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(On January 27, 2016, the Florida Department of Law Enforcement received a referral from the Lee County ‘Sheris Office in reference toa possible unauthorized breech of the Lee County Elections Office website. It \was discovered that an opponent in the election for Lee County Superiser of Elections, Dan Sindla, has been advertising that an associate of his named David Levin, owner of Vanguard Cybersecurity, was able 0 perform @ SQL (Structured Query Language) injection attack on the Lee County Elections Office website. An ‘SQL injection is code injection technique used to attack data-driven applications. An SQL injection enables ‘an individual obtain secure information, such as usernames and passwords, from vulnerable websites. It \was also discovered that Levin performed a separate SQL injection attack agains the Dhsion of Elections in Tallahassee, Florida, (On January 26, 216, Sinclair and Levin posted two YouTube videos explaining the SOL injaetion thet was. performed on the Lee County Elections Office website. Levin explained that an SOIL injection attack ticks the system ino giving you information that might not otherwise be accessible tothe publi. During the YouTube \idoos Levin demonstrated how he performed the SQL injection attack onthe Lee County Elections Office website, Levin displayed screenshots of his computer device that showed the program Levin ulize to Perform the SQL injection. Levin also showed screenshots of him logging inte the Lee County Elections Orie website with Sharon Harrington's credentials, the current Lee County Supervisor of Elections. Levin then demonstrated how he was abe to navigate the Lee County Elections Office website as an administrator. (On January 25, 2016, Sinclair and Levin conducted an interview with a local Fort Myers television news ‘tation. During this interview, Lovin damonststed how he was able to perform an SAL inaction on the Le County Elections Office website. When referring tothe SQL injection he performed on the Lee County Elections Office database Lovin stated" hacked it" Lovin stated that he used Sharon Harrington's credentials 1 19 into the system. ‘On February 1, 2016, Special Agent (SA) Christopher Tissot was forwarded an e-mail wth a Vanguard ‘Cybersecury. cecurty research report attached. The e-mail was orginally sent to an employee within he Department of State, Division of Elections, from Daniel Sinclar. The report was writen by David Levin and cutlined the Structured Query Language (SQL) injection attacks he conducted on both the Lee County Elections Office website as well asthe Division of Elections, The report included screenshots of the actual ‘SOL injection attacks that ware performed on the Division of Elections in Tallahassee, Florida as wel as alist ‘ofthe diferent types of data that Levin obtained from performing the SQL injection attacks. The report was. dated January 27, 2016. on February 9, 2016, EE 02 Lovin was conducted by members withthe Floride Deparment of Law Enforcement, 0 ir, TE «vin wes asked about the SAL Injection attack he performed on the Lee County Elections Orfice websita as well asthe Office of Elections in Toliahassee, Fonda The folowng sa summary (On February 8, 2016, members ofthe Florida Department of Law Enforcement (FDLE) executed a search warrant at 9512 Foxhall Way, Unit 2, Estero, FL. 33928, At approximately 8:00 AM, Special Agent Supervisor (SAS) Jason Knowles and Special Agent (SA) Christopher Tissot proceeded to the target location, 9812 Foxhall Way, Unit 2, Estero, FL 33628, in attempts to interview Davis Lovin, Upon arrival a the target location, SAS Knowles and SA Tlesot made contact with Jacquelyn Leah Levin, David Levin's wile. Jacquelyn advised the agents Lovin was not home, he was at work. SA Tissot roquested Jacquelyn to call Levin to see if he could come back to the residence fo speak with the agents. Jacquelyn callod Levin and after she made contac\ with him she handed SA Tisst the phone. SA Tissol advised Levin ‘thatthe agents wished to speak with him regarding the SL injection he performed. Levin stated he would ‘tum tothe residence, 9812 Foxhall Way, Unit 2, to speak wih the agents ‘Approximately thty minutes later Levin arrived atthe residence. Upon arrival, Levin invited both SAS. Knowles and SA Tissot inside the residence. Once inside, Levin agreed to speak with both SAS Knowles and SSA Tissot and a recorded interview wae subsaquently conducted, “The fllowing isa summary ofthe interview: COs : During the interview, Levin ulizeg his MacBook computer and showed SA Tissot the video Levi recorded of the SL injection attack he performed on the Lee County Elections Office. Levin algo showed SA Tissot Wo tnatine utizes to perform the attacks (Once the interview was complete, SA Tiesot advised Levin that SA Tissot had @ eearch warrant for the residence. SA Tissol contacted the other agents/membere who were staging nearby wo then responded to the residence to assist with the execution of the search warrant. Both Levin and his wife Jacquelyn remained Outside wile the search warrant was executed. While previewing Levin's MacBook computer, Systams Programming Consuitant (SPC) Vince DallAcco copied several files from the computer onto a USB thumb ‘ve for evidentiary purposes, Several electronic devices were ceized during the execution ofthe search ‘warrant including Levin's MacBook computer and iPhone 6S Plus. (On February 11.2018, Spacial Agant (SA) Cheitopher Tae! and Systams Pragramming Consultant (SPC) Vinee DeliAeco interviewed Sharon Harrington, Lee County Supervisor af Elections. The interview took piace atthe Florida Department of Law Enforcement Fort Myers Regional Operation Center located at 4700 Terminal Drive Suite 1, Fort Myers, Florida 33907. ‘The folowing is 2 summary ofthe interview with Sharon Harrington: ‘Sharon did not grant David Levin, nor anyone else permission o perform a Structured Query Language (SQL) Injection or any other type of network intrusion agains the Lee County Elections Office. Sharon did not grant David Levin, nor anyone else permission to ulliz her username and password to log into the Lee County Elections Office website. Sharon Harington was notified of the breech on approximately January 25, 2076. Daniel Sincair left a voicemail with Sharon Harrington's assistant. Sharon Harrington first reported the network intrusion to the Lee County She's Office, who in tun referred her to the Florida Department of Law Enforcement (On February 23, 2016, Special Agent (SA) Christopher Tissot and Systems Programming Consutant (SPC) Vince DelwAcco interviewed Daniel Sincai. The interview took place at Sinclair's residence located at 640 Dabney St, Fort Myers, FL 33965. Daniel Sinclar inited both SA Tissot and SPC DellAcco inside of his residence for a consensual interview: ‘The folowing i a summary ofthe interview with Danie! Sinclair Sinclar met David Levin at @ Young Republican's Event in 2015. Levin contacted Sinclair December 19, 2015 and explained the Structured Query Language (SCL) injection he had performed to Sinciai. Levin shared the ‘ideo of the SQL injection he had performed on the Lee County Elections Office website on January 8, 2016, with Sinclair via Levin's Oropbox account. Sinclair contacted both the Lee County Elections Ofice and the Division of Elections to report the two incidents thal occurred on December 19, 2018 and January 4, 2016, Sinclair dda ask Lovin to perform the SQL injection attacks; he was made aware ofthe attacks after he fact, by Levin On February 23, 2018, SA Tissot obtained a search warrant for Levin's Dropbox, Ine. account that was ‘sssociated with his gmail «cco. I 4 copy of the search warrant was sont to Dropbox, In. on February 24, 2016. ‘on March 17,2016, Special Agent (SA) Christopher Taso received the requestd information from Drop, Ine inference othe saarch warrant ha wna submited on February 24,2016. Dropbox. Ie. orvied a sver 8 gigabyte Kingston USB drive. SA Tse accessed the USB dive to review he information provided by Dropbox In. Alter revaing the n¥ormaton, SA Tissot discovered the Dropbox, ne. account associated wth the om occ'es I vs coistored o “Dav Levi" ar was created on October 1. 2015, Levin had th ic rie Oropbox, ne: folder. This veo shows Levin performing a Structured Query Language (SAL) Injection attack against the Lee County Office of Elections website, ‘On March 24, 2016, SPC Vince DeliAccio completed his analysis ofthe Lee County Elections Office website log files. SPC DeliAcco discovered an SOL injection attack on the Lee County Elections Otfice website on ‘numerous dates including December 19, 2015. This isthe date Levin told investigators that he performed the ‘SQL injacton attack onthe Lee County Office of Elections website: ts also the same date PEI on uvized or the atacks crested an HTML repr fe that dcumentes the actual atick. The HTL fle report contained a bret summary of the attack Levin performed and the informetion he obtained. (on Aoproxmatly Al 14, 2018, SPC Vine DetAccocomplated his ana ofthe Divison of Elections wobsie fies. SPC Delco cscavered an SQL inaction attack to the Osion of Elections website on numerous occasion incuding danvary 31,2016, SPC DellAcco was also able to locale png screen capture fe on Levin's seized MacBook Air computer. The screen capure fle depicted an SOL. nection allack Levin performed onthe Dison of lactone webste. Thong sreen capture fle was creatad on Janvary 31,2018, SPC Deli ls located an HTML le on Levi's sized MacBook computer. The HTML fe was reper that wos crested I! Lovin uized forthe stacks. The HTML report fe consid the infomation Levin obtained 9 a resut ofthe attack. The HTML fle was created by he I HIB orvary 4, 2016, nicating te attack occured on the same dy. ‘Based on the evidence obtained regarding the SAL Injection attack Levin performed against the Les County Offic of Elections on December 19, 2018, probable cause does exist to charge Levin with unauthorized ‘access of any computer, computer system, computer network, or electronic device, a violation of Florida ‘Statute 818.06(2)(), a third degree felony ‘Based on the evidence obtained regarding the SOL injection attacks Levin performed against the Division of Elections on January 4, 2016, probable cause does exist to charge Levin with unauthorized access of any computer, computer system, computer network, or electronic device, a violation of Florida Statute £815.06(2}(0),@ thie degree felony. Based on the evidence obtained regarding the SOL injecbon attacks Levin performed against the Division of Elections on January 31, 2016, probable cause does exist to charge Levin with unauthorized access of any ‘computer, computer system, computer network, or electronic device, a violation of Florida Statute £818.06(2\(), a thre degree felony Your Affiant beleves that based upon the investigation in its entirely, to inchide the swom statements provided by the winesses and physical evidence gathered during the investigation probable cause exists to charge DAVID MICHAEL LEVIN with 3 counts of unauthorized access of any computer, computer system, computer network, or electric dovice, a violation of Florida Statute 815,08(2Xa), a third degree felony eo i ws aie WHEREFORE, your Affiant prays that a warrant will be issued commanding all and singular, Rick L. ‘Swearingen, Commissioner, Florida Department of Law Enforcement or any of his duly authorized Special ‘Agents; ll Sheritfs and Police Chiefs of the State of Florida or any of thelr duly authorized deputies o officers to arest instanter DAVIO MICHAEL LEVIN and bring him before the Court so that he may be dealt with according to law. Florida Department of Law Enforcement STATE OF FLORIDA COUNTY OF LEE ‘The foregoing instrument was acknowledged before me this ~/> dey of May, 2046-By Special Agent Christopher Tissot who identiis himself to me and who did take ah oath iACUNICOUNYY JUDGE LEE CODNTY, FLORIDA Hon. Amy 8. Howthome (Creat Court gn Co ag ee