Can we get one thing straight here. Gray Powell was not the owner of the phone, Apple was and is. Any talk of contacting Powell as the owner is forgetting that.
As for whether the court would find that a reasonable amount of effort was exercised in the return, it can be argued both ways. However, the fact remains that a conviction where a major issue is what is 'reasonable' is incredibly difficult to obtain. Add in the fact that utilization of any information obtained from the search likely results in a state supreme court case and I'd be absolutely stunned if there's a theft conviction. People are already somewhat upset about what is perceived by some to be an Apple pushed investigation, imagine how well a multi year hundreds of thousands of dollars court battle would go over.
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