N.D.Ill.: While merely being close to another for whom there is reason to frisk or arrest is not PC, here there actually was PC

The FBI had more than reasonable suspicion based on mere propinquity to others. There were specific facts involving defendant that rose to reasonable suspicion. United States v. Amaya, 2016 U.S. Dist. LEXIS 174615 (N.D.Ill. Dec. 16, 2016).*

Defendant’s cell site location information was obtained by search warrant, so his lawyer couldn’t be ineffective for not challenging it unless the challenge went to probable cause, something not raised. This circuit treats CSLI as a business record. United States v. Moffitt, 2016 U.S. Dist. LEXIS 173194 (W.D.Pa. Dec. 15, 2016).*

Another Playpen warrant upheld. United States v. Vortman, 2016 U.S. Dist. LEXIS 175235 (N.D.Cal. Dec. 16, 2016).*

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