S.D.N.Y.: “GPS Affidavit [does not need] to include the ‘use and aims’ of the location information” to be valid

A “GPS Affidavit [does not need] to include the ‘use and aims’ of the location information” to be valid. [No case even suggests that.] United States v. Shulaya, 2017 U.S. Dist. LEXIS 209340 (S.D. N.Y. Dec. 20, 2017).

Defendant consented to a search of his lawfully stopped car and motel room. The police went to the motel and found additional stolen property, and they followed up with a search warrant to seize what they found. It was valid on the totality. United States v. Fields, 2017 U.S. Dist. LEXIS 207155 (E.D. Pa. Dec. 15, 2017).*

Defendant hasn’t shown a reasonable expectation of privacy in his recorded jail calls, and they won’t be suppressed just because there was no subpoena or court order to produce them. United States v. Feaster, 2017 U.S. Dist. LEXIS 207651 (W.D. N.Y. Nov. 6, 2017) (R&R).*

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