UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,

v.

SEAN COMBS, Defendant.

MOTION TO SUPPRESS EVIDENCE

Defendant, SEAN COMBS, by and through his undersigned counsel, respectfully moves this Honorable Court for an Order suppressing all evidence seized during the searches of his properties in Los Angeles and Miami on March 2024, including, but not limited to, the seized firearms and electronic devices. Defendant further moves to suppress any and all evidence, including observations and photographs, obtained from the search of his jail cell.

MEMORANDUM OF LAW IN SUPPORT OF MOTION TO SUPPRESS EVIDENCE

I. INTRODUCTION

The Fourth Amendment to the United States Constitution guarantees “the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.” This fundamental right is enforced through the exclusionary rule, which mandates the suppression of evidence obtained in violation of constitutional protections, as well as the “fruits of the poisonous tree” derived from such unlawful conduct. Weeks v. United States, 232 U.S. 383 (1914); Mapp v. Ohio, 367 U.S. 643 (1961); Wong Sun v. United States, 371 U.S. 471 (1963).

In the present case, federal agents executed search warrants at Mr. Combs’ residences in Los Angeles and Miami. However, the application and execution of these warrants, as well as the subsequent search of Mr. Combs’ jail cell, demonstrate egregious violations of Mr. Combs’ Fourth Amendment rights. The warrants were overbroad, lacked particularity, and were predicated on a distorted and incomplete presentation of facts, leading to an unreasonable search and seizure of property. Furthermore, the search of Mr. Combs’ jail cell, despite the government’s claims, appears to have been an unconstitutional targeted search. Therefore, all evidence obtained as a result of these unlawful actions must be suppressed.

II. STATEMENT OF FACTS

1. In March 2024, federal agents with Homeland Security Investigations (HSI), acting pursuant to search warrants issued out of the Southern District of New York, executed searches at Sean “Diddy” Combs’ properties in Los Angeles and Miami. These searches were reportedly related to an ongoing sex trafficking investigation.
2. During the searches, law enforcement officers seized “three AR-15s with defaced serial numbers, as well as a drum magazine” from Combs’ residences.
3. Phones were seized from Mr. Combs in Miami before he was scheduled to depart for a trip to the Bahamas.
4. Mr. Combs’ legal team asserts that the warrant applications were overbroad, excluded facts favorable to Mr. Combs, and presented a distorted picture of reality to the issuing magistrate.
5. While Mr. Combs was in jail following his arrest, investigators searched his cell. The government claims this search was part of a “larger safety and security initiative” and was pre-scheduled, not targeted at Mr. Combs.
6. During the jail cell search, items such as a manila folder marked “legal,” a notebook, an address book, and personal effects were found. Photos were taken of the notebook and address book, but these items were not physically removed from his cell.

III. ARGUMENT

A. The Search Warrants for Mr. Combs’ Residences Were Constitutionally Deficient, Violating the Fourth Amendment’s Requirements for Probable Cause and Particularity.

The Fourth Amendment mandates that “no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.” U.S. Const. amend. IV. A warrant that fails to satisfy these requirements is facially invalid, and any evidence seized pursuant to it must be suppressed. Groh v. Ramirez, 540 U.S. 551, 557 (2004).