If anyone has the full motion from NP I'd like to read it. In the meantime, I did some research. I couldn't find a super direct code section but there are some code sections I found involving trying to seek the return of evidence.
One applies mostly to victims of crime whose property was stolen or taken and used by another in the omission of a crime. The section talks mostly about stolen property but there are some key phrases in that section that may be important here as there may be case law building upon those ideas or they may reflect general principles about seized property in CT. There is also a portion that seems to more directly apply.
One is that stolen property must be returned to the owner upon request unless "good cause" can be shown for its retention and then it can be held for a period determined by the court.
There's also a part in which it states that other property seized that was not stolen from a victim (and was not drugs or other contraband) will be returned to the owner at
the end of the criminal case. Which is typical and important here:
Connecticut General Statutes Title 54. Criminal Procedure § 54-36a. Definitions. Inventory. Return of stolen property. Disposition of other seized property. Return of compliance
(c) Unless such seized property is stolen property and is ordered returned pursuant to subsection (b) of this section or unless such seized property is adjudicated a nuisance in accordance with
section 54-33g , or unless the court finds that such property shall be forfeited or is contraband, or finds that such property is a controlled drug, a controlled substance or drug paraphernalia as defined in
subdivision (8), (9) or (20) of section 21a-240 , it shall,
at the final disposition of the criminal action or as soon thereafter as is practical, or, if there is no criminal action, at any time upon motion of the prosecuting official of such court, order the return of such property to its owner within six months upon proper claim therefor. (Emphasis by me).
Connecticut General Statutes Title 54. Criminal Procedure § 54-36a | FindLaw
The other code section is about "unlawfully obtained" property. That one discusses how one can move to seek the return and suppression of evidence unlawfully obtained - no warrant or a lack of sufficient probable cause, e.g.- so the key word there in looking at is probable cause:
"A person aggrieved by search and seizure may move the court which has jurisdiction of such person’s case...on the ground that:...there was not probable cause for believing the existence of the grounds on which the warrant was issued".
» Connecticut General Statutes 54-33f – Motion for return of unlawfully seized property and suppression as evidenceLawServer
Taken together, and without benefit of reading his actual motion (and also by considering due process laws regarding evidence in other states), I believe that NP is seeking to force the issue as to whether there is actual probable cause to seize the property (which may give him an idea as to its evidentiary value) and good cause to retain it.
He is doing every last thing he can to fight the state.