Two on waiver for untimeliness

Pro se defendant making a motion to suppress during trial was waiver. He talked about it with his former attorney and waited until the government offered it into evidence. United States v. Young, 2020 U.S. App. LEXIS 10820 (7th Cir. Apr. 7, 2020).*

Defendant learned of new information that he thought justified a Franks motion. Waiting 30 days, however, wasn’t timely. He had to file it within five days. The trial court found waiver but denied it on the merits. Defendant never showed good cause for the delay. Thompson v. State, 2020 Md. App. LEXIS 331 (Apr. 7, 2020).*

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