In what circumstances have agents used the catch-all clause in a search warrant to limit what constitutes "other evidence"?

Nor is this a case where the agents used other language in the warrant to narrow the catch-all provision. See United States v. Young, 745 F.2d 733, 759 (2d Cir.1984) ("money" in prior clause of warrant used to limit what constitutes "other evidence"). The rental agreement was completely outside the class of items named with specificity in the warrant. The majority claims that "the warrant supplied sufficient examples of the type of records that could be seized--bank records, business records, and safety deposit box records." The warrant, however, lists these records as a subset of "records of the investment of proceeds of drug trafficking." A storage locker rental agreement cannot be reasonably analogized to a record of the investment of proceeds of drug trafficking. This language, while in words limiting the discretion of the agent to act pursuant to the catch-all language, in fact provides no effective constraint.

The rental agreement by itself cannot be considered evidence of the crime charged in the warrant. It is not contraband or illegal on its face. See United States v. Morisse, 660 F.2d 132, 136 n. 1 (5th Cir.1981) (if item to be seized cannot be facially determined to be illegal, warrant must inform law enforcement agent how to distinguish it from legal item). The agreement had expired several months before its seizure. At most, it was material that might lead to evidence of some crime.