QUESTION 1: Does Riley v. California , 573 U.S. 373
(2014) prohibit the Government from searching privacy
protected GPS information in the metadata of a digital
video labeled contraband when neither the warrant nor the
Government's forensic review specified GPS or metadata
as responsive to the charges identified in the warrant
and the purpose of the search was to look for evidence
of a crime not specified in the warrant and for which the
Government admitted it had no probable cause?

QUESTION 2: Does the standard federal plea agreement
clause that the government agrees not to bring any other
charge "known to" the United States at the time of the
agreement preclude subsequently bringing a new charge
based on a digital video file admittedly in its possession;
physically viewed by it; and after informing Defendant
all seized files had been thoroughly searched because the
government maintains it was unaware of the potential
charge due to an undisclosed prosecutorial mistake?

QUESTION 3: Is a search for a file's GPS metadata
constitutionally unreasonable/untimely and/or unfair
when it is not conducted until fifteen months after the
Fed. R. Crim. P. 41(e) forensic review failing to identify
the metadata or GPS responsive to the warrant was
completed; ten months after a plea agreement resolving
the warrant specified charges was executed; eight months
after Defendant, in reliance on the agreement, went into
custody; and four months after the case and any prospect
of trial was terminated by sentencing pursuant to the
agreement?

Does Riley v. California prohibit the Government from searching privacy protected GPS information in the metadata of a digital video labeled contraband?