Defendant was arrested after a police surveillance team observed him make several exchanges of glassine envelopes for cash. On occasion, defendant was observed to retrieve a brown paper bag which was secreted, alternatively, in leaves or in a garbage can within 10 feet of his location. One of the purchasers was arrested in his car moments after a sale, and two glassine envelopes containing heroin were recovered. A backup team then arrested defendant. The brown bag was not...
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