E.D.Pa.: Work product privilege in product of a SW is burden of defense

A special master reviewed the product of the search warrant for work product materials. The defendants have the burden of proof on work product, and they didn’t meet it. United States v. Vepuri, 2022 U.S. Dist. LEXIS 151833 (E.D. Pa. Aug. 24, 2022).

Defendant’s search claim wasn’t presented below, and it should be treated as waived. Going to the merits anyway, the search was justified by the automobile exception. Pollard v. State, 2022 Del. LEXIS 255 (Aug. 24, 2022).*

There was probable cause for this vehicle search based on an informant’s information. United States v. Reza, 2022 U.S. Dist. LEXIS 151626 (D.N.M. Aug. 23, 2022).*

The search warrant affidavit established nexus for the place to be searched. Also, the good faith exception applies. United States v. Esherick, 2022 U.S. Dist. LEXIS 151778 (D. Minn. Aug. 24, 2022).*

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