Alexandrapolous v. United States

observing that admissions against penal interest have been held sufficient to establish probable cause for search warrant | finding admissible a letter from Honduran Navy attached to certification from United States Embassy in Honduras | requiring, however, that there be other indicia of reliability surrounding the statement to make it relevant to rebut the charges of fabrication | considering the defendant charged “with aiding and abetting [another] in knowingly receiving and possessing illegal machine guns in violation of 18 U.S.C. § 2 and 26 U.S.C. § 5861(c)” | noting courts’ refusals “to treat a bill of par ticulars as a general investigative tool for the defense, or as a device to compel disclosure of the government’s evidence or its legal theory prior to trial” | Court dismisses facial challenge to 46 U.S.C.App. § 1901 et seq. and refers to history of judicial acceptance of 21 U.S.C. § 955a(a) | “[T]elephone records are clearly included under this rule as discoverable objects to which defendants are entitled.” | defendant provided with discovery of affidavits submitted in support of wiretap application to permit him to challenge validity of wiretap order