Boilerplate motion to suppress should be denied for failing to specify what was illegally seized and how. This search was by search warrant and it was presumptively valid. United States v. Jones, 2009 U.S. Dist. LEXIS 112286 (D. Minn. October 30, 2009):

Moreover, the Defendant has not identified the evidence, that was secured by the Search Warrant, should be suppressed, nor has he offered any factual or legal grounds for suppression. Having so failed to satisfy his burden of production, we recommend denying his Motion to Suppress on that basis alone. See, e.g., United States v. Mims, 812 F.2d 1068, 1074 (8th Cir. 1987) (On a Motion to Suppress telephonic interceptions, the defendant's failure to "assert what may have been wrong with the interceptions, or in fact, even what interceptions that he [was] concerned with," justified the District Court's decision to deny the Motion without the conduct of an Evidentiary Hearing); see also, United States v. Quiroz, 57 F. Supp.2d 805, 822-23 (D. Minn. 1999) ("boilerplate motion" to suppress statements denied due to failure to satisfy specificity requirement). Nonetheless, in an abundance of caution, we proceed with addressing the merits of the Defendant's Motion by considering the probable cause detailed in the Warrant's supporting papers, and by examining for any other fatal deficiencies in the Warrant. See, United States v. Edwards, supra at 995. As we detail below, no basis to suppress the evidence obtained by the warranted search and seizure has been established, and therefore, we recommend that Jones' Motion to Suppress be denied.

Defendant failed to show that the SW was issued without probable cause. The reference in the motion to timeliness was apparently boilerplate, and it was rejected as well. United States v. Brooks, 2007 U.S. Dist. LEXIS 98921 (E.D. Tenn. November 29, 2007).*

SW for a particular room in a motel was constitutionally sufficient. [Why argue this?] United States v. Patterson, 2007 U.S. Dist. LEXIS 98923 (N.D. Ga. June 27, 2007).*

Where defendant was admittedly lawfully stopped for speeding, being “asked” out of the car was not a separate seizure requiring more cause. It was valid under Mimms. United States v. McChesney, 2009 U.S. Dist. LEXIS 112197 (N.D. Ind. December 2, 2009):

The Defendant argues that Officer Hatfield impermissibly started a new seizure by asking him to exit the vehicle and commencing an investigation that was unrelated to the traffic stop. In other words, the Defendant asks the Court to break up the encounter into two or more different seizures, and apply a separate analysis to each. However, the Seventh Circuit has rejected this sort of multiple seizure analysis in favor of an overarching analysis that takes into account the traffic stop as a whole. In United States v. Figueroa-Espana, the defendant argued that once his traffic stop had been completed, any additional investigation by the police officer qualified as an improper second encounter, and any evidence produced therefrom should be excluded. The Seventh Circuit declined to adopt that framework and held that "[t]he fact that the troopers sought further information [unrelated to the traffic stop] does not render this second phase of questions a new seizure .... Rather, the events ... are more appropriately analyzed as ... an extension of the initial stop based on reasonable suspicion." 511 F.3d 696, 702 (7th Cir. 2007) (citing United States v. Rivera, 906 F.2d 322-23 (7th Cir. 1990) (finding that an officer's request to search a car, after giving the motorist a written warning, returning his identification, and indicating that he was free to leave, was part of a consensual encounter and not a new seizure)).

“Given that the stop was proper, Trooper Rindlisbacher did not violate the Fourth Amendment by conducting a license and registration check. See U.S. v. Chavez-Valenzuela, 268 F.3d 719, 724 (9th Cir. 2001), amended 279 F.3d 1062 (9th Cir. 2002). Thus, he properly discovered that none of the occupants in the vehicle owned the car or had a valid driver's license.” The search of defendant’s purse was not invalid. She was allowed to go, but the ride she called had not arrived, and the officer wasn’t going to wait around any longer, so he searched her purse by consent before she got in the car so he could drive her. [The video of the stop supported it.] United States v. Rojas, 2009 U.S. Dist. LEXIS 112346 (D. Idaho December 2, 2009).*

Detention of defendant who was on foot to get his ID to run his information was an unreasonable detention without reasonable suspicion. State v. Montano, 2009 NMCA 130, 223 P.3d 376 (2009).*

[*1] Defendant Ray Anthony Montano asserts that the district court erred in refusing to suppress drug-related evidence obtained from his person in a search incident to his arrest. Neither the record of the hearing nor the suppression order shows specific grounds for denial. The issue is whether the police officer's actions in stopping and questioning Defendant, who was on foot, and then obtaining Defendant's identification and running it through dispatch constituted an unlawful investigatory detention. The State acknowledges that the officer did not have reasonable suspicion of criminal activity up to the point that dispatch informed the officer of an outstanding warrant. The State's position is that the circumstances constituted either a consensual community caretaker encounter excluded from the Fourth Amendment to the United States Constitution or a community caretaker encounter that was subject to, but reasonable under, the Fourth Amendment.

[*2] We hold under the Fourth Amendment that what started out as either a consensual or non-consensual community caretaker encounter became an unlawful investigatory detention. We therefore reverse the district court's denial of Defendant's motion to suppress the evidence obtained by the officer after the search incident to Defendant's arrest on the outstanding warrant.

Owner could validly consent to a search against a guest under Randolph. Testa v. Commonwealth, 55 Va. App. 275, 685 S.E.2d 213 (2009):

Randolph involved the application of the exclusionary rule to "a warrantless search of a shared dwelling" for evidence of a crime. Id. at 120 (emphasis added); see also id. at 119 (noting that the majority was "recognizing limits on merely evidentiary searches"); id. at 122 (limiting issue to situation involving an "express refusal of consent to a police search"). Here, the deputies did not search Griffin's home. They simply entered it with the owner's permission, walked into the common hallway at the owner's invitation, and remained there throughout with the owner's approval. 2 Testa was not a co-owner, renter, or boarding house tenant. He simply occupied a bedroom in his stepfather's home. Nothing in Randolph suggests that a live-in guest of a homeowner can veto the owner's right to invite anyone he may choose (whether police officers or anyone else) to accompany him into the common areas of his own home. See id. at 114 (explaining that Fourth Amendment privacy analysis takes into account any "recognized hierarchy" between the consenter and objector).

n.2 Because of our holding, we need not decide whether Testa's guttural outburst ("Go fuck yourself") can be analogized to the statements of the co-owner in Randolph who "unequivocally refused" when the officers asked for consent to search his home. Id. at 107.