“Given that the Defendant admitted that he had used the laptop to view child pornography previously, it appears beyond dispute that Couch had such probable cause. … [¶] Defendant instead argues that the Government failed to prove that an exigent circumstance necessitated the warrantless seizure of the computer because there was no evidence anything on the computer would be destroyed. … Courts routinely recognize the ease of destroying digital evidence in child pornography cases.” United States v. Dzionara-Norsen, 2020 U.S. Dist. LEXIS 107523 (W.D. N.Y. June 18, 2020).
The juvenile court can, as can an infraction court, absent a prosecutor, cause witnesses to be subpoenaed to the hearing on the motion to suppress and the application of exceptions to the warrant requirement. People v. Cotsirilos, 2020 Cal. App. LEXIS 560 (4th Dist. June 19, 2020).*