Motion for Return of Property & Suppress Evidence. - Alaska State of ...

David S. Haeg Created 9/14/06P.O. Box 123Soldotna, AK 99669(907) 262-9249IN THE DISTRICT/SUPERIOR COURT FOR THE STATE OF ALASKAAT KENAI, ALASKASTATE OF ALASKA ))Plaintiff, ))vs. ))DAVID HAEG,) Case No.: 4MC-S04-024 Cr.)Defendant. )_______________________________)MOTION & REQUEST FOR EVIDENTIARY HEARINGAND ORAL ARGUMENTI certify this document and its attachments do not contain the (1) name of victim of a sexual offense listed in AS 12.61.140 or (2) residence orbusiness address or telephone number of a victim of or witness to any offense unless it is an address identifying the place of a crime or an addressor telephone number in a transcript of a court proceeding and disclosure of the information was ordered by the court.COMES NOW Defendant, DAVID HAEG, in the above referencedcase, and hereby files the following addendum to the motion forreturn of property & to suppress evidence in accordance with AkRule of Criminal Procedure No. 42(e) & (f). Haeg requested thesemotions in his supplemental motion but did not include them inthe title as required by Ak Rule of Criminal Procedure No. 42(g).Haeg, in order to properly and effectively present his case,requires an evidentiary hearing complete with oral argument. Haegrequests that he be allowed to issue subpoenas and requirewitness testimony during the evidentiary hearing. This witnesstestimony is absolutely essential for Haeg prove his case beyondany shadow of a doubt.Motion & Request for Evidentiary Hearing & Oral Argument Page 1 of 2

Haeg estimates the time needed for all parties to submitevidence is approximately 3 hours. Haeg estimates time for oralarguments to be under 30 minutes.This motion is supported by the attached Affidavit ofDefendant.RESPECTFULLY SUBMITTED this ____ day of ____________, 2006.Defendant,_____________________________David S. HaegI HEREBY CERTIFY that a copy of theforegoing was served on the ProsecutingAttorney's office, in personon ______________, 2006By: ___________________________Motion & Request for Evidentiary Hearing & Oral Argument Page 2 of 2