SMITH & SMITH

Law Office
11223 Lawyer Street
Hammonton, NJ 08037
(609) 567-1235
Fax:(609) 567-1897
Attorney for defendant File No. 1003883730
STATE OF NEW JERSEY, SUPERIOR COURT OF NEW
: JERSEY
: CRIMINAL DIVISION
: CUMBERLAND COUNTY
Plaintiff :

: Indictment Number: 05-01-00027

: I/A
v. :

JOHN DOE Criminal Action

:
Defendant : NOTICE OF MOTION TO
SUPPRESS EVIDENCE
______________________________ :

TO: Stephen Mystic; Deputy Prosecutor

18623 Lowly Way
East State, NJ 47645

Please take notice that SAMSON S. SMITH, attorney for above named
defendant, will present a Motion to Suppress Evidence to the Honorable Judge
Lefty in this matter, on Wednesday March 25 ,2020 or as soon after that time the
motion could be heard, at the courthouse Criminal Division 1767 Criminal Drive,
East State, NJ.

Proposed method of Hearing: The motion will be conducted as an oral hearing.

Purpose for Motion: To suppress said evidence found from illegal search and
seizure.

Grounds for Motion:

In Pursuant of:

U.S. Const. amend. XIV, § 2

U.S. Const. amend. IV

NJ Court Rule 3:5-7

1. John Doe was arrested inside of Thirsty Lounge, located at 2316 Oak Way.
2. John Doe’s secured vehicle was parked in the parking lot owned and operated
by Thirsty Lounge.
3. Said defendant did not give permission for any search or seizure to take place
on his car, home, or any other property owned by him.
4. New Jersey State police did not have required court ordered search warrant
giving permission to search defendant’s vehicle or any other property owned by
defendant outside of his person.
5. NJ Court Rule 3:5-7 gives said defendant allowance to challenge submission of
evidence obtained through illegal search and seizure.

Dated: March 8,2020 ____Samson Smith_________________________

SAMSON S. SMITH
Attorney for Defendant
Constitute, CONSTITUTE,
https://www.constituteproject.org/constitution/United_States_of_America_1992
(last visited Mar 15, 2020).

New Jersey Law, Findlaw, https://statelaws.findlaw.com/new-jersey-law.html (last

visited Mar 15, 2020).

“U.S. Constitution - Amendment 4 - The U.S. Constitution Online.” Amendment 4

- The U.S. Constitution Online - USConstitution.net, 3AD,
www.usconstitution.net/xconst_Am4.html.