M.D.La.: Typo in the address of the place to be searched not fatal where officers surveilled it before

There was an error in the address on the search warrant, but it’s clear to the court that there was no likelihood that the wrong apartment would be searched because the officers had surveilled it. There was reasonable suspicion for defendant’s stop near a drug sale because defendant called the CI to say he was coming as the CI predicted. Also, defendant has no reasonable expectation of privacy in a gated parking lot where the police entered. United States v. Grant, 2018 U.S. Dist. LEXIS 156238 (M.D. La. Sep. 13, 2018).

Defendant was alleged to be part of a drug trafficking organization for a decade. He’s alleged to have done a drug deal in May 2017, and that led in part to a wiretap. After the wiretap produced results, a search warrant for the phone was not stale. Even so, it was valid under the good faith exception. United States v. Davis, 2018 U.S. Dist. LEXIS 156379 (S.D. N.Y. Sep. 13, 2018).*

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