by Kate Battan
Signed by Judge Henry E. Nieto
May 11, 1999
TO: INVESTIGATOR KATE BATTAN, an officer authorized by law and any other officer authorized to execute search warrants within the County of JEFFERSON, State of Colorado.
INVESTIGATOR KATE BATTAN, having this date filed an affidavit for a search warrant in conformity with the provisions of Rule 41, Colorado Rule of Criminal Procedure and C.R.S. 16-3-301, et seq., as amended, for the following described PROPERTY, to wit:
Any and all access records with associated time and date of access to the below accounts, User Profiles, billing records, customer statements, invoices, or other correspondence associated with the accounts of Eric Harris; Dylan Klebold; [DELETE] and [DELETE]
Any and all electronic mail, email file attachments, read, unread, saved or forwarded email, or any other type of email file associated with the accounts of Eric Harris; Dyland Klebold; [DELETE] and [DELETE]
Any and all user files, saved files, signature files, email address list files, newsgroup subscription files, or any other file currently stored by or for the use of the accounts of Eric Harris; Dylan Klebold; [DELETE]; AND [delete]
Believed to be situated IN THE COMPUTER known and described as
A Dell Poweredge Server 4200, model SME, serial #C0F8C
Upon one or more grounds set forth in Rule 41, Colorado Rules of Criminal Procedure and C.R.S. 16-3-302, as amended, namely:
Which is designed or intended for use as a means of committing a criminal offense; or
Which would be material evidence in subsequent criminal prosecution in this state or in another state; or
Other: ANY DOCUMENTS AND/OR PAPERS TENDING TO SHOW OCCUPANCY OR CONTROL OF SAID PREMISES.
I am satisfied that there is probable cause to believe that the property so described is located within the COMPUTER above described, and that the grounds for this search warrant exist.
YOU ARE THEREFORE COMMANDED to search the place above described for the property above described, and seize those items described.
YOU ARE FURTHER COMMANDED to leave a copy of the search warrant and receipt for the property taken with the person from whom or from whose premises the property is taken; or, in lieu thereof, to leave a copy of the search warrant and receipt at the place from which the property is taken.
YOU ARE FURTHER COMMANDED to make return of this search warrant and a written inventory of the property taken to the undersigned judge within ten days from date hereof.
On the basis of the information set forth in the affidavit and pursuant to C.R.S. 16-3-301, et. seq., as amended, YOU ARE AUTHORIZED to execute this search warrant in the manner set forth above, with the following special conditions, to wit: NONE.
Dated this 11 day of May, A.D. 1999, Judge Henry E. Nieto
Investigator Kate Battan, being duly sworn upon oath says:
That the foregoing offense(s) alleged was committed of this affiant's own personal knowledge, and the facts stated therein are true.
Your affiant is of lawful age and a sworn peace officer of the Jefferson County Sheriff's Office, Golden, Colorado, in the County of Jefferson.
Your affiant states that the following facts are true and based upon his/her personal knowledge, as a result of his/her conversations with the person(s) named herein and reviewing their written reports.
On April 20, 1999, at about 11:20 a.m., Jefferson County Sheriff's Office Dispatch received a call stating that there was a bomb in the area of Ken Caryl and Chatfield, County of Jefferson, State of Colorado. At the same time Dispatch received another call reporting that there was a girl "down" in the parking lot at Columbine High School. Deputy Paul Magor was dispatched at 11:16 a.m. to the bomb, and Deputies Scott Taborsky and Eric Miller were dispatched to Columbine High School, 6201 South Pierce Street, County of Jefferson, State of Colorado. Upon their arrival, Deputies Taborsky and Miller observed numerous students who were yelling and screaming as they ran out of the school. Deputies Taborsky and Miller also heard what they believed to be gunshots coming from inside the school. Deputies Taborsky and Miller were told by numerous students that people had been shot inside the school. Your affiant subsequently learned that fifteen individuals with gunshot wounds were killed inside Columbine High School, as well as about twenty-five individuals injured. Two of the dead were identified as Eric Harris, dob 040981 and Dylan Klebold, 091181.
Jefferson County Sheriff's Investigator Ralph Gallegos interviewed Alejandra Marsh, a student of Columbine High School. Marsh stated that she had been in class in Columbine High School, when she heard shooting. Marsh went to the corridor where she saw Dylan Klebold and a male known to her as "Reb." Marsh stated that both "Reb" and Dylan Klebold were wearing black pants and full length black dusters. Marsh saw that Dylan Klebold was carrying a rifle type weapon at waist height and was firing down the hall.
Your Affiant interviewed Wade Alan Frank, a student of Columbine High School, who stated that about 11:30 a.m., lunch time, he was in the parking lot of Columbine High School with Tyler Jackman, when he heard gunshots inside the school. Wade Frank saw a male wearing a long black trench coat at the top of the stairs at the entrance to Columbine High School. Wade Frank mentioned to Jackman that he thought it was [DELETE]. Jackman told Frank it was Dylan Klebold. The male in the trench coat was also wearing a black hat, possibly a baseball hat backwards or a ski mask. Wade Frank saw the male walk down the stairs, approach a male lying face down at the bottom of the stairs, and shoot a sawed off shotgun into his back. Wade Frank saw the male throw a white PVC pipe bomb, which exploded. Wade Frank saw the male walk to the top of the stairs, where there was a second male dressed the same.
Investigator Art Peterson interviewed Columbine High School student John Savage. Savage stated that during the shooting he was hiding under a table in the library. He recognized Eric Harris and Dylan Klebold, both wearing black. Dylan Klebold pointed a black handgun under the table at Savage. Savage said, "What are you doing?" Dylan responded, "We're out killing people." Klebold told Savage to identify himself and Savage responded, "It's John." Savage then asked, "Are you going to kill me?" Klebold responded, "No, run, just get out of here.
Investigator Mike Heylin of the Jefferson County District Attorney's Office stated that he had been contacted by Randy and Judy Brown, parents of Brooks Brown, in early 1998. The Brown's told Investigator Heylin that Eric Harris, who attends Columbine High School with Brooks Brown, had been harassing and threatening Brooks Brown. Randy and Judy Brown told Investigator Heylin that Eric Harris belonged to a "black trench coat gang" and had a web site reference murder and killing. They provided Investigator Heylin with possible web site addresses of HTTP://members.aol.com/rebdomine/index.html or http://members.aol.com/rebdoomer/index.html.
Investigator Cheryl Zimmerman discovered a report made to the Jefferson County Sheriff's Office on March 18, 1998, 985504, by Randy Brown. Randy Brown stated that Eric Harris was making death threats towards his son, Brooks Brown. Randy Brown provided ten pages of material copied from Eric Harris' web page to Deputy Mark Miller. One of the printouts reads, "Wie gehts. Well as you people out there can just kiss my ass and die. From now on, I don't give a fuck what almost any of you mutha fuckas have to say, unless I respect you which is highly unlikely, but for those of you who happen to know me and know that I respect you may peace be with you and dont be in my line of fire. for the rest of you, you all better fucking hide in your houses because im comin for EVERYONE soon, and I WILL be armed to thes fuckin teeth and I WILL shoot to kill and I WILL fucking KILL EVERYTHING! No I am not crazy, crazy is just a word, to me it has no meaning, everyone is different, but most of you fuckheads out there in soceity, going to your everyday fucking jobs and doing your everyday routine shitty things, I say fuck you and die. if you got a problem with my thoughts, come tell me and ill kill you, because ....god damnnit, DEAD PEOPLE DONT ARGUE!" Another page has an entry which states, "I will rig up explosives all over a town and detonate each one of them at will after I mow down a whole fucking area full of you snotty ass rich mother fucking high strung godlike attitude having worthless pieces of shit whores. I dont care if I live or die in the shootout, all I want to do is kill and injure as many of you pricks as I can, especially a few people Like brooks brown." Randy Brown told Deputy Miller that Eric Harris is also known as "Reb." Randy Brown stated that Harris also has an acquaintance by the name of Dylan Klebold, who is also known as "Vodka."
Investigator Ralph Gallegos interviewed Christopher Morris, who stated that he used to be part of TCM, Trench Coat Mafia. Morris told Investigator Gallegos he believed the people inside Columbine High School doing the shooting were Dylan Klebold, Eric Harris, and [DELETE]. Christopher Morris stated that Eric Harris also goes by "Reb." Morris said, two weeks ago Eric Harris had been picked on by "Jocks" at Columbine High School. Following this incident, while at Dylan Klebold's house, Harris told Christopher Morris, "Wouldn't it be nice to kill jocks." Christopher Morris said while this conversation was taking place, they were reading books about Nazi's and discussed cutting the power to the school and placing PVC bombs with screws inside at the doors of the school.
On April 27, 1999, Agent Charles E. Davis of the Colorado Bureau of Investigation, Computer Crime Investigations Unit, conducted a cursory analysis of two computer systems located in the Tech Lab of the Columbine High School. Agent Davis specifically examined these computers as a result from a lead from Terry Lawson, a student at Columbine High School. Lawson spoke with Agent Rick Griffith of the Colorado Bureau of Investigation, and stated that he (Lawson) had seen a computerized movie of students enacting a shooting. This movie was located by Agent Chuck Davis on a computer that is connected to a scanner. Agent Davis found that there is only one scanner in the Tech Lab, however, two computers are to the immediate right of the computer and the scanner is connected to both. All of the computer systems in the Tech Lab are in an open area accessible to anyone entering the Lab. Although the systems are connected to a network that requires a password for access to the main server, the local storage on each of the computers hard disk drives are open to anyone who sits down at the system. This was verified by Rich Long, an instructor at the Tech Lab at Columbine High School.
During an examination of the computer to the right of the scanner, and on the same table, Agent Davis found several computerized movies in the AVI format. These movies depicted what appears to be a movie of Dylan Klebold jumping into a car as the car sped away down a street. This computer system was seized and taken into evidence. During an examination of the computer system to the right of the scanner, but on a separate table, Agent Davis found a lengthy (in excess of 12 minutes) computerized video in which several students enacted a shooting incident at a business. A sticker on a television monitor next to this computer read "REB" and a sticker on a videotape recorder under the television monitor read "VODKA." This computer system was also seized. Agent Davis examined each system in the Tech Lab, all of which were of immediate access to anyone who entered the Tech Lab, but found no additional computerized movies.
On April 28, 1999, Agent Davis spoke with Rich Long, a teacher at Columbine High School who was in charge of the Tech Lab. Located in Long's office were four computer servers that run the network at the school. Long explained that one server was the system that contained the user files that the students had access to, using user log ins and passwords, and that each student potentially had a set of files on the server. All servers were safely shut down and secured, and the student server was seized as evidence without examination.
Based upon the aforementioned information, your affiant respectfully requests that the court issue a search warrant for the student server, located at The Colorado Bureau of Investigation, 690 Kipling Street, County of Jefferson, State of Colorado, described as:
A Dell Poweredge Server 4200, model #SME, serial #C0F8C
For the purpose of searching for the following:
Any and all access records with associated time and date of access to the below accounts, User Profiles, billing records, customer statements, invoices, or other correspondence associated with the accounts of Eric Harris; Dylan Klebold; [DELETE] and [DELETE].
Any and all electronic mail, email file attachments, read, unread, saved or forwarded email, or any other type of email file associated with the accounts of Eric Harris; Dylan Klebold; [DELETE] and [DELETE].
Your affiant further requests that this affidavit and warrants or orders resulting from this affidavit be sealed by the court to preserve the integrity of the on-going criminal investigation.
Approved: Henry E. Nieto, Judge
Sworn to before me this 11th day of May, 1999
Henry E. Nieto, Judge