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(S.D.N.Y. 2013) (quoting United States v. Vilar, No. 05 Cr. 621 (KMK), 2007 WL 1075041, at *27 (S.D.N.Y. Apr. 4, 2007)); see also United States v. DeFilippo, No. 17 Cr. 585 (WHP), 2018 WL 740727, at *2 (S.D.N.Y. Jan. 31, 2018) ("As courts in this Circuit have recognized, it is not shocking that every af
is case are far removed from the "narrow" circumstances in which the Supreme Court has found an exception to the third party doctrine. For example, the Carpenter Court, while stressing that its holding was a "narrow one," 138 S. Ct. at 2220, held that "[g]iven the unique nature ofcell phone location records," which
(S.D.N.Y. 2013) (quoting United States v. Vilar, No. 05 Cr. 621 (KMK), 2007 WL 1075041, at *27 (S.D.N.Y. Apr. 4, 2007)); see also United States v. DeFilippo, No. 17 Cr. 585 (WHP), 2018 WL 740727, at *2 (S.D.N.Y. Jan. 31, 2018) ("As courts in this Circuit have recognized, it is not shocking that every af
is case are far removed from the "narrow" circumstances in which the Supreme Court has found an exception to the third party doctrine. For example, the Carpenter Court, while stressing that its holding was a "narrow one," 138 S. Ct. at 2220, held that "[g]iven the unique nature of cell phone location records," whic
(S.D.N.Y. 2013) (quoting United States v. Vilar, No. 05 Cr. 621 (KMK), 2007 WL 1075041, at *27 (S.D.N.Y. Apr. 4, 2007)); see also United States v. DeFilippo, No. 17 Cr. 585 (WHP), 2018 WL 740727, at *2 (S.D.N.Y. Jan. 31, 2018) ("As courts in this Circuit have recognized, it is not shocking that every af
is case are far removed from the "narrow" circumstances in which the Supreme Court has found an exception to the third party doctrine. For example, the Carpenter Court, while stressing that its holding was a "narrow one," 138 S. Ct. at 2220, held that "[g]iven the unique nature of cell phone location records," whic
(S.D.N.Y. 2013) (quoting United States v. Vilar, No. 05 Cr. 621 (KMK), 2007 WL 1075041, at *27 (S.D.N.Y. Apr. 4, 2007)); see also United States v. DeFilippo, No. 17 Cr. 585 (WHP), 2018 WL 740727, at *2 (S.D.N.Y. Jan. 31, 2018) ("As courts in this Circuit have recognized, it is not shocking that every af
is case are far removed from the "narrow" circumstances in which the Supreme Court has found an exception to the third party doctrine. For example, the Carpenter Court, while stressing that its holding was a "narrow one," 138 S. Ct. at 2220, held that "[g]iven the unique nature of cell phone location records," whic
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