What is the case law on the "fellow officer rule" and is Officer Tosi's information not sufficient to support a finding of probable cause to arrest?

The Defendant argues that, pursuant to the "fellow officer rule," the information obtain by Officer Aigotti can only support a finding of probable cause to arrest where there is evidence that the arresting officer acted upon the direction of an officer with knowledge sufficient to establish probable cause, or the arresting officer acted as a result of communication with a fellow officer who had knowledge sufficient to establish probable cause. The Defendant argues that Officer Tosi does not fit into either one of those categories. In support of this position the Defendant points to People v. Powell, 101 AD3d 756, 758, 955 N.Y.S.2d 608, 610 (2nd Dept.2012), wherein the court made the following observations: