In People v. Hollman, 79 NY2d 181, 590 N.E.2d 204, 581 N.Y.S.2d 619 (1992), the Court of Appeals refined the first two levels of inquiry, holding that general, non-accusatory questions or requests for information qualified as level one inquiries but that more pointed, accusatory questions pinpointing possible criminality rise to level two. A request for information is a general, nonthreatening encounter in which an individual is approached for an articulable reason and asked briefly about his or her identity, destination, or reason for being in the area ... Once the police officer's questions become extended and accusatory and the officer's inquiry focuses on the possible criminality of the person approached, this is not a simple request for information. Where the person approached from the content of the officer's questions might reasonably believe that he or she is suspected of some wrongdoing, the officer is no longer merely asking for information. The encounter has become a common-law inquiry that must be supported by founded suspicion that criminality is afoot. Id. at 191. The Court of Appeals held that the contents of a bag searched by the police pursuant to a consent search should have been suppressed. The court held that although the defendant's furtive behavior may have triggered the first stage of People v. DeBour - the right to approach a defendant and ask rudimentary questions, such as identity and address - it was "certainly not so suspicious as to warrant the further intrusion of a request to rummage through defendant's luggage". As the Hollman court stated: "No matter how calm the tone of narcotics officers may be, or how polite their phrasing, a request to search a bag is intrusive and intimidating and would cause reasonable people to believe that they were suspected of criminal conduct. These factors take the encounter past a simple request for information." (Id. at 191-192.)