“The lack of a video under these circumstances is not a basis for rejecting the Magistrate Judge’s credibility finding.” Defendant’s becoming loud and obnoxious when asked to leave justified a frisk. United States v. Tymes, 2020 U.S. Dist. LEXIS 47638 (M.D. Ala. Mar. 19, 2020).
Aside from having developed probable cause as to the residence to be searched, the officers had reasonable suspicion from a CI that was corroborated as to defendant’s involvement which was omitted from the warrant application. That enabled them to stop defendant, and he was ordered from the car, which he failed to respond to and they pulled him out. Pulling him out didn’t still raise it to a de facto arrest. United States v. Cabrera-Vasquez, 2020 U.S. Dist. LEXIS 47866 (D. Neb. Feb. 10, 2020),* adopted, 2020 U.S. Dist. LEXIS 46477 (D. Neb. Mar. 18, 2020).*