govinfo:USCOURTS-kywd-3_24-cr-00067-1

- 1 - 
 
UNITED STATES DISTRICT COURT 
WESTERN DISTRICT OF KENTUCKY 
LOUISVILLE DIVISION 
 
UNITED STATES OF AMERICA, 
 
 Plaintiff, 
 
v. 
 
JOSEPH LANHAM (01), 
LAURA LANHAM (03), 
 
Defendants. 
)
)
)
)
)
)
)
)
 
) 
) 
 
 
 
Criminal Action No. 3:24-cr-00067-CHB-
01, 03 
 
MEMORANDUM OPINION AND 
ORDER 
 
*** *** *** *** 
 This matter is before the Court on Defendant Joseph Lanham’s1 Motion to Suppress 
Evidence and Request for a Franks Hearing (“Motion”). [R. 62]. The United States filed a response 
opposing the Motion. [R. 75]. Joseph then filed a reply.2 [R. 88]. Defendant Joseph then filed a 
Renewed Motion for Hearing to Present Witnesses (“Renewed Motion”), [R. 89], and the United 
States filed a r enewed response in opposition, [R. 90]. As such, the matter is ripe and ready for 
review. For the following reasons, the Court will deny the Motion and the Renewed Motion. 
Defendant Laura Lanham also filed a Motion to Adopt and Join In Co-Defendant Joseph’s 
Motion to Suppress Evidence and Request for a Franks Hearing (“Motion to Join”). [R. 67]. No 
response was filed to this Motion to Join, and the Court therefore understands that the United States 
has no objection to Laura’s request. The Court will grant Laura’s Motion to Join.3 
 
1 For clarity, the Court will refer to Joseph and Laura Lanham by their first names. 
 
2 The reply covered both the United States’ response for this motion as well as the other pending motion to suppress 
relating to the search and seizure of cellphones and data. See [R. 88]; [R. 46]. 
 
3 Although the United States does not raise this issue, Laura does not have standing to challenge any of the warrants 
outside of the Johnsontown Way Warrant, which is the only warrant that involved her residence. See infra pp. 8–9. In 
any event, as detailed below, the Motion for a Franks hearing fails on the merits as to each property. PageID #:
<pageID>
- 2 - 
 
I. BACKGROUND 
On June 4, 2024, Defendants Joseph, Laura, and Richard Elble II were indicted by a Grand 
Jury for Money Laundering Conspiracy (Count 1), Monetary Transactions in Proceeds of Specified 
Unlawful Activity (Counts 2–5), Obstruction of Proceedings Before Departments and Agencies 
(Count 6), and Falsification of Records in a Federal Investigation (Count 7). [R. 1]. Joseph was 
indicted on all counts, while Laura was indicted on Counts 1 and 3. Id. The other co-defendant, 
Elble, was indicted on Count 1. Id. All of the defendants have pled not guilty to the charges in the 
Indictment. See [R. 11]; [R. 23]; [R. 24]. 
According to the facts alleged in the Indictment, Joseph “engaged in narcotics trafficking 
activities for which he received cash proceeds” and “use[d] various methods to conceal his actual 
ownership and control over his real and personal property, as well as their source,” including 
having Laura, his mother, and Elble, a relative by marriage, act “as nominee purchasers and owners 
in his transactions and [carry] out other transactions on his behalf.” See [R. 1, ¶¶ 2–4]. 
On August 10 and 11, 2022, search warrants were executed at five different properties 
owned by or otherwise connected to Joseph or his drug trafficking activities. [R. 75-1, p. 14]; 
[R. 75-2, p. 25]; [R. 75-3, p. 24]; [R. 75-4, pp. 24–26]; [R. 75-5, p. 25]. These five properties were 
located at (1) Sea Wave Ct., (2) Johnsontown Way, (3) Nanisinh Way, (4) Pine Lake Dr., and (5) 
Blankenbaker Access Dr. Id. Various drugs, cash, firearms, firearm accessories, and other related 
items were seized pursuant to these searches. See id. The affidavits, including appendices, 
supporting each of the five warrants spanned numerous pages with evidence gathered from 
multiple investigations. [R. 75-1, pp. 1–11 (eleven pages)]; [R. 75- 2, pp. 1–5, 9–24 (twenty- one 
pages)]; [R. 75-3, pp. 1–4, 8–23 (twenty pages)]; [R. 75-4, pp. 1–4, 8–23 (twenty pages)]; [R. 75-
5, pp. 1–4, 8–23 (twenty pages)]. The warrants each permitted the seizure of any d rugs, drug PageID #:
<pageID>
- 3 - 
 
paraphernalia, evidence of money laundering, records of drug activity or sale, cellular phones or 
records identifying drug buyers or sellers, firearms, currency attributed to the sale of drugs, and 
other drug related contraband. [R. 75-1, pp. 12–13].
4 
The affidavits detailed the extensive findings gathered by detectives during the course of 
their investigation into Joseph and his alleged broader drug trafficking and money laundering 
operation. See [R. 75-2, pp. 10–24]; [R. 75-3, pp. 9–23]; [R. 75-4, pp. 9–23]; [R. 75-5, pp. 9–23].5 
In addition to Joseph, the affidavits include information about his alleged confederates and known 
drug traffickers—Jordan Marcum, Joseph Alvey, Joshua Boston, Brian Reed Jr., and Joseph M. 
Lanham (“Little Joe”), Joseph’s son, see [R. 75-3, p. 22]—and findings from the search of property 
and residences owned or used by them. See [R. 75-2, pp. 10–24]; [R. 75-3, pp. 9–23]; [R. 75-4, 
pp. 9–23]; [R. 75-5, pp. 9–23]. The affidavits also detail the seizure of several postal packages 
shipped by Joseph that contained large sums of cas h meant for his al leged marijuana supplier in 
California. See id. The affidavits further trace detectives’ findings into Joseph’s alleged drug 
trafficking and money laundering operations through the use of direct or electronic observation, 
 
4 The only difference in this regard between the five warrants was that the Sea Wave Ct. Warrant authorized data 
extraction from cellphones, tablets, and computers, whereas the other four warrants excluded this provision. Compare 
[R. 75-1, pp. 12–13 (Sea Wave Ct. Warrant)], with [R. 75-2, pp. 6–8 (Johnsontown Way Warrant)], [R. 75-3, pp. 4–6 
(Nanisinh Way Warrant)], [R. 75-4, pp. 5–7 (Pine Lake Dr. Warrant) ], and [R. 75-5, pp. 5–7 (Blankenbaker Access 
Dr. Warrant)]. 
 
5 These citations are to “Appendix B,” which is attached to each warrant except for the Sea Wave Ct. Warrant and 
contains much of the same information provided in the affidavit for the Sea Wave Ct. Warrant. Compare [R. 75-2, 
pp. 10–24 (Johnsontown Way Warrant Appendix B) ], [R. 75-3, pp. 9–23 (Nanisinh Way Warrant Appendix B) ], 
[R. 75-4, pp. 9–23 (Pine Lake Dr. Warrant Appendix B)], and [R. 75-5, pp. 9–23 (Blankenbaker Access Dr. Warrant 
Appendix B )], with [R. 75-1, pp. 2–9 (Sea Wave Ct. Warrant affidavit) ]. However, the four warrants that include 
Appendix B each specifically incorporate all the material within it by reference in the affidavit. [R. 75-2, p. 4]; [R. 75-
3, p. 3]; [R. 75-4, p. 3]; [R. 75-5, p. 4]. Appendix B in all four of these warrant affidavits is virtually the same. 
Compare [R. 75-2, pp. 10–24 (Johnsontown Way Warrant Appendix B) ], with [R. 75-3, pp. 9–23 (Nanisinh Way 
Warrant Appendix B) ], [R. 75-4, pp. 9–23 (Pine Lake Dr. Warrant Appendix B) ], and [R. 75-5, pp. 9–23 
(Blankenbaker Access Dr. Warrant Appendix B) ]. For the remainder of this Memorandum Opinion and Order, the 
Court will refer to Appendix B as part of the affidavit for the warrant in which it was incorporated by reference. PageID #:
<pageID>
- 4 - 
 
GPS tracking, and the use of a reliable confidential informant (“RCI”) , and outline suspected 
illegal activities occurring at each of the five properties covered by the warrants. See id. 
Counsel for Joseph filed the instant motion requesting a Franks hearing and arguing that 
the affidavits supporting the warrants contained false information. [R. 62]. The United States filed 
a response opposing the Motion, [R. 75], and Joseph replied. [R. 88]. As mentioned, Defendants6 
recently filed a Renewed Motion for a Franks hearing. [R. 89]. The United States filed a renewed 
response in opposition. [R. 90]. As such, the matter is ripe and ready for review. 
II. LEGAL STANDARD FOR A FRANKS HEARING 
The Fourth Amendment to the United States Constitution protects “[t]he right of the people 
to be secure in their persons, houses, papers, and effects, against unreasonable searches and 
seizures,” and provides that “no Warrants shall issue, but upon probable cause, supported by Oath 
or affirmation, and particularly describing the place to be searched, and the persons or things to be 
seized.” U.S. Const. Amend. IV. “The text of the [Fourth] Amendment thus expressly imposes two 
requirements. First, all searches and seizures must be reasonable. Second, a warrant may not be 
issued unless probable cause is properly established and the scope of the authorized search is set 
out with particularity.” Kentucky v. King, 563 U.S. 452, 459 (2011). These requirements apply to 
warrants issued in federal and state courts. United States v. Helton, 35 F.4th 511, 517 (6th Cir. 
2022). 
Federal Rule of Criminal Procedure 12(b)(3)(C) permits defendants to file pretrial motions 
to suppress evidence, which are “appropriate when evidence sought to be introduced in a criminal 
case is alleged to have been unlawfully obtained.” United States v. Salazar, No. 1:14-CR-00029-
GNS-1, 2016 WL 2903282, at *1 n.1 (W.D. Ky. May 18, 2016) (internal quotation marks and 
 
6 For the remainder of this opinion, the Court uses “Defendants” to refer only to Joseph and Laura. Elble did not join 
in either the Motion or the Renewed Motion. PageID #:
<pageID>
- 5 - 
 
citations omitted); see also United States v. Nailor, 683 F. Supp. 3d 678, 682 (E.D. Mich. 2023) 
(citing Fed. R. Crim. P. 12(b)(3)). “The proponent of a motion to suppress has the burden of 
establishing that his own Fourth Amendment rights were violated by the challenged search or 
seizure.” United States v. Richards, 659 F.3d 527, 536 (6th Cir. 2011) (quoting Rakas v. Illinois, 
439 U.S. 128, 130 n.1 (1978) ). Should a court find that evidence was unlawfully obtained, “ that 
evidence collected in violation of the Fourth Amendment may be excluded from the criminal trial 
of the victim of the unlawful searc h.” United States v. Novak, 814 F. App’x 1009, 1012 (6th Cir. 
2020) (citing Mapp v. Ohio, 367 U.S. 643, 648 (1961)). This is known as “the exclusionary rule.” 
See id. 
A Franks hearing, as defendants request here, is an evidentiary hearing where defendants 
can present evidence challenging the veracity of statements included in the search warrant 
affidavit. See Franks v. Delaware, 438 U.S. 154, 171–72 (1978). If at that hearing, the defendants 
establish “by a preponderance of the evidence (1) that ‘ a false statement knowingly and 
intentionally, or with reckless disregard for the truth, was included by the affiant in the warrant 
affidavit,’ and (2) that ‘with the affidavit’s false material set to one side, the affidavit’s remaining 
content is insufficient to establish probable cause ,’” then the search warrant “must be voided.” 
United States v. Keszthelyi, 308 F.3d 557, 566 (6th Cir. 2002) (quoting Franks, 438 U.S. at 155–
56). However, search warrant affidavits are entitled to a presumption of validity. United States v. 
Bateman, 945 F.3d 997, 1008 (6th Cir. 2009) ( citing Franks, 438 U.S. at 171). Thus, a defendant 
challenging an affidavit in support of a search warrant “bears a heavy burden.” Id. 
A defendant is only entitled to a Franks hearing to challenge the veracity of the statements 
in such an affidavit if he 
1) makes a substantial preliminary showing that the affiant knowingly and 
intentionally, or with reckless disregard for the truth, included a false statement or PageID #:
<pageID>
- 6 - 
 
material omission in the affidavit; and 2) proves that the false statement or material 
omission is necessary to the probable cause finding in the affidavit. 
 
United States v. Young, 847 F.3d 328, 348–49 (6th Cir. 2017) (quoting United States v. Pirosko, 
787 F.3d 358, 369 (6th Cir. 2015)); see also Franks, 438 U.S. at 155–56. An officer’s statement is 
made with “ reckless disregard for the truth” only if the defendant s can show that the officer 
“subjectively entertain[ed] serious doubts as to the truth of his [or her] allegations.” Bateman, 945 
F.3d at 1008 (alterations in original) ( quoting United States v. Cican, 63 F. App’x 832, 836 (6th 
Cir. 2003)). Finally, “if, when material that is the subject of the alleged falsity or reckless disregard 
is set to one side, there remains sufficient content in the warrant affidavit to support a finding of 
probable cause, no hearing is required.” Bateman, 945 F.3d at 1008 (quotation modified) (quoting 
Franks, 438 U.S. at 171–72). 
III. ANALYSIS 
Defendants claim that they are entitled to a Franks hearing because the affidavit s 
supporting the five warrants at issue contain false statements . In their Motion, Defendants 
specifically allege that (1) the RCI never existed and (2) Marcum never made any statements to 
investigators inculpating Joseph. [R. 62, p. 3]. In support of the allegation that Marcum never made 
any such statements, Defendants attach to their motion a sworn affidavit signed by Marcum 
attesting to this fact.
7 [R. 62-1, pp. 1–3]. Defendants argue that “[t]he probable cause used to obtain 
these warrants hinged entirely on these statements .” [R. 62, p. 3 (emphasis added)]. Defendants 
recently filed a Renewed Motion for a Franks hearing claiming that three of the alleged associates 
of Joseph who were mentioned in the affidavits —Alvey, Reed, and Boston—“did not give any 
 
7 In its response, the United States expresses concerns about the authenticity and procurement of Marcum’s affidavit. 
See [R. 75, pp. 4–5 (“It is unlikely that Marcum drafted the proffered affidavit on his own. . . . The challenged warrant 
affidavits also state that Marcum feared [Joseph] because of threats of violence, which could have provided motivation 
for signing the affidavit.”)]. While the Court understands these concerns, the Court need not address these arguments 
for resolution of the Motion because the Motion otherwise fails under Franks. PageID #:
<pageID>
- 7 - 
 
statements that the United States claims they made against Joseph Earl Lanham.” [R. 89, p. 1]. 
Before turning to the Franks analysis, the Court will first handle some preliminary matters. 
First, the current Motion filed on June 17, 2025, is untimely. [R. 62]. According to Joseph’s 
Order Following Arraignment and Scheduling Order, his defensive motion deadline was July 11, 
2024—nearly a year earlier. See [R. 11, p. 5]. No other orders extended this deadline, and no 
extension was sought. Neither the United States nor Defendants discuss the Motion’s untimeliness. 
See generally [R. 62]; [R. 75]; [R. 88]. Even so, the Court could deny the Motion on this ground 
alone. See, e.g., United States v. W alden, 625 F.3d 961, 964–65 (6th Cir. 2010) (citing Fed. R. 
Crim. P. 12(c)). 
Further, the reply improperly raises new Franks arguments. Compare [R. 88 (reply)], with 
[R. 62 (Motion)]. The Court need not consider these new arguments. See Ryan v. Hazel Park, 279 
F. App’x 335, 339 (6th Cir. 2008) (citing Scottsdale Ins. Co. v. Flowers , 513 F.3d 546, 553 (6th 
Cir. 2008)) (“Generally, this Court has found that an issue raised for the first time in a reply to a 
response brief in the district court is waived .”); see also Settle v. Parris , No. 3:19-CV-32, 2021 
WL 1566074, at *5 (E.D. Tenn. Apr. 21, 2021) (“[O]rdinarily, courts do not consider an argument 
that a party raises for the first time in a reply brief.”); Laughlin v. United States, No. 20-5433, 2020 
WL 9423256, at *2 (6th Cir. Oct. 28, 2020). 
Except for an argument related to Joseph’s criminal history, which the Court addresses 
below, these arguments principally culminate in a general denial of Joseph trafficking drugs. See 
[R. 88, pp. 2–3 (stating that “[Joseph] has never been convicted” of trafficking large quantities of 
drugs and that “[t]here has never been a connection of the dots from narcotics, large sums of 
money, and/or guns”)]. However, this general denial has no bearing on the Franks analysis, as it PageID #:
<pageID>
- 8 - 
 
fails to make a substantial showing that specific false information was included in the warrant 
affidavits. Further, in doing so, defense counsel misstates the record. Defense counsel claims that 
[a] list of the property seized from [Joseph] ’s home is attached hereto and 
designated Exhibit 9. No drugs were found. There has never been a connection of 
the dots from narcotics, large sums of money, and/or guns. 
 
Id. at 3 (emphasis added). This claim is plainly contrary to the record and makes the Court question 
whether defense counsel even reviewed his own exhibit. The “Item Seized Report” for the Pine 
Lake Dr. Warrant —which is what defense counsel is referring to as “Exhibit 9” —includes 
numerous entries for drugs, cash, and firearms that were seized from Joseph’s home. See [R. 88-
9, pp. 1–5]. By the Court’s count, there are four separate entries for drugs, eight separate entries 
of “US Currency,” and six separate entries for firearms or firearm accessories. See id. 
Second, the Motion references “six search warrants,” [R. 62, p. 2], and Marcum’s affidavit 
includes a sixth property located on Old Church Road, [R. 62-2, p. 2]. In a footnote in its response, 
the United States mentions this sixth warrant and notes that “the United States has not yet obtained 
a certified copy, but understands that the same challenges are intended to apply to it, based on the 
present motion.” [R. 75, p. 6 n.2]. However, between all of the briefing and attachment s filed, 
neither Defendants nor the United States have provided this sixth warrant or warrant affidavit for 
the Court’s consideration or made any arguments concerning it . See generally [R. 62]; [R. 75]; 
[R. 88]; [R. 89]; [R. 90]. Consequently, the Court will deny D efendants’ Motion insofar as it 
pertains to this sixth warrant. 
Third and lastly, Defendants do not have standing to challenge the Sea Wave Ct. Warrant. 
The “rights assured by the Fourth Amendment are personal rights” that can only “be enforced by 
exclusion of evidence only at the instance of one whose own protection was infringed by the search 
and seizure.” Simmons v. United States , 390 U.S. 377, 389 (1968) (citation omitted) ; see also PageID #:
<pageID>
- 9 - 
 
Richards, 659 F.3d at 536 (quoting Rakas, 439 U.S. at 130 n.1) (“The proponent of a motion to 
suppress has the burden of establishing that his own Fourth Amendment rights were violated by 
the challenged search or seizure. ”). The Sea Wave Ct. Warrant authorized the search of Reed’s 
residence and vehicle. [R. 75-1, pp. 12–13]. As Defendants point out in their own reply “[t]he 
home is not owed [sic] by or leased by [Joseph].” [R. 88, p. 3]. Consequently, neither Joseph nor 
Laura have standing to challenge the Sea Wave Ct. Warrant. For similar reasons, Laura does not 
have standing to challenge any of the other warrants—which involve properties and storage units 
belonging to Joseph—except for the Johnsontown Way Warrant , which authorized the search of 
her residence. See [R. 75-2, pp. 6–8, 19].8 
With these preliminary issues addressed, and to ensure a full record, the Court will address 
the merits of the Motion and consider (1) whether Defendants have made a substantial preliminary 
showing that the affiant, with an intention to mislead, included false information in the affidavit , 
and (2) whether that alleged false information was necessary to the probable cause finding 
supporting the warrants. 
A. Substantial Showing 
As noted above, there exists “a presumption of validity with respect to the affidavit 
supporting [a] search warrant.” Franks, 438 U.S. at 171. The Supreme Court has explained that, 
in light of this presumption, a defendant seeking a Franks hearing must present more than 
conclusory attacks, and his challenge to the search warrant affidavit “must be supported by more 
than a mere desire to cross-examine.” Id. More specifically, 
[t]here must be allegations of deliberate falsehood or of reckless disregard for the 
truth, and those allegations must be accompanied by an offer of proof. They should 
point out specifically the portion of the warrant affidavit that is claimed to be false; 
 
8 Likewise, Joseph likely does not have standing to challenge the Johnsontown Way Warrant, since he apparently 
neither lived at nor owned this residence. See [R. 75-2, pp. 6–8, 19]. Regardless, even if Joseph and Laura had standing 
with respect to all of the challenged warrants, the Motion for a Franks hearing fails on the merits for each property. PageID #:
<pageID>
- 10 - 
 
and they should be accompanied by a statement of supporting reasons. Affidavits 
or sworn or otherwise reliable statements of witnesses should be furnished, or their 
absence satisfactorily explained. Allegations of negligence or innocent mistake are 
insufficient. 
 
Id. (emphasis added). 
 In the present case, Defendants allege that the five warrant affidavits included false 
information because (1) the RCI does not exist , [R. 62, p. 3], (2) Marcum never made any 
statements to investigators incriminating Joseph, id., and (3) Alvey, Reed, and Boston likewise 
never made any statements against Joseph, [R. 89, p. 1]. In their reply, Defendants also allege that 
the affidavits contained false information about the extent of Joseph’s drug trafficking activities 
and criminal history. [R. 88, p. 2]. 
1. Statements by RCI, Alvey, Reed, and Boston 
The first principal allegation is that the RCI who detectives used throughout their 
investigation of Joseph and referenced in the affidavits never actually existed. [R. 62, p. 3]. 
Specifically, they argue that “[Joseph] has evidence that there was no confidential informant.” Id. 
They further state that “[t]here is no indication in the government’s response to discovery that a 
[RCI] will testify or disclosed [sic] the [RCI]’s identity or any corroborating documentation that a 
[RCI] ever actually existed.” Id . In its response, the United States rightly points out that “ [t]he 
defendants make no specific offer of proof to negate the existence of a [RC I] or any of the 
statements made by that [RCI].” [R. 75, p. 3]. The Court agrees. 
Defendants’ claim that no RCI exists is nothing but a bare assertion, a far cry from the 
substantial showing required by Franks. Defendants state that “[Joseph] has evidence” of this fact, 
[R. 62, p. 3], yet they provide none in support of their claim. Nowhere do Defendants provide any 
proof substantiating their claim that the RCI does not exist. Their bare assertion fails to meet their 
burden under the first prong of Franks. PageID #:
<pageID>
- 11 - 
 
Similarly, Defendants filed a Renewed Motion for a Franks hearing alleging that Alvey, 
Reed, and Boston will give testimony that “they did not give any statements that the United States 
claims they made against Joseph.” [R. 89, p. 1]. Defendants further state that Boston “claims he 
never made any statements against Defendant [Joseph] , that his drug charges had nothing to do 
with [Joseph], and that there was no information in his phone about [Joseph].” Id. As with the RCI 
allegation, Defendants make a conclusory attack only and fail to provide any evidence to support 
that claim. They again fail to make a substantial showing under Franks. See Franks, 438 U.S. at 
171. 
2. Statements by Jordan Marcum 
Defendants also argue that Marcum never made any statements to investigators 
incriminating Joseph contrary to what the affidavits provide . [R. 62, p. 3]. In support, defense 
counsel attaches to the Motion a sworn affidavit by Marcum denying that he ever made the 
statements that the warrant affidavits claim that he did. See [R. 62-2, pp. 1–3]. Specifically, the 
sworn affidavit by Marcum claims the following: 
Prior to my charges, I have never met Joseph Earl Lanham. I was introduced to 
[Joseph] after I was charged because I was being accused of hearsay that I was 
making statement against [Joseph] . I communicated with [Joseph] by phone 
explaining that I since I did not know him and could not recognized [sic] him, I 
never made any such statement. During my case, I could not have made statements 
implicating [Joseph] since I have not met [Joseph] until afterwards. 
 
Id. at 1. As far as the Court can tell, Marcum’s testimony and Defendants’ argument is that because 
Marcum allegedly had never met Joseph before the date that Marcum supposedly implicated him, 
Marcum could never have made the statements attributed to him in the warrant affidavits. See id. 
 While Defendants have supplied some offer of proof by way of Marcum’s affidavit , the 
Court need not decide w hether Defendants have met Franks ’ “substantial showing” prong 
because— as discussed in detail below —D efendants’ Motion fails under the second prong of PageID #:
<pageID>
- 12 - 
 
Franks. Namely, even when setting aside the challenged information, sufficient evidence remains 
to support a finding of probable cause for each of these warrants. 
3. Joseph’s Criminal History 
Defendants raise a new Franks hearing argument in their r eply. Specifically, they argue 
that the warrants were “ based on false information and mere speculation” because the affidavits 
alleged “that [Joseph] was found to be in position [sic] of large amounts of marijuana .” [R. 88, 
pp. 1–2]. But, defense counsel argues, “[Joseph] has never been convicted of being in possession 
of or trafficking in large amounts of marijuana.” Id. 
First, this argument was improperly raised for the first time in Defendants’ reply. Compare 
[R. 88 (reply)], with [R. 62 (Motion)]. Accordingly, the Court need not consider it. See Ryan, 279 
F. App’x at 339 (citing Scottsdale Ins. Co., 513 F.3d at 553) (“Generally, this Court has found that 
an issue raised for the first time in a reply to a response brief in the district court is waived.”); see 
also Settle, 2021 WL 1566074, at *5 (“[O]rdinarily, courts do not consider an argument that a 
party raises for the first time in a reply brief. ”); Laughlin, 2020 WL 9423256, at *2. Even 
considering the argument, it fails. 
By way of background, the warrant affidavits 9 contain a CourtNet history search for 
Joseph, that reads as follows: 
Detectives conducted a Courtnet history search of Joseph Earl Lanham and found 
the following: 
- 19-CR-3382 – enhanced traff marijuana, fleeing and evading police 
2nd on foot. 
- 16-F-9985 – enhanced traff marijuana over 5lbs, traff controlled 
substance 1st degree drug unspecified, receiving stolen property 
firearms 
- 11-F-7990 – Traff Controlled substance 1st degree meth over 2gms 
- 01-F-232866 – traff in marijuana with a minor. 
 
 
9 The Sea Wave Ct. Warrant affidavit makes no mention of Joseph’s criminal history. See [R. 75-1, pp. 2–9 (Sea Wave 
Ct. Warrant affidavit)]. PageID #:
<pageID>
- 13 - 
 
[R. 75-2, p. 10]; [R. 75-3, p. 9]; [R. 75-4, p. 9]; [R. 75-5, p. 9]. In support of the argument that 
Joseph’s drug trafficking activities—or criminal history —are overstated, defense counsel attach es 
several CourtNet documents related to Joseph, Boston, and Marcum. [R. 88-3]; [R. 88-4]; [R. 88-
5]; [R. 88-6]; [R. 88-7]; see also [R. 88, pp. 1–2]. Most of these items are plainly irrelevant . As 
mentioned, they include the disposition of cases involving Boston, [R. 88-5], and Marcum ,10 
[R. 88-7], that Joseph was never a party to. They also include the dismissal without prejudice —
pending disposition of this federal prosecution —of the state charges relating to the same 
underlying conduct of the instant case. [R. 88-6]. 
 The only case involving Joseph cited in the r eply that was listed in the search warrant 
affidavit was 19-CR-3382. Id. at 2. But in doing so, defense counsel misstates the record, claiming 
that “the case was dismissed.” Id. This is simply not true. As defense counsel’s own exhibit shows, 
the 2019 case was not dismissed. See [R. 88- 4, p. 1]. Instead, the charge of “Enh Traffic in 
Marijuana, > 5 Lbs” was ultimately amended down to “Traffic in Marijuana, Less Than 8 Oz.” Id. 
He was found guilty of this amended- down charge as well as a charge of “F leeing or E vading 
Police.” Id. at 1–2. The reply later acknowledges that Joseph was convicted of this lesser drug 
trafficking charge. See [R. 88, pp. 2]. 
Finally, the r eply references a drug trafficking allegation from 2016 and argues that the 
case was “dismissed and expunged.” [R. 88, p. 1]. Defense counsel attaches a CourtNet print out 
that contains no reference to a 2016 case against Joseph . [R. 88- 3]. Nor do any of his other 
attachments. See generally [R. 88-4]; [R. 88-5]; [R. 88-6]; [R. 88-7]. As best the Court can tell, 
defense counsel is arguing that the CourtNet history listed in the affidavits falsely reference s a 
2016 case—16- F-9985— which Defendants allege has been “dismissed and expunged.” Compare 
 
10 Marcum’s case was not mentioned in the reply, see [R. 88, pp. 1–2], but was attached as an exhibit, [R. 88-7]. PageID #:
<pageID>
- 14 - 
 
[R. 88, p. 1 (reply)], with [R. 75-2, p. 10 (Johnsontown Way Warrant)], [R. 75-3, p. 9 (Nanisinh 
Way Warrant)], [R. 75-4, p. 9 (Pine Lake Dr. Warrant)], and [R. 75-5, p. 9 (Blankenbaker Access 
Dr. Warrant) ]. But even assuming that this charge was ultimately dismissed and expunged, 
Defendants have made no substantial showing that a materially false statement appears in the 
warrants. The warrant affidavits make no mention of the ultimate disposition of the listed cases. 
Instead, the affidavits simply provide that “Detectives conducted a Courtnet hist ory search of 
Joseph Earl Lanham and found the following.” [R. 75-2, p. 10]; [R. 75-3, p. 9]; [R. 75-4, p. 9]; [R. 
75-5, p. 9]. Defendants have failed to make a substantial showing that any information concerning 
Joseph’s criminal history or alleged involvement in drug trafficking was false, much less that the 
affiant included this allegedly false information either intentionally or with a reckless disregard 
for the truth. See Franks, 438 U.S. at 171.11 
In sum, with the possible exception of Marcum’s statements, Defendants have failed to 
meet their burden of showing that false statements were included in the warrant affidavits , much 
less that they were made intentionally or with a reckless disregard for the truth. The Court now 
turns to the probable cause analysis under the second prong of Franks. 
B. Necessary for Probable Cause 
The Fourth Amendment guarantees that “no Warrants shall issue, but upon probable cause, 
supported by Oath or affirmation, and particularly describing the place to be searched, and the 
persons or things to be seized.” T he Supreme Court has explained that, so long as the magistrate 
judge had a “substantial basis for . . . concluding that a search would uncover evidence of 
wrongdoing, the Fourth Amendment requires no more.” Illinois v. Gates , 462 U.S. 213, 236 
(1983). More specifically, the magistrate judge “m ust find that ‘given all the circumstances set 
 
11 For the reasons outlined below, even if the Court excluded any reference to the 2016 case from the affidavits, 
probable cause remains. PageID #:
<pageID>
- 15 - 
 
forth in the affidavit . . . there is a fair probability that contraband or evidence of a crime will be 
found in a particular place.’” United States v. Berry , 565 F.3d 332, 338 (6th Cir. 2009) (quoting 
Gates, 462 U.S. at 236). In other words, “the affidavit supporting the search warrant must 
demonstrate a nexus between the evidence sought and the place to be searched.” United States v. 
Brown, 828 F.3d 375, 382 (6th Cir. 2016) (citing United States v. Carpenter , 360 F.3d 591, 594 
(6th Cir. 2004)). To meet this nexus requirement, “the circumstances must indicate why evidence 
of illegal activity will be found in a particular place.” Carpenter , 360 F.3d at 594 (citation and 
internal quotation marks omitted). The affidavit must indicate “that there is reasonable cause to 
believe that the specific thing to be searched is located on the property to which entry is sought, 
and not merely that the owner of the property is suspected of a crime.” United States v. 
McPhearson, 469 F.3d 518, 524 (6th Cir. 2006)) (quotation modified) (quoting Zurcher v. Stanford 
Daily, 436 U.S. 547, 556 (1978)). 
For example, in Berry, officers were investigating a drug operation when they received a 
tip that the defendant, Berry , was living in the same duplex as the subject of their investigation, 
who was a known drug dealer. 565 F.3d at 335 –36. The officers were familiar with Berry ’s 
criminal history, including a drug trafficking conviction, and his status as a probationer. Id. at 335. 
Berry’s status as a probationer required him to notify his probation officer of this most recent 
address change, something he had not done. Id. Officers eventually arrested Berry in the driveway 
of the duplex and searched his vehicle incident to the arrest. Id. In the car, they found cocaine. Id. 
Officers then obtained a search warrant for the duplex, which allowed them to search for evidence 
of drugs a nd evidence establishing that Berry lived at the property in violation of his terms of 
probation. Id. at 335–37. After both drugs and guns were found in the home, Berry was charged 
with several drug trafficking and firearms charges. Id. at 337. PageID #:
<pageID>
- 16 - 
 
Berry filed a motion to suppress, arguing that the search warrant affidavit failed to establish 
the requisite nexus between the duplex and the drug activity. Id. The district court denied the 
motion. Id. On appeal, the Sixth Circuit affirmed, explaining that 
[a]lthough a defendant’s status as a drug dealer, standing alone, does not give rise 
to a fair probability that drugs will be found in defendant ’s home, there is support 
for the proposition that status as a drug dealer plus observation of drug activity near 
defendant’s home is sufficient to establish probable cause to search the home. 
 
Id. at 339 (internal citations omitted). In Berry , the warrant established probable cause, as it 
specified that the defendant was known to be involved in drug trafficking based on a prior 
conviction, and officers discovered crack cocaine in his car during the search incident to arrest. Id. 
It also noted that he had been renting the duplex under an alias and paid his rent in cash, facts that 
the officers had uncovered during the course of their investigation. Id. Finally, the affiant-officer 
stated that based on his experience, vehicles “parked on the premise of the places where controlled 
substances are found or sold oftentimes contain controlled substances.” Id. (quoting the affidavit). 
The Sixth Circuit therefore concluded that “[c]ertainly, the affidavit established ‘a fair probability 
that contraband or evidence of a [drug] crime’ would be found at” the duplex. Id. (quoting Gates, 
462 U.S. at 238). 
In a separate instance, the Sixth Circuit has found that a search warrant affidavit lack s 
probable cause if it does nothing more than state where the defendant resides and that the defendant 
has been found with a quantity of crack cocaine on his person during an unrelated arrest . 
McPhearson, 469 F.3d at 524. In McPhearson, the defendant had been arrested on an outstanding 
warrant for simple assault and was not known to be involved in drug trafficking. Id. at 524–25. 
The Sixth Circuit concluded that there was an insufficient nexus between the residence and the 
defendant’s drug activity to create the probable cause necessary to search his residence. Id. ; see 
also Brown, 828 F.3d at 382 (failing the nexus requirement to find probable cause where the search PageID #:
<pageID>
- 17 - 
 
warrant affidavit “contained no evidence that Brown distributed narcotics from his home, that he 
used it to store narcotics, or that any suspicious activity had taken place there.”). However, where 
the affidavit includes facts outlining suspected drug activity in and around a known drug dealer’s 
residence, then probable cause and its nexus requirement are satisfied. See Berry, 565 F.3d at 339. 
Here, Defendants’ motion focuses exclusively on the RCI and Marcum in addressing 
probable cause; that is, the reply and Renewed Motion fail to address the merits of probable cause. 
Defendants argue that absent “the alleged [RCI], and the statement made by Mr. Marcum, there 
was no probable cause to search the Defendant’s properties.” [R. 62, p. 3]. They argue that “[t]he 
probable cause used to obtain these warrants hinged entirely on these statements .” Id. (emphasis 
added). The Court disagrees and questions whether defense counsel even read the full warrant 
affidavits before making the baseless claim that the affidavits hinged entirely on Marcum and the 
RCI. The affidavits —including appendices —supporting each of the five warrants spanned 
numerous pages with evidence gathered from multiple, expansive investigations. [R. 75-1, pp. 1–
11 (eleven pages)]; [R. 75-2, pp. 1–5, 9–24 (twenty-one pages)]; [R. 75-3, pp. 1–4, 8–23 (twenty 
pages)]; [R. 75-4, pp. 1–4, 8–23 (twenty pages)]; [R. 75-5, pp. 1–4, 8–23 (twenty pages)]. 
Although Defendants have wholly failed to make any showing (much less a substantial 
one) of false information within the affidavits (except possibly as to Marcum, which was supported 
by an affidavit), for purposes of the Court’s probable cause analysis, it will assume that Defendants 
have met their “substantial showing” burden under the first step of Franks as to (1) the existence 
of the RCI; (2) Marcum’s statements; and (3) Alvey’s, Reed’s, and Boston’s statements . 
Accordingly, the Court will set aside any and all statements attributed to the RCI, any use of the 
RCI to purchase drugs from Reed or others, and any statements by Marcum, Alvey, Reed, or 
Boston that in any way incriminate Joseph. See id. As detailed below, even removing this evidence, PageID #:
<pageID>
- 18 - 
 
the contents of the affidavits still support a finding of probable cause. Accordingly, D efendants 
are not entitled to a Franks hearing. Franks, 438 U.S. at 171–72 (“Finally, if these requirements 
are met, and if, when material that is the subject of the alleged falsity or reckless disregard is set 
to one side, there remains sufficient content in the warrant affidavit to support a finding of probable 
cause, no hearing is required.”). 
1. General Evidence Supporting Probable Cause for all Five Warrants 
Before addressing the probable cause evidence specific to the five properties, the Court 
will first trace some of the extensive evidence outlined in the affidavits that relates more broadly 
to Joseph and his associates, including Little Joe and others, and their alleged illegal activities 
including drug trafficking and money laundering. 
As noted above, Joseph’s criminal history includes a 2019 conviction for trafficking 
marijuana, [R. 88-4, p. 1], along with other charges, the disposition of which is not entirely clear 
from the CourtNet print outs. See [R. 75-2, p. 10]; [R. 75-3, p. 9]; [R. 75-4, p. 9]; [R. 75-5, p. 9]. 
A prior drug trafficking conviction may be considered as part of the probable cause calculus. See 
United States v. Sanders , 106 F.4th 455, 461–62 (6th Cir.), cert. denied , 145 S. Ct. 603 (2024) 
(stating that the “exploration of a suspect’s criminal history” is one of the “time-honored markers 
in our Fourth Amendment jurisprudence”); United States v. Talley, 692 F. App’x 219, 222–23 (6th 
Cir. 2017) (discussing how a defendant’s prior drug conviction is a relevant consideration for 
probable cause even when the conviction is over nine years old). 
The affidavits detail years-long investigations into Joseph and his associates relat ing to 
drug trafficking, money laundering, and other criminal activities. This includes investigations by 
Detective Pawul of L ouisville Metro Narcotics, who advised that “[Joseph] is trafficking large 
amounts of marijuana throughout Louisville, upwards of hundreds of pounds a week. . . . [and] PageID #:
<pageID>
- 19 - 
 
routinely deal[s] in hundreds of thousands of dollars from the sale of narcotics .” [R. 75-2, p. 10]; 
[R. 75-3, p. 9]; [R. 75-4, p. 9]; [R. 75-5, p. 9]. Further, detectives observed Joseph make numerous 
“short stays” throughout Louisville consistent with drug trafficking and meet up with known and 
suspected narcotics traffickers . Id.; see also United States v. Briggs , No. 23- 1963, 2024 WL 
5135701, at *2–3 (6th Cir. Dec. 17, 2024), cert. denied , 145 S. Ct. 1945 (2025) (finding that the 
frequency and duration of short stays supported probable cause of drug trafficking). Jeffersontown 
Police Department detectives also observed Joseph using counter surveillance techniques to evade 
or look for police surveillance in a manner common amongst narcotics traffickers. [R. 75-2, p. 10]; 
[R. 75-3, p. 9]; [R. 75-4, p. 9]; [R. 75-5, p. 9] ; see also United States v. $99,990.00 in U.S. 
Currency, 69 F. App’x 757, 761 (6th Cir. 2003) (“Courts have recognized such counter -
surveillance techniques as incriminating.”); United States v. Health, 259 F.3d 522, 529 (6th Cir. 
2001) (considering the defendant’s use of counter-surveillance techniques as a basis for reasonable 
suspicion). 
Officers frequently observed Joseph associating with other known drug traffickers. See 
United States v. Davidson, 936 F.2d 856, 859 (6th Cir. 1991) (considering the defendant’s 
association with known or convicted drug traffickers in a probable cause analysis); Libretti v. 
Woodson, 600 F. App’x 367, 372 (6th Cir. 2015) (“[A]ssociation with suspected and known drug 
traffickers is another appropriate consideration.”). This included his son, Little Joe, who lived with 
Joseph at his residence at Pine Lake Dr. [R. 75-2, p. 20]; [R. 75-3, p. 19]; [R. 75-4, p. 19]; [R. 75-
5, p. 19]. In two separate instances, a Dodge Charger driven by Little Joe fled officers in excess of 
one hundred miles per hour. [R. 75-2, p. 11–12]; [R. 75-3, p. 10–11]; [R. 75-4, p. 10–11]; [R. 75-
5, p. 10–11]. Soon after, officers located the Charger with Little Joe at the wheel. A search of the 
vehicle produced a handgun, individual packages of marijuana consistent with trafficking, and an PageID #:
<pageID>
- 20 - 
 
undetermined amount of cash. [R. 75-2, p. 12]; [R. 75-3, p. 11]; [R. 75-4, p. 11]; [R. 75-5, p. 11]; 
see also id. (describing multiple meetings between Joseph and Artemia Medina, a known cocaine 
trafficker, at Joseph’s residence and one meeting at Medina’s residence). 
The affidavits also include information about known drug trafficker, Joseph Alvey, whose 
storage unit, residence, and mother’s residence were searched by Jeffersontown Police detectives 
months before the instant searches, uncovering an estimated $130,000 i n cash, money counters, 
marijuana packaging materials, forged vehicle titles, and cell phones. [R. 75- 1, p. 5]; [R. 75-2, 
p. 11]; [R. 75-3, p. 10]; [R. 75-4, p. 10]; [R. 75-5, p. 10] . During the investigation, detectives 
observed Joseph’s GMC truck—seeming ly driven by Joseph or Little Joe —at Alvey’s mother’s 
residence. [R. 75-2, p. 12]; [R. 75-3, p. 11]; [R. 75-4, p. 11]; [R. 75-5, p. 11] . Further, the 
affidavits provide that the “ [d]etective knows Alvey and have a relationship revolved around 
trafficking large amounts of marijuana.” Id. 
The affidavits similarly describe the activities of known drug trafficker, Joshua Boston, 
who detectives believed served as Joseph’s drug runner until Boston’s arrest. [R. 75- 1, p. 5]; 
[R. 75-2, p. 11]; [R. 75-3, p. 10]; [R. 75-4, p. 10]; [R. 75-5, p. 10]. Using GPS tracking, detectives 
uncovered Boston’s stash location, where a search uncovered over two hundred pounds of 
marijuana, over forty pounds of THC cartridges, $2,897 in cash, packaging materials, other various 
drugs, and a firearm. Id. A separate search of Boston’s phone revealed messages between Boston 
and an individual identified only as “J” reflecting Boston was moving large amounts of marijuana 
for “J.” Id. Officers had knowledge that Boston continued to traffic marijuana and at one point 
observed Little Joe, driving Joseph’s GMC truck, visit Boston’s stash location for approximately 
thirty minutes, where officers believe Little Joe was collecting money for Joseph. [R. 75-2, p. 12]; 
[R. 75-3, p. 11]; [R. 75-4, p. 11]; [R. 75-5, p. 11 ]. Further, the affidavits state that “contact PageID #:
<pageID>
- 21 - 
 
between Boston and [Joseph] has been for the purpose of trafficking large amounts of marijuana.” 
Id. 
The affidavits also included information about known drug trafficker, Brian Reed Jr., who 
detectives believe became Joseph’s drug runner after Boston was arrested. [R. 75-1, pp. 4, 6]; 
[R. 75-2, p. 10]; [R. 75-3, p. 9]; [R. 75-4, p. 9]; [R. 75-5, p. 9]. Detectives witnessed Joseph and 
Reed meet up multiple times throughout the investigation. [R. 75-2, p. 18]; [R. 75-3, p. 17]; [R. 75-
4, p. 17]; [R. 75-5, p. 17]. They would often do so late at night, in a parking lot, and would meet 
only for a short time. Id. Detectives believed that these activities were consistent with drug 
trafficking and the delivery of cash to Joseph for shipment to his source of supply in California. 
Id. 
The search of Reed’s Sea Wave Ct. residence—discussed in in the next section—yielded 
approximately twenty to thirty pounds of marijuana, THC cartridges, drug ledgers, scales, a 
firearm, and a large amount of cash. [R. 75-2, p. 19]; [R. 75-3, p. 18]; [R. 75-4, p. 18]; [R. 75-5, 
p. 18]; see also [R. 75-1, p. 4 (Item Seized Report for the Sea Wave Ct. Warrant)]. Importantly, 
this search occurred on August 10, 2022, the day before the searches for the remaining four 
properties at issue in this case. The search warrant affidavits for the remaining four properties 
incorporated the search results and information related to Reed’s residence as part of the calculus 
for probable cause. [R. 75-2, p. 19]; [R. 75-3, p. 18]; [R. 75-4, p. 18]; [R. 75-5, p. 18]. 
Finally, the affidavits detail how agents twice tracked Joseph depart ing his Pine Lake Dr. 
residence in his GMC truck carrying several large white postal boxes, travel ing to multiple post 
office locations, and depositing the boxes for shipment to California. [R. 75- 1, p. 6–7]; [R. 75-2, 
p. 13–16]; [R. 75-3, p. 12 –15]; [R. 75-4, p. 12–15 ]; [R. 75-5, p. 12–15]. The boxes, which had 
alias sender information and return addresses, were intercepted by law enforcement and ultimately PageID #:
<pageID>
- 22 - 
 
searched after a detection dog, Maya, alerted on the packages. Id. The packages contained 
approximately $110,000 in cash that had been extensively wrapped in vacuum -sealed packages. 
Id. No one ever made a formal loss claim for the seized packages, notwithstanding the fact that 
they contained large sums of cash. Id. 
2. Sea Wave Ct. Warrant, [R. 75-1] 
The Sea Wave Ct. Warrant authorized the search of Reed’s residence and vehicle and 
phone. [R. 75-1, pp. 12–13]. As mentioned, detectives had evidence that Reed served as Joseph’s 
drug runner after Boston was arrested. Id. at 6. The affidavit section titled “Brian Reed Jr and 4103 
Sea Wave Ct. Louisville Ky.,” id. at 7–10, details the investigators’ findings related to Reed’s drug 
trafficking and money laundering activities and his Sea Wave Ct. residence. See id. The highlights 
include the following evidence: detectives following Reed, a known narcotics trafficker with 
multiple marijuana convictions, and observing him leave his residence and make multiple short 
stays around Jefferson County, id. at 8; multiple instances of Reed carrying large garbage bags 
from his house to his vehicle, leaving with those bags, and then making short stops at various 
locations, including locations of known narcotics traffickers, then returning to his house id. at 8–
9; and an instance where Reed brought a small black bag into this residence that was consistent 
with bags used to carry a large amount of cash, id. at 8. As mentioned previously, officers also 
surveilled Joseph and Reed meeting at various locations throughout Louisville, often at night and 
in parking lots, for brief exchanges. Id. at 9. On one occasion, officers observed two individuals 
enter Reed’s residence with a backpack, stay for only eleven minutes, and then leave with the 
backpack looking “considerably fuller.” Id. at 8. The detectives followed these individuals and 
attempted to pull them over. Id. The individuals fled the scene and dropped the backpack, which 
contained three to five pounds of marijuana. Id. PageID #:
<pageID>
- 23 - 
 
The Sea Wave Ct. Warrant, even setting aside the challenged evidence, contained sufficient 
probable cause that Reed was conducting drug trafficking activities (and handling cash proceeds) 
at this location and that evidence of these illegal activities would be found at the residence, 
satisfying the nexus requirement established in Gates. See Berry, 565 F.3d at 339; Brown, 828 
F.3d at 378–79 (considering as evidence of probable cause ); Novak, 814 F. App’x at 1011 
(considering officers’ observations of drug buys at a residence as evidence supporting criminal 
activity under the good-faith exception); United States v. Gunter, 266 F. App’x 415, 419 (6th Cir. 
2008) (“[A] nexus exists between a known drug dealer ’s criminal activity and the dealer ’s 
residence when some reliable evidence exists connecting the criminal activity with the 
residence.”). 
3. Johnsontown Way Warrant, [R. 75-2] 
The Johnsontown Way Warrant authorized the search of Laura’s residence. [R. 75- 2, 
pp. 6–8, 19]. The affidavit section titled “9606 Johnsontown Way Louisville Ky 40258” details 
the investigators’ findings using property records, FinCEN queries, and IRS agents, related to 
Joseph’s extensive financial dealings and his use of cash and nominees—like Laura—to purchase 
and hold real estate, allegedly using drug proceeds. Id. at 19 –20. The affidavit also describes 
suspected drug activity occurring at Laura’s Johnsontown Way residence. See id. 
The highlights include the following evidence: Joseph’s use of nominees (often people 
close to him, like Laura), to purchase and hold real estate using cash, id. at 19; Laura strictly using 
cash for her last two known real estate purchases , even though she ha d bank accounts and no 
significant cash transactions based on FinCEN queries were found for Laura, id at 19–20; law 
enforcement previously conducting a controlled delivery of two hundred pounds of marijuana to 
Joseph at this address and $160,000 cash recovered from his vehicle, id. at 20; and detectives PageID #:
<pageID>
- 24 - 
 
observing multiple instances, including in the days leading up to the search, of Reed making “short 
stops” at this residence, including one instance where detectives witnessed Reed load a small 
bag—consistent with a large amount of cash —into his vehicle , drive directly to Laura’s residence, 
stay for approximately two minutes, drive back to his Sea Wave Ct. residence, and then enter his 
residence without the bag, id. 
The Johnsontown Way Warrant, even setting aside the challenged evidence, contained 
sufficient probable cause that Laura and Joseph were conducting drug trafficking and money 
laundering activities at this location and that evidence of these illegal activities would be found at 
the residence, satisfying the nexus requirement established in Gates . See Berry, 565 F.3d at 339; 
United States v. 1978 Cessna Turbo 210, No. 97-6254, 1999 WL 407469, at *6 n.7 (6th Cir. 1999) 
(citing United States v. Four Parcels of Real Prop. in Greene & Tuscaloosa Ctys. in State of Ala., 
941 F.2d 1428, 1440–42 (11th Cir. 1991)) (finding that probable cause existed in part because the 
property was purchased with a large amount of cash). 
4. Nanisinh Way Warrant, [R. 75-3] 
The Nanisinh Way Warrant authorized the search of a vacant residence owned by Joseph. 
[R. 75-3, pp. 4–6, 22]. The affidavit section titled “7104 Nanisinh Way. Louisville Ky. 40258” 
details the investigators’ findings, using electronic surveillance and other investigative tools, 
related to Joseph’s and Little Joe’s alleged drug trafficking, money laundering, and other illegal 
activities that involved the Nanisinh Way property. Id. at 22–23. 
The highlights include detectives observing Joseph and Little Joe coming and going 
frequently from this residence but never staying overnight, and Little Joe taking items to and from 
this residence consistent with packages of marijuana and cash. Id. at 22. On one occasion, 
detectives observed Little Joe arrive at Nanisinh Way with a second male, and the unidentified PageID #:
<pageID>
- 25 - 
 
male walk out of the residence with something hidden under his sweatshirt. Little Joe then later 
carried out a bag from the house, placed it in the car, and left, only to return a few hours later 
carrying the bag inside, and then leaving within a minute wi th nothing. Id. The affidavit also 
describes an instance where Little Joe arrived at the residence empty-handed, left carrying a small 
bag, drove to a barber shop, and the barber was later arrested with ten pounds of marijuana . Id. 
Further, Nanisinh Way is the last place detectives spotted a certain Chevrolet Corvette, suspected 
by detectives to be stolen and part of Joseph’s illegal activities involving the “re-vinning” of stolen 
vehicles.
12 
The Nanisinh Way Warrant, even setting aside the challenged evidence, contained 
sufficient probable cause that Joseph and Little Joe were conducting drug trafficking and stolen-
vehicle re-vinning activities at this location and that evidence of these illegal activities would be 
found at the residence, satisfying the nexus requirement established in Gates. See Berry, 565 F.3d 
at 339; Novak, 814 F. App’x at 1011 (considering officers’ observations of drug buys at a residence 
as evidence supporting criminal activity under the good-faith exception); Gunter, 266 F. App’x at 
419 (“[A] nexus exists between a known drug dealer’s criminal activity and the dealer’s residence 
when some reliable evidence exists connecting the criminal activity with the residence.”). 
5. Pine Lake Dr. Warrant, [R. 75-4] 
The Pine Lake Dr. Warrant authorized the search of Joseph’s and Little Joe’s primary 
residence. [R. 75-4, pp. 4–6, 22]. The residence was owned by co- defendant Elble. Id. at 22. The 
affidavit section titled “8904 Pine Lake Dr. Jeffersontown Ky 40299” details the investigators’ 
findings related to their alleged drug trafficking, money laundering, and other illegal activities that 
involved the Pine Lake Drive residence. Id. at 19–20. 
 
12 See infra pp. 26–27. PageID #:
<pageID>
- 26 - 
 
The highlights include the following evidence: detectives observing Joseph collect ing 
money from suspected narcotics transactions and bringing it straight to this house, id. at 19; Joseph 
meeting with numerous known drug traffickers at this residence, id.; and the seized postal parcels 
containing large amount s of cash that Joseph carried out of t his residence before traveling to 
multiple post office locations to ship them to California, id.; see also id. at 12–15 (postal warrant 
sections). The stolen Chevrolet Corvette was also observed at this location. Id. 
The Pine Lake Dr. Warrant, even setting aside the challenged evidence, contained 
sufficient probable cause that Joseph was using this residence to conduct his alleged drug 
trafficking, money laundering, and stolen-vehicle re-vinning activities and that evidence of these 
illegal activities would be found at the residence, satisfying the nexus requirement established in 
Gates. See Berry, 565 F.3d at 339. 
6. Blankenbaker Access Dr. Units # 134 & 135 Warrant, [R. 75-5] 
The Blankenbaker Access Dr. Warrant authorized the search of two storage units rented by 
Joseph. [R. 75-5, pp. 5–7, 20–22]. The affidavit sections titled “11440 Blankenbaker Access Dr. 
Unit #’s 134 & 135” and “Stolen Vehicles/Fraudulent Titles” detail the investigators’ findings 
related to Joseph’s drug trafficking, money laundering, and stolen-vehicle “re-vinning” activities. 
See id. The highlights include evidence that the paperwork for the storage units traced back to 
Joseph and stated that the property stored there included a n SRT Charger worth $55,000 and a 
Jeep worth $80,000. Id. at 20. Detectives believed Joseph had purchased the vehicles with drug 
trafficking proceeds. Id. at 20. Further, detectives believed that at least one of these vehicles was 
re-vinned and stolen. Id. The affidavit provided extensive evidence of Joseph and his associates 
allegedly re-vinning stolen vehicles to make their titles appear “clean.” Id. at 20–22. This included 
the Corvette that detectives last spotted at the Nanisinh Way residence, and an SRT Charger—the PageID #:
<pageID>
- 27 - 
 
same type of vehicle that Little Joe fled the police in. Id. Detectives believed that there was a “high 
probability that paperwork and Forged Titles” would be found in these units, as well as Joseph’s 
Pine Lake Dr. residence. Id. at 21. As part of the broader scheme, detectives also noted that drug 
traffickers often used storage units like these to store cash proceeds from their drug trafficking. Id. 
at 20; see also Sanders, 106 F.4th at 461–62 (stating that the “averments about an officer’s training 
and experience” is one of the “time-honored markers in our Fourth Amendment jurisprudence”). 
The Blankenbaker Access Dr. Warrant, even setting aside the challenged evidence, 
contained sufficient probable cause that Joseph was using these units to store potentially stolen 
vehicles believed to be purchased with the proceeds of drug trafficking, and that evidence of these 
illegal activities—including cash proceeds, and/or associated paperwork and vehicle titles—would 
be found in the units, satisfying the nexus requirement established in Gates . See Berry, 565 F.3d 
at 339; United States v. Elbe, 774 F.3d 885, 889–90 (6th Cir. 2014) (stating that the “nexus can be 
inferred from the type of crime being investigated, the nature of things to be seized, the extent of 
an opportunity to conceal the evidence elsewhere and the normal inferences that may be drawn as 
to likely hiding places.” (internal quotation marks and citation omitted)); United States v. Burrus, 
No. 2:21- CR-20204-JTF, 2023 WL 4397268, at *8–9 (W.D. Tenn. May 3, 2023), report and 
recommendation adopted, No. 2:21- CR-20204-JTF-1, 2023 WL 4118784 (W.D. Tenn. June 22, 
2023) (finding probable cause to search storage units rented by the defendant because he was tied 
to drug trafficking activities, the storage units were accessed after he told associates to hide 
evidence, and the affiant stated that—based on his experience —drug traffickers often use storage 
units to house drug proceeds, ledgers, financial documents, and other related assets). PageID #:
<pageID>
- 28 - 
 
In sum, D efendants have failed to demonstrate that the warrants, even excluding the 
challenged evidence, lacked sufficient probable cause to search the various properties. 
Accordingly, their Motion for a Franks hearing and related Renewed Motion will be denied. 
IV. CONCLUSION 
Therefore, and the Court being otherwise sufficiently advised, it is HEREBY ORDERED 
as follows: 
1. Defendant Laura Lanham’s Motion to Join, [R. 67], is GRANTED. 
2. The Second Motion to Suppress, [R. 62], is DENIED. 
3. The Renewed Motion, [R. 89], is DENIED. 
This the 14th day of October, 2025. PageID #:
<pageID>

Passage view · GavelSight