in january 2009, day one of bitcoin. there was satoshi, hal finney and atleast 1 other person mining. so even if funds from day 1 moved. its still only atmost 33% chance it was satoshi.
under 33% proves nothing

withing days weeks more people mined. so the odds of an address mined on those days becomes less and less.
by december 2009 the odds were well under 5% that an address holding funds mined in december belonged to satoshi