N.D.Ga.: It’s reasonable to infer that def’s shipping firearms to Trinidad would have records in residence and on computers and cell phones there

Defendant was suspected of shipping firearms to Trinidad from Atlanta. “The nature of the criminal conduct in which Defendant was engaged, purchasing firearms for the unlawful export to Trinidad and involving utilizing third parties to make the unlawful firearms purchases and to assist with the unlawful export — all of which required record keeping and communication and coordination with his co-conspirators nearby and in Trinidad — is of the type that it is reasonable to infer that evidence of this activity would be maintained by Defendant in a readily accessible place, that is, his residence. And, due to the need to communicate with individuals in Trinidad, the Magistrate Judge quite reasonably concluded that Defendant did so electronically — either utilizing a telephone or computer. Furthermore, along with drawing his own reasonable inferences regarding where evidence of Defendant’s firearms trafficking and export would be stored, Magistrate Judge Anand was entitled to rely on Affiant’s opinion as to the probable location of this evidence. Affiant, based on his training and experience, opined that individuals engaged in the type of criminal conduct in this case maintained records, ledgers and other documents, such as, money orders and receipts, both on paper and by use of cellular telephones and computers, and that – with respect to the export of firearms – individuals are required by law to maintain records.” United States v. Alfred, 2017 U.S. Dist. LEXIS 132437 (N.D. Ga. July 18, 2017),* adopted, 2017 U.S. Dist. LEXIS 131894 (N.D. Ga. Aug. 17, 2017).*