M.D.Pa.: The fact def’s cell phone was used to call the CI was PC for search of the phone

Nexus was shown for defendant’s cell phone: “The affidavit described various calls made between the CI and defendant regarding the planning of the jewelry store robbery, the dates of the calls, as well as discussions about how the firearm needed for the robbery would be obtained. There was also probable cause for the agents to believe that defendant’s cell phone would have text messages to Ricky about the jewelry store and its owner. As the government states in its brief, (Doc. 51 at 2), ‘[the affidavit] detailed the defendant’s repeated use of [his cell] phone in furtherance of the alleged crime, why agents believed evidence would be found on the phone, and what form that evidence would be found in during the search.’” United States v. Santiago-Rivera, 2017 U.S. Dist. LEXIS 168909 (M.D. Pa. Oct. 12, 2017).

Defendant was a postal contractor who consented to a search of his truck leading to finding stolen mail. United States v. Morris, 2017 U.S. Dist. LEXIS 167927 (S.D. Va. Oct. 11, 2017).*