D.Haw.: Def failed in her motion to reconsider overseizure by failure to specify exactly what was

Defendant’s motion to suppress was previously denied, but she was allowed to specify what documents were overseized. “[T]he court will consider a motion to suppress specific documents or other evidence based on proof that such items were seized and that such seizure exceeded the scope of the search warrant. Despite her contention that she is now providing such proof, see ECF No. 639 at PageID #7288, in fact, Defendant is providing only photos of boxes holding documents separated by file tabs and her allegations regarding the type of documents pertaining to those file tabs. That is, Defendant still has not provided actual newly discovered evidence that a particular seized document was outside the scope of the search warrant and should be suppressed.” United States v. Sullivan, 2020 U.S. Dist. LEXIS 56334 (D. Haw. Feb. 28, 2020)

The search of defendant’s house occurred before he consented. The police clearly had probable cause for a search warrant for a house where a killing occurred. Inevitable discovery applied. State v. Little, 2020 Mo. App. LEXIS 374 (Mar. 31, 2020).*