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the motion requests that the Court Order the prosecution to provide notice in advance of trial that conforms to the standards set forth in People v. Spoto. Further, if the prosecution seeks to introduce such evidence, the Defendant moves that a hearing on the admissibility of such evidence be held sufficiently in advance of trial in order to afford counsel adequate time to confront the proffered evidence.

Sample to suppress Defendant’s statements while in custody without proper Miranda advisement. Well written motion to exclude evidence from an unlawful interrogation