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Every file read. Every motion drafted. Every deadline watched.

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Summarize a 214-document discovery dump

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arrest-report.pdf bodycam.mp4 scene-01.jpg statement.rtf cctv.webm
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Defendant's Motion to Suppress Evidence

COMES NOW the Defendant, JOHN DOE, by and through undersigned counsel, and pursuant to the Fourth Amendment and Article I, Section 12 of the Florida Constitution, moves to suppress all evidence obtained as a result of his unlawful detention, and states:

1.  The Defendant was stopped for a minor traffic infraction on the date in question.

2.  An officer may not extend a completed traffic stop to conduct a dog sniff absent reasonable suspicion. Rodriguez v. United States, 575 U.S. 348, 350–51 (2015).

3.  The deputy concluded the mission of the stop, then detained the Defendant an additional seven minutes without a lawful basis.

WHEREFORE, the Defendant respectfully requests that this Court suppress all evidence flowing from the unlawful detention.

Respectfully submitted,
/s/ Jordan Reyes
Jordan Reyes, Esq.
Florida Bar No. 100482
Counsel for Defendant

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Police may not prolong a completed stop absent reasonable suspicion. See

Supreme Court of the United States

No. 13–9972

Dennys Rodriguez, Petitioner v. United States

Decided April 21, 2015

“A police stop exceeding the time needed to handle the matter for which the stop was made violates the Constitution's shield against unreasonable seizures.”

Real opinion · Free Law Project

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0:00 / 0:00

What happened in this video?

A sheriff's deputy detains a Walmart shoplifting suspect. She struggles with the officers, is handcuffed, and keeps resisting in the patrol car.

When was she handcuffed?

At officers handcuff her after a visible struggle.

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