464 Mass. 566 - Appellant Montoya Brief - Mass Cases

The defendant then called Geir Boger, s
oyer, as a character witness. Mr. Boger testi
was the proprietor of a const business
the defendant had worked for for six years
and t the defendant had an Ie work ethic
a reputation veracity and hfulness in
workplace.
SUMMARY OF ARGUMENT
The evidence at the motion to suppress and
findings made by motion judge show that at t
t that the defendant was arrested by Trooper
Saunders, the sum tot of the col i ve facts known
to police officer may have been cient grounds
for reasonable s icion but not probable cause to
arrest him for distribution of cocaine. Pp. 22-28
The statements that the defendant made disclos
existence of hide were not vOluntarily
e he had been kept in custody handcuffed to
a 1, told that was in serious trouble and
should tal k to the police and reasonably fe
his car would damaged by a lice search for
20