The following excerpt is from People v. Williams, 114 N.Y.S.3d 815 (Table), 63 Misc.3d 1223 (A) (N.Y. Cty. Ct. 2019):
As to the second requirement, the search occurred several minutes after the defendant's arrest and therefore did not occur "contemporaneously" with the arrest (see People v. Gokey, 60 NY2d at 312 ).
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