The following excerpt is from U.S. v. Wanless, 882 F.2d 1459 (9th Cir. 1989):
12 We review this question de novo United States v. Merriweather, 777 F.2d 503, 505 (9th Cir.1985), cert. denied, 475 U.S. 1098, 106 S.Ct. 1497, 89 L.Ed.2d 898 (1986). We note, however, that the district court never decided whether items 1 through 8 alone established probable cause for the investigative searches, since it based its decision on items 1 through 12 collectively.
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