STATE OF RIDGEWAY
BEFORE THE SUPERIOR COURT OF RIDGEWAY FOR RIDGEWAY COUNTY
STATE OF RIDGEWAY,
Plaintiff, Case No. RSC-CM-6609
v. Presiding Judge: N/A
NOAHBADNOLIE,
Defendant,
DEFENDANT'S OMNIBUS MOTION FOR (I) DISCOVERY AND PRODUCTION OF
SEARCH WARRANT MATERIALS; (II) DISMISSAL OF COUNTS ONE HUNDRED
FIFTY-FIVE THROUGH ONE HUNDRED FIFTY-NINE; AND (III) DISMISSAL OR
BILL OF PARTICULARS AS TO COUNTS ONE HUNDRED SIXTEEN THROUGH
ONE HUNDRED FIFTY-FOUR
COMES NOW the Defendant, NOAHBADNOLIE, by and through undersigned counsel,
and respectfully moves this Honorable Court for the relief set forth below, and in support thereof
states as follows:
I. MOTION FOR DISCOVERY AND PRODUCTION OF SEARCH WARRANT
MATERIALS
1. The State has charged Defendant in a 159-count Criminal Information arising
from a search executed on or about July 6th, 2026, at the RCSO Headquarters,
Palmer, and at Defendant's residence, 3400 Majellan Way, Sterling Heights.
2. The Receipt of Goods produced to Defendant reflects that the search was
executed by Captain Dankesche of the Ridgeway State Police, and identifies the
individual served as Defendant.
3. Defense counsel is presently without a copy of the underlying warrant application,
supporting affidavit of probable cause, or the signed warrant itself authorizing the
DATED: August 1, 2026
1
search, documents essential to determining the lawful scope of the search and the
validity of the seizures made pursuant to it.
4. Defendant is informed and believes that the search may have been authorized for
the person and vehicle of Defendant only, for the specific purpose of locating
illegal weaponry, and further that items were seized from a residence at 3400
Majellan Way, a location and category of place not encompassed by a warrant
limited to person and vehicle.
5. Without production of the warrant and its supporting affidavit, Defendant is
unable to determine (a) the full scope of premises and items authorized to be
searched, (b) whether a separate warrant or other lawful authority independently
authorized the search of 3400 Majellan Way, and (c) whether the seizure of
non-weapon items, including lockpicks and duffel bags, fell within any
recognized exception to the warrant's scope.
WHEREFORE, Defendant respectfully requests that this Court order the State to
produce, within a reasonable time set by the Court and in any event prior to arraignment or as
soon as practicable thereafter:
a. The complete search warrant application and supporting affidavit of probable cause;
b. The signed warrant(s) authorizing the search of Defendant's person, vehicle(s), and/or
residence, including any separate warrant purporting to authorize the search of 3400 Majellan
Way;
c. The docket entry or judicial record identifying the issuing judge and date of issuance
for each warrant executed in this matter; and
d. Any incident or investigative report prepared in connection with the execution of the
warrant(s).
DATED: August 1, 2026
2
II. MOTION TO DISMISS COUNTS ONE HUNDRED FIFTY-FIVE THROUGH
ONE HUNDRED FIFTY-NINE (RECEIVING STOLEN PROPERTY, R.C.C. § 4.12)
6. Counts One Hundred Fifty-Five through One Hundred Fifty-Nine charge
Defendant with Receiving Stolen Property in violation of R.C.C. § 4.12, based on
the alleged possession of five gold duffle bags located within a vehicle.
7. R.C.C. § 4.12 requires that a defendant "receive, retain, or dispose of the property
of another... knowing or having reason to believe that the property has been
obtained through the commission of a theft offense."
8. The Criminal Information does not allege, anywhere in Counts One Hundred
Fifty-Five through One Hundred Fifty-Nine, that the duffel bags in question were
in fact stolen, that they were obtained through any theft offense, or any facts from
which Defendant's knowledge or reason to believe the same could be inferred.
9. The Receipt of Goods produced in this matter confirms that the contents, if any, of
the duffel bags remain unknown, and no theft victim, stolen item, or predicate
theft offense has been identified anywhere in the charging document or discovery
provided to date.
10. A charging document that fails to allege each essential element of the offense
charged is legally insufficient and fails to state an offense. As pled, Counts One
Hundred Fifty-Five through One Hundred Fifty-Nine omit the essential element
that the property was obtained through a theft offense, and further omit any
factual basis for the requisite knowledge element.
WHEREFORE, Defendant respectfully requests that this Court dismiss Counts One
Hundred Fifty-Five through One Hundred Fifty-Nine for failure to state an offense.
DATED: August 1, 2026
3
III. MOTION TO DISMISS, OR IN THE ALTERNATIVE FOR A BILL OF
PARTICULARS, AS TO COUNTS ONE HUNDRED SIXTEEN THROUGH ONE
HUNDRED FIFTY-FOUR (POSSESSION OF BURGLARY TOOLS, R.C.C. § 4.09)
11. Counts One Hundred Sixteen through One Hundred Fifty-Four charge Defendant
with thirty-nine counts of Possession of Burglary Tools in violation of R.C.C. §
4.09, based on the alleged possession of thirty-nine lockpicks located within a
vehicle.
12. R.C.C. § 4.09 does not criminalize mere possession of tools capable of facilitating
forcible entry or theft offenses. Rather, the statute requires that such tools be
possessed "under circumstances evincing an intent to use or knowledge that some
person intends to use the same in the commission of an offense of such character."
13. The Criminal Information alleges only that the lockpicks were possessed "which
in officers experience is used in the commission of an offence." This allegation
describes a generic characteristic of the item itself and does not allege any
circumstance particular to Defendant evincing an intent to use, or knowledge that
another intends to use, the lockpicks in the commission of an offense.
14. An allegation that an item is commonly associated with criminal use, standing
alone, does not substitute for the circumstance-specific intent or knowledge
element the statute requires. As pled, the Information fails to allege facts
sufficient to satisfy this essential element as to any of the thirty-nine counts.
15. In the alternative, should the Court decline to dismiss these counts outright,
Defendant requests a bill of particulars requiring the State to specify the particular
circumstances it contends evince Defendant's intent or knowledge as to each
count, so that Defendant may adequately prepare a defense.
DATED: August 1, 2026
4
WHEREFORE, Defendant respectfully requests that this Court dismiss Counts One
Hundred Sixteen through One Hundred Fifty-Four for failure to state an offense, or, in the
alternative, order the State to provide a bill of particulars as to the intent or knowledge element
for each count.
IV. CONCLUSION
WHEREFORE, for the foregoing reasons, Defendant respectfully requests that this
Honorable Court:
A. Order the State to produce the search warrant, supporting affidavit, and related judicial
records identified in Section I above;
B. Dismiss Counts One Hundred Fifty-Five through One Hundred Fifty-Nine for failure
to state an offense; and
C. Dismiss Counts One Hundred Sixteen through One Hundred Fifty-Four for failure to
state an offense, or, in the alternative, order a bill of particulars as to the intent or knowledge
element of those counts.
Respectfully submitted,
By: ____________________________
BellaRevelation, Esquire
Counsel for Defendant NOAHBADNOLIE
DATED: August 1, 2026
5
