D.Mont.: FBI 302s not discoverable to aid in PC and particularity challenge

Defendant cannot get discovery of FBI 302s just to see if the search warrant was based on whatever information that would disclose. United States v. Purkey, 2024 U.S. Dist. LEXIS 104824 (D. Mont. June 11, 2024). After all, the four corners of the affidavit is the key.

The statement of a witness in support of a search warrant was attempted to be used as a prior inconsistent statement in People v. Thornton, 2024 IL App (4th) 220798 (June 14, 2024),* see concurrence at ¶ 114. It was the first time this judge had seen anything like it.

CSLI claim is unpreserved for review. People v. Ruiz, 2024 NY Slip Op 03189 (2d Dept. June 12, 2024).*

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