D.N.M.: SW wasn’t stale; def was doing enough to show his conduct was ongoing, and the officers didn’t even know he’d moved just before the raid

The search warrant was not stale. While there was reference to activities three months before the warrant was issued, defendant was seen coming and going from the location on the way to do drug transactions with a known drug dealer officers had under surveillance. The officer averred [as they always do] that evidence of drug dealing would be found at the house: paraphernalia, books, ledgers, more drugs. “The United States asserts that agents did not know Angulo had moved at the time they executed the search warrant, but that regardless, such knowledge would not have nullified probable cause to search 9000 Zuni. … This is because the warrant was intended to search for ‘evidence related to a larger DTO,’ and there was no reason to believe Angulo had taken all of the evidence with him when he moved.” United States v. Topete-Madrueno, 2019 U.S. Dist. LEXIS 143456 (D. N.M. Aug. 23, 2019).*