Mohammad Mehrmanesh appeals his conviction after jury trial for importing heroin and attempting to possess with intent to distribute heroin in violation of 21 U.S.C. §§ 841(a)(1), (b), 846, 952(a), 960(a)(1), (b) and 18 U.S.C. § 2. After careful consideration of the numerous assertions of error presented, we affirm.
I. BACKGROUND
A. Procedural History
On March 20, 1980 appellant Mohammad Mehrmanesh (hereinafter “Mehrmanesh”), his wife, Patricia, and his brother, Abolfazl, were arrested and charged by complaint with various narcotics offenses. After several pretrial hearings, which resulted in 16 days of excludable delay under the Speedy Trial Act, 18 U.S.C. §§ 8161-3174 (1976 & Supp. Ill 1979), the Government sought and obtained an order permitting additional time within which to file an indictment. A total of 47 days of excludable delay were involved prior to indictment.
On July 9, 1980 a two-count indictment was filed charging the three with the importation of approximately 8.3 pounds of heroin and the attempt to possess with intent to distribute approximately 8.3 pounds of heroin. 21 U.S.C. §§ 841(a)(1), (b), 846, 952(a), 960(a)(1), (b); 18 U.S.C. § 2. Accordingly, there were 64 nonexcludable days between arrest and indictment.
The defendants moved to dismiss the indictment on July 14,1980, alleging violation of the Speedy Trial Act for failure to indict within 30 nonexcludable days after arrest.
See
18 U.S.C. §§ 3161(b), 3162(a)(1), 3163 (1976 & Supp. Ill 1979). The District Court denied the motion and the defendants immediately appealed to this Court. We dismissed the appeal for lack of an appealable order.
See United States
v.
Mehrmanesh,
After a five-day trial before Judge Wesley E. Brown, under a superseding indictment that added the charge of aiding and abetting the listed offenses, the jury acquitted Abolfazl but found Mehrmanesh guilty on both counts. Patricia was acquitted by the court pursuant to a Judgment of Acquittal entered at the close of all the evidence. The court found Mehrmanesh to be a dangerous special drug offender under 21 U.S.C. § 849 and sentenced him on each count to 15 years’ imprisonment and a $25,-000.00 fine.
*826 B. Factual History
On March 12, 1980 an Iranian citizen named Ali Pirani entered the United States through the port of entry at Chicago’s O’Hare International Airport, following a direct flight from Frankfurt, Germany. Pi-rani, who had a California driver’s license, requested a tourist visa valid for forty-five days. As part of his Customs declaration, Pirani indicated that his United States address would be 8414 East Vista, Scottsdale, Arizona, a home then rented and occupied by Mehrmanesh. U.S. Immigration Inspector Michael Goldstein checked Pirani’s hand-carried luggage and found two air waybills. Goldstein became suspicious since the waybills indicated that personal effects were being shipped. People traveling internationally usually pay weight overage charges and carry their personal effects with them to ensure their safe arrival. Both waybills were shipped from Kuwait with the same Post Office box number and telephone number given as the address of origin; however, the names of the shippers were different. One waybill related to a shipment by Pirani to “Mr. Mehrmanesh” at 6615 North Smoketree, Scottsdale, Arizona, a home owned by Mehrmanesh. The other was a shipment to Dudley Johnson at the East Vista address; this shipment was never located. Goldstein made copies of the waybills, granted Pirani a forty-five day visa, and referred the waybills to U.S. Customs.
The suitcase shipped by Pirani arrived in Chicago on March 13, 1980 and was searched while “in bond” before the suitcase had cleared Customs. Customs Inspector Joann Ronkowski, who had received the waybills, opened the suitcase and, after noticing a slight bump in the suitcase lining, cut into the bump. She found inside the lining a light brown powdery substance that tested positive for opium alkaloids. Ronkowski referred the matter to the Drug Enforcement Administration (DEA) and entrusted the suitcase to Special Agent Valentine who transported the suitcase to Phoenix.
In Phoenix DEA agents took the suitcase to a local luggage shop where the lining and the 8.3 pounds of heroin it concealed were removed and a new lining installed. A small sample of heroin was placed beneath the new lining.
The contract carrier for the suitcase, American Airlines, sent a letter on March 14, 1980 to the Smoketree Lane address, notifying the consignee, Mr. Mehrmanesh, that the suitcase had arrived and could be claimed. At approximately 11:00 a. m. on March 20, 1980, Mehrmanesh’s brother, Abolfazl, and adolescent son, Dudley, arrived to claim the suitcase. After about 45 minutes the bag was delivered to Customs inspectors, who, after a cursory inspection, turned the suitcase over to Abolfazl. DEA agents followed Abolfazl, Dudley, the suitcase, and the car containing them out of the airport area as they drove towards Mehrmanesh’s residence at 8414 East Vista. The car stopped once en route when Abolfazl appeared to use a pay phone. About this same time Mehrmanesh received a phone call at the East Vista residence and spoke in Farsi to the caller. After the phone call Abolfazl drove on to the East Vista residence and took the suitcase into the house. About five minutes later Kenneth Uran left the East Vista residence and drove away in his Mercedes. Uran was arrested a few blocks from the house for possession of small amounts of heroin and cocaine.
DEA agents, relying on the above facts, plus informant information that Mohammad Mehrmanesh was engaged in the importation and distribution of large quantities of heroin, obtained a search warrant for the East Vista residence. As agents quietly approached the front door of the residence and were about to knock, the door was opened by Dudley Mehrmanesh. The officers entered the house and kicked in the locked bedroom door where Mehrmanesh was located. They immediately located the suitcase, the contents of which had been removed. The heroin sample had not been touched. In searching the master bedroom, the agents found large quantities of various drugs, drug paraphernalia, and certain documents which indicated Mehrmanesh lived *827 at the East Vista address. The agents also discovered approximately one pound of opium wrapped in gray duct tape in a wall cavity covered by corkboard. After Mehrmanesh was advised of his rights the agents questioned him. He explained that when the suitcase arrived and he opened it he saw a bundle wrapped in gray tape, which he said he knew to be opium. He said he then hid the opium in the wall behind the corkboard. Following the search, Mehrmanesh, his wife, and Abolfazl were arrested and removed. The other people at the residence, including defendant’s mother and sister, Zhara, were allowed to remain at the residence.
At trial the drugs, drug paraphernalia, and other items found during the search of the East Vista house, along with the 8.3 pounds of heroin previously removed from the suitcase, were introduced over objections into evidence. Uran, testifying for the Government, stated that he had obtained drugs, usually heroin, cocaine, or opium, from Mehrmanesh at least ten times during the 18-month period preceding the March 20, 1980 arrest. He also testified that after the arrest Mehrmanesh told him that he did know what was in the suitcase, that he was just doing a favor for a friend, and that he felt he was not guilty. Michael Reedy, who began remodeling Mehrmanesh’s house on Smoketree Lane, testified that he had used heroin from April to December 1980 at Mehrmanesh’s house and that he had negotiated with Mehrmanesh in December 1980 for the purchase of a large quantity of heroin. The court also allowed a DEA agent to testify concerning an incident 5 in 1975 in which Mehrmanesh admitted involvement in smuggling hashish into the United States. Mehrmanesh declined to testify at trial as a result of the court’s ruling that his conviction for the 1975 incident could be used as impeachment. After four days of trial the jury found Mehrmanesh guilty on both counts of the indictment.
II. DISCUSSION
Mehrmanesh raises six , issues on this appeal: (1) whether the District Court erred in refusing to dismiss the indictment for a Speedy Trial Act violation; (2) whether evidence of Mehrmanesh’s prior and subsequent crimes and wrongs were properly admitted under Fed.R.Evid. 404(b); (3) whether the District Court erred in ruling that Mehrmanesh’s 1975 conviction could be used as impeachment if Mehrmanesh testified; (4) whether items seized at the East Vista residence should have been suppressed as the result of an invalid search warrant; (5) whether the charge of aiding and abetting in the indictment was fatally defective; and (6) whether improper remarks by the prosecutor during closing argument prejudiced Mehrmanesh’s right to a fair trial. We dispose of these contentions in order.
A. Speedy Trial Act Claim
Mehrmanesh contends that the District Court erred in denying his motion to dismiss the indictment based on sanctions provided for violations of the Speedy Trial Act, 18 U.S.C. §§ 3161-3174 (1976 & Supp. III 1979).
1
The court found that the sanctions for arrest-to-indictment delay did not apply to this case since Mehrmanesh was arrested before July 1,1980, the effective date of the Act’s sanctions.
See
18 U.S.C. § 3163(c) (Supp. III 1979). There is no dispute that a violation of the Act occurred;
2
the only issue is whether sanctions for the violation apply. Because this case involves an interpretation of the language of the Act, we review the District Court’s determination de
novo. See United States v. Fielding,
*828
Section 3163(c) provides that the sanctions set forth in section 3162 for violations of the Act’s time limits “shall become effective and apply to all cases commenced by arrest or summons, and all informations or indictments filed, on or after July 1, 1980.” 18 U.S.C. § 3163(c) (Supp. Ill 1979). Mehrmanesh was arrested on March 20, 1980 and indicted on July 9, 1980. Thus, Mehrmanesh argues, since the late indictment was filed after July 1, 1980 the sanction of automatic dismissal for arrest-to-indictment delay is applicable here.
3
See United States v. Mehrmanesh,
We do not find, however, the words of section 3163(c) as plain and straightforward as Mehrmanesh insists. Although in statutory construction the language of the statute itself ordinarily is regarded as conclusive,
Bread Political Action Committee v. FEC,
Unfortunately, however, this is a case in which the legislative history as well as the statutory language provides no express answer.
See Abramson,
Judicial construction of the sanctions as they went into effect temporarily on July 1, 1979
5
was not altogether explicit. Although the courts that addressed the issue seemed to agree that the original language of section 3163(c) did not make the sanctions applicable to cases in which indictments were filed before July 1, 1979, those courts left uncértain the applicability of the sanctions to cases in which only the arrest occurred before July 1, 1979.
See United States v. Addison,
In our view the construction of the amended section 3163(c) advanced by the Government is the only one that gives meaning to all words of the section and accords with the structure and purposes of the Act: Sanctions for an arrest-to-indictment delay apply only when the arrest takes place or the summons is served on or after July 1, 1980; sanctions for an indictment-to-trial delay apply only when the indictment or information is filed on or after July 1, 1980 (and even if the arrest or summons was before July 1, 1980). 7
In so construing section 3163(c) we are guided by the statutory scheme of the Speedy Trial Act, which recognizes two separate stages, and corresponding time periods, in the criminal trial process. See 18 U.S.C. §§ 3161(b), (c), 3162(a), (b), 3163(c). We infer from the language of the section a legislative recognition of this dichotomy. Section 3163(c), more specific than the language of the original section, manifests a legislative intent that sanctions would not apply to every case pending on July 1,1980 that involved a Speedy Trial Act violation. The amended language represents a judgment that the sanctions would apply in some cases only when the arrest or summons occurred on or after July 1,1980 — i.e., those cases involving an arrest-to-indictment delay. 8
We cannot accept a construction, such as that advanced by Mehrmanesh, that is guided by only a single phrase within the subsection.
See Philbrook v. Glodgett,
*830
In our view the construction we have placed on section 3163(c) most accurately reflects the intent of Congress, is most consistent with the structure of the Act, and most fully serves the purposes of the statute.
See Abramson,
B. Other Acts Evidence
Mehrmanesh next contends that the District Court erred in admitting evidence of his prior and subsequent crimes and wrongs under Federal Rule of Evidence 404(b) and that the cumulative effect of this evidence denied him a fair trial. We find no reversible error in the District Court’s admission and the prosecutor’s use of the other acts evidence.
Rule 404(b) forbids admission of evidence of a person’s other crimes, wrongs, or acts “to prove the character of a person in order to show that he acted in conformity therewith.” Such evidence “may, however, be admissible for other purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.” Fed.R.Evid. 404(b). We have uniformly recognized that the rule is one of inclusion and that other acts evidence is admissible whenever relevant to an issue other than the defendant’s criminal propensity.
See United States
v.
Green,
The Government, however, must carry the burden of showing how the proffered evidence is relevant to one or more issues in the case; specifically, it must articulate precisely the evidential hypothesis by which a fact of consequence may be inferred from the other acts evidence.
United States v. Hernandez-Miranda,
We now apply these settled principles to the four categories of other acts evidence admitted against Mehrmanesh: (1) evidence of hashish smuggling, for which he was convicted, in 1975; (2) evidence of his use of narcotics; (3) evidence of his prior and subsequent sales of narcotics; and (4) evidence of his possession of narcotics at the time of arrest.
1. The 1975 hashish smuggling incident
The Government sought, successfully, to introduce evidence that in June 1975 Mehrmanesh possessed packets of hashish that had been smuggled into the United States, for which Mehrmanesh pleaded guilty to a charge of smuggling under 18 U.S.C. § 545.
9
Although the
*831
Government consistently has maintained that such evidence is relevant to motive, opportunity, intent, preparation, plan, knowledge, and absence of mistake or accident, nowhere has it specifically established which facts such evidence is relevant. to show, nor has it articulated the hypotheses by which the jury could infer such facts from the proffered evidence.
See, e.g., Hernandez-Miranda,
Nevertheless, prior cases in this Circuit compel us to conclude that there is at least some logical connection, however weak, to a central element of this case: whether Mehrmanesh knew that the suitcase from Kuwait contained heroin. In
United States v. Sinn,
United States v. Hernandez-Miranda,
The record shows that Judge Muecke, in pretrial proceedings, undertook a careful and considered balancing of the probative value of the 1975 incident and the potential for unfair prejudice to the defendant.
See
Reporter’s Transcript [R.T.] at 701-12. At trial Judge Brown gave careful limiting instructions to the jury to minimize the prejudicial impact to- the defendant.
See
R.T. at 1200, 1861. On this record we cannot say that the court abused its discretion in admitting evidence of the 1975 incident.
See Sangrey,
2. Use of narcotics
Although in pretrial rulings the court held inadmissible drug use paraphernalia seized at Mehrmanesh’s residence, see R.T. at 704, 707-09, at trial Judge Brown admitted over objections testimony concerning Mehrmanesh’s use of cocaine, see R.T. at 1525-27, 1547. On appeal the Government contends generally that this testimony is relevant to show intent, knowledge, motive, opportunity, and absence of mistake or accident. See Brief of Appellee at 22. Again, however, it has not, before this Court or the trial court, articulated precisely the hypothesis by which one or more consequential facts can be inferred from this evidence.
Our decision in
United States v. Masters,
Because the error in admission of this evidence amounted only to a violation of an evidentiary rule,
see United States v. Valle-Valdez,
On our review of the entire record, we find that the amount of evidence of cocaine use was relatively small,
see
R.T. at 1525-27, 1547; the prosecution made only two brief references to Mehrmanesh’s drug use at closing argument,
see
R.T. at 1819, 1847; the jury was cautioned carefully by both the court and the prosecution about the limited inferences they could draw from such testimony,
see
R.T. at 1822, 1834, 1849, 1861-62;
12
and, most importantly, the direct and circumstantial evidence against Mehrmanesh was quite strong, if not overwhelming.
See Hernandez-Miranda,
3. Possession and sale of narcotics
Finally, Mehrmanesh contends that the admission of (1) large quantities of other drugs seized at his home when he was arrested and (2) testimony regarding his numerous sales of heroin and cocaine before and after the arrest was error that denied him of a fair trial.
We have consistently held that evidence of a defendant’s prior possession or sale of narcotics is relevant under Rule 404(b) to issues of intent, knowledge, motive, opportunity, and absence of mistake or accident in prosecutions for possession of, importation of, and intent to distribute narcotics.
See Sinn,
Mehrmanesh’s reliance on
United States
v.
Powell,
Further, as we noted above, both the trial court and counsel carefully cautioned the jury throughout the trial as to the proper use of this other acts evidence. See R.T. at 1374-75, 1822, 1849, 1861-62. The record shows that the court in pretrial proceedings carefully balanced the potential for prejudice and the probative value of the drugs seized. See R.T. at 701-02. On this record *833 we cannot say the trial court abused its discretion in admitting evidence of Mehrmanesh’s possession and sales of narcotics.
C. Evidence of Prior Conviction as Impeachment
Mehrmanesh contends that the District Court erroneously held the 1975 hashish conviction admissible for impeachment purposes under Fed.R.Evid. 609, thus preventing him from testifying and denying him a fair trial.
See United States v. Cook,
The Government argues that Mehrmanesh’s 1975 smuggling conviction was automatically admissible under Fed.R. Evid. 609(a)(2) as a crime that “involved dishonesty or false statement.” We have recognized that Congress intended to limit Rule 609(a)(2) to those crimes that involve some element of misrepresentation or other “indicium of a propensity to lie and excluding those crimes which, bad though they are, do not carry with them a tinge of falsification.”
United States v. Ortega,
We conclude that Mehrmanesh’s prior conviction for smuggling or clandestinely introducing into the United States merchandise (hashish) in violation of 18 U.S.C. § 545 does not fall within the scope of Rule 609(a)(2). One is guilty of smuggling under 18 U.S.C. § 545 when he or she employs any method of introducing goods into this country surreptitiously with the intent to avoid and defeat United States customs laws.
See United States v. Kurfess,
The Government, moreover, did not present any facts demonstrating that this particular conviction actually involved fraud or deceit, such as false statements on customs forms.
See Glenn,
Evidence of Mehrmanesh’s prior conviction was admissible to attack his credibility, therefore, only if the District Court determined that the probative value of admitting the conviction outweighed its prejudicial ef
*834
feet to the defendant. Fed.R.Evid. 609(a)(1).
See United States v. Field,
It is evident from the transcript, however, that the District Court failed to undertake a balancing of the probative value and prejudicial effect as required by Rule 609(a)(1). The pertinent colloquy between defense counsel and the court
15
reveals no consideration of the factors that bear on the probative value of the conviction to the defendant’s
credibility
— e.g., the age of the prior conviction and to what degree it reflected on veracity — or on the prejudicial effect of the conviction to a fair determination of the defendant’s
case
— e.g., the similarity of the prior conviction to the current charge.
See Field,
Although the abuse of discretion standard is applied to review a District Court’s probative value/prejudicial effect determination under Rule 609(a)(1),
see Field,
D. Other Contentions
Mehrmanesh’s other contentions merit only brief discussion. First, the warrant that authorized the search of Mehrmanesh’s house was supported by a sufficient affidavit and was not impermissibly over-broad. We find no error in the magistrate’s conclusion that the affidavit established probable cause to believe that Mehrmanesh’s house would contain, besides the incriminating suitcase, “a scale, cutting agent[,] narcotics packaging equipment, passports and other documents relating to travel and shipping, and any indicia of ownership and control of the premises.” Opening Brief of Appellant at 29 n.8 (quoting the Warrant Language). Considering “the type of crime [here the importation of 8.3 pounds of heroin in a suitcase from Kuwait], the nature of the missing items, the extent of the suspect’s opportunity for concealment, and normal inferences as to where a criminal would be likely to hide [incriminating] property,”
United States v. Spearman,
Mehrmanesh’s contention that the indictment was fatally defective because it did not name the principal whom he was charged with aiding and abetting also is without merit. Although the failure of an indictment to detail each element of the charged offense generally constitutes a fatal defect,
United States v. King,
Finally, we reject the claim that the prosecutor made improper remarks in closing argument that caused incurable prejudice to Mehrmanesh. The record does not support the contention that the prosecutor commented improperly on the Rule 404(b) prior acts evidence.
See
Part 11(B)
supra.
Although the prosecutor’s remark concerning the absence of certain explanations by Mehrmanesh after his arrest was improper under
Doyle v. Ohio,
The judgment of conviction is
AFFIRMED.
Notes
. This issue previously was raised, but not decided, in an interlocutory appeal to this Court.
See United States v. Mehrmanesh,
. Section 3162(a)(1) provides for the automatic dismissal of a charge in any indictment or information not filed within 30 days from the date of arrest or service with summons. See 18 U.S.C. § 3161(b) (1976). Mehrmanesh contends, and the Government does not disagree, that 64 days of this 111-day period constituted nonexcludable delay. See Appellant’s Opening Brief at 3, 14.
. Mehrmanesh does not contend that the arrest-to-indictment delay violated his Sixth Amendment speedy trial right or the district’s Plan for Prompt Disposition of Criminal Cases.
See United States v. Fielding,
. The Senate bill originally had provided for deferring the sanctions two years until July 1, 1981; the House voted to defer the sanctions only until July 1, 1980. See H.R.Rep.No.96-390, 96th Cong., 1st Sess. 8-9, reprinted in 1979 U.S.Code Cong. & Ad.News 812-13.
. The 1979 amendments were not signed into law until August 2, 1979, thus creating a period of slightly more than a month in which the sanctions were in effect under the terms of the original Act.
See
Speedy Trial Act Amendments Act of 1979, Pub.L.No.96-43, 93 Stat. 327, 332 (1979);
Fielding,
. Senator Biden interpreted the original language of section 3163(c) in yet another way: sanctions could apply to late indictments when the arrest or summons occurred before July 1, 1979, but only when the indictment was filed more than 30 days after July 1, 1979; sanctions could apply to late trials when the indictment was filed before July 1, 1979, but only when the trial began more than 60 days after July 1, 1979. See 125 Cong.Rec. S8011 (daily ed. June 19, 1979) (statement of Sen. Biden).
. This construction also is recommended in guidelines prepared by the Judicial Conference of the United States which, although not binding on this Court, we find persüasive. See Committee on the Administration of the Criminal Law, Judicial Conference of the United States, Guidelines to the Administration of the Speedy Trial Act of 1974 As Amended 66-67 (December 1979 revision).
.
But cf. United States v. Mack,
. In a pretrial ruling the court held admissible the facts of the incident but ruled that the fact of conviction could not be used in the Government’s case-in-chief. See Reporter’s Transcript [R.T.] at 711 12.
. In view of our conclusion, the fact of Mehrmanesh’s conviction for the 1975 incident was admissible as well under Rule 404(b).
See Sigal,
. The prosecutor explained to the jury in closing argument that “because Mohammad Mehrmanesh uses drugs he has a motive to get the drugs into the country so he can use them.” See R.T. at 1847.
. At one point in closing argument the prosecutor cautioned the jury to “[u]se that information [about defendant’s other acts] to show you what was going on in their heads on March 20th and a few days prior to March 20, 1980.” R.T. at 1849.
. Many Circuits, including the Ninth, have recognized that when a prior conviction by its definition is neither clearly covered nor clearly excluded by Rule 609(a)(2), the prosecution may invoke the automatic admissibility provision by demonstrating that a particular prior conviction rested on facts warranting the dishonesty or false statement description.
See Glenn,
. This holding is consistent with our conclusions in previous cases that “prior narcotics convictions” (not specified in the opinions) were not within the scope of Rule 609(a)(2).
See United States v. Tercero,
. MR. PICCARRETA [for the defendant]: I only wanted — not in regard to what we just talked about — Mr. Storrs earlier in the court ruled if any defendants testified, all the 404(b) materials they would be allowed to cross-examine on. Presumably the Court’s order includes if Mr. Mehrmanesh testified he could be impeached by his 1975 smuggling conviction, if that is included in the order, and the only thing I would—
THE COURT: (Interposing.) Well, his course of conduct, including the 1975 deal, that goes back enough, yes. You are not going to hide that from somebody who is in ■ the business. Sure, it could be used.
MR. PICCARRETA: I am not going to reargue, but I am required by law to just say that he is not going to testify under those rulings. If he would testify he would just testify as to
the March 20th transaction that he had no knowledge that the suitcase contained heroin. Ali Pirani shipped the suitcase. He picked it up as a favor.
Some of that evidence came in through Mr. Uran but I am required by law to make a proffer to the Court in relationship to the suitcase. It would be that he had no knowledge of the contents.
THE COURT: Fine. That is fine. It goes back to what I am saying. They want to come on and only testify as to what they want to testify. They don’t want to have anything brought up that would tend to show motive or experience or knowledge of how to do it for which they were admitted to do it. They want all of those things kept out. I don’t think they can be kept out.
R.T. at 1746-47.
. The DEA agent stated in the affidavit that
[i]t has been my experience, and the experience of other Special Agents of the DEA, that where narcotics traffickers are “cutting” or diluting controlled substances, they will frequently have a scale to weigh the narcotics and the diluents [sic] to insure the proper mixture. They will also have with them “cutting” agents to dilute the narcotics thereby increasing the volume the narcotics while decreasing the purity. Once the narcotics have been “cut,” they are frequently then placed in the narcotics packaging materials or equipment which the narcotics traffickers will keep on hand. It has also been my experience and the experience of other DEA agents that individuals or aliens lawfully travelling in this country will often possess and carry with them passports, visas, and other documents necessary for their lawful travel in the United States. Individuals who are shipping materials will often carry with them shipping invoices, receipts or other documents relating to the items being shipped. Additionally, it has been my experience and the experience of other DEA agents in searching residences and apartments that the persons occupying or controlling the premises will keep with them indicia of ownership and control of the premises such as phone records, rent receipts, and other miscellaneous records.
Opening Brief of Appellant -at 29 n.8 (quoting the affidavit).