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” d 294, 296 (Minn. 1992).

It relies on State v. Needham, in which the supreme court stated, “[A] pretrial motion to suppress should specify, with as much particularity as is reasonable under the circumstances, the grounds advanced for suppression in order to give the state as much advance notice as possible as to the contentions it must be prepared to meet at the hearing.”

“[A] pretrial motion to suppress should specify, with as much particularity as is reasonable under the circumstances, the grounds advanced for suppression in order to give the state as much advance notice as possible as to the contentions it must be prepared to meet at the hearing.” d 294, 296 (Minn. 1992).

Moreover, a motion to suppress “should specify, with as much particularity as is reasonable under the circumstances, the grounds advanced for suppression in order to give the state as much advance notice as possible as to the contentions it must be prepared to meet at the hearing.”

The state’s brief to this court characterizes Klevgaard’s demand to cross-examine the trooper at a pretrial hearing as a discovery “tool.” The state relies on caselaw stating that notice of the legal issues to be raised at an omnibus hearing is necessary to give the opposing party “a full and fair opportunity to meet its burden.” -97 (Minn. 1992).

State v. Needham , -97 (Minn. 1992) (concluding that reopening omnibus proceedings was nece ssary so state could present additional evidence because it lacked notice of defendant’s challenge to adequacy of Miranda warning).

However, while a pretrial motion to suppress 5 should provide the state with reasonable notice of issues raised by the defendant, “[i]n practice, the defense counsel at the outset of an omnibus hearing often makes a rather general statement of the issues.”

However, while a pretrial motion to suppress should provide the state with reasonable notice of issues raised by the defendant, “[i]n practice, the defense counsel at the outset of an omnibus hearing often makes a rather general statement of the issues.”

A pretrial motion to suppress evidence must specify the grounds for suppression “with as much particularity as is reasonable under the circumstances.” State v. Needham , s -10 (Minn. App. 1994) (concluding appellant did not forfeit challenge to particularity of search warrant description where appellant notified prosecutor “all usual omnibus hearing issues would be contested;” asked to have all police officers present; and

“Although the rules of criminal procedure do not specifically authorize motions for reconsideration of omnibus rulings, the district court has the inherent authority to consider such a motion.” State v. Papadakis , -57 (Minn. App. 2002); (remanding for reopened omni bus hearing).

State v. Needham , –97 (Minn. 1992) (holding that pretrial suppression motion should specify with reasonable particularity the grounds for suppression so that state has advance notice and can meet its burden at the hearing).

But the district court did not dismiss the complaint solely because of a factual determination; rather, the district court’s determination that there is no probable 4 For its first argument

“[A] pretrial motion to suppress should specify, with as much particularity as is reasonable under the circumstances, the grounds advanced for suppression in order to give the state as much advance notice as possible as to the contentions it must be prepared to meet at the hearing.” State v. Needham

We went on to state, however, that police officers “who clearly and completely give a standard form Miranda warning containing [the] four carefully-worded individual warnings, or their equivalent, need not fear a later determination by this court that the warnings given were inadequate or misleading.” Id.; , 295 n. 1 (Minn.1992) (reiterating that a police officer who reads the standard form Miranda warning “need not fear a later determination by this court that the warning given was inadequate o

(citing 1 W. LaFave and J. Israel, Criminal Procedure § 10.1(b) (1984)).

at 107 ; (remanded for reopened omnibus hearing).

(where state did not have advance notice of issues to be raised at omnibus hearing, it was proper to reopen hearing to allow state to present additional evidence).