Depke and Fregoso also argue that the Steins fail to analyze the facts. Doc. 89 at 12 (citing United States v. Kubbo, 17 Fed.Appx. 543, 545 (9th Cir. 2001)). But Kubbo involved a withdrawal of consent that fell "far short of an unequivocal act or statement of withdrawal" such as in this case, 17 Fed.Appx. at 545, and the Steins do sufficiently analyze the facts that justify Jackie's withdrawal of consent.
Nevertheless, a defendant's withdrawal must be clearly communicated to the searching officers in order to be effective, and “police officers do not act unreasonably by failing to halt their search every time a consenting suspect equivocates.” $304,980.00 in U.S. Currency, 732 F.3d at 820; see also Gray, 369 F.3d at 1026 (“[I]ntent to withdraw consent must be made by unequivocal act or statement.”); United States v. Kubbo, 17 Fed.Appx. 543, 545 (9th Cir.2001) (“Mere reluctance to a continued search, once an explicit and unambiguous statement of consent has been provided, is not necessarily sufficient to imply a withdrawal [of] such consent.”). 31 Applying these standards here, the Court finds that Defendant withdrew her consent prior to the discovery of the ammunition that forms the basis of the government's prosecution.