IN THE CIRCUIT COURT FOR FAIRFAX COUNTY COMMONWEALTH OF VIRGINIA
MSXUQh Tft SUEEBE^ fvidence
Defendant. Mir Aimal Kansi. through counsel, respectfully moves this Court io suppress as evidence against him any statements, objects or information gatheredull of his seizure in this case as having been obtained in violaiionofthe fourth arnc^dmem to the Untied States Consuiuuon and Article I. Scct.onf the Virginia Consuiution. In support of this motion, counsel states;
|. Some time at the beginning ofhe defendant, Mir Aimalas abducted from Pakistan by police forces of the Untied States acting pursuantapias issued by ihe Circuit Court of Fairfax County. The abductionecure under ihe Untied Slates and Virginia Constitutions.
2. At ihe lime of lhe abduction, an extradition ircaiy existed between theand Pakistan which described the procedures required when one countrythe other country delivererson accusedrime in one jurisdiction who ismetemiocy ofwas the case here where Mr Kans..
accusedrime in the United Slates was found wtthin the lerritory of Pakistan. In addition, both counirics have erucied statutes which create procedures to carry out extradition requests.
APPROVED FOP PELEASE DATE:
j. Theeizure ol' Mr. Kansi was accomplished in violation of ihe Extradition Ireaij between ihe Limed Suites and Pakistan and wnhuui imoking the procedures set oui by the laws of each country The manner in which the seizure was made was therefore illegal and unreasonable and violated the United Slates and Virginia Constitutions.
4. Because the manner in which Mr. Kansi was seized was unconsiituuonal. any evidence securedesult of the seizure must be suppiessed.
WHEREFORE, for the foregoing reasons, and any further reasons which may appear io the Courtearing in ihis matter, the Defendant respectfully requests that his motion be GRANTED.
Richard C. Goemann Office of the Public3 Chain Bridge Road
Respectfully submitted. MIR AIMAL KANSI By CounselOriginal document.