"This was clearly a deliberate and willful misrepresentation to the court to conceal the use of extrajudicial clandestine surveillance by the Baltimore City Police Department," Insley wrote in this motion. He believes police and prosecutors broke a number of rules by denying using a stingray. "Despite repeated attempts by counsel to obtain the disclosure of evidence ... the Office of the State's Attorney intentionally misrepresented to counsel the nature of the evidence."