If you type "+" on your keyboard, this document will transform itself from an empty "Form 1" to an example ITO.


Information To Obtain a Search Warrant

Canada,

Province of ___________British Columbia,

(territorial division).

New Westminster

This is the information of A.B. Cst Conn Stable , of _____ the Douglas College Police Force in the said (territorial division) New Westminster , (occupation) peace officer , hereinafter called the informant, taken before me.

The informant says that

(describe things to be searched for and offence in respect of which search is to be made),
Ellie Student used a gray Apple laptop computer with stickers of spiders on the lid to possess or access child pornography on September 18, 2025 at New Westminster


and that he believes on reasonable grounds that the said things, or some part of them, are in the (dwelling-house, etc.) of C.D., of _____, in the said (territorial division) apartment of Ellie Student at #3-1234 Bluebell Lane, in New Westminster, British Columbia. (Here add the grounds of belief, whatever they may be.)

I, Conn Stable, a peace officer of the Douglas College police force, solemnly affirm:

    My Role

  1. I have worked in law enforcement for over 30 years, including general duty, and drug and gang enforcement.

    2. Complaint

  2. After John Cater’s criminal law class, on September 18, 2025, Roger Rat, a student in that class told me:
    1. He was sitting behind Ellie during the class.
    2. He saw that instead of taking notes on her computer, she was viewing photographs.
    3. The pictures depicted “naked kids, little kids, like 8 or 10 years old”
    4. Some pictures depicted adult males engaging in sexual acts with the children.
    5. Roger saw at least ten such photographs before Ellie closed her computer and put it in her backpack.
    6. Her laptop has stickers on it. “Spiders and stuff.”

    3. Identifying Ellie

  3. I asked John Cater, a member of the staff of Douglas College to look up Ellie’s address on the College’s database. He told me that database showed her name to be Ellie Student, and her home address and her mailing address were both #3-1234 Bluebell Lane, in New Westminster, British Columbia.

    4. Roger Rat's Credibility

  4. I asked John Cater what he knew about Roger Rat. Mr Cater told me:
    1. The College admitted Mr Rat on a special programme to rehabilitate street kids.
    2. Mr Rat was a drug user who supported his habit using drugs. He has a substantial criminal record.
    3. In the first class, Mr Rat sat close to Ellie, and appeared to try to engage her in conversation. She turned her back to him, and then eventually told him to leave her alone.
    4. Mr Rat has several times expressed loathing of sexual offenders, particularly pedophiles.

    5. Ellie Student's Habits

  5. I asked John Cater what he knew about Ellie’s habits. He told me:
    1. She’s a bit of a loner.
    2. She does not hang out at the library, nor socialize with the other kids.
    3. The school computer system shows that she has no classes at school tomorrow.
    4. He has seen her use a grey Apple laptop computer with a stickers of black spiders on the lid.

    6. Why I believe the offences occurred

  6. Mr Rat’s unsavoury history makes me think that he might tell lies.
  7. The interactions Mr Cater saw in class suggest to me the possibility that Ellie rejected his efforts to befriend her, which raises the possibility that he might want to seek revenge of some sort against her.
  8. I do not think this is the case. My experience with drug users on the street is that they dislike speaking to law enforcers, and they resist giving witness statements about criminal activity. If Mr Rat's unsavoury past still guides his behaviour, I would not expect him to engage with police officers such as myself.
  9. For this reason, I do not believe that Mr Rat made this allegation because Ellie spurned him. I think it is more likely that his hatred of sexual abuse of children compelled him to speak to me.
  10. Therefore, I believe that Mr Rat was honest about what he saw.
  11. He described seeing photographs of explicit sexual activity with children under the age of 18, which fits the definition in s.163.1 of the Criminal Code.
  12. He saw that she possessed or accessed these using her computer. That falls within the offences defined in s.163.1(4) and (4.1) of the Criminal Code.

    13. Why I believe the computer is at #3-1234 Bluebell Lane

  13. Whether Ellie uses her computer for school work or for sexual gratification, I think it reasonable to expect her to keep it with her, rather than leaving it in a locker at school.
  14. Therefore, I expect she takes it home when not at school.
  15. When I apply for this warrant, I expect that her computer will be in her apartment.

    16. Why the computer qualifies for seizure

  16. The computer may contain evidence of Ellie’s access, and when I obtain it, I will likely seek a warrant to search its contents.
  17. Even if it contains no evidence of the offence, it qualifies for seizure because it was used in the commission of the offence, making it “offence-related property” for the purposes of s.487(c.1).

Wherefore the informant prays that a search warrant may be granted to search the said (dwelling-house, etc.) apartment for the said things.

Sworn before me this ____ day of ___, _____A.D., at ________.
A Justice of the Peace in and for _________ British Columbia (Signature of Informant) Cst Conn Stable
Informant