In State v. Brewster, 157 Ohio App.3d 342, 2004 Ohio 2722, 811 N.E.2d 162, the appellant, who was convicted of forgery and possession of criminal tools, appealed. The appellant argued, in part, that while searching his hotel room pursuant to a search warrant, police officers had improperly seized and opened fire safes without a separate search warrant. The court, however, held that the fire safes found in a hotel room fell within the scope of a warrant to search the hotel room. The search warrant in such case permitted police officers to search for equipment or articles used in manufacturing or reproducing negotiable items, including software, receipts and personal papers. The court held that fire safes could have contained documents or other things used in manufacturing, reproducing, or using forged checks.