How have courts interpreted the words "may include but not limited to," and "other items" in a search warrant?

arguments when context limited the scope of the search. (Doc. No. 40 at 9.) For example, in United States v. Reeves, 210 F.3d 1041 (9th Cir. 2000), the words "may include, but is not limited to," and "other items" did not make a warrant impermissibly overbroad because context made clear that the search was for "evidence of the possession, manufacture, and delivery of the controlled substance methamphetamine." Id. at 1046. And in United States v. Shi, 525 F.3d 709 (9th Cir. 2008), the words "including, but not limited to" did not make a warrant insufficiently particular because it authorized a search of only the limited area the defendant inhabited. See id. at 731.