Case 8:10-cr-00637-PJM Document 96 Filed 12/06/10 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND

UNITED STATES *
*
v. * Criminal No.: PJM-10-637
*
JOSE MORENO *

MOTION TO SUPPRESS EVIDENCE

Comes now the Defendant herein, Jose Moreno, through undersigned

counsel, and pursuant to the Rule 12(b)(3) of the Federal Rules of Criminal

Procedure requests that this Honorable Court grant Defendant’s Motion and

suppress all evidence obtained by the police in this case. In support of this Motion,

Defendant states as follows:

1. That all potentially incriminating evidence against Defendant in the above

captioned case was obtained as a result of an illegal stop/detention when the

Defendant was stopped by the police and subsequent unlawful search of his person,

automobile and/or belongings, the illegal and unlawful seizures resulting from the

said detention and searches.

2. That the law enforcement officials who stopped/detained Defendant and

conducted the subsequent questioning and searches and seizures acted without

appropriate warrants or probable cause.

3. That any statement taken by police was obtained in violation of the

Defendant’s constitutional rights to counsel, privacy and right against incrimination

under the Fourth, Fifth and Sixth Amendments of the United States Constitution.
 Case 8:10-cr-00637-PJM Document 96 Filed 12/06/10 Page 2 of 3

W HEREFORE, for these reasons and for such other reasons as may be

assigned at the hearing on this motion, Defendant respectfully requests that this

Honorable Court grant Defendant’s Motion and suppress all statements and

evidence obtained by police in this case.

Respectfully submitted,

_____/s/___________________
Michael E. Lawlor
Andrew R. Szekely
Lawlor & Englert, LLC
6305 Ivy Lane
Suite 608
Greenbelt, Maryland 20770
301.474.3404
 Case 8:10-cr-00637-PJM Document 96 Filed 12/06/10 Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on this day, December 6, 2010, a copy of the foregoing
was delivered electronically to the Office of the United States Attorney, 6500
Cherrywood Lane, Suite 400, Greenbelt, MD 20770.

_______/s/_________________
Michael E. Lawlor