S.D.Ga.: Motion to suppress wasn’t timely and discovery wasn’t that complicated; but he’d lose on standing or merits anyway

Defendant’s motion to suppress wasn’t timely, and he had plenty of time to get it filed and didn’t give an excuse or even mention it being late. “Large volumes of discovery can indeed constitute good cause for addressing a motion’s merits despite its untimeliness. … But nothing of the sort exists here. The Government represented — and defense counsel did not contest — that it produced a relatively small number of documents, and it estimated the video footage to last approximately 1.5 hours, not 3 to 4. In actuality, the videos total less than one hour.” But, “[e]ven if untimeliness is excused, Moss has not shown that he had the requisite privacy interest in the vehicle which he occupied to contest the constitutionality of the police entry or search of that vehicle.” “Untimeliness and standing issues aside, the entirety of the circumstances establishes that the officers committed no Fourth Amendment violation at all, much less one that aggrieved Moss.” United States v. Moss, 2016 U.S. Dist. LEXIS 95910 (S.D.Ga. July 21, 2016).