Terrorists Identified

My lawyer said the next step is for Dakota to file a motion through the court for return of his property. I have drafted a rough draft and sent it to him. Here is what I sent to him. All he has to do is fill in the blanks, take it to the court and file it. 

IN THE MUNICIPAL COURT OF LA MARQUE, TEXAS

GALVESTON COUNTY

Cause No. __________

STATE OF TEXAS

v.

___________________________

MOTION FOR RETURN OF SEIZED PROPERTY

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES the Defendant, ___________________________ (hereinafter “Defendant”), and respectfully moves this Court to order the return of certain personal property unlawfully seized and held by law enforcement, and in support thereof would respectfully show the Court as follows:

1. Background

On or about ___________________________ (insert date of arrest), Defendant was arrested by officers of the La Marque Police Department following a traffic stop for allegedly failing to maintain a single lane of travel. Defendant was subsequently detained and spent the night in jail, and his vehicle was towed from the scene.

2. Seized Property

Upon release, it was discovered that certain personal items were missing from Defendant’s possession, specifically:

• Defendant’s cell phone; and

• A purse belonging to a relative of the Defendant, which was inside the vehicle at the time of towing.

Upon inquiry, officers of the La Marque Police Department stated that these items had been seized and are being held pending the acquisition of a search warrant.

3. Legal Basis for Return

Defendant asserts that the continued seizure of said property constitutes an undue and unreasonable deprivation of personal property under the Fourth and Fourteenth Amendments to the United States Constitution, as well as Article I, Sections 9 and 19 of the Texas Constitution.

Defendant further contends that there is no legal basis for the indefinite retention of these personal items, particularly given that they have not been presented as evidence in any formal proceeding, nor has a valid search warrant been provided or disclosed to justify the seizure.

4. Prayer

WHEREFORE, PREMISES CONSIDERED, Defendant respectfully requests this Court to issue an order directing the immediate return of the seized items—namely, Defendant’s cell phone and the purse belonging to his relative—and for such other and further relief as the Court may deem just and proper.

Respectfully submitted,

⸻

[Defendant or Attorney Name]

[Address]

[Phone Number]

[Email]

CERTIFICATE OF SERVICE

I certify that a true and correct copy of this Motion has been served upon the La Marque City Attorney and/or Prosecutor’s Office on this the ________ day of __________________, 2025.

⸻

[Defendant or Attorney Name]

⸻

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