Motion to Exclude Police Testimony About How Drug Deals Happen, the Behavior of Drug Traffickers, Quantities of Drugs that Indicate Distribution, and the Relationship Between Firearms and Drug Trafficking

This motion relies on the Federal Rules of Evidence to argue for exclusion of police testimony about the behavior of drug traffickers. Pages 13-14 rely on social science to argue that users of fentanyl, methamphetamine, and cocaine consume large quantities of each of those drugs daily to support their habit such that courts cannot infer distribution from larger amounts. Pages 15-16 collect national data to refute the suggestion that drug traffickers typically possess firearms.