The facts before the USMJ, based on two emails, showed probable cause to believe that defendant’s two email accounts would have further evidence of money laundering. United States v. Bradley, 2017 U.S. Dist. LEXIS 43719 (W.D. Va. March 24, 2017).
A video of the execution of a search warrant from 1987 was available to the defense all along, so he gets no equitable tolling of filing a recent coram nobis petition based solely on the prosecutor’s misstatement on the record at trial that the video started in a different place than it did. Cauthern v. State, 2017 Tenn. Crim. App. LEXIS 223 (March 24, 2017).*