The following excerpt is from U.S. v. Thomas, 893 F.2d 482 (2nd Cir. 1990):
In contrast, we have not upheld warrantless entries where the agents lacked any objective basis--other than their own actions unnecessarily alerting the defendants to their presence--to believe there was an urgent need to enter the premises without waiting to obtain a warrant. Thus, in United States v. Reed, we ruled that there were no exigent circumstances where the officers had made purchases from the targeted defendants some 2 1/2 months earlier and had had no contact with them since:
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