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Leo, a kidnapping suspect, is detained at a city police station. He speaks Waray. A detective reads a standard rights notice in English: “You have the right to remain silent; anything you say may be used against you; You have the right to counsel; If you cannot afford counsel, one will be provided.” After a brief pause, Leo signs a written waiver of rights and agrees to be questioned without an attorney. The interrogation lasts 50 minutes, during which Leo confesses to participating in the kidnapping. No counsel was present during custodial interrogation. The detective later introduces the confession as evidence. (a) Identify the controlling doctrine governing the validity of Leo’s waiver of rights. (b) Based on the facts, determine whether the waiver was valid, applying the requisites of a valid waiver (voluntary, knowing, intelligent). (c) If the waiver is invalid, discuss whether the confession is admissible under the Exclusionary Rule.

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