No. 000000
THE STATE OF TEXAS§IN THE DISTRICT COURT OF
§
vs.§HARRIS COUNTY, TEXAS
§
JEAN VALJEAN§999th JUDICIAL DISTRICT
MOTION TO SUPPRESS EVIDENCE
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES JEAN VALJEAN, Defendant herein, and files his Motion to Suppress Evidence, and moves the Court to suppress any and all evidence seized as a result of an illegal search and seizure, and requests a hearing, and would show unto the Court the following:
I.
Defendant was arrested without a warrant in violation of Chapter 14, Texas Code of Criminal Procedure, and items alleged to be controlled substances were seized.
II.
The admission into evidence of the fruits the search of Defendant's person and automobile would violate Tex. Code Crim. Pro. Ann. art. 38.23.
WHEREFORE, PREMISES CONSIDERED, Defendant prays that the Court hold a hearing on this Motion and at the conclusion of same, grant this Motion and enter an order suppressing any evidence seized or obtained as a result of the arrest and search of Defendant.
Respectfully submitted,
______
Daniel Webster
Attorney for Defendant
SBN 99999999
1234 Main Street
Clutch City, Texas 77002
(713) 228-1111
FAX (713) 228-2222
CERETIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing Motion to Suppress was hand-delivered to the District Attorney’s Office on this the _____ day of
______, 2003.
______
Daniel Webster
No. 000000
THE STATE OF TEXAS§IN THE DISTRICT COURT OF
§
vs.§HARRIS COUNTY, TEXAS
§
JEAN VALJEAN§999th JUDICIAL DISTRICT
ORDER ON MOTION TO SUPPRESS EVIDENCE
Upon the foregoing Motion to Suppress Evidence, it is hereby
ORDERED that such Motion is in all things GRANTED; and it is further
ORDERED that substances alleged to be controlled substances as described in such Motion are hereby suppressed. It is further
ORDERED that the attorney for the State not mention, refer to or attempt to elicit any evidence of such controlled substances in the trial of this case.
SIGNED this ______day of ______, 2003.
______