Motion to Suppress

• Due Tuesday by 11:59pm 
• Submitting a text entry box or a file upload
• Jul 29 at 11:59pm

1. Search Warrants Executed at Combs’ Properties:

• In March 2024, federal agents with Homeland Security Investigations (HSI) executed search warrants at Sean “Diddy” Combs’ properties in Los Angeles and Miami.
• The search warrants were related to an ongoing sex trafficking investigation, according to law enforcement sources.
• The warrants were out of the Southern District of New York.
• Combs was in the Miami area when the searches were executed. 

2. Items Seized During the Searches:

• Law enforcement officers seized “three AR-15s with defaced serial numbers, as well as a drum magazine” from Combs’ residences.
• Phones were seized from Combs in Miami before he was scheduled to depart for a trip to the Bahamas. 

3. Legal Challenges to the Searches:

• Combs’ lawyers are challenging the search warrants and aiming to suppress evidence found during the searches.
• They argue that the warrant applications were overbroad, excluded facts that could have been favorable to Combs, and presented a distorted picture of reality. 

4. Search of Combs’ Jail Cell:

• While Combs was in jail, investigators searched his cell as part of a “larger safety and security initiative” at the facility.
• The government claims the search was scheduled before Combs’ arrest and was not targeted at him.
• Items such as a manila folder marked “legal”, a notebook, an address book, and personal effects were found in Combs’ cell.
• Photos were taken of the notebook and address book but were not removed from his cell. 

Instructions:  Apply relevant procedural rules (e.g., Fourth Amendment, Miranda) and draft a draft a motion to suppress evidence, identifying the specific procedural rule violated by the police and arguing why the evidence should be excluded.