Defendant Emmet Bowens' Motion to Suppress/Preclude Statements (Case No. 6:21-cr-00141-RBD-EJK)

Summary

Document 237-3 in Case No. 6:21-cr-00141-RBD-EJK, United States of America v. Emmet Bowens, U.S. District Court, Middle District of Florida, Orlando Division, is a short excerpt of two defense motions. The first is a Motion to Suppress/Preclude Statements, which seeks to suppress statements allegedly made to a U.S. Customs and Border Protection officer and an FBI agent on December 1, 2022, under the Fifth Amendment and Miranda v. Arizona, 384 U.S. 436 (1966). The second is a Motion to Dismiss Count Two of the Indictment Due to Improper Venue under Fed. R. Crim. P. 12(b)(3)(A)(i). Its procedural history says a grand jury returned the Indictment on November 10, 2021, charging two counts of wire fraud and four counts of money laundering.

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“Defendant Emmet Bowens' Motion to Suppress/Preclude Statements (Case No. 6:21-cr-00141-RBD-EJK).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flmd-396523-237-3-2d6bc7b1d5/, SHA-256 bdb7f18aa580ed0050c9d4f1a8696fdf8c99fbcbb34ddf7ea2089799caa807dc.

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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION

UNITED STATES OF AMERICA, _ )
Plaintiff,

Vv. Case No. 6:21-cr-00141-RBD-EJK
EMMET BOWENS,
Defendant.
)

DEFENDANT EMMET BOWENS’
MOTION TO SUPPRESS/PRECLUDE STATEMENTS

The Defendant, Emmet Bowens (“Mr. Bowens”), by and through the
undersigned counsel, hereby moves to suppress statements allegedly made to a
U.S. Customs and Border Protection (“CBP”) officer and a Federal Bureau of
Investigation (“FBI”) agent on December 1, 2022, as said statements were obtained
in violation of the Fifth Amendment of the United States Constitution and Miranda
v. Arizona, 384 U.S. 436 (1966). In the alternative, Mr. Bowens seeks to preclude
the introduction of the statements he allegedly made on December 1, 2022 under

the Federal Rules of Evidence. In support thereof, Mr. Bowens states as follows:
866

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION

UNITED STATES OF AMERICA, _ )

Plaintiff,
Vv. Case No. 6:21-cr-00141-RBD-EJK
EMMET BOWENS,

Defendant. |

DEFENDANT EMMET BOWENS’ MOTION TO DISMISS
COUNT TWO OF THE INDICTMENT DUE TO IMPROPER VENUE

The Defendant, Emmet Bowens (“Mr. Bowens”), by and through the
undersigned counsel, hereby moves to dismiss Count Two of the Indictment (Doc.
1), pursuant to Fed. R. Crim. P. 12(b)(3)(A)(i), on the grounds that venue for this
Count is improper in the Middle District of Florida. In support thereof, Mr.
Bowens states as follows:

STATEMENT OF FACTS

Relevant Procedural History

1. On November 10, 2021, a federal grand jury in the Middle District of
Florida returned an Indictment charging Mr. Bowens with two counts of wire
fraud, in violation of 18 U.S.C. § 1343 (Counts One and Two), and four counts of

money laundering, in violation of 18 U.S.C. § 1957 (Counts Three through Six).

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