Realizing that CORRUPT JUDGE CHRISTOPHER COLLIER is not the brightest bulb in the Medina County Courthouse/Mosque & Railroad Station, Defense Counsel decided to file a SUPPLEMENT TO DEFENDANT'S MOTION TO SUPPRESS, and rightly so.
Defense Counsel decided that CORRUPT JUDGE COLLIER needed unfailingly to understand the controlling case law, which he clearly does not.
Once again, because of the length of the SUPPLEMENT TO DEFENDANT'S MOTION TO SUPPRESS (17 pages), it is not possible to publish the Motion here in its entirety. I will however, as I did in setting forth the principles of the MOTION TO SUPPRESS, set out here the subheadings of the Supplemental Motion.
HERE THEN ARE THE SUBHEADINGS OF THE SUPPLEMENT TO DEFENDANT'S MOTION TO SUPPRESS:
I. THE BURDEN IS ON THE STATE TO DEMONSTRATE THAT A DEFENDANT'S CUSTODIAL STATEMENT WAS MADE KNOWINGLY AND VOLUNTARILY.
II. THE OFFICERS VIOLATED THE DEFENDANT'S RIGHTS WHEN THEY DENIED THE DEFENDANT'S REQUESTS TO SPEAK WITH AN ATTORNEY AND INSTEAD INTERROGATED HIM AFTER HE INVOKED THE RIGHT TO COUNSEL.
III. EVEN IF MIRANDA WARNINGS WERE GIVEN AT THE TIME OF ARREST, THE ALLEGED SUBSEQUENT STATEMENTS, NEVERTHELESS, ARE NOT ADMISSIBLE, BECAUSE THE ARREST WAS ILLEGAL (THE ARREST WAS NOT BASED ON PROBABLE CAUSE).
IV. EVEN IF MIRANDA WARNINGS WERE GIVEN AT THE TIME OF ARREST, THE ALLEGED SUBSEQUENT STATEMENTS MUST BE SUPPRESSED BECAUSE THE DEFENDANT DID NOT UNDERSTAND HIS RIGHTS AND DID NOT WAIVE ANY RIGHTS. THE TOTALITY OF THE CIRCUMSTANCES SHOW THAT FRESH MIRANDA WARNINGS WERE REQUIRED AT THE TIME OF THE INTERROGATION.
(THIS IS THE LEGAL CHALLENGE SALISBURY ATTEMPTED TO EVADE AND AVOID WHEN HE FALSIFIED THE DISCOVERY DOCUMENT, PREVIOUSLY DISPLAYED AT THIS BLOG ON FEBRUARY 4, 2011) and found at http://medinacorruption.blogspot.com/2011/02/collier-applauds-as-salisbury.html
THESE WERE THE ISSUES BRIEFED TO CORRUPT JUDGE COLLIER BY DEFENSE COUNSEL, ALONG WITH THE CONTROLLING CASE LAW.
To do a quick tally, Defense Counsel filed the Motion to Suppress, consisting of 43 pages, and Supplement to Defendant's Motion to Suppress, consisting of 17 pages.
Defense Counsel filed a total of 60 pages, with controlling case law, in support of the suppression of illegally seized and illegally acquired "evidence" by sheriff's deputies.
THE TOTAL OF PAGES FILED BY SALISBURY OPPOSING THE PROPOSITIONS, SUPPORTED BY LAW, OF DEFENDANT'S MOTION TO SUPPRESS: ZERO!
FOLLOWING ARE THE CONTROLLING CASE AUTHORITIES CITED BY DEFENSE COUNSEL IN THE SUPPLEMENT TO DEFENDANT'S MOTION TO SUPPRESS:
Miranda v. Arizona, 384 U.S 346 (1966)
State v. Kassow (1971), 28 Ohio St 2d 141
Lego v. Twommey, 404 U.S. 477, 487-89 (1972)
State v. Arrington (6th App. Dist. 1984), 14 Ohio App. 3d 111, 114
State v. Garcia (9th App. Dist. 1986), 32 Ohio App 3d 38
State v. Gray (1st. App. Dist. 1994), 14 Ohio App. 3d 43
Edwards v. Arizona, 451 U.S. 477 (1981)
Davis v. United States, 512 U.S. 452 (1993)
United States v. Hinckley, 673 F.2d 115 (D.C. Cir 1982)
Lanier v. North Carolina, 474 U.S. 25 (1985)
Brown v. Illinois, 422 U.S. 590 (1975)
Wong Sun v. United States, 371 U.S. 471 (1963)
Taylor v. Alabama, 475 U.S 687 (1982)
State v. Sims, (2nd App. Dist. 1998), 127 Ohio App. 3d 603, 614-16
Kaup v. Texas, 538 U.S. 626 (2003)
Tague v. Louisiana, 444 U.S. 469 (1980)
State v. Lester (1989), 126 Ohio App. 3d 1, 6
Defense Counsel cited to 17 additional controlling case authorities in this Supplement to Defendant's Motion to Suppress, over and above the 19 controlling case authorities cited in the Motion to Suppress.
TOTALLY CORRUPT MEDINA JUDGE CHRISTOPHER COLLIER LIKELY NEVER READ THIS BRIEF, AS WELL, AND HAS FAILED TO YIELD TO THE HOLDINGS OF SUPERIOR COURTS, ALL OF WHICH ARE FAR, FAR SUPERIOR TO THE MEDINA COUNTY COURT OF COMMON PLEAS, INCLUDING THE UNITED STATES SUPREME COURT.
SET OUT BELOW ARE ALL THE CASE AUTHORITIES CITED BY SALISBURY IN OPPOSITION TO THE SUPPLEMENT TO DEFENDANT'S MOTION TO SUPPRESS:
(NONE)
Once again, it is more than obvious that the services of TOTALLY CORRUPT JUDGE CHRISTOPHER COLLIER HAVE BEEN BOUGHT AND PAID FOR BY CORRUPT MEDINA COUNTY PROSECUTOR DINO HOLMAN.
A LAST LOOK AT THE FINAL TALLY:
Briefs filed: Defendant = 2
Salisbury = 0
Pages filed: Defendant = 60
Salisbury = 0
Case cited: Defendant = 36
Salisbury = 0
It is beyond question that SALISBURY, A COMPLETE ZERO, has won the heart and mind of COLLIER who completely ignored controlling case law, including decisions of the UNITED STATES SUPREME COURT.
There is little question that, from the outset, this Defendant was denied a fair trial by COLLIER WHO IS, BEYOND ANY QUESTION TOTALLY CORRUPT, ALL IN HIS OWN SELF-INTEREST. DOES THE TERM "PROSTITUTE" COME TO MIND?
MUCH MORE TO COME ....
No comments:
Post a Comment