Filed: 4/11/2024 8:56 AM

Carroll Circuit Court

Carroll County, Indiana

STATE OF INDIANA ) IN THE CARROLL CIRCUIT COURT

)ss:
COUNTY OF CARROLL ) CAUSE NO. 08C01-2210—MR—000001

STATE OF INDIANA

VS.

RICHARD M. ALLEN )

MOTION TO SUPPRESS STATEMENTS

The Defendant, Richard M. Allen, by Counsel, Bradley A. Rozzi, respectfully

requests that this Court suppress as evidence in this cause any and all oral and written

communications, confessions, statements or admissions alleged to have been made by

Defendant Allen during his pre-trial detention in this cause. In support of this Motion,

Defendant Allen states the following:

1. Defendant Allen is charged with two counts of Felony Murder (Counts 1 &

2) and two counts of Murder (Counts 3 & 4).

2. During the course of Defendant Allen's pre-trial detention, it is alleged that

Defendant Allen communicated incriminating statements to State actors and/or their

agents, all of which the State of Indiana intends to present to a jury at the trial in this

cause.

3. The statements were involuntary, and thus obtained in violation of the

following:
a. Fifth Amendment of the United States Constitution;

b. Sixth Amendment of United States Constitution;

c. Fourteenth Amendment of the United States Constitution; and

d. Article I, Sections 12, 13, and 14 of the Indiana Constitution.

HILLIS. HILLIS.
Rozzx & DEAN. LLC
ATTORNEYS AT LAW 4. The statements sought to be suppressed were obtained as a result of
FOURTH ST.
200
LOGANSPORT. IN 48947
I574) 7294560 psychological and mental coercion illegally directed against the Defendant and such
FAX (570 722-2659
JOHN R. HILLIS
statements were, therefore, involuntarily given.
LD. #753309
BRADLEY A. Rozzx
1.13. #2336509
BRADEN J. DEAN
Lu. "31941-34
 5. The statements sought to be suppressed were obtained as a result of physical

coercion illegally directed against the Defendant and such statements were, therefore,

involuntarily given.

Therefore, any and all communications, confessions, statements, or admissions

alleged to have been offered up by Defendant Allen were elicited in Violation of his

constitutional rights under the Fifth, Sixth and Fourteenth Amendments to the

Constitution of the United States and his rights under Article 1, § 12, 13 and 14 of the

Indiana Constitution.

WHEREFORE, Defendant Allen, by Counsel, respectfiilly requests this Court:

1. Conduct a pre-trial hearing to determine if the statements alleged to have
been given were voluntary in nature; and

2. Suppress as evidence in this cause any and all communications,

confessions, statements or admissions, written or oral, made by him su uent to his

arrest in this cause.

'
J

Attorney for
. ozzi 23365—09
e'fendant
/
CERTIFICATE 0F SERVICE
I certify that I have served a copy of this document by the County
system upon the Carroll County Prosecutor's Office and Andrew J. Baldwin the
e—filing/
day of April, 2024.
HILLIS. HILLIS.
Rozz1 & DEAN, LLC
ATTORNEYS AT LAW
200 FOURTH ST.
LOGANSPOR'T. IN 46947 Bradlév Wzi. #23365—09
1514) 722-4560
FAX I574) 1292859 HILLIS. RGZZI & DEAN
200 Fourth S
JOHN R. Hmms
Ln. #753309 Logansport, IN 46947
BRADLEY A. Razz;
Ln. «23305.09
BRADEN J. DEAN
1.1). 331941-34