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You are a paralegal at a defense attorney's office. She asks you to draft a Motion to Suppress and has provided the following summary of

You are a paralegal at a defense attorney's office. She asks you to draft a Motion to Suppress and has provided the following summary of events, taken from the police reports and the client's statements. Please refer to the sample motions supplied in the class materials section for proper format. You may also want to review the Jones and Ross cases we discussed in class. The assignment will be graded on the following criteria: 1. Overall appearance, including formatting. Legal work must look professional. 2. Grammar, spelling, and lack of typos. Small errors reflect a lack of diligence. 3. Persuasiveness of the argument. 4. The motion should contain all of the proper parts (i.e. the four parts of a motion). 5. You should include a few cites to cases that we reviewed, or other cases if you would like. Try to follow the proper citation form, although I realize not all of you have completed a class in legal research and writing. When in doubt, do what attorneys do simply base your citation on a similar citation. 6. Attention to facts and detail. Usually, each fact is important and can impact the outcome of the case.

Summary of Events: The client, Donny Defendant, is standing out on a street in downtown Georgetown, Delaware, when he notices four uniformed police officers in two marked police cruisers. They do not put on the lights or sound the siren, but they drive by Donny several times, staring at him.

After driving by Donny several times, one of the police cars stops and the officers get out. They start walking toward Donny but they don't say anything. Donny starts to walk away slowly and the police officers start to say "excuse me, do you have a second to talk with us." Donny walks about a block with the police officers walking behind him, while continuing to repeat their request. When he gets to the end of the block the other police car stops in the street directly in front of him, blocking his path. The two officers in that car jump out and yell "hold up for a second, we just want to ask you a few questions." Donny turns and runs, throwing a small bag into some bushes. The police officers chase him and eventually grab him. Of course, the bag that Donny threw contains cocaine. The police reports indicate the police had received an anonymous 911 call informing the police that a suspicious woman was selling drugs in the same location as where Donny was found. It turns out that the police merely wanted to question Donny about whether he saw the suspicious woman and that they had no intention of arresting him until he fled.

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