Corktown coal-mining operation has been in business for over twenty years. Times have been rough for the mining operation, and it has had to cut expenses and lay off dozens of workers. In addition, former and current employees have been filing grievances regarding the company's management. Accusations of tax fraud, mismanagement, and money laundering have run rampant. The Internal Revenue Service (IRS) is convinced that Corktown owes it hundreds of thousands in back taxes. It has sworn affidavits from former employees that the operation has been "rearranging" the numbers on its spreadsheet through its computer accounting software. To gather additional evidence, the IRS asks the Department of Justice (DOJ) to use its enforcement powers and attempt to acquire the computer records and files to prove the allegations made against Corktown. If the business to be searched were not a highly-regulated industry, the warrant could be broad and all-encompassing regarding what can be searched.

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