Tuesday, July 29, 2008

Conclusion

X. Conclusion

For the reasons stated more fully above, Pennsylvania law controls analysis of the search warrant of the defendant’s residence because Pennsylvania law enforcement was involved in the issuance and execution of the warrant and Pennsylvania has the greater interest in the outcome, Pennsylvania warrant procedure was not followed and therefore the evidence should be suppressed. However, if this Court ultimately concludes that Virginia law controls, suppression is still warranted because Virginia procedure was not followed The defendants request preclusion of any evidence, references to or argument regarding all fruits of the search warrant.


Respectfully Submitted,

Shelly L. Centini, Esq.
Attorney for Defendant Kerekes

John Pike, Esq.
Attorney for Defendant Kerekes

Steven Menn, Esq.
Attorney for Defendant Cuadra

Michael B. Senape, Esq.
Attorney for Defendant Cuadra