isfied its "gatekeeping function"); United States v. Herrera-Osornio, 521 F. App'x 582, 586 (9th Cir. 2013) (unpublished) ("dog sniffs do not necessarily trigger . . . the district court to conduct a reliability inquiry under Daubert"; finding dog-sniff evidence reliable based on defendant's "ample opportunity to subject the dog's handler to voir dire and cross-examination"); United States v. Almeida, No. 2:11-CR-127, 2012 WL 75751, at *11 (D. Me. Jan. 9, 2012), report and recommendation adopted, No. 2:11-CR-127, 2012 WL 948457 (D. Me. Mar. 20, 2012), aff'd, 748 F.3d 41 (1st Cir. 2014) (defendant failed to present authority for idea that government must present Daubert-type evidence to establish scientific reliability of drug-sniffing training; "courts generally have rejected the proposition that a Daubert-type scrutiny is appropriate in these circumstances and/or have held that evidence of a drug detection dog's training and certification establishes its reliability" (citing cases)); United States v. Adler, No. 8:08CR354, 2008 WL 4816555, at *1 (D. Neb. Nov. 3, 2008) (Gossett, M.J.) (denying defendant's request for Daubert hearing challenging use of dog-sniff evidence because "the use of drug detection dogs has been established as scientifically reliable," and reliability of drug-detection dog would be "deemed merged into the defendant's Motion to Suppress"). -------- IT IS ORDERED: