California, United States of America
The following excerpt is from People v. El Badry, C090714 (Cal. App. 2020):
and deferential. Depending on the nature of the crimes and the specific facts of the case, evidence set forth in the affidavit may be sufficiently fresh to provide probable cause even though the information is much older than the two years at issue in this case. (See, inter alia, People v. Lazarus (2015) 238 Cal.App.4th 734, 764-765 [in a 20-year-old murder investigation where the motive was "romantic obsession," it was probable that defendant would have "continued to retain items evidencing her relationship" with the victim and her husband].)
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