NO STATE OF TEXAS IN THE COUNTY COURT LAUREN ELIZABETH DAVIS HOOD COUNTY, TEXAS MOTION TO SUPPRESS PHYSICAL EVIDENCE AND ARREST
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1 NO STATE OF TEXAS IN THE COUNTY COURT vs. AT LAW OF LAUREN ELIZABETH DAVIS HOOD COUNTY, TEXAS MOTION TO SUPPRESS PHYSICAL EVIDENCE AND ARREST TO THE HONORABLE JUDGE OF SAID COURT: Now comes Lauren Elizabeth Davis, Defendant, and files this Motion to Suppress and shows the following: 1. Defendant has been charged with the offense of Possession of Marijuana Under Two (2) Ounces. 2. The actions of the law enforcement agency did illegally search her purse which violated the constitutional and statutory rights of the Defendant under the Fourth, Fifth, Sixth and Fourteenth Amendments to the United States Constitution, Article I, Section 9 of the Texas Constitution, and under Article of the Texas Code of Criminal Procedure. 3. Lauren Elizabeth Davis was arrested without lawful warrant, probable cause or other lawful authority in violation of the rights of Lauren Elizabeth Davis pursuant to the Fourth, Fifth, Sixth, and Fourteenth Amendments to the United States Constitution, Article I, Sections 9, 10 and 19 of the Constitution of the State of Texas. 4. Any statements obtained from Lauren Elizabeth Davis were obtained in violation of Article of the Texas Code of Criminal Procedure and in violation of the rights of Lauren Elizabeth Davis pursuant to the Fourth, Fifth, Sixth, and Fourteenth Amendments to the United States Constitution, Article I, Sections 9, 10 and 19 of the Constitution of the State of Texas.
2 5. Any tangible evidence seized in connection with this case, including but not limited to marijuana was seized without warrant, probable cause or other lawful authority in violation of the rights of Lauren Elizabeth Davis pursuant to the Fourth, Fifth, Sixth, and Fourteenth Amendments to the United States Constitution, Article I, Sections 9, 10 and 19 of the Constitution of the State of Texas. 6. Therefore, Defendant requests that the following matters be suppressed at trial of this cause: a. All physical evidence including, but not limited to, any and all green leafy substances which are alleged to be marijuana, a small plastic baggy which was alleged to contain the leafy substance, a pack of Zig Zag rolling papers, and a glass pipe contained a burnt residue which is alleged to be marijuana seized on or about July 7, 2007, from the Defendant s purse which was located at the Granbury Whataburger by law enforcement officers of the Granbury Police Department. b. All photographs, digital still images and videotaped images taken of the physical evidence and the places or persons searched by law enforcement officers of the Granbury Police Department. c. All testimony of any law enforcement officers, their agents, and all other persons working in connection with such officers and agents, as to the finding of any physical evidence at the scene of the illegal search challenged herein. d. The results of any and all scientific tests or procedures conducted on any item of physical evidence seized under the illegal warrantless search challenged herein. e. All statements, either written or oral of the Defendant, obtained as a result of the illegal warrantless search challenged herein.
3 f. Any other matters that the Court finds should be suppressed upon hearing of this motion. WHEREFORE, PREMISES CONSIDERED, Defendant prays that the Court suppress such matters at trial of this cause, and for such other and further relief in connection therewith that is proper. Respectfully submitted, The Law Offices of Daniel P. Webb 800 Autumn Ridge Dr. Granbury, TX Tel: (817) Fax: (817) By: Daniel P. Webb State Bar No Attorney for Lauren Elizabeth Davis CERTIFICATE OF SERVICE This is to certify that on, a true and correct copy of the above and foregoing document was served on the County Attorney's Office, Hood County,, by hand delivery. Daniel P. Webb
4 ORDER FOR A SETTING On, 2007, the Defendant filed a Motion to Suppress. The Court finds that the party is entitled to a hearing on this matter, and it is THEREFORE ORDERED that a hearing on this motion is set for, at. Signed on. JUDGE PRESIDING
5 NO STATE OF TEXAS IN THE COUNTY COURT vs. AT LAW OF LAUREN ELIZABETH DAVIS HOOD COUNTY, TEXAS O R D E R On, 2007, came on to be considered Lauren Elizabeth Davis's Motion to Suppress, and said motion is hereby (Granted) (Denied) JUDGE PRESIDING
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(THE O-GAH-PAH In re Petition for Change of Name of: Petitioner. PETITION FOR CHANGE OF NAME COMES NOW the Petitioner,, and alleges and states to the Court the following, to wit: 1. That Petitioner,, of