As to one challenged search of Google, when the government says it won’t use challenged evidence at trial, the motion to suppress becomes moot. A motion to suppress another search warrant to Google led to reissuance of a search warrant and that was not unreasonable. United States v. Beck, 2020 U.S. Dist. LEXIS 191678 (N.D. Ga. Oct. 16, 2020).
Defendant’s Franks challenge fails. “The disputed ‘focal point’ language isn’t necessary to the probable-cause finding here because stripping that language from the affidavit leaves a finding that comfortably rests on at least the following facts that are not in dispute for purposes of the motion to suppress: ….” Defendant requested an AT&T service call at this house, and the service tech saw thumbnails of child pornography on his computer screen. United States v. Zappe, 2020 U.S. Dist. LEXIS 191122 (W.D. Tex. Oct. 15, 2020).*