Adding to the clues that the Justice Department is heating up its investigation of former President Donald Trump is the fact that federal authorities have seized cell phone devices from two more of his associates.

Federal authorities seized cell phones from Trump's campaign and others. The New York Times reported that about 40 subpoenas were issued by the Justice Department to other people.

Cell phones can't be seized without probable cause. David Weinstein is a former prosecutor and a criminal defense attorney.

Law enforcement can corroborate a lot of other evidence.

Federal authorities have seized phones and electronic devices from at least nine people in Trump's circle since the Justice Department began investigating the January 6 insurrection.

Here's a look at who they are and how they might be involved in the investigation.

Rudy Giuliani
Former New York City Mayor Rudy Giuliani.
Mary Altaffer/Associated Press

Rudy Giuliani

Rudy Giuliani was a lawyer for Trump. Federal authorities searched his home and seized 18 electronic devices. According to the Associated Press, federal prosecutors said at the time that the devices were owned by Giuliani and some of his employees.

Giuliani's attorneys said that federal agents treated their client like a drug dealer rather than a lawyer.

Giuliani peddled election fraud conspiracy theories after the 2020 presidential election.

Victoria Toensing
Victoria Toensing is a former federal prosecutor.
Photo by David S. Holloway/Getty Images for Turner

Victoria Toensing

Toensing is a close friend of Giuliani and Trump. She had her electronic devices seized by federal authorities last April. The government obtained a warrant to look for a device, according to prosecutors. The Justice Department said that the devices were sent to the New York district.

Toensing did not reply.

michael McDonald
Nevada State Republican Party Chairman Michael McDonald.
Photo by Ethan Miller/Getty Images

Michael McDonald

The phone of Nevada State Republican Party Chairman Michael McDonald was seized last June.

The House select committee is investigating the January 6 insurrection and has subpoenaed him and 13 other people to testify. The congressional certification of Biden's victory may have been derailed by the effort to name electors for Trump in states that he won.

McDonald didn't reply to Insider's question.

Pennsylvania Rep. Scott Perry
Rep. Scott Perry of Pennsylvania.
Carolyn Kaster/AP

Scott Perry

The cell phone device of a Pennsylvania Republican congressman was seized by the federal government.

The Justice Department was sued for not returning the cell phone data to him. He asked the judge to stop federal authorities from looking at his phone data.

Insider asked if she would comment, but she didn't reply.

John Eastman
Former Trump legal adviser John Eastman.
AP Photo/Susan Walsh

John Eastman

The then-Vice President Mike Pence's advisers warned that he would be in violation of the law if he overturned the election result.

White House counsel Pat Cipollone testified before the House select committee investigating the January 6 insurrection and said that he confronted the author of the theories to overturn the election results.

Jeffrey Clark stands at a DOJ podium.
Jeffrey Clark, a former DOJ official.
Yuri Gripas/Pool via AP, File

Jeffrey Clark

Clark worked for the DOJ in the Trump administration. Federal authorities searched his home in Virginia and seized his electronic devices.

During their public hearings, the House select committee revealed that Clark, a former environmental lawyer, wrote up a letter claiming that there was election fraud during the 2020 presidential elections and was prepared to send it out to state legislatures in an effort to overturn Biden's victory in those states.

Clark was critical of the Justice Department's investigation.

The Insider asked him to comment, but he didn't reply.

A November 19, 2020 photo shows Trump campaign advisor Boris Epshteyn during a press conference at the Republican National Committee headquarters in Washington, DC.
Former Trump campaign advisor Boris Epshteyn.
MANDEL NGAN/AFP via Getty Images

Boris Epshteyn

The former campaign adviser to Trump is working on the former president's legal team. The Fulton County District Attorney wants to know if Trump and his associates tried to overturn Georgia's election results. He was subpoenaed by the January 6 committee.

Insider asked him to comment, but he didn't.

Mike Roman

Roman worked for Trump's re- election campaign. According to The Hill, he delivered false election certificates to a Republican congressman.

mike lindell mypillow cpac
MyPillow CEO Mike Lindell.
REUTERS/Octavio Jones

Mike Lindell 

Federal authorities subpoenaed the CEO of My Pillow to get the contents of his phone. Trump's theories on voter fraud are being sued by a voting systems company.

He didn't reply to the request to comment on the matter.