STATE OF GEORGIA

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In the Interest of:    | Indictment No. 123456

                       | Judge_______________

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PRELIMINARY MOTION TO SUPPRESS

COMES NOW the child in the above-styled action, and respectfully moves the Court as follows:

1.

Child moves the Court suppress all evidence and statements which were obtained in violation of the Fourth, Fifth or Sixth Amendments of the Untied States Constitution and the Constitution of the State of Georgia.

2.

Since discovery and defense investigations are still incomplete, this motion is being filed in preliminary form. This motion preserves Child’s right to challenge the legality of any search and seizure of evidence the State may introduce against Child at trial.

3.

Child requests the following:

a.) that Child be permitted to supplement this motion when more facts become known;

b.) that the Court hold evidentiary hearings on this motion, when appropriate;

c.) that Child be permitted to file a brief subsequent to any hearing; and

d.) that the Court suppress all evidence obtained in violation of Child’s constitutional and statutory rights.

This______ day of __________, 20