The following excerpt is from United States v. Hayat, 710 F.3d 875 (9th Cir. 2013):
criminal behavior. United States v. ValenciaAmezcua, 278 F.3d 901, 90809 (9th Cir.2002) (quoting United States v. Johnson, 735 F.2d 1200, 1202 (9th Cir.1984)). We have allowed modus operandi testimony that drug traffickers often employ counter-surveillance driving techniques, register cars in others' names, make narcotics and cash deliveries in public parking lots, and frequently use pagers and public telephones. Id. at 909 n. 4.
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