The following excerpt is from U.S. v. McGrew, 122 F.3d 847 (9th Cir. 1997):
2 This court has "criticized repeatedly the failure to describe in a warrant the specific criminal activity suspected," United States v. Kow, 58 F.3d 423, 427 (9th Cir.1995) (collecting cases); we do so again here.
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