Page 70 - Juvenile Practice is not Child's Play

Appendix B. Sample Motions

Sample Motions to Suppress Based on the NJDC Materials

Sample Motion to Suppress

CAUSE NO. 123567

IN THE MATTER OF § IN THE DISTRICT COURT
§
§ XXXth JUDICIAL DISTRICT
§
CLIENT NAME § HARRIS COUNTY, T E X A S

NOTE TO RECIPIENTS: What follows is a draft of a memorandum of law in support of a motion to suppress

a juvenile statement. It is a far from perfect draft, but is meant to provide a framework for such a pleading.
Of course, before using any of the law contained within this motion, the cases should be Shepardized and the
pleading should be edited to incorporate local law.

RESPONDENT’S MOTION TO SUPPRESS EVIDENCE

COMES NOW, the Respondent, F.L., by and through his attorney and respectfully moves the Court to suppress all
physical evidence and all statements or confessions obtained as a result of the arrest of this Defendant, and in support
of said Motion would show the following:

I.
Establish JDX
Respondent, F.L. is a child pursuant to Tex. Fam. Code Ann. § 51.02(b), who was born on the ____ day of

____ A.D. 20____.