Defendant can’t get an order for return of property where he can’t show that the government even has it. United States v. Tziu-Uc, 2018 U.S. App. LEXIS 34105 (9th Cir. Dec. 4, 2018).
Self-represented defendant claimed ineffective assistance of counsel from former counsel’s failure to file a motion to suppress, but he alleges nothing from which the court could see that it had any merit at all. People v. Shareef, 2018 NYLJ LEXIS 3961 (App. Term 2d Dept. Dec. 3, 2018).*