Commonwealth v. Moss
In Commonwealth v. Moss, 14 Va. App. 750, 752, 420 S.E.2d 242, 243 (1992), the Court held that a five-day delay in executing a search warrant was permissible.
Where the evidence reveals ongoing drug activity, there is "no basis for deeming that the circumstances providing probable cause for the search had grown stale by the time the warrant was executed." Id. at 753, 420 S.E.2d at 243.