affidavits for search warrants indicated probable cause of ongoing criminal enterprises, of a wide variety. See generally 2 Wayne R. LaFave, Search & Seisure § 8."T(a), 344-46 nn. 17-26 (3d ed.1996) (illegal paramilitary operations, gambling operations, ongoing fraud or loansharking operations, ongoing processing or repeated sales of drugs, liquor, or guns, repeated thefts or receipt of stolen property). Especially with regard to illegal drugs, probable cause of ongoing sales and production has been expressly distinguished from probable cause of mere use. Compare Andresen, ("The observation of half-smoked marijuana cigarette in an ashtray at a cocktail party may well be stale the day after the cleaning lady has been in .. ..") with United States v. Hyde, 574 F.2d 856 (5th Cir.1978) (<HOLDING>) In light of the nature of the manufacturing or
holding probable cause and exigent circumstances justified warrantless search of automobile where officers received information from an informant that defendants would be traveling in a vehicle containing illegal drugs and due to the lateness of the hour it would have been impractical to get a search warrant holding that executing officers reasonably relied on judges determination that there was probable cause to search motel room for evidence of drug activity even though search warrant affidavit failed to mention a connection between motel room and criminal activity holding that in light of hj inc s special emphasis on the sheer duration of criminal activity  we conclude that activity continuing as alleged here for a period of ten years must be considered to have extended over a substantial period of time hence to constitute long term conduct meeting the pattern requirement holding warrant valid where search warrant application affidavit was signed and probable cause existed for issuance of warrant holding in context of widespread and continuing conspiracy to smuggle drugs the upshot of this rule to practical application has been to allow fairly long periods of time to elapse between information and search warrant of criminal activity