Whether the court will revisit a motion to suppress evidence based on newly discovered perjured testimony by a detective in obtaining a search warrant, and whether multiple legal challenges to the trial court's evidentiary and procedural rulings warrant review

1. Detective Josh Pavlov of the Bordentown Township Police Dept, applied for and obtained a search warrant for the home of the defendant ’s father under false swearing under oath. A motion to suppress evidence was held and denied to which the defense was unaware of crucial perjured evidence. During the trial it was revealed that the detective lied under oath in connection with obtaining the search warrant, would the court consider revisiting the motion to suppress in light of the newly discovered evidence? 2. In Erlinger, the Supreme Court held that when the Gov. Wants an extended term Under 18 U.S.C. 924(e) (1) and the Courts prior decision in Apprendi v. New Jersey, 530 U.S. 466 (2000) require a jury to decide whether the predicate offenses took X place on different occasions. In this case before the court a judgenot a jurydecided the predicate offenses were committed at different times. Taking all the factors in this I brief inconsideration and pursuant to Erlingler and Apprendi, does the defendants extended term under N.J.S.A 2C: 44-3 become invalidated? 3. Lieutenant Shaune E. Lafferty #6002 and Det. Pavlov #3271 of the Bordentown Police Department executed a search of the defendants (father) home, the defense contends that U.S. currency was stolen and evidence was manufactured during the search. 4. Based upon the foregoing allegation, the defense compelled the prosecution to produce the body worn camera footage utilized in the search of 12 Jarvis Place. Prosecutor Julian Harris put forth a slew of reasons as to why he could not produce the requested B WC (See defendants brief for slew of reasons). Accordingly, could the court rule on whether the defense was illegally denied the aforementioned exculpatory evidence? 5. Likewise the defense was denied BWC footage of the investigation that took place in the bank wherein the investigating officer (Chief Pesce) remarks to the bank tellers “How great this doesn ’t even seem like a robbery. ” Will the court rule as to whether this Body Worn Camera footage qualify as exculpatory evidence that the defense should have been privy of? 6. During the trial, the defendant sought to enter documentations (records) of unemployment benefits in the trial in order to establish that he had an income at the time of the alleged offense. Judge Breland held a mock preliminary hearing to determine if the documents could be used as records and in the interest of the defense. The Judge ultimately ruled that they were inadmissible as business records although the court appointed investigator acquired them form the Executive Director of Legal and Regulatory Services (Mr. David Fish). Will the court reexamine this preliminary hearing to ascertain the defendant ’s denial of exculpatory evidence? 7. During the trial evidence supported that the crime did not rise to the level of robbery, when asked what did the note mean to her when it was passed, the bank teller responded by stating “(just as it said give him the money and that’s what she was trained to do)”, she also testified that there were no threats in the note, based on this testimony does the guilty verdict merit review? 8. The State relied on a fear theory in support of a robbery indictment, the defense contends that the indictment was manifestly deficient and a subversion of the Grand Jury Process. To return an indictment a grand jury must determine whether the State has established a prima facie case that a crime has been committed and the accused had committed it. Relevant to the present case, the State did not present sufficient evidence to the grand jury to establish the offence of robbery. During the grand jury process one of the jurors specifically ask the prosecutor if the bank teller has to be in any fear of injury in order to meet the requirement of 2nd degree robbery to which the prosecutor simply rereads the definition of the statute, will the court review the grand jury process in this matter? 9. Prior to the trial and during the ar