Full opinion text
MEMORANDUM OPINION ROYCE C. LAMBERTH, Chief Judge. Pending before the Court are numerous pre-trial motions filed by six defendants and the government. All six defendants have filed motions to suppress evidence seized through physical searches of their homes or homes to which they had a connection; defendant Scurry moves to suppress evidence seized diming a search of his vehicles. Defendant Hudson also moves to suppress statements he made during the search of his home. Scurry, Savoy, and Brown have filed additional miscellaneous motions which are dealt with in turn below. Finally, the government has filed one motion to allow impeachment of defendants Hudson and Robinson with their prior felony convictions. Upon consideration of the defendants’ and government’s motions, responses of the parties, and relevant law, the Court hereby DENIES defendants’ motions to suppress physical evidence [35, 37, 38, 58, 63, 67, 89, 101, 201]; DENIES Savoy’s Motion for a Pretrial Hearing [36], DENIES Scurry’s Motion to Compel Disclosure of Information Regarding Confidential Informants, Witnesses, and Cooperating Criminals [53]; DENIES Scurry’s Motion for a Bill of Particulars [54]; DENIES Scurry’s Request for Notice Prior to Trial of Government’s Intention to Present Evidence Pursuant to 404(b) [55]; DENIES Scurry’s Motion for Discovery of Detector Dog Information [70]; DENIES Brown’s Request for Preservation of Electronic Mail [60]; and GRANTS Hudson’s Motion to Suppress Statements [76]. The Court does not rule today on the Government’s Motion to Impeach Defendants with Prior Convictions Pursuant to Rule 609 [68]. I. Background In 2009, prompted by renewed violence in the 4200 block of Fourth Street, S.E., Washington, D.C., the Federal Bureau of Investigation’s (FBI) Safe Streets Task Force began investigating the cocaine and crack dealers in that area. Agents and detectives introduced a confidential informant into the area, who made a series of controlled purchases of crack cocaine from Eric Scurry from November 2009 to March 2010. In addition to reliance on physical and audio- and video-surveillance, the task force also secured warrants to intercept cellular telephone wire communications of defendants Scurry, Hudson, Savoy, and Johnson. The government’s theory, as outlined in the affidavits, suggests that Jerome Johnson sold wholesale amounts of powder cocaine to Robert Savoy. Gov’t Omnibus Resp. Defs.’ Mots., Ex. 8, at 9, ECF No. 111-8. Savoy also collaborated with James Brown to buy wholesale quantities of cocaine. Id. Savoy then re-sold powder cocaine and crack cocaine to others, including Terrence Hudson and an unindicted suspect. Id. Hudson, Brown, and a second unindicted suspect resold powder and crack cocaine to others. Specifically, Hudson would resell to Eric Scurry and two additional unindicted suspects. Id. Finally, Nathan Robinson allegedly sold narcotics in the same geographic area as Scurry and a fifth unindicted suspect and the three would assist one another with sales in that area. Id. Based on the evidence generated during this investigation, a grand jury issued multiple indictments against various alleged co-conspirators. The most recent, the Third Superseding Indictment issued in December 2011, charged Savoy, Hudson, Johnson, Eric Scurry, Robinson, and Brown, with Conspiracy to Distribute and Possess with Intent to Distribute 5 Kilograms or More of Cocaine and 280 Grams or More of Cocaine Base, in violation of Title 21, United States Code, Section 846. The indictment also included an additional thirty seven substantive counts against defendants. Defendants filed motions to suppress evidence obtained from the government’s interceptions of them wire communications. This Court denied those motions in August 2012. The Court now considers additional pre-trial motions filed by defendants and the government. II. Motions to Suppress Evidence Seized through Searches [35, 37, 38, 58, 63, 67, 89,101, 201] a. Background Each of the six defendants has filed a motion to suppress physical evidence recovered during a search of his residence and defendant Scurry has filed a motion to suppress evidence recovered from his vehicles. Between November 7 and November 9, 2010, Special Agent (“SA”) Christopher M. Ray of the FBI submitted three applications for search warrants to the U.S. District Court for the District of Maryland and the U.S. District Court for the District of Columbia. Gov’t Omnibus Resp. Defs.’ Mots., Exs. 2, 4, 5, 7, 9-11, ECF No. 111-2, 111-4, 111-5, 111-7, 111-9-111-11. SA Ray requested search warrants for eight locations in Maryland and three locations in the District of Columbia, including the residences of all six defendants, as well as warrants for three vehicles, belonging to Scurry. Id. The warrant applications were accompanied by lengthy affidavits from SA Ray. Gov’t Omnibus Resp., Exs. 3, 8, 12, ECF No. 111-3,111-8,111-12. The affidavits included facts gleaned from the FBI’s lengthy investigation into the distribution of powder and crack cocaine in and around the Washington, D.C. metro area. Gov’t Omnibus Resp., Ex. 8, at 8. Specifically, they detailed information obtained from cooperating witnesses, controlled buys, physical surveillance, and finally, intercepted wire communications from the wiretaps authorized by Judge Henry H. Kennedy of the U.S. District Court for the District of Columbia. Id. According to SA Ray, each of the defendants had drug trafficking related communications or interactions with one or more co-defendants, controlled buyers, and/or unindicted suspects. Id. at 9-10. The affidavits also outlined the government’s theory regarding the defendants alleged criminal activities. Finally, each of the co-defendants and unindicted suspects whose residences the government sought to search had at least one, and typically multiple, prior narcotics charges or convictions. Id. at 10-21. b. Legal Standard i. Fourth Amendment Protections Generally The Fourth Amendment protects against unreasonable searches and seizures by government actors. U.S. Const. amend. IV. Warrantless searches are generally per se unreasonable subject to limited exceptions. Katz v. United States, 389 U.S. 347, 357, 88 S.Ct. 507, 19 L.Ed.2d 576 (1967) (“[T]his Court has emphasized that ... searches conducted outside the judicial process, without prior approval by judge or magistrate, are per se unreasonable ... subject only to a few specifically established and well-delineated exceptions.”) (citations omitted). Thus, a warrant is usually required before a search may be conducted and the warrant must be supported by probable cause. U.S. Const. amend. IV; Katz, 389 U.S. at 357-58, 88 S.Ct. 507. For a warrant to issue, the magistrate must make a “practical, commonsense decision whether, given all the circumstances set forth in the affidavit before him, including the ‘veracity’ and ‘basis of knowledge’ of persons supplying hearsay information, there is a fair probability that contraband or evidence of a crime will be found in a particular place.” Illinois v. Gates, 462 U.S. 213, 237, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983). Thus, a probable cause determination encompasses both the probability that criminal activity is afoot, as well as a nexus between that activity and the place to be searched. Additionally, probable cause may not be based on mere allegations or conclusory statements. See id. at 239, 103 S.Ct. 2317 (citing cases in which “wholly conclusory” or “bare bones” affidavits failed to provide a sufficient basis for probable cause). Suppression of evidence derived from an unlawful search is the baseline remedy for Fourth Amendment violations. However, as will be described in more detail below, this exclusionary rule has, for almost thirty years, been subject to a significant exception in cases where officers conducted the search pursuant to a warrant. ii. Standing to Challenge an Allegedly Unlawful Search or Seizure A defendant must have standing to challenge an allegedly unlawful search or seizure and to seek suppression of evidence derived therefrom. Fourth Amendment rights are “personal” rights and may not be asserted by third parties. Rakas v. Illinois, 439 U.S. 128, 132-34, 99 S.Ct. 421, 58 L.Ed.2d 387 (1978). Thus, to challenge the validity of a search or the introduction of evidence seized therefrom, an individual must have a “legitimate expectation of privacy” in the place searched. Id. at 143, 99 S.Ct. 421. One moving to suppress evidence on the basis of an illegal search bears the burden of demonstrating that his own Fourth Amendment rights were violated by the search. Id. at 131 n. 1, 99 S.Ct. 421 (citations omitted). In Rakas, for example, the court held that petitioners lacked standing in part because they made “no showing that they had any legitimate expectation of privacy” in the areas searched. Id. at 148, 99 S.Ct. 421. An individual’s expectation of privacy is perhaps at its height in his own home. However, individuals often have standing to challenge searches of places other than their own homes, including vehicles or the residence of another. Id. at 142, 99 S.Ct. 421 (citing Jones v. United States, 362 U.S. 257, 265, 80 S.Ct. 725, 4 L.Ed.2d 697 (I960)). This is part due to the Supreme Court’s finding that Fourth Amendment rights do not depend upon “a property right in the invaded place but upon whether the person who claims the protection of the Amendment has a legitimate expectation of privacy in the invaded place.” Id. at 143, 99 S.Ct. 421. Some early cases suggested that an individual might have standing to challenge the search of a location if he was “legitimately on premises.” See Jones, 362 U.S. at 267, 80 S.Ct. 725 (holding that a guest staying temporarily in a friend’s apartment had standing to challenge the search of that apartment). However, subsequent cases have made clear that mere legitimate presence at a location does not automatically confer standing to challenge a search of that location. See Rakas, 439 U.S. at 142-43, 99 S.Ct. 421 (noting that Jones “merely stands for the unremarkable proposition that a person can have a legally sufficient interest in a place other than his own home” and rejecting the notion that merely being “legitimately on premises” confers standing to challenge a search of that location). Rakas outlined a number of factors which, in Jones, had given rise to standing, including the fact that the movant had permission to stay in the apartment, had been given a key to the apartment, kept belongings there, and had “complete dominion and control over the apartment and could exclude others from it.” Rakas, 439 U.S. at 142-43, 149, 99 S.Ct. 421. Subsequent to Jones and Rakas, however, the Supreme Court made clear that a guest in another’s home need not have the level of “dominion and control” over the residence that gave rise to standing in Jones. The Court, in Minnesota v. Olson, held that an overnight guest had standing to challenge the warrantless search of his host’s home. 495 U.S. 91, 98-99, 110 S.Ct. 1684, 109 L.Ed.2d 85 (1990). In finding that the individual had a “legitimate expectation of privacy” in his host’s home, the Court emphasized societal expectations of privacy in such circumstances and noted that “[w]e are at our most vulnerable when we are asleep [for example, in another’s home] because we cannot monitor our own safety or the security of our belongings.” Id. at 99, 110 S.Ct. 1684. With respect to vehicle searches, Supreme Court precedent suggests that a defendant may have standing to challenge the search of a vehicle in which has a property or possessory interest. See Rakas, 439 U.S. at 148, 99 S.Ct. 421 (rejecting petitioners’ claims in part because they “asserted neither a property nor a possessory interest in the automobile, nor an interest in the property seized”). Moreover, the fact that a vehicle is registered in another’s name need not negate standing for one who has some privacy interest in the vehicle. See, e.g., United States v. Williams-Davis, 1992 WL 26025, at *1-2 (D.D.C.1992) (holding that defendant had standing to challenge search of car that he used and drove even though the car was registered in his aunt’s name and the ownership of the car was disputed). iii. Probable Cause In making a probable cause determination for purposes of issuing a warrant, a magistrate should make a “practical, common-sense decision whether, given all the circumstances set forth in the affidavit before him ... there is a fair probability that contraband or evidence of a crime will be found in a particular place.” Gates, 462 U.S. at 238, 103 S.Ct. 2317 (1983). The magistrate’s decision is owed “ ‘great deference by reviewing courts.’ ” Id. at 236, 103 S.Ct. 2317 (quoting Spinelli v. United States, 393 U.S. 410, 419, 89 S.Ct. 584, 21 L.Ed.2d 637 (1969); accord United States v. Spencer, 530 F.3d 1003, 1006-07 (D.C.Cir.2008)). The magistrate’s decision should not be subjected to de novo review. Id. The Supreme Court has directed that reviewing courts should not “invalidate ... warrants] by interpreting affidavits] in a hypertechnical, rather than a commonsense, manner.” Id. (citation omitted). “[S]o long as the magistrate had a “substantial basis for ... concluding]” that a search would uncover evidence of wrongdoing, the Fourth Amendment requires no more.” Id. at 236-37, 103 S.Ct. 2317 (quoting Jones, 362 U.S. 257, 271, 80 S.Ct. 725 (1960)). In examining whether probable cause existed to grant a search warrant, reviewing courts look at the “totality of the circumstances” rather than considering facts in isolation. Id. at 238, 103 S.Ct. 2317. Relevant factors may include the affiant’s experience and training, the reliability of any informants, prior similar criminal acts by individuals allegedly participating in the investigated criminal activity, etc. See, e.g. United States v. Laws, 808 F.2d 92 (D.C.Cir.1986) (discussing the importance of the affiant’s experience and noting that the criminal records of the suspects bore “weightily” on the issue of probable cause). While each fact within an affidavit may be insufficient when standing alone, the combination of all of the facts can establish probable cause. See United States v. Catlett, 97 F.3d 565, 574 (D.C.Cir.1996); United States v. Halliman, 923 F.2d 873, 881 (D.C.Cir.1991). Of particular importance to this case is the magistrate’s ability to look to the affiant’s experience in putting potentially ambiguous or seemingly innocent conduct into context. See United States v. Gilliam, 167 F.3d 628, 633 (D.C.Cir.1999). The D.C. Circuit has recognized the role that law enforcement experience can play in probable cause determinations. In United States v. Laws, for example, the court noted that an officer’s more than ten years of experience in investigating narcotics distribution “enabled him to fit the informants’ descriptions of the suspects’ behavior into a pattern familiar to drug-law enforcers” and to recognize facts as part of a modus operandi typical of drug trafficking. 808 F.2d 92, 103 (1986). “Law-enforcement officers may draw upon their expertise in translating activity that appears innocuous to the untrained mind into grounds supporting a search or arrest warrant.... In assessing probable cause, as the Supreme Court has declared, ‘the evidence ... collected must be seen and weighed not in terms of analysis by scholars, but as understood by those versed in the field of law enforcement.’ ” Id. at 103-04. Also relevant to this case is the ability of magistrates, in making a probable cause determination, to consider the past criminal involvement of the target of a warrant. The D.C. Circuit has noted that the prior drug trafficking records of suspects may be one factor corroborating other information forming the basis of a probable cause decision, for example, the reliability informants’ statements. Id. at 104. As already mentioned, probable cause requires not only a fair probability of criminal activity but also a nexus between that activity and the place to be searched. In other words, it requires “a fair probability that contraband or evidence of a crime will be found in a particular place.” Gates, 462 U.S. at 237, 103 5.Ct. 2317 (emphasis added). The D.C. Circuit has held that “ ‘observations of illegal activity occurring away from the suspect’s residence, can support a finding of probable cause to issue a search warrant for [the suspect’s] residence.” United States v. Thomas, 989 F.2d 1252, 1254 (D.C.Cir.1993) (per curiam). The court in Thomas noted that the nexus simply requires a “reasonable basis to infer from the nature of the illegal activity observed, that relevant evidence will be found in the residence.” Id. at 1255. In that case, probable cause to infer that evidence would be found in defendant’s residence was supported by the affiant officer’s statement that, “in his experience, drug dealers frequently keep business records, narcotics, proceeds from sales, and firearms in their houses.” Id. at 1254; see also id. at 1254-55 (citing cases from the Eighth and Ninth Circuits finding probable cause to search residences of those suspected of drug-related activities). To establish probable cause, the facts relied upon in the government’s application must also support an inference that evidence of a crime will be found in the place to be searched at the time of the search. This is often referred to as a requirement that information supporting the application not be “stale.” The D.C. Circuit has noted that, while not controlling, the length of time between an event supporting the issuance of a warrant and the actual application of a warrant is an important factor. United States v. Webb, 255 F.3d 890, 904 (D.C.Cir.2001) (citing Schoeneman v. United States, 317 F.2d 173, 177 (D.C.Cir.1963); Sgro v. United States, 287 U.S. 206, 210, 53 S.Ct. 138, 77 L.Ed. 260 (1932)). However, Courts need not simply look to the number of days or months between events in determining whether information is stale. Rather they may look to the type of criminal activity alleged, the characteristics of the suspect and the evidence sought, and the nature of the place to be searched. See United States v. Bruner, 657 F.2d 1278 (D.C.Cir.1981) (noting that a court may examine the character of “ ‘the crime (chance encounter in the night or regenerating conspiracy?), of the criminal (nomadic or entrenched?), of the thing to be seized (perishable and easily transferable or of enduring utility to its holder?), of the place to be searched (mere criminal forum of convenience or secure operational base?), etc.’ ”) (quoting Andresen v. State, 24 Md.App. 128, 331 A.2d 78, 106 (Md.Ct.Spec.App.1975), aff'd, 427 U.S. 463, 96 S.Ct. 2737, 49 L.Ed.2d 627 (1976)). The D.C. Circuit has upheld searches based on information obtained at least 109 days prior to application for the warrant, though it has expressed some discomfort with delays this long. See, e.g., Webb, 255 F.3d at 904. Again, however, the Circuit’s decisions have not relied solely on a numerical calculation of elapsed days. For example, in Schoeneman v. United States, the court held that probable cause did not exist to believe that unlawfully held classified documents would be recovered from defendant’s home. The warrant affidavit was based on a tip that the documents had been seen at the defendant’s residence 107 days prior to the warrant application. Schoeneman, 317 F.2d at 177-78. In Webb, the Circuit upheld a search based on information 109 days old, but found it “troubling” that the warrant to search for documents related to narcotics trade was based on information of that vintage. 255 F.3d at 904. Nevertheless, the Webb court upheld the search because, even if the information was too stale to support a showing a probable cause, the Leon good faith exception made suppression inappropriate. Id. at 904-05. In support of its finding, the court distinguished Schoeneman as relating to a “single-incident crime.” Webb, 255 F.3d at 905 (noting that the warrant in Schoeneman had issued on the basis “solely of an informant’s statement that he had seen classified documents in the defendant’s home on [a] single occasion”). In contrast, the Webb affidavit suggested ongoing or recurring narcotics transactions and contained an informant’s statement that Webb had been selling drugs “ ‘for an extended period of time.’ ” Id. The court noted that “[c]ourts have been considerably more lenient in assessing the currency of information supporting probable cause in the context of extended conspiracies than in the context of single-incident crimes” and continued that “it would not necessarily have been unreasonable for an officer to conclude that a longtime drug dealer, whose most recent known deal had occurred three months earlier, would still retain papers permitting him to get back in touch with his customers or ... his supplier.” Id. Likewise in United States v. Bruner, the D.C. Circuit rejected an argument that a January 1978 affidavit was based on stale information when it relied on information from the previous summer or early fall. 657 F.2d 1278, 1298 (D.C.Cir.1981). The Court emphasized that the information related to a suspect who had been involved in a drug trafficking conspiracy for six years, that the conspiracy continued to exist, and the suspect lived at the place to be searched. Id. at 1298-99. The Court also noted that the evidence included in the affidavit (observation of a drug display cabinet in the suspect’s home) had long been kept in defendant’s residence and that the suspect had expressed his intention to keep the cabinet as long as he sold drugs. Id. at 1299. iv. Leon Good Faith Exception Even where a reviewing court disagrees with the magistrate’s finding of probable cause, such disagreement does not automatically suggest the need to suppress evidence uncovered during the search. In United States v. Leon, the Supreme Court confirmed a “good faith” exception to the exclusionary rule. 468 U.S. 897, 104 S.Ct. 3405, 82 L.Ed.2d 677 (1984). Specifically, the Court held that law enforcement officers may rely on the probable cause determination of the magistrate approving the search warrant. Id. at 922, 104 S.Ct. 3405. As long as the executing officer relied in good faith on the warrant, the exclusionary rule does not apply. Id. at 920, 104 S.Ct. 3405. In fact, the D.C. Circuit has noted that the degree of deference owed by police to the magistrate’s probable cause determination is even greater than the “great deference” owed by reviewing courts to that determination. Spencer, 530 F.3d at 1007 (“[T]he ‘degree of police deference to the magistrate which is perceived by courts as reasonable under Leon exceeds significantly that ‘great deference’ owed the magistrate by reviewing courts under Gates.’ ”) (quoting 1 Wayne R. Lafave, Search and Seizure § 1.3(f), at 97-98 (4th ed.2004)). The Supreme Court has limited application of the Leon “good faith” exception and suppression of evidence remains an appropriate remedy where: (1) “the magistrate or judge in issuing a warrant was misled by information in an affidavit that the affiant knew was false or would have known was false except for his reckless disregard of the truth;” (2) “the issuing magistrate wholly abandoned his judicial role”; (3) the warrant was based on an affidavit “so lacking in indicia of probable cause as to render official belief in its existence entirely unreasonable”; or (4) the warrant was “so facially deficient— i.e., in failing to particularize the place to be searched or the things to be seized— that the executing officers cannot reasonably presume it to be valid.” Leon, 468 U.S. at 923, 104 S.Ct. 3405. Only two of these exceptions to the exception are raised by defendants, namely that the affiant relied, knowingly or with reckless disregard for the truth, on false information and that the affidavit was so lacking in indicia of probable cause as to render it unreasonable to rely on. There appear to be few cases granting motions to suppress on the basis of the third exception to Leon (that the affidavit was so lacking as to render reliance entirely unreasonable). However, the cases appear to include situations where, for example, the affidavit failed to link the suspect to the location to be searched, and failed to explain why the affiant believed evidence of criminal activity would be found at the location, failed to explain why evidence would be present long after officers received relevant information to support the affidavit. See, e.g., United States v. Johnson, 332 F.Supp.2d 35, 39 (D.D.C.2004). In another case, discussed in more detail below, officers learned 178 days prior to issuance of a warrant that photographs showing illegal activity had been taken in a suspect’s home. United States v. Lindsey, 596 F.Supp.2d 55 (2009). This Court held that the affidavit at issue was so lacking in indicia of probable cause as to make reliance upon it unreasonable. The affidavit did not specify when the photographs had actually been taken, and therefore when the criminal activity had occurred. Moreover, there was no additional corroborating evidence subsequent to the discovery that the photos were taken in Lindsey’s home. Finally, the Court reiterated that the case involved a single-incident crime, rather than an ongoing crime for which evidence of criminal activity would presumably be present in the location to be searched for a longer period of time. Cases finding that the Leon requirements were not met appear to be the exception rather than the rule. As the D.C. Circuit has noted, “ ‘[w]hen officers have acted pursuant to a warrant, the prosecution should ordinarily be able to establish good faith without a substantial expenditure of judicial time.’ ” Spencer, 530 F.3d at 1007 (quoting Leon, 468 U.S. at 924, 104 S.Ct. 3405). c. Defendants’ Motions i. Hudson Motions to Suppress [35, 63] 1. Background Defendant Terrence Hudson filed two nearly identical motions arguing that the November 10, 2010 search of his home at 6902 Hudson Avenue, Oxon Hill, Maryland, was unlawful and urging suppression of evidence seized pursuant to that search. Def. Hudson’s Mot. Suppress Phys. Evid. 1, ECF No. 35; Def. Hudson’s Mot. Suppress Phys. Evid. 1, ECF No. 63. That search resulted in the seizure of various items including a firearm and ammunition; a plate, straw, razor, and scale with residue; various rock-like substances; over $6,000 in cash; and cell phones and documents. Gov’t Omnibus Resp. Defs.’ Mots., Ex. 5, at 4-5, ECF No. 111-5. Mr. Hudson concedes that he lived at the home searched and this is supported by the information contained in SA Ray’s affidavit. Hudson’s Mot. 5. Hudson thus has standing to challenge the search and seizure. Hudson argues that the government’s warrant affidavit did not establish probable cause. Hudson’s Mot. 5. Specifically, he points to the affidavit’s reliance on admittedly ambiguous wiretapped conversations between Hudson and co-defendant Savoy. In one such conversation, Savoy told Hudson “I just got a new pair of shoes, I’m getting ready to go in here and try em on right now.” Hudson replied, “Alright, let me know something.” Gov’t Omnibus Resp. Defs.’ Mots., Ex. 8, at 28, ECF No. 111-8. Savoy responded that he would “let [Hudson] know in about 40 minutes” and an hour later called to state “we real cool ... you can run all day if you want to.” Id. at 28-29. Four days later, Savoy called Hudson to ask “What’s the word?” Hudson replied, “Oh yeah that’s straight right there. I need to see you when you get out.” Id. at 30. The two then drove separately to a parking lot in Oxon Hill, Maryland where Savoy got into Hudson’s vehicle for less than 30 seconds before returning to his own vehicle. Each then drove away in different directions. Id. at 31. Special Agent Ray interpreted these conversations to include narcotics code language and to relate not to shoes, but to drugs. Id. at 28-29. He argued that “try[ing] on” the “shoes” referred to cooking cocaine into cocaine base or crack cocaine to test the quality. Id. According to SA Ray, Savoy’s comment, “we real cool,” and Hudson’s comment, “that’s straight,” were references to the satisfactory quality of the drugs Savoy provided Hudson. Id. at 29. SA Ray also believed that during the meeting in the parking lot, Savoy provided Hudson with another supply of drugs. Id. at 31. Hudson argues that SA Ray’s interpretations of the wiretapped conversations amount to “conclusory explanations ... insufficient to make up for the lack of probable cause” that contraband would be found at Hudson’s residence. Hudson’s Mot. 6. Specifically, Hudson suggests that codes are usually used more than once and that the mention of “a new pair of shoes” in only one call does not support the inference that the phrase was code for drugs. Hudson’s Mot. 8. He argues that more corroboration was necessary to show probable cause that Hudson was part of the conspiracy and that his home would contain illegal drugs or other evidence of criminal activity. Hudson’s Mot. 6. Hudson goes on to suggest that Leon’s good faith exception does not save the allegedly defective warrant because the affidavit was so lacking in indicia of probable cause as to make reliance upon it unreasonable. Hudson’s Mot. 6-7. Again, Mr. Hudson argues that the affidavit’s reliance on coded conversations cannot support the officers’ good faith reliance on the warrant. Hudson’s Mot. 8. 2. Probable Cause Existed to Search Hudson’s Residence Hudson’s motion downplays or fails to mention several key pieces of information. First, Special Agent Ray has served on a drug and violent crime squad since October 2008 and, prior to that, was a Public Safety Officer and Detective for approximately eight years with the Highland Park Department of Public Safety in Highland Park, Texas. Gov’t Omnibus Resp. Defs.’ Mots., Ex. 8, at 1-2, EOF No. 111-8. His affidavit provides some eight pages of information detailing his experience, training, and involvement in the present investigation as well as patterns he has observed in other drug trafficking investigations. Id. at 1-8. As outlined above, his experience and interpretations are entitled to some weight. Second, two cooperating witnesses informed the FBI that Hudson sold crack cocaine and that he had been seen with defendant Scurry. Id. at 21-23. Cooperating Witness (“CW1”), for example, had been cooperating with the FBI since July 2007 and had known Hudson “for a number of years.” Id. at 21-22. CW1 informed the FBI that Hudson had been selling crack cocaine for “some time,” at least since 2007. Id. at 22. Although the cooperating witnesses have criminal records and one has been paid for some of “its” cooperation, the information they provided was corroborated “to the extent possible.” Id. Moreover, the affidavit laid out these facts for the magistrate’s consideration. Id. at 23. Third, the affidavit stated that Hudson had two prior charges for possession with intent to distribute a controlled substance and that Savoy, the person with whom Hudson was talking, has two prior charges for possession with intent to distribute cocaine. Id. at 10-11. Although the information is not dispositive, a magistrate making a probable cause determination may consider a suspect’s prior involvement in the same type of criminal activity being investigated. Finally, and perhaps most importantly, Hudson’s motion fails to mention an intercepted call between Savoy and Hudson on August 4, 2010. According to SA Ray, the two discussed meeting so that Savoy could provide Hudson with “ ‘five,’ ” which Ray interpreted to mean five 31-gram packages of powder cocaine. Id. at 31-32. Savoy and Hudson then met in the parking lot of the House of Chang restaurant in Fort Washington, Maryland. Id. A subsequent traffic stop of Hudson by Prince George’s County Police resulted in the seizure of five plastic bags each containing approximately 31 grams of powder cocaine from the center console of Hudson’s car. Id. Based on a totality of the circumstances, the magistrate’s approval of a search warrant for Hudson’s home was reasonable. The affidavit supporting the warrant application was based on a combination of factors, including information from two cooperating witnesses previously determined reliable by the FBI, interpretations of coded conversations by SA Ray, the prior narcotics involvement of both men, two unexplained meetings between Hudson and Savoy in parking lots, and the seizure of five bags of cocaine from Hudson shortly after he had discussed meeting with Savoy to get “five.” These were sufficient to support a finding of probable cause that Hudson was engaged in narcotics trafficking with Savoy. Furthermore, D.C. Circuit precedent supports the inference that evidence of narcotics trafficking would be found in Hudson’s home, despite the fact that most evidence of it was derived from activity that may have taken place elsewhere. See United States v. Johnson, 437 F.3d 69, 71-72 (D.C.Cir.2006); Spencer, 530 F.3d at 1007 (“Common experience suggests that drug dealers must mix and measure the merchandise, protect it from competitors, and conceal evidence of their trade ... in secure locations. For the vast majority ... the most convenient location to secure items is the home.”). Finally, even if probable cause were lacking, the agents relied upon the warrant in good faith. The Court rejects Hudson’s assertion that the affidavit was “so lacking in probable cause” as to render reliance on it unreasonable. Furthermore, the Court is mindful that “ ‘[w]hen officers have acted pursuant to a warrant, the prosecution should ordinarily be able to establish good faith without a substantial expenditure of judicial time.’ ” Spencer, 530 F.3d at 1007 (quoting Leon, 468 U.S. at 924, 104 S.Ct. 3405). For the foregoing reasons, Hudson’s Motions [35, 63] to Suppress are DENIED. ii. Savoy Motions to Suppress [37, 38] 1. Background Savoy moves to suppress the introduction of evidence seized during the November 10, 2010 search his residence at 3766 Stonesboro Road, Fort Washington, Maryland. Def. Savoy’s Omnibus Mot. 3-4, ECF No. 37; Def. Savoy’s Mot. Suppress Tangible Evid. 1, ECF No. 38. During the search, agents seized a variety of items including what was believed to be over one kilogram of cocaine, two digital scales, multiple firearms and ammunition, and over $35,000 in cash. Gov’t Omnibus Resp. Defs.’ Mots., Ex. 7, at 4-6, ECF No. 111-7. Savoy argues that the affidavit in support of the search warrant contains “multiple representations in the nature of conjecture, inferences and conclusions ... [and] does not set forth any facts or circumstances pertaining to any participation by Mr. Savoy in any specified ... act of criminal conduct.” Savoy’s Mot. 2 (emphasis omitted). Savoy argues that the affidavit “failed to provide the essential specifications of fact and circumstances that might have supported a finding of probable cause.” Savoy’s Mot. 3. Little other detail is provided regarding why probable cause might be lacking. Savoy requests an evidentiary hearing to “confirm the facts alleged above” and an order suppressing the use of the evidence by the government. Id. Savoy concedes that the search conducted was of his residence and this is supported by the surveillance information outlined in SA Ray’s affidavit. Savoy’s Mot. 4; Gov’t Omnibus Resp. Defs.’ Mots., Ex. 8, at 48, ECF No. 111-8. Savoy thus has standing to challenge the search and seizure. 2. Probable Cause Existed to Search Savoy’s Residence The facts supporting probable cause as to Savoy overlap significantly with those supporting probable cause as to two other defendants and one unindieted suspect. The affidavit incorporates the details of these facts by reference to the sections dealing with the other defendants. Id. The affidavit refers to a number of calls, detailed above, in which Savoy told Hudson, he had gotten a new pair of shoes and was going to try them on. It also refers to the meeting between Savoy and Hudson in the House of Chang parking lot, after which Hudson was stopped with five, 31-gram baggies of cocaine. The affidavit also refers to calls and a meeting between Savoy and co-defendant Johnson. On July 27, 2010, Savoy received a call from Johnson in which Savoy stated he “made me a good move last night” and that he “got rid of, well, you know.” Id. at 44. The next day, Johnson called Savoy and Savoy said “Hopefully somebody will hit me and clean me up today----If they do, I will hit you and let you know.” Id. at 45. Special Agent Ray believed that in this conversation, Savoy was telling Johnson that he had sold most of the cocaine he had and that he would be ready to buy more from Johnson when another buyer contacted him that day. Id. About two weeks later, during a call between Johnson and Savoy, Johnson said, “Yea, it’s good” and asked “where you want to holler at me?” Savoy responded “... I guess the regular” and the two met shortly thereafter in a parking lot in Fort Washington, Maryland. Id. at 46. They spoke for approximately 10 minutes before each driving away. Id. at 46-47. Special Agent Ray believed that Johnson provided Savoy with a kilogram of cocaine at this meeting. Id. at 47. Johnson later called Savoy and Savoy said, “[It] should have been six five and one deuce” to which Johnson replied “Oh yeah, thirty-two right?” Id. Savoy said “The six fives was in two bands and the deuce was in one band down the middle.” Id. Special Agent Ray interpreted this to refer to $32,000 or a price consistent with the retail price for a kilogram of powder cocaine in Washington, D.C. at the time. Id. The affidavit also describes conversations and a meeting between Savoy and an unindicted suspect in which the unindicted suspect told Savoy he needed to see him and Savoy replied, “[Y]ou done already? ... That joint was cool?” Id. at 50. The next day, the unindicted suspect and Savoy met in the parking lot at the House of Chang restaurant and the unindicted suspect walked toward Savoy holding what looked like a white envelope. Id. at 52. The two met briefly before each driving away. Id. SA Ray believed the unindicted suspect had sold all of his cocaine, needed a new supply from Savoy, and met Savoy to purchase it. Id. at 50. In addition to the interpretations of these conversations and meetings, the affidavit outlined Savoy’s previous criminal charges and at least one narcotics conviction. Id. at 10. The totality of the circumstances supports the magistrate’s finding that there was probable cause to search Savoy’s home. Perhaps most telling is the meeting between Savoy and Hudson after which Hudson was pulled over and police found five, 31-gram baggies of cocaine. Additionally, the conversations between Savoy and Johnson and between Savoy and an unindicted suspect, while in ambiguous language, support SA Ray’s inference that Savoy was purchasing drugs from Johnson and selling them to the unindicted suspect. This interpretation is further supported by meetings between the parties and the apparent exchange of a white envelope between the unindicted suspect and Savoy. Special Agent Ray’s interpretations of these conversations, in light of his prior experience, is to be given credence. Finally, Savoy’s prior narcotics involvement and the prior narcotics convictions of those with whom he was interacting likewise support the finding of probable cause. 3. Leon Good Faith Exception Applies As with the Hudson warrant, even if the above were not sufficient to establish probable cause, it would be enough to support the agents’ good faith reliance on the warrant under Leon. The warrant included significant information linking Savoy to the alleged drug conspiracy and officers were able to corroborate at least one alleged drug transaction through the traffic stop of and associated seizure of drugs from Hudson. There is nothing to suggest that the affidavit was so lacking in indicia of probable cause as to render reliance upon it entirely unreasonable. 4. Evidentiary Hearing Not Required Finally, no evidentiary hearing is needed to address the issue of probable cause. The probable cause determination was made on the basis of the warrant application and the affidavit provided. Review of that determination can be made within the four corners of those documents and the defendant’s motion. For this reason, at a hearing on August 14, 2012, the Court denied the request of Savoy and other defendants to call witnesses and noted that the Court would make its determination on the papers. For the foregoing reasons, Savoy’s Motions [37, 38] to Suppress are DENIED, iii. Scurry Motion to Suppress Evidence Seized from Search of his Room [58] 1. Background Defendant Scurry argues that the Court should suppress evidence recovered from Room “M” during the November 10, 2010 search of 6902 Dudley Avenue, Oxon Hill, Maryland. Def. Scurry’s Mot. Suppress 1-3, ECF No. 58. The search resulted in the seizure of a number of items from that room including, an off-white rock substance in the pocket of a pair of jeans, ammunition, and various documents. Gov’t Omnibus Resp. Defs.’ Mots., Ex. 5, at 4-5, ECF 111-5. At the time of the search, Scurry was allegedly residing in this room at the home of co-defendant Terrance Hudson. Scurry does not concede in his motion that he resided there at the time of the search, instead noting that the affidavit “claim[ed] that [he had] resided at the residence ‘as of recent weeks’ ” and that evidence was recovered from the room he was “said to occupy.” Scurry’s Mot. 1-2. Scurry also does not tell the Court why he has a legitimate expectation of privacy in the room searched. At the time of approval of the search warrant, significant evidence existed that Scurry was involved in the narcotics trade, including nine controlled buys, many of which were audio- or video-recorded, and numerous wiretapped conversations. Scurry’s primary argument in support of his motion to suppress is that information on which probable cause was based was “stale.” Scurry’s Mot. 3. Specifically Scurry states that the most recent information on which issuance of the warrant was grounded consisted of calls on April 24, 2010, 199 days before the warrant was issued. Scurry’s Mot. 3-4. He also points to a wiretapped conversation from April 14, 2010 between himself and his wife in which he stated that Hudson had seen a “strange car by his house.” Scurry reported telling Hudson that he was going to “go in the house [and] clean my little dirty room.” Scurry’s wife responded “I was praying for both of [y’all] earlier today, saying both of [y’all] need to do something with [y’all] seifs ... getting [too] old for that nonsense.” Gov’t Omnibus Resp. Defs.’ Mots., Ex. 8, at 37, ECF No. 111-8. Scurry replied “You right.” Id. Scurry mentions this exchange to support his claim that no evidence supported any continuing involvement in drug trafficking by November 2010. Finally, Scurry notes that, during earlier points in the investigation, he had resided elsewhere. Scurry’s Mot. 4. Scurry alludes to the fact that this might defeat the nexus between the probable cause and the place to be searched. Scurry’s Mot. 4-5. Scurry argues that the Leon good faith exception cannot apply because the warrant was so lacking in probable cause as to render reliance on it unreasonable. Scurry’s Mot. 5. 2. Stateness Scurry points to a case from this Court, United States v. Lindsey, 596 F.Supp.2d 55 (2009), to support his assertion that evidence supporting his warrant was stale. In Lindsey, the Washington, D.C. Metropolitan Police Department (MPD) obtained photographs of an adult giving a Glock pistol and a Tec-9 assault pistol to a toddler. 596 F.Supp.2d at 57. The MPD determined that the adult was the child’s father, executed a search warrant at his residence on August 24, 2006, but did not find either of the pictured weapons. Id. Evidence later suggested that the photos had been taken in January or February of 2006 in the home of Ricky Lindsey. Id. Subsequently, another search of Johnson’s residence in November 2007 also failed to produce the pictured weapons and on February 7, 2008, an FBI agent obtained a warrant to search Lindsey’s residence on the basis of the photographs. Id. Relying on United States v. Webb, the Court held that the warrant for Lindsey’s residence, issued at least 178 days after law enforcement personnel learned where they were taken, did not issue upon probable cause. Id. at 59. The Court noted that this interval was much longer than in Webb and that, unlike Webb, the case involved a single-incident crime rather than an ongoing conspiracy. Id. Furthermore, the Court held that the Leon good-faith exception did not apply because the affidavit was so lacking in probable cause as to render reliance on it unreasonable. Id. at 60-61. Specifically, the Court distinguished the case from Leon where officers were held to have reasonably relied on a warrant and the affidavit contained an informant’s statement that he had seen drugs (i.e. witnessed criminal activity) five months before the search. Furthermore, the informant’s statements were corroborated by observations within the month preceding issuance of the warrant. In Lindsey, officers learned 178 days prior to issuance of the warrant that the photographs had been taken in Lindsey’s home. The affidavit did not include information about when the photographs had actually been taken, and therefore when the criminal activity had occurred. Furthermore, there was no additional corroborating evidence subsequent to the discovery that the photos were taken in Lindsey’s home. Finally, the Court reiterated that Lindsey involved possession of a weapon, a single-incident crime, rather than an ongoing crime like the drug conspiracy in Leon. Id. at 61. Leon itself also involved an affidavit that relied on a five-month old tip. In Leon, the Court held that, although the affidavit did not support probable cause, evidence obtained from the search could nevertheless be admitted during the prosecution’s case-in-chief because the officers reasonably relied on the warrant. 3. Scurry Lacks Standing to Challenge Search Scurry has not met his burden of showing that he has standing to challenge the search of Room M at the Hudson residence. While the government believes that Scurry had been residing at the house in the weeks leading up to the search and information gleaned during the search suggests he was living there at the time, Scurry refuses to acknowledge that he lived there or even that he had been staying at the home. Moreover, Scurry makes no argument as to why he may have had a legitimate expectation of privacy in the place to be searched. As a result, Scurry does not have standing to challenge the search. 4. Evidence Nevertheless Admissible Even if the Court were to find that Scurry enjoyed standing, the evidence seized during the search would be admissible. While Scurry raises a legitimate concern regarding the possible staleness of the evidence against him and the Court acknowledges that this is a close case, several facts cut against Scurry and lead the Court to conclude that suppression would be inappropriate (if not based on adequate probable cause, then under the Leon good faith exception). First, although Scurry cites April 24, 2010 as the last date on which the government acquired information regarding Scurry’s involvement in the narcotics conspiracy, this was arguably not the most recent relevant evidence. The search warrant affidavit outlines calls between Scurry and an unindicted suspect, as well as between Scurry and Hudson, as late as May 19, 2010 and July 13, 2010, respectively. Gov’t Omnibus Resp. Defs.’ Mots., Ex. 8, at 59-60, ECF No. 111-8. These calls linked Scurry to the alleged conspiracy within 174 or 119 days of the warrant, respectively. Specifically, in a call on April 29, 2010, the unindicted suspect asked Scurry whether he had talked to his “peoples” for him. Id. at 57. The following the day, the unindicted suspect called Scurry to say he was outside and Scurry said he would send his cousin “out there and get it.” Id. at 58. Three minutes later, Scurry called the unindicted suspect and said ‘You gave him seven or six?” Id. When the unindicted suspect replied “Six ... Why would I give him seven?” Scurry said, “What you mean man, I’m tripping like shit.” Id. He then said he was “about to go up there” and would “let [him] know something about five minutes.” Id. SA Ray interpreted this conversation as a transaction between the unindicted suspect and Scurry in which the unindicted suspect paid Scurry (possibly $600) to buy drugs from Scurry’s supplier on his behalf. Id. at 58-59. After being arrested, charged with Possession with Intent to Distribute Cocaine, and briefly jailed, the unindicted suspect spoke with Scurry again on May 19, 2010 about getting in touch with his “peoples” so that he could “keep [his] balling rolling.” Id. at 59. SA Ray interpreted these calls to suggest that the unindicted suspect was trying to resuscitate his drug business after being in jail. Id. Finally, on July 13, 2010, after the unindicted suspect had been re-arrested, Scurry told Hudson, “I finally went and got [his] car today ... but they took his money ... It was still there though, lucky me. They got a search warrant from the judge saying they ... wanna search the car because illegal drugs in the car, some shit. These [people] did all that, lying, and it was still there.” Id. at 59-60. SA Ray interpreted this to mean that Scurry had found drugs stashed in the unindicted suspect’s car. Id. at 60. In addition to these more recent intercepted calls, two cooperating witnesses reported their belief that Scurry had been selling crack cocaine since at least 1992 and 2005, respectively. Id. at 21-23. These contentions are supported by the affidavit’s inclusion of Scurry’s extensive narcotics convictions, stretching from 1990 to 2009. Id. at 12-13. The fact that Scurry then participated in nine controlled buys suggests little indication that Scurry planned to cease his narcotics operation. While Scurry cites the April 2010 conversation with his wife to negate the possibility of probable cause in November, this argument is simply not persuasive enough to counter evidence that Scurry had sold drugs over the past two decades, continued to sell drugs throughout most of this investigation, and was, according to the government, living with one of his alleged co-conspirators at the time of the search. Unlike a search for a firearm, as in Lindsey, searches for evidence of a drug trafficking conspiracy may be based on older information given the continuing nature of that crime and the fact that drug dealers may store inventory and records at their homes for some time. See United States v. Hopkins, 128 F.Supp.2d 1, 7 (D.D.C.2000). When viewed in totality, the evidence appears to be sufficient to support a finding of probable cause. However, the Court need not decide the issue of probable cause because, even if the search warrant were based on stale information, the good faith exception would prevent suppression of evidence seized during the search. There was significant evidence linking Scurry to drug trafficking and to the alleged conspiracy. Scurry’s primary argument relates to the potential staleness of this information. However, unlike in Lindsey, Scurry was charged with a continuing offense for which the standard with respect to staleness is more relaxed. Moreover, even if this were a close call, Leon would not require suppression unless the affidavit was so lacking in indicia of probable cause as to render reliance upon it “entirely unreasonable.” That was clearly not the case in this instance. For the foregoing reasons, Scurry’s Motion [58] to Suppress is DENIED, iv. Scurry Motion to Suppress Evidence Seized from Search of His Vehicles [89] 1. Background On November 17, 2010, SA Ray applied for, and the court issued, warrants to search three vehicles belonging to Scurry and his wife. Searches of the vehicles resulted in the seizures of various documents, photographs, GPS devices, and other items. Gov’t Omnibus Resp. Defs.’ Mots., Ex. 9, at 4, ECF No. 111-9; Gov’t Omnibus Resp., Ex. 10, at 4, ECF No. 111-10; Gov’t Omnibus Resp., Ex. 11, at 3, ECF No. 111-11. Scurry argues that evidence seized from the vehicles, as well as evidence of canine alerts to areas of the vehicles, must be suppressed because the warrants were either based on information obtained from the allegedly illegal use of a GPS tracker on Scurry’s GMC Denali or based on stale information. Def. Scurry’s Mot. Suppress Evid. Vehicles 3. Specifically, Scurry argues that the last fact to establish probable cause occurred 177 days before issuance of the warrant, though it is not entirely clear how he calculated this figure. Scurry’s Mot. 4. Because the Court determined during an August 2012 hearing that the “independent source” and the inevitable discovery doctrines overcame any concerns related to potentially unlawful use of a GPS, the Court deals now only with Scurry’s argument as to probable cause. While Scurry does not explicitly assert that he has standing to challenge introduction of the evidence seized from the vehicles, however, he asserts that the vehicles are “his.” Suggesting either an ownership or possessory interest in the vehicles. Moreover, the government’s affidavit supporting its warrant application provided extensive information about Scurry’s use of the searched vehicles. While each of the three vehicles was registered in Scurry’s wife’s name, this would not defeat standing so long as Scurry maintains a possessory interest in the vehicle. See, e.g., Williams-Davis, 1992 WL 26025. The Court is satisfied that he has met his burden by conceding that the vehicles belong to him and his wife. Scurry’s Mot. 1-2. 2. Probable Cause Likely Existed to Search Vehicles Again, it is unclear how Scurry calculated that 177 days elapsed between the last fact to establish probable cause and the issuance of the warrant, though it may represent the time between a May 23, 2010 alleged drug transaction in Scurry’s GMC Denali, Gov’t Omnibus Resp. Defs.’ Mots., Ex. 12, at 17, ECF No. 111-12, and the November 17, 2010 issuance of the warrant for all three vehicles. However, as the Court will point out, subsequent events also supported probable cause to search the Denali and the other vehicles. The affidavit outlines probable cause with respect to each vehicle separately. Gov’t Omnibus Resp. Ex. 8, ECF No. Ill— 8. With respect to a 1998 white van, registered in Keena Scurry’s name at Hudson’s address, the affidavit stated that the van had been used during two controlled buys in November 2009 and January 2010 and stated that agents had seen the van driven by Scurry between April and July 2010 and parked where Scurry allegedly sold drugs. Id. at 16. The affidavit also noted that the van bears a business advertisement for the remodeling business SA Ray believed to be a front for Scurry’s narcotics trafficking organization. Id. To support probable cause to search the 2004 grey GMC Denali, registered in Keena Scurry’s name, the affidavit cited visual surveillance of the vehicle being used during two alleged drug transactions on April 22, 2010 and May 23, 2010. Id. at 17-18. It also noted that agents had, at various times between April and October 2010, seen the vehicle being driven by Scurry and parked where he allegedly sold drugs. Id. at 17. Finally, with respect to a 2006 Silver Chrysler 300, also registered in Keena Scurry’s name, SA Ray saw Scurry, at various times between April and October 2010, driving the vehicle and parking it where he allegedly sold drugs. Id. at 18. If this information was the only information provided by the affidavit, the Court might have lingering concerns regarding the potential staleness of the evidence. The most recent evidence with respect to the white van was either a January 2010 controlled buy or a July 2010 sighting of Scurry in the driving or parking the van near where he allegedly sold drugs. With respect to the other two cars, the evidence shows a buy in the Denali on May 23 and sightings of Scurry driving the vehicles and parking them near where he sold drugs in October. The mere sightings of Scurry parking these vehicles near where he sold drugs, without more, might not particularly support probable cause. Moreover, it may be that a warrant for the search of a car for evidence of drug-related activity must be supported by more recent evidence than a warrant to search a suspect’s home. A vehicle, by nature, mobile. Scurry was likely to have used it for many different purposes at many different places during the course of the investigation. Unless routinely garaged, a vehicle is also routinely visible to the public and driven or parked on public roads. While contraband might be hidden in the trunk or other concealed places within the car, it seems far less likely that one engaged in criminal activity would store evidence of his activity in a vehicle for months at a time rather than in his residence. Indeed, the majority of the background information contained in the affidavit recites the affiant’s experience that drug traffickers maintain evidence of their crimes in their residences, the residences of friends or family, stash houses, storage facilities, business locations, and other “secure locations.” Id. at 3-8. Nevertheless, the affidavit does state that, in SA Ray’s experience, Eric and Keena Scurry used their vehicles to “transport, store and facilitate drug trafficking operations” and that drug traffickers will “often use their vehicles to transport and to store their narcotics as well as the accouterments of their narcotics trade, such as scales, packaging materials, and ... other items” and will “routinely alternate vehicles in order to elude law enforcement.” Id. at 9, 15. Moreover, the affidavit recites evidence of Scurry’s more recent narcotics involvement through presentation of evidence from the search of Scurry’s room seven days earlier. Id. at 14. Specifically, the affidavit provides support for the notion that Scurry resided in that room and details the discovery of 5.6 grams of crack cocaine in the pocket of a pair of pants believed to belong to Scurry. Id. at 14. Scurry has argued that that the search of his “alleged” room was unlawful and if the court were to find that to be the case, it would not consider the fruits of that search in evaluating probable cause for another search. However, as already stated, the Court does not hold that the search of Scurry’s room was based on less than probable cause and as such, the evidence obtained was lawfully used by SA Ray in seeking a warrant for the search of Scurry’s vehicles. While the presence of crack cocaine in the defendant’s room supports only an attenuated inference that evidence of drug trafficking would be found in Scurry’s vehicles, the Court assumes that this, combined with Scurry’s lengthy, narcotics-related criminal record and previous use of all three vehicles for his activities, is sufficient to support probable cause to search the vehicles. 3. Leon Good Faith Exception Excuses Any Defect Again, however, the court need not decide the issue of probable cause because the search was reasonable under the Leon good faith exception. The affidavit was not so lacking as to render reliance upon it entirely unreasonable. SA Ray outlined the basis for his belief that Scurry was engaged in criminal activity and continued to be engaged in such activity leading up to issuance of the search warrant. He also stated the basis upon which he believed that contraband would be found in the vehicles. Once the magistrate accepted these assertions and issued the warrant, officers acted reasonably