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Legal Pleadings

Motions to Suppress Evidence

Motion to Exclude Blood Analysis Results

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, by and through the undersigned counsel, pursuant to Fla. R. Crim. P. 3.190(a), and moves this Honorable Court for entry of an Order instructing the prosecutor and any and all state witnesses to refrain from making mention by statement or interrogation, directly or indirectly, in any…

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Motion To Exclude Retrograde

By Fallgatter Catlin & Varon, P.A.

DEFENDANT’S MOTION TO EXCLUDE EVIDENCE OF RETROGRADE EXTRAPOLATION COMES NOW the Defendant, by and through his undersigned attorney, pursuant to §§ 90. 105(1), 90.702, and 90.403, Fla. Stat., and moves in limine to prevent the admission of any testimony, documents and/or other evidence concerning the opinion of witnesses regarding retrograde…

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Motion to Suppress – DUI – Actual Physical Control

By Fallgatter Catlin & Varon, P.A.

MOTION TO SUPPRESS COMES NOW the Defendant, by and through his undersigned attorney, pursuant to Rule 3.190(h), Florida Rules of Criminal Procedure, and respectfully moves this Court to suppress any and all evidence seized and/or obtained from the Defendant, including the officers’ observations, the results of the Field Sobriety Exercises…

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Motion to Suppress – DUI – Recollection of Incident

By Fallgatter Catlin & Varon, P.A.

SUPPLEMENT TO MOTION TO SUPPRESS COMES NOW the Defendant, by and through his undersigned attorney, and provides this Supplement to his previously filed Motion to Suppress, and states as follows: Facts 1. The Defendant was arrested on November 28 for Driving Under the Influence (DUI). Arrest and Booking Report. 2.…

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Motion to Suppress – DUI – Unlawful Detention

By Fallgatter Catlin & Varon, P.A.

MOTION TO SUPPRESS COMES NOW the Defendant, by and through his undersigned attorney, pursuant to Rule 3.190(h), Florida Rules of Criminal Procedure, and respectfully moves this Court to suppress any and all evidence seized and/or obtained from the Defendant, including the officers’ observations, the results of the Field Sobriety Exercises…

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Motion To Suppress – Search and Bad Stop

By Fallgatter Catlin & Varon, P.A.

MOTION TO SUPPRESS COMES NOW the Defendant, by and through his undersigned attorney, pursuant to Rule 3.190(h), Florida Rules of Criminal Procedure, and respectfully moves this Court to suppress any and all evidence seized and/or obtained from the Defendant, including his identity, the officers’ observations, the results of the Field…

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Motion To Supress – Field Sobriety Exercises

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, by and through his undersigned attorney, pursuant to Rule 3.190(h), Florida Rules of Criminal Procedure, and respectfully moves this Court to suppress any and all evidence seized and/or obtained from the Defendant, including the officers’ observations, Deputy G.’s testimony regarding the speed of the defendant’s vehicle,…

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Motion To Suppress – Dog Sniff

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, by and through the undersigned counsel, pursuant to Rules 3.190(h), Florida Rules of Criminal Procedure, and respectfully moves the Court to suppress any and all evidence seized and/or obtained from him, including the firearm recovered from his person and/or the vehicle which he occupied, and any…

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Motion to Suppress Evidence – Traffic Stop

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, pursuant to Rule 3.190(h), Florida Rules of Criminal Procedure, and respectfully moves this Honorable Court to suppress the traffic stop in this case, and any evidence derived therefrom, and in support thereof states as follows: FACTS 1. On May 5, the client was cited with a…

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Motion to Supress Evidence – DUI

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, by and through his undersigned attorney, pursuant to Rule 3.190(h), Florida Rules of Criminal Procedure, and respectfully moves this Court to suppress any and all evidence seized and/or obtained from the client, including the officers’ observations, any written or oral statements, the results of the Implied…

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