STATE OF GEORGIA

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In the Interest of:    | Case number 123456

                       | Judge_______________

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MOTION TO SUPPRESS ORAL STATEMENT

NOW COMES the Child and requests that an Order be entered suppressing any oral statements made by him and as grounds for the Motion, shows that:

1.

On or about _____________, the Child was arrested and detained at the Gwinnett County Police Department, Gwinnett County, Georgia.

2.

The detention and arrest on ____________ was for ________________. Neither at the time of the arrest, nor ar any time thereafter, was the Child advised of his Miranda Rights.

3.

The Child has related to counsel that he recalls making certain statements to officers of the Gwinnett County Police Department. Since no Miranda warnings were given to Child, these statements are not admissible for use as part of the State’s case. Hence, the Child will be deprived of his rights to a fair and impartial trial if any oral statements which the Child may have made are introduced in evidence against the Child.

4.

That on or about__________, a secretive and clandestine videotaped statement of the Child was taken by ___________, Gwinnett County Police Department, at the Gwinnett County Police Department, Gwinnett County, Georgia.

5.

In that oral statements and confessions are extremely suspect, the Child moves the Court to conduct a pre-trial examination into the facts and circumstances surrounding the alleged crime and to make a determination of the admissibility of said oral statements or confessions.

6.

Said determination cannot reasonably be delayed until time of trial because evidence of such statements would cause extremely prejudicial effect on the Child. Therefore, the Child requests that a pre-trial hearing be had and at such time as would permit defense counsel to properly prepare for trial on the basis of any oral statements made by this Child which the Court may find to be admissible.

WHEREFORE, the Child prays that the Court issue an Order for a pre-trial hearing by the court on the matter of the Motion to Suppress any oral statement and that all statements be suppresses and not allowed into evidence.