D.Neb.: Historical CSLI is mere third party information, and no REP in it

“The court notes some of this information has never been protected, and this does not change simply because the phone records arise from use of a cell phone rather than a landline. See Smith, 442 U.S. at 745 (no reasonable expectation of privacy in the phone numbers dialed). [¶] But basic telephone records and historical cell-site information are not ‘sensitive records’ that a person may keep on a cell phone or in a home. Cell-site information is not private information; it is information gathered and documented by a third party in the regular course of business. Accordingly, Defendant’s reliance on Riley is misplaced. See Guerrero, 768 F.3d at 359-60; Ledbetter, 2015 WL 7758930 at *14.” United States v. Hudson, 2016 U.S. Dist. LEXIS 44967 (D.Neb. Feb. 19, 2016).