The following excerpt is from United States ex rel. Gary v. Follette, 418 F.2d 609 (2nd Cir. 1969):
In determining whether there were sufficient "underlying circumstances" to support the informer's report, we are guided by what the court said in United States ex rel. Schnitzler v. Follette, 379 F.2d 846, 848 (2d Cir. 1967) about probable cause to issue a search warrant:
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