause to believe that evidence of this crime is in the suspect’s possession. 427 U.S. at 480 n. 10, 96 S.Ct. 2737. Thus, at least in cases involving fraudulent schemes where the proof of guilt involves the piecing together of seemingly innocuous documents, some breadth and generality in warrant descriptions have been tolerated. In the instant case, although the Defendants contend that too broad a set of records was called for in the search warrants, the Court is unpersuaded. To be sure, the warrants are broadly worded and encompass many documents. However, warrants of such breadth have been upheld, especially in white-collar crime cases involving fraud where a “paper puzzle” must be assembled “from a large number of seemingly innocuous pieces of individual evidence.” Wuagneux, 683 F.2d at 1349. The investigation here had revealed the existence and use of four shell companies as part of a scheme to employ unauthorized aliens and evade taxes, and many documents would be relevant to such a case. The Government was, quite reasonably, interested in determining or verifying who had ownership interests in the various businesses and the sources and flow of funds among the individuals and entities involved. The specific categories about which the Defendants complain are not so far removed from the crimes alleged that they are not connected to the probable cause allegations, and they do not render the warrants unconstitutionally over-broad. And, the failure of the Government to pinpoint exactly which records would be found at each location does not invalidate the warrant; there is no way the Government could have made such predictions, and the Master Affidavit presented enough information to support a reasonable conclusion that any of the locations could have housed any of the records sought. The parties have fiercely debated the notion of “pervasive fraud” and whether it applies in this case to justify the broad seizure of records. This dispute stems from a line of cases holding that “in cases involving a pervasive scheme to defraud, all the business records of the enterprise may properly be seized.” United States v. Sawyer, 799 F.2d 1494, 1508 (11th Cir.1986) (citing United States v. Accardo, 749 F.2d 1477 (11th Cir.1985) and United States v. Brien, 617 F.2d 299 (1st Cir.1980)). The Defendants contend that because the businesses at issue here—with the exception of the four shell companies— are undisputedly involved in legitimate retail operations, not all records could be seized. The Government, however, argues that the extent of the employment of unauthorized aliens at BBW—at one 80% of the workforce was allegedly made up of unauthorized aliens—justified a broad but not wholesale seizure of records and rendered many items potentially relevant to the case. Thus, the Government does not contend that the Defendant businesses are sham businesses, but it asserts that the extent of the unlawful employment practices by the businesses justified a wide-scale seizure. The Government has the better argument on this point. Although not “illegal” operations, the businesses that were the subject of the warrants are alleged to have employed a large number of unauthorized aliens and to have evaded a large amount of taxes by virtue of that employment. As noted above, many documents ' could be relevant to piecing together the whole picture, and the extent of the alleged scheme justified authorization of seizure of the described categories of items. Next, as to insufficient particularity, the Defendants contend that the warrants failed to provide guidance to the searching agents as to what documents could properly be seized, in essence authorizing a general seizure. However, under controlling case law, the warrants at -issue pass muster in this regard because they were limited to the crimes described in the warrants and the supporting affidavit. In Wuagneux, the Eleventh Circuit examined the particularity issue in the context of a white-collar crime case. The court explained: [The Fourth Amendment’s particularity] requirement is aimed at preventing “general, exploratory rummaging in a person’s belongings.” A description is sufficiently particular when it enables the searcher to reasonably ascertain and identify the things authorized to be seized. Failure to adequately enforce the particularity requirement would undermine the warrant requirement itself, and increase the risk of an excessive intrusion into the areas of personal rights protected by the Fourth Amendment. 683 F.2d at 1348-49. Although in Marron v. United States, 275 U.S. 192, 196, 48 S.Ct. 74, 72 L.Ed. 231 (1927), the Supreme Court had stated that “as to what is to be taken, nothing is [to be] left to the discretion of the officer executing the warrant,” this assertion has often been recognized as an overstatement and a description of a standard which few warrants could meet. See, e.g., Wuagneux, 683 F.2d at 1349 n. 4 (“As this court and others have observed ... if this statement [from Marrón ] were construed as a literal command, no search would be possible. Instead, our concern is whether the warrant provides sufficient guidelines and limitations to meet the test of particularity already described above.”) (citations omitted); United States v. Tranquillo, 330 F.Supp. 871, 875 (M.D.Fla.1971) (“[T]he doctrine in Marrón suffered from overstatement. If it were to be applied literally, there could never be a valid seizure of anything not described in a search warrant.”). Instead, “[i]t is universally recognized that the particularity requirement must be applied with a practical margin of flexibility, depending on the type of property to be seized, and that a description of property will be acceptable if it is as specific as the circumstances and nature of activity under investigation permit.” Wuagneux, 683 F.2d at 1349. As noted earlier, in Wuagneux the Eleventh Circuit emphasized the Supreme Court’s “recognition] that effective investigation of complex white-collar crimes may require the assembly of a ‘paper puzzle’ from a large number of seemingly innocuous pieces of individual evidence.” 683 F.2d at 1349 (citing Andresen v. Maryland, 427 U.S. 463, 481, 96 S.Ct. 2737, 49 L.Ed.2d 627 (1976)). The Wuagneux court thus reasoned that “in cases ... involving complex financial transactions and widespread allegations of various types of fraud, reading the warrant with practical flexibility entails an awareness of the difficulty of piecing together the ‘paper puzzle.’ ” 683 F.2d at 1349. The warrants at issue in the instant case are sufficiently particular. They are limited as to time frame, as to the crimes for which the items are sought, and as to the persons and entities whose records could be seized. These limitations are sufficient to satisfy the Fourth Amendment. The first sentence of Attachment B to the warrants states, “Items and information to be seized shall include the records, documents, and property described in Paragraph C found at the below-listed premises, for the time period 1997 to present relating to the employment and harboring of illegal aliens.” (Attach. B to warrants, ¶ A). The second sentence then lists the entities and individuals at issue. (Id.) These sentences limit the scope of the warrant as to time, offense, and subject matter, and similar limitations through prefatory language, consideration of the totality of the warrants’ terms, and reference to the supporting affidavit have been upheld. See, e.g., United States v. Weinstein, 762 F.2d 1522, 1531-32 & n. 4 (11th Cir.1985) (concluding that exhibit to warrant particularly described property to be seized, noting that “the nature of the case under investigation” must be considered and the supporting affidavit set forth the scope and operation of the scheme); Wuagneux, 683 F.2d at 1350-51 (finding all of warrant’s eleven categories of items to be seized were sufficiently particular when read in conjunction with affidavit); In re Grand Jury Subpoenas, 926 F.2d at 857 (finding warrants sufficiently particular where they “listed a variety of documents as objects of the search ... [b]ut the list was qualified by the requirement that the document seized be ‘in the name of or have reference to’ [the defendant] or one of the twenty-one persons or entities that had been linked to him through the investigation”); In re Search Warrant Dated July 4, 1977, 572 F.2d 321, 326-27 (D.C.Cir.1977) (reversing district court’s determination that warrant was impermis-sibly broad, finding that district court had ignored warrant’s limitation to evidence of the particular crimes described in the affidavit); Agent Buechner’s Master Affidavit explained the scheme and crimes under investigation, and even though that affidavit was not attached to the warrant, in this circuit such attachment is not required for successful incorporation of its terms into the warrant, at least where, as here, the affidavit was provided to the searchers. Cf Wuagneux, 683 F.2d at 1350 n. 6 (finding that “the searchers were adequately informed of the limitations on the search given their instruction by [the affiant agent], their opportunity to read the affidavit, and its presence at the search site” even though “it was neither incorporated into the warrant by express reference nor attached to an accompanying warrant”). Warrants have survived particularity challenges even where they have called for the seizure of many categories of items. Although the warrants at issue here encompass many types of records, they sufficiently describe what is within their terms. See Andresen v. Maryland, 427 U.S. 463, 479-81, 96 S.Ct. 2737, 49 L.Ed.2d 627 (1976) (holding that the inclusion of the phrase “together with other fruits, instru-mentalities and evidence of crime at this [time] unknown” did not render search warrants impermissibly general where it was “clear from the context that the term ‘crime’ in the warrants referred] only to the crime of false pretenses with respect to the sale of [one specific real estate lot]”); Wuagneux, 683 F.2d at 1350 n. 5 (finding, in case involving racketeering, embezzlement, mail fraud, bank fraud, and the filing of false tax returns, that search warrant was sufficiently particular; warrant provided for seizure of eleven categories of records, the last of which encompassed “property that constitutes evidence of the above-enumerated offenses, fruits of the crimes named-above and property which is or has been used to commit the crimes enumerated herein”); see also United States v. Majors, 196 F.3d 1206, 1216 (11th Cir.1999) (concluding that “[d]ue to the peculiar nature of a charge of fraud, especially where corporations are used as vehicles of fraud, an application to search the premises of [the corporate office] for ‘[b]ooks, [l]edgers, [Receipts, [fin-voices, [b]usiness records, the identification of [fjinancial accounts and any other evidence which is evidence in violation of [two sections of Title 18]’ describefd] with particularity the items to be seized”); United States v. Sawyer, 799 F.2d 1494, 1508-09 & n. 15 (11th Cir.1986) (affirming denial of motion to suppress and finding search warrant sufficiently particular in case involving conspiracy and financial fraud; warrant authorized seizure from a corporate office of numerous types of records, including “banking records,” “personnel files,” and “financial records,” and the court noted that “the government here had no obligation to restrict the search to specific documents where the evidence, detailed fully in the accompanying affidavits, demonstrated widespread efforts to defraud customers through a variety of misleading disclosures and representations”); United States v. Santarelli, 778 F.2d 609, 613-14 (11th Cir.1985) (affirming denial of motion to suppress in case involving charges of subscription to false statements on income tax returns, finding that warrant authorizing seizure of, inter alia, “United States currency, promissory notes, life insurance policies, documents of assignment of life insurance policy proceeds” and “all property constituting evidence of the crimes of making and conspiring to make extortionate extensions of credit, financing extortionate extensions of credit, and collections of and conspiracy to collect extortionate extensions of credit” and “ ‘all property’ constituting evidence of loansharking” was sufficiently particular) ; United States v. Weinstein, 762 F.2d 1522, 1531-32 (11th Cir.1985) (finding warrant sufficiently specific in RICO conspiracy and mail and wire fraud case despite fact that name of co-defendant was in warrant but not affidavit where warrant and its attached exhibit clearly indicated that correspondence addressed to co-defendant and two business entities was within the scope of probable cause, and finding extensive list of firms and entities whose property was to be seized passed muster because the attached warrant affidavit clarified ambiguities as to the dates at issue and the scope of the fraudulent scheme); United States v. Blum, 753 F.2d 999, 1001 (11th Cir.1985) (rejecting “general warrant” argument in mail fraud case where warrant authorized seizure of specific items “and miscellaneous merchandise fraudulently obtained from vendors throughout the United States ... in violation of [three sections of Title 18]” and finding that “[t]he warrant was as specific as possible under the circumstances as to all merchandise seized”). In sum, the warrants are neither impermissibly broad nor insufficiently particular. 2. Computer Provisions The Defendants also challenge the warrants’ specificity regarding the search and seizure of computers. The Defendants contend that the warrants did not limit the scope of the computer searches and that no probable cause was given to support the conclusion that evidence of the alleged crimes would be found on computers. The Defendants assert that because of the massive amount of data that computers can store, it was highly likely that the seized computers would contain records that were not within the warrant. In the Master Affidavit, Agent Buechner devoted of the 59 pages to the “Computer Search.” (Master Aff. at 51-57). In that portion of the Master Affidavit, Buechner stated that “Big Bargain World Stores, Sports Dominator Stores, Maali Enterprises, ‘the warehouse,’ and Port-lock’s office ... used a computer network and stand alone desktop and laptop computers,” while it was “unknown whether the residence[ ] of ... Maali ... [was] tied to the computer ‘network,’ or contained] stand-alone computers.” (Master Aff. at 51 ¶ 82a). One of the confidential informants had advised that the “warehouse” locations contained corporate offices, including office space for Mr. Khanani and Mr. Maali, (Master Aff. at 52 ¶ 82d), and that “workers were recently employed to work in the corporate office and computerize employee files which were formerly kept on paper” (Master Aff. at 53-54 ¶ 84). Agent Buech-ner further states that “[t]he relevant information, • which may be found on the computer hardware, may be accessed by the software programs used by the stores, offices and possibly from home computers located at the homes of the principal subjects.” (Master Aff. at 52 ¶ 82e). The Master Affidavit further states that “Bargain World, Sports Dominator, Maali Enterprises, and Portlock’s computer hardware, software, related documentation, passwords, and data security devices have been used in the preparation of documents and materials in furtherance of the violations of ... law listed above.” (Master Aff. at 53 ¶ 83). The computer-related items are stated to be “integral tools of this crime and constitute the means of committing it,” and thus are both “instru-mentalities and evidence of the violations designated.” (Master Aff. at 53 ¶83). Agent Buechner further states in the Master Affidavit that based on his knowledge, training, and experience, and based on his consultations with the FBI Computer Analysis Response Team (CART), he knows that because of the volume of evidence that can be stored on computers, because of the possibility of attempted concealment of' evidence on computers, and because information deleted from computer equipment can sometimes still be recovered through ’special analytical methods as computer “residue,” search of computers often requires' the seizure of most or all computer equipment from a site so that it can “be searched later by a qualified computer examiner in a laboratory or other controlled environment.” (Master Aff. at 54-55 ¶ 85). Similarly, the same concerns render it necessary for peripheral devices, software, documentation, and data security devices to be seized for later examination by a qualified computer examiner in a laboratory or other controlled environment. (Master Aff. at 55-56 ¶ 86). The Master Affidavit provides that “[t]he government ... wish[es] to seize (or' retain) th'e hardware defined and described [in the Master Affidavit] in order ■ to properly search the contents of those devices.” (Master Aff. at 56 ¶ 89). Attachment B to the thirteen search warrants that provide for the seizure- of computer equipment states that “[a]s-to the seizure of computers and computer components, the government will return the computers promptly after retrieving and storing the information contained therein, which period will not exceed ten days.” (See Khanani Exs. 1-13, Attach. B). The provisions of the Master Affidavit are sufficient to support probable cause that evidence of the alleged crimes would be found on computers at the search locations. Agent Buechner recounted information provided by an informant as to the use and presence of computers at the businesses. Additionally, surveillance and trash pulls had revealed evidence of computer usage at the businesses. And, the Master Affidavit’s allegations, including the description of evidence that Mr. Maali took business records home, is sufficient, if only marginally so, to support seizure of computers at his residence. Furthermore, the lack of a detailed computer “search strategy” does not render the warrant deficient as to the search and seizure of computers. Some courts have required a detailed description of the strategy to be employed in a computer search.- See United States v. Hunter, 13 F.Supp.2d 574, 584 (D.Vt.1998) (“To withstand an overbreadth challenge, the search warrant itself, or materials incorporated by reference, must have specified the purpose for which the computers were seized and delineated the limits of their subsequent search.”); see also United States v. Barbuto, No. 2:00CR197K, 2001 WL 670930, at * 4-5 (D.Utah Apr.12, 2001) (concluding that computer search exceeded limits of the Fourth Amendment under controlling Tenth Circuit precedent and noting that search “methods or criteria should have been presented to the magistrate before the issuance of the warrants or to support the issuance of a second, more specific warrant once intermingled documents were discovered”). However, other courts have rejected arguments that a warrant must set forth the government’s proposed strategy for searching computers once seized. See United States v. Hill, 322 F.Supp.2d 1081, 1090 (C.D.Cal.2004) (rejecting defendant’s argument “that the warrant was overbroad because it did not define a ‘search methodology’ ” and finding defendant’s proposed methodology unreasonable). The Defendants rely in part on a Department of Justice computer search manual in support of their argument that a computer search strategy should have been provided in the Master Affidavit. (Computer Crime and Intellectual Prop. Sec., Crim. Div., U.S. Dep’t of Justice, “Searching and Seizing Computers and Obtaining Electronic Evidence in Criminal Investigations” (July 2002), Khanani Ex. 28). That manual does recommend the inclusion of a search strategy in the warrant affidavit. (See, e.g., Khanani Ex. 28 at 69 (“The third step in drafting a successful computer search warrant is to explain both the search strategy and the practical considerations underlying the strategy in the affidavit.... The affidavit should also explain what techniques the agents expect to use to search the computer for specific files that represent evidence of crime and may be intermingled with entirely innocuous documents.”)). However, the Defendants acknowledge that the manual is not authoritative. (See, e.g., Khanani’s Supplemental Brief, Doc. 414 at 16 n.30 (“Although Mr. Khanani in no way contends that the DOJ Guidelines are authoritative as to the constitutional requirements for the lawful search and seizure of computers and computer files, the violation of such Guidelines is evidence of the Government’s failure to act in good faith.”)). While it may be preferable and advisable to set forth a computer search strategy in a warrant affidavit, failure to do so does not render computer search provisions unduly broad. Cf. United States v. Thorn, 375 F.3d 679, 685 (8th Cir.2004) (finding that search warrant “which explicitly authorized the search and seizure of electronic storage media containing images of minors involved in sexual acts[ ] was sufficient to provide the authority to examine the contents of the various computer-related media” and that second warrant was not necessary before search of computers could be conducted). Warrants authorizing seizure of computer equipment for later off-site search of their contents for evidence pertaining to the alleged crimes have been upheld, especially where, as here, the supporting affidavit explained the reason such off-site analysis was necessary. See, e.g., United States v. Hay, 231 F.3d 630, 637 (9th Cir.2000) (“[T]he affidavit explained why it was necessary to seize the entire computer system in order to examine the electronic data for contraband. It also justified taking the entire system off site because of the time, expertise, and controlled environment required for a proper analysis.”); United States v. Upham, 168 F.3d 532, 535 (1st Cir.1999) (noting that “[a]s a practical matter, the seizure and subsequent off-premises search of the computer and all available disks was about the narrowest definable search and seizure reasonably likely to obtain the images” and that “[a] sufficient chance of finding some needles in the computer haystack was established by the probable-cause showing in the warrant application[,] and a search of computer and co-located disks is not inherently more intrusive than the physical search of an entire house for a weapon or drugs”); cf. Schandl, 947 F.2d at 465-66 (noting that “it might have been far more disruptive had the agents made a thorough search of each ... computer disc before removing it from [the defendant’s] home and office”). The fact that many records other than those responsive to a search warrant are likely to be stored on computers does not render seizure of computers for offsite searching impermissible. See, e.g., Upham, 168 F.3d at 535; Hunter, 13 F.Supp.2d at 583 (“[UJntil technology and law enforcement expertise render on-site computer records searching both possible and practical, wholesale seizures, if adequately safeguarded, must occur. At the very least, the government should copy and return the equipment as soon as possible.”). The warrants at issue here did provide for prompt return of the computers. The better practice would have been to follow the DOJ guidelines in developing a search strategy and presenting that strategy to the magistrate judge, and the failure to do so is troubling. However, the lack of a detailed offsite search strategy does not render the warrants’ computer search provisions insufficiently particular, and the computer search provisions otherwise satisfy the Fourth Amendment. 3. The Date on the Fourteenth Warrant Mr. Portlock challenges the sufficiency of the fourteenth warrant, which was issued for the search of a Shurgard storage unit after searches of the other thirteen locations had already begun. Mr. Portlock contends that the fourteenth warrant was “defective and vague, on its face, because it fails to identify or state an issuance date any more specific than November of 2002.” (Def. Portlock’s Reply and Supplemental Mot. to Suppress Tangible Evidence, Doc. 306 at 2)1 However, there is no merit to Mr. Portlock’s argument that the lack of a day of the month on the face of the fourteenth warrant renders it impermissibly vague. The fourteenth warrant does contain an incomplete date. It is signed by the magistrate judge and states that the search was to be conducted on or before November 24, 2002, but at the bottom where there is a space for the date of issuance of the warrant the line reads only “November , 2002,” with no day of the month filled in. (Government’s Ex. 14). However, on the “Application and Affidavit for Search Warrant” the magistrate judge signed the jurat, “Sworn to before me, and subscribed in my presence November 14, 2002,” following DEA Agent Jones’s signature, and the magistrate judge also signed the jurat that provides, “Sworn and subscribed to before me this 14th day of November, 2002” on DEA Agent Jones’s “Affidavit in Support of Search Warrant.” (Government’s Ex. 14). Moreover, the body of Jones’s affidavit describes the November 14, 2002 search of Portlock’s accounting office in its explanation of the reason for which the fourteenth warrant was sought, and it is undisputed that the actual search of the Shurgard unit also occurred on November 14. Logically, then, the warrant was signed in between the time the affidavit was sworn to (on November 14) and the time the search was conducted (later on November 14), and thus the warrant was also signed on November 14. Although Mr. Portlock does not assert that the date on the affidavit (November 14) is incorrect or that the warrant was not actually issued on November 14, he nevertheless argues that the lack of a precise date renders the warrant defective. Mr. Portlock does not cite any authority for his assertion that the lack of a complete date on the warrant renders it constitutionally infirm, nor has any been located. On the contrary, similar clerical errors and omissions have been held not to affect the validity of a search warrant. See, e.g., United States v. Bonner, 808 F.2d 864, 866-67 (1st Cir.1986) (finding warrant valid despite omission of address of location to be searched and referring to such as “a minor, technical omission”); Ross v. United States, No. CR. 496150(1)JRTAJB, Civ. 03-1020(JRT), 2003 WL 22076607, at *4 n. 4 (D.Minn. Sep. 2, 2003) (rejecting claim that warrant was invalid where, due to clerical error, warrant reflected that it was issued on August 31 but executed on August 27); United States v. Albert, 195 F.Supp.2d 267, 274 (D.Mass.2002) (concluding that omission from warrant of reference to list of items to be seized was merely “a clerical error that posed no real risk to legitimate privacy interests”); cf. United States v. Berry, 113 F.3d 121, 124 (8th Cir.1997) (reversing district court’s grant of motion to suppress which had been based on warrant’s failure to specifically authorize nighttime search; affidavit clearly had contemplated a nighttime search, warrant was presented for signature at issuing judge’s home at 12:30 a.m., and it was thus apparent to the appellate court “that the wording of the concluding paragraph in the warrant was the result of some sort of clerical error”); United States v. Klaia, 127 F.2d 529, 530 (2d Cir.1942) (finding omission of date from copy of search warrant was trivial and harmless where original was properly dated). Moreover, any such “invalidity” was cured by the searching officers’ good-faith reliance on the warrant containing the clerical error. See United States v. Russell, 960 F.2d 421, 423-24 (5th Cir.1992) (applying good-faith exception where warrant was “defective because of clerical error” of omission of list of items to be seized, finding “nothing to be gained by laying fault for this apparent clerical error at [IRS agent’s] feet”); United States v. Curry, 911 F.2d 72, 77-78 (8th Cir.1990) (applying good-faith exception to uphold search conducted pursuant to warrant which lacked address of premises to be searched); Bonner, 808 F.2d at 867 (“Even assuming that the search warrant was invalid due to the omission of the address, the evidence was properly admitted under the good faith exception to the warrant requirement.”); see also United States v. Smith, 63 F.3d 766, 769 (8th Cir.1995) (noting, in ruling that failure of magistrate judge to sign jurat on warrant affidavit did not negate probable cause for warrant, that the exclusionary rule does not apply “to clerical mistakes by judges”). Thus, Mr. Portlock’s argument that the missing date on the fourteenth warrant renders it invalid is not persuasive. k-