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Legal Pleadings

Motions to Suppress Evidence

Motion to Suppress – Bad Stop

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, any written or oral statements by the Defendant, the refusal…

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Motion to Suppress Evidence – Possession of Cocaine

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, by and through her undersigned counsel, pursuant to Rules 3.190(g) and (h), Florida Rules of Criminal Procedure, and respectfully moves the Court to suppress any and all evidence seized and/or obtained from the Defendant, including the officers’ observations of her, evidence recovered from her person and/or…

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Motion to Suppress Evidence – All Evidence Seized & Obtained

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, by and through his undersigned counsel, respectfully moves this Honorable Court to suppress any and all evidence seized and/or obtained from the client, including all items found in his vehicle, any and all written and oral statements made by him, and the observations of the officers,…

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Motion to Suppress Evidence – Controlled Calls

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, by and through his undersigned counsel, pursuant to Rule 3.190(h), Florida Rules of Criminal Procedure, and §§ 934.03 and 934.06, Fla. Stat., and respectfully moves the Court to suppress any and all evidence of the controlled calls made by the alleged victim to the Defendant, and…

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Motion to Suppress Evidence – Statements and Property

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, by and through his undersigned counsel, and, pursuant to Rule 3.190(h), Fla. R. Crim. P., moves this Honorable Court to suppress certain evidence, and any evidence acquired as a result thereof, including statements of the Client, obtained by an unlawful search and seizure, in any criminal…

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Warrant Issued Without Probable Cause

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, by and through his undersigned counsel, and hereby files this Motion to Suppress, and respectfully moves the Court to suppress any and all evidence seized and/or obtained from the residence the Client shares with his wife as a result of the search of the residence conducted…

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Motion to Suppress – Field Sobriety Test

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 Client, including the officers’ observations, the results of the Field Sobriety Exercises (“FSE”), any written or…

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Motion to Supress – Stop and Frisk Law

By Fallgatter Catlin & Varon, P.A.

COMES NOW the defendant, by and through his undersigned counsel, and hereby respectfully moves this Court, pursuant to Rule 3.190(g) of the Florida Rules of Criminal Procedure, to suppress the evidence seized from him, and in support thereof, states as follows: Introduction 1. The client was arrested on November 5,…

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Motion to Reconsider – Child Pornography

By Fallgatter Catlin & Varon, P.A.

MOTION TO RECONSIDER ORDER DENYING DEFENDANT’S MOTION TO SUPPRESS EVIDENCE COMES NOW the Defendant, by and through his undersigned counsel, and, hereby requests this Honorable Court reconsider the Court’s August 30 Order Denying Defendant’s Motion to Suppress Evidence (“Order”), and grant said Motion to Suppress, and in support thereof, hereby…

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Motion to Suppress Digital Media

By Fallgatter Catlin & Varon, P.A.

COMES NOW the Defendant, Client, by and through his undersigned counsel, pursuant to Rules 3.190(g) and (h), Fla. R. Crim. P., and respectfully moves this Honorable Court to enter an order to suppress the below listed evidence, obtained by an unlawful and warrantless search and seizure, and/or as the fruit…

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