your home law enforcement must have probable cause that is approved by a judge will magistrate judge and that is the issue here is what is lacking in the search warrant in this case there are a few established principles yes judges a that drug dealers keep evidence they are regularly activities in their homes most often in a search warrant that is information given to the charge by the offie on it which there is i am an expert about all these investigation here the reasons why i believe that there will be drugs found in this home none of that is present in this case and what we have here and the other way that the government argues that is that basically there is no nexus requirement for there doesn't need to be direct park at home but they never saw him get drugs from a place and drive to a deal and deliberate spark your statements you're alluding to something that i have a little bit of a concern with you're ok and that is that apartment or more land at boulevard right ok but we also know there's not much in the record on this but there was a search warrant that was executed on the park at the perkins road address and rihanna what simultaneously the other cases that were referenced by the government is usually bustling with one house right this two houses so you have him staying with a girlfriend at twenty thirty percocet which is in fact what he was doing and distributing drugs potentially from that location because as they were also say that drug dealers often have stash houses with extra girlfriends where they stop there so here's why i raise this ok i totally understand why the government is reliant upon our case law that says we can infer that people keep drugs in the place where they live the the predicate of that though needs to be within the four corners of the warrant application in other words to get the benefit of that case law don't you need to put in front of the the magistrate judge where does the individual the chargeable on to this woman who had a relationship which is also a relationship with the woman at twenty thirty perkins road there's no real indication of where the drugs are stored or located except for the fact that nobody ever saw him leave per liter moreland boulevard address so if you're if you're being commonsense about this if you call somebody and say i'd like to make a drug deal with you and you're following him and he appears at the gas station does the drug deal having come from twenty thirty  inference is that's where the drugs are because he left with the drugs to go make the deal ok but you've got you've got to address the flip side of it though too and that is that at least on two occasions he drove to moreland right after the deals were made which meant their  guess what else they saw him cooking crack in that house so there's always some some nexus some ability for them to say yeah there's a connection between the drug activity and this residence either they saw the drugs in the house but that the car was where the drug deal took place and a drug deal took place in the car in the driveway of his now in that case the fact that it happened in the car is pretty close i mean it's adjacent to the house they can see he's bringing the drugs from the house into the car do the deal the driveway go right back in the house noted earlier your honor it is not it is certainly possible here that mr garber resided at both residences it is not uncommon for a drug dealer to potentially live at and use more than one residence in connection with his drug dealing i did the trial in this case i have no recollection of anybody saying the currency was murder recovered from that residence so as far as we can assume for the purposes of argument today it was not martin would have been untraceable once they got into that residence to follow up on another question that was asked in terms of which which now if the government is there watching has to be continued and any where his car is located or anybody who knows who lives there is a place where they can search so if you visit his mother three times a week and had driven there after a drug deal to get to that they get searched mom's house that he needed more so link this defendant to that residence before getting the search warrant and the fact that a judge signed off on it doesn't fix the error yes he might have gone to get but everybody who looks at them should know that there is not enough to get into that house and because of that i mean if we keep writing off police officers decisions about good faith good faith good faith good faith in the fourth amendment that it's not even there so at what point does it become obvious enough that