Full opinion text
RULING ON THE DEFENDANTS’ “STANDING” TO CHALLENGE THE ADMISSABILITY OF EVIDENCE SEIZED AT SUITE 301, 210 PONCE DE LEON AVENUE, PUERTA DE TIERRA; EL CENTRO CONDOMINIUM, SUITE 249, BUILDING I, MUNOZ RIVERA AND LA HIJA DEL CARIBE STREETS, HATO REY; AND COOPERATIVA LOS ROBLES, APARTMENT 1012A, VILLA NEVA-REZ, RIO PIEDRAS, PUERTO RICO CLARIE, Senior District Judge. The defendants in this case, with the exception of Paul Weinberg, each claim standing to challenge the legality of searches conducted at 1) Suite 301, 210 Ponce de Leon Avenue, Puerta de Tierra, Puerto Rico (hereinafter “Ponce de Leon”); 2) El Centro Condominium, Suite 249, Building 1, Munoz Rivera and La Hija del Caribe Streets, Hato Rey, Puerto Rico (hereinafter “El Centro”); and 3) Coopera-tiva Los Robles, Apartment 1012A, Rio Pie-dras, Puerto Rico (hereinafter “Apartment 1012A”). Each defendant, with the exception of Paul Weinberg, claims to have had, at the time of each search, a legitimate, reasonable expectation of privacy in each of these locations. The Court finds, however, 1) that only the defendant Filiberto Ojeda Rios has made out a colorable standing claim with regard to the Ponce de Leon premises; 2) that all of the other defendants have failed to adequately allege the existence of legitimate expectations of privacy in each of the three locations at issue; and 3) that defendant Ojeda Rios has also failed to adequately allege the existence of such an interest with regard to the El Centro condominium and Apartment 1012A. Facts Suite 301, 210 Ponce de Leon Avenue is a two-room “office” located in a multi-story commercial building in a business sector of Puerta de Tierra, Puerto Rico. Government agents searched this location on April 3, 1984 pursuant to a warrant. The El Centro Condominium is likewise a suite of rooms located in a multi-story commercial structure in Hato Rey, Puerto Rico. Apartment 1012A is a multi-room apartment located in a residential building in Rio Piedras, Puerto Rico and is the home of non-defendant Sylvia Mulling Cowert. Government agents searched the apartment, as well as the El Centro condominium pursuant to a warrant on August 30, 1985. The present indictment charges the defendants with various illegal acts associated with the September 12, 1983 robbery of the Wells Fargo Depot in West Hartford, Connecticut. More specifically, the indictment charges the defendants with, among other things, participation in various conspiracies to commit numerous illegal acts, including the robbery itself, and the transportation of stolen monies across state and national boundaries. The Government represents that it will use items seized at the three locations cited above as part of its case-in-chief. The defendants object to the intended introduction of this evidence, challenging the legality of the searches and seizures on a variety of grounds. The issue raised by the Government and addressed in this ruling is whether the defendants have Fourth Amendment “standing” to challenge the use of this evidence at trial. Discussion A. The Defendants’ Compliance with the Court’s Previous Orders The defendants have filed a number of documents setting out their various standing claims. As permitted by Rule 12(c), the Court originally required all defendants to file their suppression motions by December 22, 1986, stating specifically that “[a]ll defendants shall ... file all remaining substantive motions, including but not limited to motions regarding ... (c) the alleged illegality of certain searches and seizures conducted against the defendants.... ” Modified Pretrial Scheduling Order, signed October 29, 1986, p. 2. Several defendants, both individually and on behalf of various co-defendants, filed motions and memoranda discussing various defendants’ privacy interests in the Ponce de Leon, El Centro, and Apartment 1012A locations. These focused largely on the defendants’ legal arguments surrounding their “collective” or “corporate” standing theories. For example, with regard to the Ponce de Leon location one defendant filed the following: Defendants do not offer separate documentary proof of the invasion of their rights to privacy at Suite 301. As noted in the affidavit of counsel, numerous warrants for electronic surveillance and physical searches have been based upon sworn statements by government agents asserting their custody and ownership of organizational files, distribution lists, minutes of meetings, publications and tangible objects. There is nothing in any of the government’s sworn documents or testimony to suggest that defendants used this location with anything other than the expectation that they would enjoy the utmost privacy there. The government can hardly now disavow those sworn statements. Defendants’ Memorandum of Law in Support of Motion to Suppress Evidence, dated December 22, 1986, p. 19 (emphasis added). Counsel argued in court that the defendants intend to rely on a “corporate” or “collective” standing theory to establish standing for each defendant in the locations at issue. Some defendants, however, also argued that they wished to pursue individual standing claims not encompassed by the defendants’ “corporate” theory. Thus, some defendants submitted more particularized accounts of the nature of his or her specific privacy interest in each location. See Supplemental Memorandum of Defendant Jorge Farinacci Garcia, filed December 23, 1986. Others argued that they wished to reserve the right to file such claims in the future in the event that their “corporate” standing theory proved to be unavailing. See e.g. Defendants’ Joint Motion to Reserve Right to Move to Suppress, filed December 22, 1986 (reservation of right to challenge search of Apartment 1012A). The Court, 1) wishing to give the defendants the opportunity to more fully present standing claims; 2) recognizing the need for greater clarification of the particular claim(s) of each individual defendant; 3) wishing to resolve the standing issues in a fair and expeditious manner; and 4) seeking to elicit a detailed, particularized factual response from each defendant so as (a) to permit the Government to respond to each defendant’s claim and (b) to enable the Court to determine the precise questions at issue and the need for further hearings, signed a supplemental order on January 30, 1987, which directed: Due to the important nature of “standing” issues; the interest in clarifying these issues; and the interest in avoiding prolonging the present suppression hearings unnecessarily, each defendant is hereby required to submit specific allegations of “standing” for each and every location and vehicle the physical search of which he or she challenges. Each individual defendant’s allegation(s) of “standing”, whether based upon an individual or collective interest in the location or vehicle searched, must specify the exact nature of the interest(s) upon which the individual defendant’s allegation(s) of “standing” is based, including any and all factual allegations supporting the individual defendant’s “standing” claim. Preliminary Ruling on Defendants’ “Standing’’ to Seek Suppression, January 30, 1987, p. 2 (emphasis added). The Court allowed the defendants until February 17, 1987 to make their particularized submissions. Id. at 2. See United States v. Purvis, 544 F.Supp. 68, 69 (S.D.N.Y.1982) (requiring defendants to submit sworn affidavits to enable the Court to gauge the validity of the defendants’ arguments and the need for a hearing). It is clear that the defendants understood that this order required of them to submit individual, detailed allegations with regard to their personal expectations of privacy in the locations at issue. Transcript of February 5, 1987, pp. 171-72, 182-83 (remarks of Attorney Avery). It is equally clear that defendants understood that each bears the burden of establishing “that his or her relationship to the premises searched was such that he or she would have a reasonable expectation of privacy there.” Id. at 142 (remarks of Attorney Avery). In this regard, each defendant has submitted a statement setting forth the specifics of his or her individual claim. To a large extent, these submissions address the extent to which each defendant claims a “corporate” standing interest in the locations at issue. However, at least one defendant filed a particularized, individual, non-corporate claim. See Supplemental Affidavit in Support of Motion to Suppress, filed January 29, 1987 (affidavit of Filiberto Ojeda Rios claiming that the Ponce de Leon location was, among other things, his “office”). Nonetheless, most address themselves solely to the collective standing argument. As directed by Rule 12(b)(3), motions to suppress evidence must be filed prior to trial. Since proof of standing is an essential element of any motion to suppress on Fourth Amendment grounds, such falls within the purview of the Rule. United States v. Gomez, 770 F.2d 251, 253 (1st Cir.1985). The defendants bear the burden of establishing Fourth Amendment standing. Rawlings v. Kentucky, 448 U.S. 98, 104, 100 S.Ct. 2556, 2561, 65 L.Ed.2d 633 (1980); Rakas v. Illinois, 439 U.S. 128, 131 n. 1, 99 S.Ct. 421, 424 n. 1, 58 L.Ed.2d 387 (1978). The Court, pursuant to Rule 12(c) set two unambiguous deadlines, and now considers the defendants’ two sets of submissions to be a complete filing of their respective standing claims. See United States v. Gomez, 770 F.2d at 253 (the defendants must bear the loss of any failure to present timely standing submissions where they have been afforded ample opportunity to prepare and present their Fourth Amendment claims). B. The Ponce de Leon “Office”, the El Centro Condominium, and Apartment 1012A The Government represents that the defendants used the Ponce de Leon location as a “safehouse.” The Government offers the following explanation of this term: [t]he groups which have historically engaged in terrorism have relied on safe-houses as bases of operation in the United States and Puerto Rico. The term “safehouse” is applied by law enforcement in terrorism investigations to apartments, offices and homes utilized by terrorists to meet, plan activities, store weapons, documents, and explosives and hide from law enforcement. Affidavit of Joseph L. Reyes, [filed in support of application for search warrant for Suite 301] p. 13, as submitted by defendants in Affidavit of Counsel in Support of Motion to Suppress Fruits of Search of Suite SOI, filed [on behalf of all defendants and on behalf of defendant Antonio Camacho Negron] December 22, 1986, exhibit 1. The defendants characterize the location in the following manner: [defendants ... adopt, for the purposes of this motion, the description of a ‘safe-house’ as an appropriate characterization of Suite 301. In other words, defendants collectively maintained and used that location as an archive or secure repository for books, records and documents relevant to the struggle for independence, and as a secure meeting place and office in which the identities, addresses and other data about militant idependentistas could be shielded from exposure to the kind of retaliation and repression which has historically been the fate of such people. Affidavit of Counsel, p. 13. Among the evidence listed as seized at the Ponce de Leon location, however, as indicated in an exhibit submitted by the defendants themselves, there is included an “explosive/incendiary device, cylindrical containing a white granular substance and wires attached,” [a bomb] “white work gloves,” “small box of wires & mise.,” “rifle case,” “wig,” “mise. F.B.I. documents,” “make-up kit,” “box with disguises,” and “box of license plates.” Affidavit of Counsel, exhibit 1. Despite the defendants’ benign characterization of the location as an “archive,” there is no doubt but that the premises truly served as a base from which the defendants conducted their alleged terrorist activities. The Government claims that the El Cen-tro condominium and Apartment 1012A were also safehouses. The defendants prefer to characterize the condominium as an organizational “office,” and Apartment 1012A as a organizational “suboffice” of the El Centro location. The defendants, however, do not offer an independent basis for their characterizations. Indeed, the defendants insist on their “right” to rely on the Government’s averments to establish their entitlement to standing, and, in fact, do rely on the Government’s characterization of these two locations as safehous-es. The Court finds that the Government’s characterizations are firmly supported by a number of evidentiary materials submitted during the course of the present suppression hearings. The Court therefore finds that the Government’s characterization of the condominium and the apartment as safehouses is indeed accurate for the Court’s present purposes. With these preliminary characterizations in place, the Court now turns to consideration of the particulars of the defendants’ standing claims, beginning with a discussion of the content of their allegations, and then proceeding to a discussion of the scope of the defendants’ assertions and the factual framework within which they are made. 1. The Defendants’ Affidavits and Memoranda Each defendant relies on the following averments made by the Government in various contexts to support his or her standing claim: 1) that he or she was a member of the militant organization known as “Los Macheteros” [“the Machete wielders”]; 2) that Los Macheteros was a highly secret, clandestine organization; 3) that each member, as a condition of membership, conducted him or herself in a manner designed to preserve anonymity and secrecy; 4) that Los Macheteros used the Ponce de Leon, El Centro, and Apartment 1012A locations to conduct secret organizational activities, and as storage facilities in which to maintain highly secret (and ultimately incriminating) records and other “materials”; and 5) that access to these locations was strictly limited. For the purposes of the present motion, the Court accepts these averments as true. It is clear, and generally conceded, that Los Macheteros was operated as a highly organized, clandestine, quasi-military outfit. It is equally clear, at this point, that each defendant, with the exception of Paul Weinberg, was a member of this organization, and that several were leading members. The defendants Jorge Farinacci Garcia and Hilton Fernandez Diamante rely on the Government’s aver-ments that they were members of the organization’s Central Committee. These defendants, and defendants Elias Castro Ramos and Juan Segarra Palmer, rely on the Government’s averments that they were members of the organization’s Directive Committee. Defendant Isaac Camacho Negron relies on the Government’s claim that he was the organization’s treasurer. Defendant Filiberto Ojeda Rios portrays himself as the ringleader of the organization, and Luis Colon Osorio relies on the assertion that, at some point, he was the organization’s bookkeeper. The Court finds, for the purposes of evaluating the defendants’ standing arguments, that these factual assertions are indeed correct. It is also clear that each defendant, as an alleged participating member of Los Ma-cheteros, attempted to keep the group’s and his or her own exploits a secret. Indeed, the Government’s averments, on which the defendants claim to rely, illustrate numerous examples of the extreme measures undertaken by certain members at various times to hide their identity, conceal their activities, and otherwise avoid detection. See Consolidated Memorandum in Support of Motion to Suppress, filed [on behalf of all defendants and on behalf of defendant Orlando Gonzales Claudio] December 22, 1986, p. 7 (“members of Los Macheteros took great care to avoid surveillance — electronic or visual”); Supplemental Memorandum of Defendant Jorge Farinacci Garcia, filed [on behalf of all defendants] December 23, 1986, p. 19 (citing Affidavit of Special Agent Jose Rodriquez, dated April 27, 1984, pp. 36-40) (“Los Macheteros trained its members to use counter surveillance techniques and to avoid detection when going and coming from ‘safehouses,’ including the alleged ‘safehouse’ belonging to Los Macheteros located at [Ponce de Leon]”); Affidavit Regarding Standing of Defendant Isaac Camacho-Negron, filed February 17, 1987, pp. 3-5 (citing examples given by the Government for the purposes of establishing standing). To the extent the defendants rely on these averments for the purposes of their standing arguments, the Court concludes that they are accurate. 2. The Defendants’ Individual Interests in the Organization’s “Safehouses” With the possible exception of Filiberto Ojeda Rios, no defendant claims a possessory or proprietary interest in any of the locations at issue, other than through his or her ties to the organization. In detailing the elaborate security measures undertaken to maintain their privacy, defendants rely on the Government’s averment that “the organization budgeted money for rental and purchase of residences and other premises to be used by the organization_” Id. p. 26 (emphasis added). See Consolidated Memorandum in Support of Motion to Suppress, filed [on behalf of all defendants and on behalf of defendant Orlando Gonzales Claudio] December 22, 1986, p. 4 (“[t]he organization is alleged to have rented or purchased the ‘safehouses’ ...”). No defendant claims that he or she used the premises at issue for personal purposes. See Affida vit in Support of Motion to Suppress Physical Evidence, filed [on behalf of all defendants and on behalf of defendant Antonio Camacho Negron] February 17, 1987, p. 4 (relying on the Government’s statements including the averment that “[s]afe-houses are used principally for the business of the organization and not for social or personal purposes ... ”). In addition, no defendant claims that he or she resided at any of these locations, or, with the exception of defendant Ojeda, that any location served as his or her personal office. Furthermore, no defendant claims that he or she used any of these safehouses on a regular basis; that (with the sole exception of defendant Ojeda) he or she possessed a key to any of these three places, or that he or she personally owned any of the materials seized at any of these locations. In the absence of allegations to the contrary, and in the face of the Government’s denial of standing, the Court concludes that the defendants (with the possible exception of defendant Ojeda) did not use these safe-houses for personal purposes, did not possess keys, did not visit them on a regular basis, and did not personally own any of the seized materials. In support of these findings, the Court also observes that no defendant claims that either the Ponce de Leon premises, the El Centro condominium, or Apartment 1012A were rented in his or her name. As indicated by documents submitted by the defendants in one of their collective memo-randa, and on which the defendants claim to rely, the Government reported that the Ponce de Leon location had been rented to an unknown female who sometimes occupied the premises on Saturday nights. No defendant has identified herself as this unknown female. Furthermore, on August 30, 1985, Government averments, on which the defendants claim to rely, establish that the El Centro Condominium was owned by an individual by the name of Emilio Trenche Calzado. No defendant has detailed his, her, or the organization's relationship to this person. And finally, all parties agree that Apartment 1012A was, at the time of its search, the residence of non-defendant Sylvia Mulling Cowert. On the basis of this information, the Court also concludes that no defendant, with the possible exception of defendant Ojeda, possessed any personal possessory or proprietary interests in any of these three locations at the time of their search other than through his or her ties to the organization. With regard to any possible interest the organization may have had in either the El Centro Condominium, Apartment 1012A, or the Ponce de Leon premises, the Court observes that the defendants do not allege, or claim reliance on any averment alleging, the existence of any personal possessory or proprietary interest in the organization itself (such as that of a shareholder, or sole proprietor). The defendants do claim to rely on the Government’s averments that some were members of the organization, and even that some were leading members of the organization. The Court finds on this basis that defendants may have had differing degrees of membership interest in the locations controlled by their organization. However, the defendants do not typically distinguish or detail their interests. Furthermore, the Court also finds that, with regard to the El Centro condominium and Apartment 1012A, most defendants were not even members of the faction that controlled these locations at the time of their search, and, in fact, the only individual who actually visited these premises on a fairly regular basis was the non-defendant Sylvia Mulling Cowert. Thus each defendant’s interest in these two locations must be qualified accordingly. C. The Adequacy of the Defendants’ Standing Claims The defendants argue that their affidavits and other submissions set out proper standing claims entitling them to seek the suppression of evidence obtained as a result of the searches at issue in this ruling. The Court finds, however, that each defendant, with the exception of Filiberto Ojeda Rios, has failed to file an adequate claim on which this Court could proceed to find that he or she possesses standing to challenge the Government’s evidence. In reaching this conclusion, the Court rejects the defendants’ characterizations of substantive Fourth Amendment law as permitting them to claim standing on the typically undetailed and unresponsive allegations they have submitted. The Court begins its analysis of the defendants’ collective and individual claims by first discussing the relevant substantive Fourth Amendment principles which are dispositive of the defendants’ collective theories. The Court analyzes at length the viability of the defendants’ corporate standing theories within this legal framework. The Court concludes that the defendants’ “corporate” theories are invalid and unavailing. The Court continues its analysis of the defendants’ standing assertions through the application of certain relevant substantive and procedural principles to each defendant’s individual submissions. Here the Court considers whether each defendant has met specific burdens imposed by 1) the Fourth Amendment, 2) the Court’s prior “Standing” order, and 3) the Rules of Criminal Procedure. The Court finds that each defendant has failed to meet these burdens, and that each defendant’s claim of standing must be denied. 1. Fourth Amendment Standing The Fourth Amendment guarantees “[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.” The Supreme Court, in approving the practice of excluding from trial evidence obtained as a result of an unlawful search or seizure, has given this guarantee significant practical effect. Simmons v. United States, 390 U.S. 377, 389, 88 S.Ct. 967, 973, 19 L.Ed.2d 1247 (1968) (citing Weeks v. United States, 232 U.S. 383, 34 S.Ct. 341, 58 L.Ed. 652 (1914); Mapp v. Ohio, 367 U.S. 643, 81 S.Ct. 1684, 6 L.Ed.2d 1081 (1961)). See United States v. Calandra, 414 U.S. 338, 347, 94 S.Ct. 613, 619, 38 L.Ed.2d 561 (1974) (the purpose of the exclusionary rule is to deter future unlawful invasions of privacy by law enforcement officials). The Court has found, however, that indiscriminate application of the exclusionary rule is not without significant societal cost. United States v. Salvucci, 448 U.S. 83, 94, 100 S.Ct. 2547, 2554, 65 L.Ed.2d 619 (1980) (quoting Alderman v. United States, 394 U.S. 165, 174-75, 89 S.Ct. 961, 967, 22 L.Ed.2d 176 (1969); Rakas v. Illinois, 439 U.S. at 137, 99 S.Ct. at 427. Accordingly, the Court has limited the range of circumstances under which defendants may invoke the rule. The Supreme Court has held that “the exclusionary rule is an attempt to effectuate the guarantees of the Fourth Amendment,” and that “it is proper to permit only defendants whose Fourth Amendment rights have been violated to benefit from the rule’s protections.” Id. at 134, 99 S.Ct. at 425. Consistent with this finding, the Court has limited the exclusionary rule’s remedial scope to cover only circumstances in which a defendant can claim that Government agents violated his or her Fourth Amendment rights. United States v. Salvucci, 448 U.S. at 86-87, 100 S.Ct. at 2550 (quoting Hatch v. Reardon, 204 U.S. 152, 160, 27 S.Ct. 188, 190, 51 L.Ed. 415 (1907)). Courts contemplating motions to exclude evidence must therefore look to the Amendment itself to determine if a particular defendant is entitled to seek the suppression of evidence through application of the rule. It has long been recognized that the Fourth Amendment “ 'protects people, not places.’ ” Smith v. Maryland, 442 U.S. 735, 739, 99 S.Ct. 2577, 2579, 61 L.Ed.2d 220 (1979) (quoting Katz v. United States, 389 U.S. 347, 353, 88 S.Ct. 507, 512, 19 L.Ed.2d 576 (1967). More specifically, the Supreme Court has held that the Fourth Amendment “protects people from unreasonable government intrusions into their ligitimate expectations of privacy.” United States v. Chadwick, 433 U.S. 1, 7, 97 S.Ct. 2476, 2481, 53 L.Ed.2d 538 (1977). Finding such expectations to be inherently personal, United States v. Watson, 423 U.S. 411, 455, 96 S.Ct. 820, 843, 46 L.Ed.2d 598 (1976) (Marshall, J. dissenting); Simmons v. United States, 390 U.S. at 389, 88 S.Ct. at 973, the Court has ruled that the legitimate privacy expectations of others may not be “vicariously” asserted. United States v. Salvucci, 448 U.S. at 86, 100 S.Ct. at 2550 (citing Alderman v. United States, 394 U.S. at 174, 89 S.Ct. at 973; Brown v. United States, 411 U.S. 223, 230, 93 S.Ct. 1565, 1569, 36 L.Ed.2d 208 (1973)). Thus, defendants wishing to invoke the force of the exclusionary rule may not do so merely on the basis that the Government conducted an illegal search or seizure. Rather, application of the rule depends, among other things, on whether the defendant has made out a proper claim that the illegal search or seizure invaded a personally held, reasonable expectation of privacy. Smith v. Maryland, 442 U.S. at 740, 99 S.Ct. at 2580. See United States v. Smith, 621 F.2d 483, 486 (2d Cir.1980), cert. denied, 449 U.S. 1086, 101 S.Ct. 875, 66 L.Ed.2d 812 (1981) (“[i]n our post-Rakas [v. Illinois ] world ... a defendant is obliged to show that he had a legitimate expectation of privacy in the area searched before he can invoke the protection of the Fourth Amendment”). The Supreme Court has developed a two-part standing test useful to determine whether a particular defendant’s personal expectations are indeed reasonable within the meaning of the Fourth Amendment. Largely adopting the approach taken by Justice Harlan in his concurring opinion in Katz v. United States, 389 U.S. 360, 88 S.Ct. at 516, the Supreme Court has found that a proper standing inquiry normally embraces two discrete questions. The first is whether the individual, by his conduct, has ‘exhibited an actual (subjective) expectation of privacy’ ... —whether ... the individual has shown that ‘he seeks to preserve [something] as private.’ ... The second question is whether the individual’s subjective expectation of privacy is ‘one that society is prepared to recognize as “reasonable” ’ ... — whether ... the individual’s expectation, viewed objectively, is ‘justifiable’ under the circumstances. Smith v. Maryland, 442 U.S. at 740, 99 S.Ct. at 2580 (citations omitted). The first prong of this test is fairly straightforward. To satisfy the subjective interest requirement, the defendant must show that he or she personally sought to preserve the particular location, and its contents, as private. See Rawlings v. Kentucky, 448 U.S. at 104, 100 S.Ct. at 2561 (defendants bear the burden of establishing the existence of a legitimate expectation of privacy); United States v. McHugh, 769 F.2d 860, 864 (1st Cir.1985) (“the burden is on the defendant to establish not only that he had a subjective expectation, but also that this expectation was objectively reasonable”). To meet this burden a defendant must demonstrate 1) that he or she possessed a significant, personal privacy interest in the location searched, and 2) that his or her privacy expectation existed contemporaneously with the search or seizure. See United States v. Manbeck, 744 F.2d 360, 374 (4th Cir.1984), cert. denied, O’Hare v. United States, 469 U.S. 1217, 105 S.Ct. 1197, 84 L.Ed.2d 342 (1985) (“[t]he privacy interest that must be established to support standing is an interest in the area searched, not an interest in the item[s] found ... [a]t most, an interest in the items found may be a factor considered when deciding whether there is a privacy interest in the area searched”); United States v. Garcia, 741 F.2d 363, 366 (11th Cir.1984) (the defendant’s privacy interest in the searched premises must be both “significant” and contemporaneous with the search); United States v. Vicknair, 610 F.2d 372, 379 (5th Cir.1980), cert. denied, 449 U.S. 823, 101 S.Ct. 83, 66 L.Ed.2d 25 (1980) (the defendant’s interest must be personal in nature rather than derivative of a collective interest). A defendant satisfies this prong of the test by alleging facts sufficient to create the impression that his or her relationship with the location was personal in nature; was more than sporadic, irregular, or inconsequential; and that the defendant maintained the location and the items within it in a private manner at the time of the search. The second prong of the Court’s standing test is more exacting, Hudson v. Palmer, 468 U.S. 517, 525 n. 7, 104 S.Ct. 3194, 3199 n. 7, 82 L.Ed.2d 393 (1984), and turns largely on close analysis of the totality of facts and circumstances surrounding each individual defendant’s particular standing claim. United States v. Salvucci, 448 U.S. at 91-93, 100 S.Ct. at 2552-53; United States v. Brown, 635 F.2d 1207, 1211 (6th Cir.1980). See Rakas v. Illinois, 439 U.S. at 152, 99 S.Ct. at 435 (Powell, J., concurring) (observing that no single facet of a defendant’s claim is properly dispositive of the Court’s inquiry); United States v. Sarda-Villa, 760 F.2d 1232, 1235 (11th Cir.1985) (observing that courts must determine objective reasonableness from a totality-of-the-circumstances perspective); United States v. Dall, 608 F.2d 910, 914 (1st Cir.1979), cert. denied, 445 U.S. 918, 100 S.Ct. 1280, 63 L.Ed.2d 603 (1980) (“the total circumstances determine whether the one challenging the search has a reasonable expectation of privacy in the locus of the search”). See also Oliver v. United States, 466 U.S. 170, 177, 104 S.Ct. 1735, 1740, 80 L.Ed.2d 214 (1984) (“[n]o single factor determines whether an individual legitimately may claim under the Fourth Amendment that a place should be free of government intrusion”). Basically, however, the cases demonstrate that, in reviewing any given claim, questions of “reasonableness” turn in large measure on the quality and object of the particular subjective expectation at issue. Courts have traditionally evaluated the quality of a given expectation by comparing it to expectations sheltered at the heart of the Fourth Amendment itself. This category of sheltered expectations necessarily has as legitimate objects a wide range of locations and items given that “houses, papers and effects” has been interpreted to include a broad range of places and possessions (even contraband). Nevertheless, courts have categorically limited legitimate privacy expectations to include only those interests of a personal dimension or quality similar in nature to expectations one would normally expect an individual to have with regard to his or her home, office, and personal belongings. Furthermore, despite its depth, the range of proper objects (categories of locations and possessions) of otherwise legitimate expectations is not all-encompassing. Courts have defined the outer reaches of the Amendment’s objective scope, concluding that some locations are incapable of sheltering reasonable privacy expectations (prison cells, abandoned locations, and public places), or are capable of harboring reasonable expectations only in some diminished capacity (automobiles, boats, and schools). Thus, as far as the exclusionary rule is concerned, the touchstones of reasonableness are 1) whether the defendant’s professed subjective expectation favorably compares to expectations courts have traditionally recognized as legitimate; and 2) whether the object of the defendant’s expectation can reasonably be said to be capable of harboring such an expectation. The practice of comparing a defendant’s claim with traditional notions of what constitutes a reasonable expectation of privacy (with its focus on normative expectations surrounding the home or an individual’s personal effects) is one long recognized by the Supreme Court. See Payton v. New York, 445 U.S. 573, 587, 100 S.Ct. 1371, 1380, 63 L.Ed.2d 639 (1980) (quoting Dorman v. United States, 435 F.2d 385, 389 (D.C.Cir.1970) (“ ‘[fjreedom from intrusion into the home or dwelling is the archetype of the privacy protection secured by the Fourth Amendment’ ”). Thus “[a] hotel room, in the eyes of the Fourth Amendment, may become a person’s ‘house,’ and so, of course, may an apartment.” Lanza v. New York, 370 U.S. 139, 143, 82 S.Ct. 1218, 1220, 8 L.Ed.2d 384 (1962) (citing Lustig v. United States, 338 U.S. 74, 69 S.Ct. 1372, 93 L.Ed. 1819 (1949); United States v. Jeffers, 342 U.S. 48, 72 S.Ct. 93, 96 L.Ed. 59 (1951); and Jones v. United States, 362 U.S. 257, 80 S.Ct. 725, 4 L.Ed.2d 697 (1960)). Thus “[a] prison ‘shares none of the attributes of privacy of a home, an automobile, an office, or a hotel room.’ ” Hudson v. Palmer, 468 U.S. at 527, 104 S.Ct. at 3200 (quoting Lanza v. New York, 370 U.S. at 143-44, 82 S.Ct. at 1220-21). This comparative approach permeates Fourth Amendment standing analysis. See Rakas v. Illinois, 439 U.S. at 153-54, 99 S.Ct. at 435-36 (Powell, J., concurring) (quoting United States v. Martinez-Fuerte, 428 U.S. 543, 561, 96 S.Ct. 3074, 3084, 49 L.Ed.2d 1116 (1976) (“[n]oth-ing is better established in Fourth Amendment jurisprudence than the distinction between one’s expectation of privacy in an automobile and one’s expectation when in other locations. We have repeatedly recognized that this expectation ... ‘[is] significantly different from the traditional expectation of privacy and freedom in one’s residence’ ”). See also United States v. Holland, 755 F.2d 253, 255 (2d Cir.1985), cert. denied, 471 U.S. 1125, 105 S.Ct. 2657, 86 L.Ed.2d 274 (1985) (some locations are not properly within a defendant’s zone of privacy “even though they are guarded by locked doors”); United States v. Mankani, 738 F.2d 538, 544 (2d Cir.1984) (comparing hotel rooms with residences, observing that “it is the transitory nature of such places [hotels] ... that diminishes a person’s justifiable expectation of privacy in them”). One explanation for this standard’s comparative focus on normative expectations centered on the home and on an individual’s personal effects (other than the obvious explanation that the express language and intent of the Amendment focus inquiry in this direction) is aptly suggested by Judge Sneed, dissenting in United States v. Quinn, 751 F.2d 980, 981 (9th Cir.1984), cert. dismissed as improvidently granted, — U.S. -, 106 S.Ct. 1623, 89 L.Ed.2d 803 (1986), where he states: [t]he Fourth Amendment protects the guilty because only by doing so can the innocent be protected. The innocent are not mere incidental beneficiaries of an amendment designed to protect the guilty. The innocent are its prime beneficiaries; the reasonableness of any expectation of privacy should be ascertained from their standpoint. See Hudson v. Palmer, 468 U.S. at 525 n. 7, 104 S.Ct. at 3199 n. 7 (society’s viewpoint must be considered in the resolution of standing issues); Oliver v. United States, 466 U.S. at 182 n. 13, 104 S.Ct. at 1743 n. 13 (“[c]ertainly the Framers did not intend that the Fourth Amendment should shelter criminal activity wherever persons with criminal intent choose to erect barriers and post ‘No Trespassing’ signs”); United States v. Oliver, 686 F.2d 356, 372 (6th Cir.1982) (en banc), aff'd., 466 U.S. 170, 104 S.Ct. 1735, 80 L.Ed.2d 214 (1984) (quoting United States v. Oliver, 657 F.2d 85, 87 (6th Cir.1981) (“society will accept expectations which: 1) are ‘normally shared by people in that setting’; and 2) ‘fall within the limits of what society can accept given its interest in law enforcement’ ”). Ke-gardless of the reasoning, however, it is clear that the proper analysis to undertake is to conduct a close, comparative review of any given claim with an eye to determining whether the professed interest comports with well-recognized notions of Fourth Amendment legitimacy. Based on the foregoing, the Court concludes that, in order to be truly reasonable within the meaning of the Fourth Amendment, a defendant must demonstrate that his or her professed subjective expectation of privacy in a particular location, viewed from the totality of the circumstances, is at least of a quality similar, in significant respects, to the privacy expectation one would ordinarily expect an individual to have with regard to his or her home or office, provided the individual undertook at least minimal efforts to maintain the privacy of the location and its contents. As undetailed as this comparative standard may be, the Court is persuaded that it is a true reflection of the central element of Fourth Amendment reasonableness (the other element being whether the location was capable of sheltering the professed expectation). Hudson v. Palmer, 468 U.S. at 525 n. 7, 104 S.Ct. at 3199 n. 7. See Rakas v. Illinois, 439 U.S. at 143 n. 12, 99 S.Ct. at 430 n. 12 (“legitimation of expectations of privacy by law must have a source outside of the Fourth Amendment,” including “reference to ... understandings that are recognized and permitted by society”); id. at 152-53, 99 S.Ct. at 435 (Powell, J., concurring) (“[t]hus, the Court has examined whether a person invoking the protection of the Fourth Amendment took normal precautions to maintain his privacy — that is, precautions customarily taken by those seeking privacy”). See also O’Connor v. Ortega, — U.S. -, 107 S.Ct. 1492, 1498, 94 L.Ed.2d 714 (1987) (opinion of O’Connor, J.) (quoting Oliver v. United States, 466 U.S. at 178 n. 8, 104 S.Ct. at 1741 n. 8) (“[a]s with the expectation of privacy in one’s home, such an expectation in one’s place of work is ‘based upon societal expectations that have deep roots in the history of the Amendment’ ”). If analysis of the totality of the circumstances reveals a substantial similarity in quality between a given subjective expectation and those traditionally recognized as legitimate, then, in the absence of mitigating circumstances (such as in situations involving incarceration, or where the location searched was abandoned or generally subject to the public view, or where the item seized was placed in a public area), a court may properly conclude that the individual possesses standing with regard to the location and its contents. See Hudson v. Palmer, 468 U.S. at 525-26, 104 S.Ct. at 3199-3200 (a prison cell is not capable of sheltering expectations of privacy); United States v. Holland, 755 F.2d at 255-56 (citing Rakas v. Illinois, 439 U.S. at 149, 99 S.Ct. at 433) (holding that the en-traneeway to a common hallway is not capable of harboring a reasonable expectation of privacy due to its inherently public nature, and observing that an expectation of privacy “will be violated only if the place is one that the defendant has the right to keep private and subject to his exclusive control”); United States v. Briones-Garza, 680 F.2d 417, 421 (5th Cir.1982), cert. denied, 459 U.S. 916, 103 S.Ct. 229, 74 L.Ed.2d 181 (1982) (a “drop-house” harboring a constant stream of illegal aliens lacks “normal expectations of privacy” even though the defendant claimed it was his residence); United States v. Arboleda, 633 F.2d 985, 991 (2d Cir.1980), cert. denied, 450 U.S. 917, 101 S.Ct. 1362, 67 L.Ed.2d 343 (1981) (defendant who tossed the contraband out the window and into the public domain found to have lost his expectation of privacy thereby; “[i]t is difficult to imagine a legitimate expectation of privacy in an open area running along the front of the second floor of a building over a street”). A defendant establishes a color-able standing claim by alleging sufficient facts to create a reasonable impression with the Court of the objective rationality (under the above standard) of his or her professed subjective privacy allegations. If the Government reasonably contests such a claim, the defendant is entitled to a hearing where he or she is required to prove facts necessary to support his or her professed subjective expectations and the overall reasonableness of his or her position. See Jones v. United States, 362 U.S. 257, 261, 80 S.Ct. 725, 731, 4 L.Ed.2d 697 (1960) (“[i]t is entirely proper to require of one who seeks to challenge the legality of a search as the basis for suppressing relevant evidence that he allege, and if the allegation be disputed that he establish, that he himself was the victim of an invasion of privacy”). See also Rawlings v. Kentucky, 448 U.S. at 104, 100 S.Ct. at 2561 (“[the defendant], of course, bears the burden of proving not only that the search ... was illegal, but also that he had a legitimate expectation of privacy in the [place searched]”); Rakas v. Illinois, 439 U.S. at 131 n. 1, 99 S.Ct. at 424 n. 1 (“[t]he proponent of a motion to suppress has the burden of establishing that his own Fourth Amendment rights were violated by the challenged search or seizure”); Simmons v. United States, 390 U.S. at 389, 88 S.Ct. at 973 (“defendants [have] the right, upon motion and proof, to have excluded from trial evidence which has been secured by means of an unlawful search and seizure”); United States v. McHugh, 769 F.2d at 864 (defendants bear the burden of establishing both the existence and the objective reasonableness of their expectations); United States v. Ramapuram, 632 F.2d 1149, 1154 (4th Cir.1980), cert. denied, 450 U.S. 1030, 101 S.Ct. 1739, 68 L.Ed.2d 225 (1981) (“it devolves upon one seeking suppression of incriminating evidence to establish as a threshhold matter the existence of a reasonable expectation of privacy in the area searched”). The defendants predictably argue that their professed collective expectations with regard to the Ponce de Leon, El Centro, and Apartment 1012A locations are manifestly “reasonable.” For numerous reasons, the defendants’ collective allegations, however, do not easily fit within the general range of permissible standing claims encompassed within the parameters set forth in the various decisions cited above. The Court is persuaded that to accept the defendants’ collective arguments would be to create a new category of Fourth Amendment deprivation victims outside the boundaries established by prior Supreme Court precedent. The Court is not persuaded that it is free to so enlarge the scope of the exclusionary rule. Before turning to the specifics of the defendants’ collective standing arguments, the Court prefaces its discussion with general consideration of the difficulties involved in entertaining an expansion of Fourth Amendment protections. The Court then turns to the particulars of the defendants’ collective claims and the specific difficulties they present. The Supreme Court has expressly rejected or overruled a variety of expansive standing theories, and, in so doing, has reaffirmed its adherence to the particular, narrow privacy interest analysis outlined above to define who is a proper Fourth Amendment deprivation victim entitled to standing. See United States v. Allison, 619 F.2d 1254, 1258 (8th Cir.1980) (the Court has adopted an analytical posture that avoids lending “credence to theories of standing which [are] inconsistent with the Court’s view of the nature of fourth amendment rights”). For example, in United States v. Salvucci, 448 U.S. at 95, 100 S.Ct. at 2554, the Court expressly overruled the automatic standing rule adopted in Jones v. United States, 362 U.S. at 264-65, 80 S.Ct. at 732-33, which allowed defendants, in cases where possession of the seized item was an essential element of the offense charged, to have automatic standing to challenge the search and seizure of the item. Addressing the argument that retention of the Jones rule would “maximize the deterrence of illegal police conduct by permitting an expanded class of potential challengers,” United States v. Salvucci, 448 U.S. at 94, 100 S.Ct. at 2554, the Court nevertheless rejected the rule’s “underlying assumption ... that possession of the seized good is an acceptable measure of Fourth Amendment interests,” id. at 92, 100 S.Ct. at 2553, concluding that the rule served “only to afford a windfall to defendants whose Fourth Amendment rights have not been violated.” Id. at 95, 100 S.Ct. at 2554 (emphasis in original). Similarly, in Rakas v. Illinois, supra, the Court rejected the defendants’ “target theory” of standing which would have permitted a defendant to challenge admission of evidence obtained as a result of an unlawful search or seizure merely because that defendant had been a target of the search or seizure. Id. at 132-33, 99 S.Ct. at 424. Once again, the Court observed that “[c]on-ferring standing to raise vicarious Fourth Amendment claims would necessarily mean a more widespread invocation of the exclusionary rule during criminal trials” with its attendant deterrent effect. Id. at 137, 99 S.Ct. at 427. The Court declined to permit such an expansion, stating: [e]ach time the exclusionary rule is applied it exacts a substantial cost for the vindication of Fourth Amendment rights. Relevant and reliable evidence is kept from the trier of fact and the search for truth is deflected. Id. at 137-38, 99 S.Ct. at 427 (citations omitted). The Court added that “[a] person who is aggrieved by an illegal search and seizure only through the introduction of damaging evidence secured by a search of a third person’s premises or property has not had any of his Fourth Amendment rights infringed.” Id. at 134, 99 S.Ct. at 425. As one explanation for continued adherence to its reasonable privacy interest approach, the Court has repeatedly asserted that application of the privacy interest standard serves the dual purpose of protecting important Fourth Amendment rights, while at the same time permitting as little intrusion as possible into the truth finding function of the trial process. In the Court’s words: The deterrent values of preventing the incrimination of those whose rights the police have violated have been considered sufficient to justify the suppression of probative evidence even though the case against the defendant is weakened or destroyed. We adhere to that judgment. But we are not convinced that the additional benefits of extending the exclusionary rule to other defendants would justify further encroachment upon the public interest in prosecuting those accused of crime and having them acquitted or convicted on the basis of all the evidence which exposes the truth. Alderman v. United States, 394 U.S. at 174-75, 89 S.Ct. at 967. A further explanation for adherence to the privacy interest analysis can be found in the very nature of the exclusionary rule itself. The Court has held that the rule is a judicially created remedy of limited applicability. United States v. Leon, 468 U.S. 897, 906, 104 S.Ct. 3405, 3411, 82 L.Ed.2d 677 (1984) (quoting United States v. Calandra, 414 U.S. at 348, 94 S.Ct. at 620); Stone v. Powell, 428 U.S. 465, 494 n. 37, 96 S.Ct. 3037, 3052 n. 37, 49 L.Ed.2d 1067 (1976). And while the rule is designed to effectuate important Fourth Amendment rights, Rakas v. Illinois, 439 U.S. at 134, 99 S.Ct. at 425, “the application of the rule has been restricted to those areas where its remedial objectives are thought most efficaciously served.” United States v. Calandra, 414 U.S. at 348, 94 S.Ct. at 620. The Supreme Court has made the determination that to expand applicability of the exclusionary rule beyond the scope of the Amendment would be to fashion an overbroad remedy that would unnecessarily trample other important societal interests. United States v. Salvucci, 448 U.S. at 94, 100 S.Ct. at 2554. Thus this Court must seriously consider whether the defendants’ claims can logically fit within the remedial scope of the rule as it presently exists. If the defendants claims do not fit within the rule’s present parameters, the Court must give serious consideration to the desirability of expanding the rule’s coverage to accomodate their interests. However, as the Supreme Court has warned, “misgivings as to the benefit of enlarging the class of persons who may invoke [the exclusionary] rule are properly considered when deciding whether to expand standing to assert Fourth Amendment violations.” Rakas v. Illinois, 439 U.S. at 138, 99 S.Ct. at 427. 2. The Defendants’ Legal Arguments The defendants, with the exception of Paul Weinberg (who does not claim standing with regard to any of the locations at issue), offer a general “collective” (or “corporate”) standing theory in support of their Fourth Amendment claims. This theory is based on the alleged factual premise 1) that each defendant was a member of the organization known as Los Ma-cheteros, and that the organization controlled each of the premises at issue; 2) that each member undertook elaborate security precautions designed to preserve his or her own privacy and anonymity as well as the privacy of the organization and its membership; and 3) that each defendant allegedly participated in various collective activities in a joint venture capacity, utilizing the locations at issue in furtherance of the crimes for which they have been indicted. The defendants’ predictably support their collective theory with three related arguments. The first argument, which the Court entitles the “organizational” argument, proposes that each defendant has standing to challenge the legality of the searches and seizures conducted at the El Centro, Ponce de Leon, and Apartment 1012A locations by virtue of the fact that an organization known as “Los Machete-ros” controlled these locations and that each defendant was a member of this organization. As one defendant asserts, “all defendants have standing to challenge the searches of [these three locations] by virtue of their alleged active involvement in an organization which allegedly maintained and used the premises secretively for purposes of the organization.” Consolidated Memorandum in Support of Motion to Suppress, filed Dec. 22, 1986, p. 1. The defendants’ second argument, which the Court labels the “membership-security” argument, is subtly different. Perhaps recognizing that mere membership, without more, is insufficient to confer standing, the defendants claim that, as members of a highly clandestine organization, they took elaborate steps to ensure the secrecy and privacy of these locations and the contents therein; concluding that such actions as they took to maintain the security of their organization establish a legitimate expectation of privacy in premises controlled by the organization. As one defendant explains, “[t]he defendants in the present case rely, to demonstrate their expectation of privacy in [these locations] not upon their mere status as members of an organization but, rather, upon the nature of the organization and the elaborate security measures taken by members to preserve privacy.” Consolidated Memorandum, at 6-7. As further explained by another defendant, [m]oreover, the government’s sworn statements aver that defendants were members of a tightly-knit, disciplined and cohesive organization which maintained the premises as so-called ‘safehouses,’ used them for organizational purposes, limited access only to trusted members of the organization, trained and required members to take extreme precautions to preserve the safety and secrecy of the locations, and kept possessions and documents belonging to all the members collectively and/or to some members individually in these locations, demonstrates that the defendants had personal Fourth Amendment interests and expectations of privacy in the locations searched. Supplemental Memorandum of Defendant Jorge Farinaeci Garcia, [filed on behalf of all defendants] filed December 23, 1986, pp. 5-6. The defendants’ third argument, • which the Court entitles the “joint venture/co-conspirator” argument, focuses on the defendants’ characterization of their activities as a “joint venture” and their status, to the extent the defendants are collectively involved in the alleged crimes, as “co-conspirators.” As fully explained by one defendant, “the government’s sworn assertions that defendants are all members and participants in a single conspiracy give them the right to assert privacy interests in locations used for the ‘joint venture’ [namely the West Hartford robbery] for which they are being tried.” Defendants’ Memorandum of Law in Support of Motion to Suppress, dated December 22, 1986, p. 20. The Court finds that each individual argument, or “sub-theory,” viewed separately, is inadequate by itself to confer standing. Both the “organizational” and “joint venture/co-conspirator” arguments are, by themselves, invalid vicarious standing theories. The defendants’ “membership-security” argument, while perhaps a relevant component of a legitimate standing argument, is as well, by itself, insufficient as a matter of law to confer standing. The Court also finds that the defendants’ general collective theory, comprised as it is of these arguments, is an unacceptable and incomplete standard against which to measure the viability of the defendants’ claims. The Court discusses the defendants’ three broad standing arguments individually, and then proceeds to discuss the defendants’ overall collective standing theory as a single unit. After rejecting the defendants’ collective theories, the Court examines the specifics of each individual defendant's personal relationship to the locations at issue, concluding that only Filiberto Oje-da Rios has made out a colorable standing claim, and that he has done so only with regard to the Ponce de Leon location, a. The Defendants’ Organizational Argument In support of their organizational argument the defendants rely, in part, on cases which have recognized a corporation’s right to claim Fourth Amendment standing on its own behalf. See Blackie’s House of Beef, Inc. v. Castillo, 659 F.2d 1211, 1216 n. 5 (D.C.Cir.1981), cert. denied, 455 U.S. 940, 102 S.Ct. 1432, 71 L.Ed.2d 651 (1982) (commercial restaurant found to have standing to challenge a warrantless search of its premises). See generally Mancusi v. DeForte, 392 U.S. 364, 367, 88 S.Ct. 2120, 2123, 20 L.Ed.2d 1154 (1968) (“[t]his Court has held that the word ‘houses,’ as it appears in the Amendment, is not to be taken literally, and that the protection of the Amendment may extend to commercial premises”). It is certainly true that collective enterprises (at least de jure legal organizations such as unions or corporations) are entitled to claim a form of “corporate” standing. Nevertheless, unlike the situation in the Castillo case just cited, the organization known as “Los Macheteros” is not a defendant in this case. See United States v. Calandra, 414 U.S. at 348, 94 S.Ct. at 620 (“standing to invoke the exclusionary rule has been confined to situations where the Government seeks to use such evidence to incriminate the victim of the unlawful search”). And whereas “Los Macheteros” as an organization, if it were a defendant, might arguably have standing to contest the legality of a search or seizure of its “corporate” property, the Supreme Court has repeatedly held time and time again that other defendants may not under any circumstances vicariously assert the Fourth Amendment rights of one whose rights have been violated. United States v. Salvucci, 448 U.S. at 86, 100 S.Ct. at 2550; Brown v. United States, 411 U.S. at 230, 93 S.Ct. at 1569 (quoting Alderman v. United States, 394 U.S. at 174, 89 S.Ct. at 966). See United States v. Alonso, 790 F.2d 1489, 1495 (10th Cir.1986) (“[sjtanding may not be conferred by the Government’s activity, no matter how war-rantless or illegal it might be, where no constitutionally protected right is violated”). The Second Circuit has long ago rejected the type of claim embodied in the defendants’ organizational standing argument. In Lagow v. United States, 159 F.2d 245, 246 (2d Cir.1946), cert. denied, 331 U.S. 858, 67 S.Ct. 1750, 91 L.Ed. 1865 (1947), the court stated: When a man chooses to avail himself of the privilege of doing business as a corporation, even though he is its sole shareholder, he may not vicariously take on the privilege of the corporation under the Fourth Amendment; documents which he could have protected from seizure, if they had been his own, may be used against him, no matter how they were obtained from the corporation. Its wrongs are not his wrongs; its immunity in not his immunity. This we have four times decided. Similarly, mere membership in an organization, without more, is far insufficient to confer standing. United States v. Allison, 619 F.2d at 1260. See Babula v. Immigration & Naturalization Service, 665 F.2d 293, 297 (3rd Cir.1981) (factory employees “do not have standing to assert the fourth amendment rights of the factory owner”). Nor is partnership, by itself, an adequate basis for standing. United States v. Hodges, 606 F.2d 520, 523 (5th Cir.1979), cert. denied, 444 U.S. 1035, 100 S.Ct. 708, 62 L.Ed.2d 671 (1980). In the Court’s view, the defendants may not look to the organization’s interests in the locations to substantiate their individual claims. The defendants instead must draw from their own individual ties to each location to demonstrate the existence of reasonable expectations of privacy. United States v. Hartley, 486 F.Supp. 1348, 1353-54 (M.D.Fla.1980). Membership in the organization thus serves as merely one relevant factor to consider in judging the overall validity of a given claim, and then only in so far as it is indicative of each defendant’s personal relationship with each location. Membership is thus not dispositive of standing one way or the other, nor is it even necessarily of any great significance. b. The Defendants’ Membership-Security Argument Turning now to the defendants’ “membership-security” argument, the Court recognizes that some courts have considered the elaborate security measures taken by defendants as indicative of an expectation of privacy in a location or item the privacy of which the security measures were designed to secure. In United States v. Brien, 617 F.2d 299, 306 (1st Cir.1980), cert. denied, 446 U.S. 919, 100 S.Ct. 1854, 64 L.Ed.2d 273 (1980), the Court of Appeals observed that the District Court, in conducting its standing deliberations, properly considered evidence that the particular defendants, both corporate officers, had taken elaborate security precautions designed to limit access to certain areas of their business. The Brien court noted that this evidence “established that [the defendants] went to great lengths to keep [their] methods of operation secret,” and that their office was a “citadel o