#25-BT-0091 State of San Andreas vs. Samuel Wheeler

[Bobby Versace]

Defendant Name: Samuel Wheeler
Defendant Phone: 440-7767
(( Defendant Discord: rustyosprey2 ))
(( Defendant Timezone: GMT+2 / CEST ))
Type of Representation (Pick one): Private Defense Attorney

Charging Department: LSSD

Date & Time of Incident(s): 19/APR/2025 02:45am
Charge(s):

• DM04 - Possession of a Controlled Substance while Armed
• DM02 - Possession of a Schedule II Controlled Substance

Narrative:
The Defendant believes he was wrongfully charged.

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I, Bobby Versace, hereby affirm that all information provided above is true and correct to the best of my knowledge, and understand that knowingly providing false information could result in additional charges and/or fines. (( I affirm that all information submitted has been obtained via In-Character means. ))

[Bobby Versace]

Bobby Versace
Private Defence Attorney
"Better Call Bobby"

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Samuel Wheeler

A Notification of Counsel was filed in the above case on the 19 of April, 2024.

I, Bobby Versace, a Private Defence Attorney, will be representing the Defendant, Samuel Wheeler the underlying case.

I will be taking the responsibility of Primary Counsel and will await further instruction from the Presiding Judge.



Private Defence Attorney
Better Call Bobby
344-6745 — [email protected]

[Sayaka Yukimura]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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NOTICE OF RECEIPT

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Samuel Wheeler

The court has hereby received and acknowledged the above case on the 29th day of April, 2025.

The Superior Court of San Andreas has received your filing and the case is now pending activation. Be advised that the bench trial court system operates off a time-slot scheduling system. Please look out for notifications from either the courts or your attorney in regards to scheduling your bench trial.

During this time, the defendant is encouraged to reach out to a licensed defense attorney in order to prepare a proper defense, otherwise, a court-appointed attorney will be assigned to the case upon its activation.

The defendant is further encouraged to speak with an authorized individual at Rockford Hills City Hall, Mission Row Police Station, or Paleto Bay Sheriff's Office for official clarification on the specific charges received and their respective date and times, as once the case has been activated, any omitted charges will be considered abandoned and unable to be disputed within this case.


Superior Court Judge
San Andreas Judicial Branch
(909) 304-2935 — [email protected]

[Sayaka Yukimura]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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NOTICE OF ACTIVATION & ORDER FOR DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Samuel Wheeler
#25-BT-0091

A Notice of Activation & Order for Discovery was entered in the above case on the #th day of Month, 2025.

The case of State of San Andreas v. Defendant is hereby activated and opened by this Court.

Be advised that the bench-trial court system runs on a weekly time-slot system. The prosecution and defense are hereby ordered to provide their evidence to the Court via Motion for Discovery within the next 30 days or file a Motion for Continuance.

If at any point in time the defendant or prosecution wishes set precedence or desire a formal criminal trial, they are welcome to file a Motion for a Change in Venue.


Superior Court Judge
San Andreas Judicial Branch
(909) 304-2935 — [email protected]

[Terence Williams]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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MOTION FOR DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Samuel Wheeler
#25-BT-0091

A Motion for Discovery was filed in the above case on the 16th of May, 2025.

The State of San Andreas, by and through the undersigned attorney, filed this Motion for Discovery, and presents the following as evidence;

• Exhibit #1: Arrest report - Samuel Wheeler, 19/APR/2025

  

  ARREST REPORT
  

  MUGSHOT

  SUSPECT 1 DETAILS

  • 
    
    
    Full Name: Samuel Wheeler
    Telephone Number: 4407767
    Licenses Suspended: Yes
    • Driver
    • Trucker
    
    Charges:
    • VF01 - Evading an Officer
    • SF02 - Murder of a Gov. employee
    • WM03 - Criminal Use of Weapon Modifications
    • WM05 - Possession of Body Armor as a Felon
    • DM02 - Possession of a Schedule II Controlled Substance
    • DM04 - Possession of a Controlled Substance while Armed
    • WF03 - Possession of a Class 2 Firearm
    • SF02 - Murder of a Gov. employee
    
    
    Additional Details (Suspect's vehicle, etc.) :

  
  
  VEHICLES INVOLVED

  
  
  DEPUTY DETAILS

  • Full Name: Aurora Rose
    Badge Number: 28365
    Callsign: 1-C-3

  
  
  INCIDENT DETAILS

  • Date of Arrest: 2025-04-19
    Deputies Involved: Vince Taylor, Bobby Kirk, Alester Carter, Leif Helgarson
    
    Provide details of the incident leading up to the arrest
    • Samuel Wheeler was pulled over for reckless by deputy Carter. A dog was requested and upon knowledge that the vehicle would be sniffed, they evaded. This pursuit lead other units into catfish where they opened fire on deputies, two deputies died during the gunfire. Upon arrival Mr wheeler was searched, disarmed and treated by MD at the scene. He was then transported to DOC.

  
  EVIDENCE DETAILS

  • Location of Evidence Locker: Sandy Station
    Exhibit A:

  
  
  ARRESTING DEPUTY SIGNATURE
  A. Rose
  

  ---

  

• Exhibit #2: Witness statement - Deputy Sheriff Trainee Aurora Rose

  

  

  
  San Andreas Judicial Branch
  Official Witness Statement
  "HERE FOR YOU | SAFE FOR YOU"

  Case Information

  • Case Number: [Case Number]
    Incident Date: [01/JAN/2000]

  Witness Information

  • Name: [Aurora Rose]
    Date of Birth: [11/NOV/1995]
    Phone Number: [562-6573]
    Occupation: [Deputy Sheriff Trainee]

  Witness Statement

  • [Hello and good morning. The evening started off with myself and my partner Deputy Taylor patrolling together, during our patrol there was a radio call from Deputy Carter advising of his conducting of a traffic stop on the defendant. He requested K9 to be on scene and as a result of this, the defendant evaded. As there was already multiple units, myself and Taylor did not respond until we heard of shots being fired. The pursuit ended and concluded in catfish, where myself and Taylor were last on scene. I noticed the defendant on the ground injured and in need of BLS and no other deputies were attending to him, so I cuffed him, read his rights and quickly attended to providing him BLS. Once this was done, I concluded patting him down and identifying him. He was in possession of Marijuana Blunts which warranted my charging of Possession while armed. After this, I was approached by a PD Detective informing of me of drugs that were retrieved from the defendant, and was asked to charge with the other possession charge, I re-confirmed this with the detective on scene, as well as my partner Deputy Taylor and placed the charge as a result of their instructions. Sadly I am not able to recall the name of the detective involved, but do remember he was within PD. The defendant was then assisted by MD where he was then taken to Paleto MD for further treatment and and moved into our cruiser for transportation to DOC.]

  Witness Affirmation

  • I, [Aurora Rose], affirm that the above statement is true to the best of my knowledge and belief. I affirm that this statement has been made voluntarily, made without promise of reward, and made not under threat, force, or coercion. ((I affirm that all information submitted has been obtained via In-Character means.))
    
    Signed,
    
    
    [Aurora Rose]
    [Deputy Sheriff Trainee]
    [Los Santos Sheriff Department]
    
    Date: [06/MAY/2025]

  

• Exhibit #3: Witness statement - Master Deputy Vince Taylor

  

  

  
  San Andreas Judicial Branch
  Official Witness Statement
  "HERE FOR YOU | SAFE FOR YOU"

  Case Information

  • Case Number: [Case Number]
    Incident Date: [01/JAN/2000]

  Witness Information

  • Name: [Vince Taylor]
    Date of Birth: [02/APR/1995]
    Phone Number: [5571310]
    Occupation: [LSSD Master Deputy]

  Witness Statement

  • [Good afternoon. In regards to this situation I really do not have much that I can add substance wise. This night it was myself and my partner Aurora Rose on patrol, when a call of a traffic stop was relayed over radio. I did not initially respond to this call, as there were a few units going to it and a K-9 unit was specified, which I am not a part of. After some time a pursuit was called and shots fired was called. Myself and Rose were the last unit to arrive of the initial bunch, and by that time shots had ceased and medical treatment was being rendered. Myself and Rose went towards the boathouse where we saw the defendant laying on the ground shot up with a large amount of bullet holes, alongside a pile of bullets from a bullpup rifle, or some style of 5.56 ammo. Rose was tasked on treating him as nobody had gotten to him yet, so we searched, ID’d, and BLSd. From what I recall, upon further investigation, marijuana was found on the man, which is grounds to charge with possession while armed.
    
    As for the LSD that was found nearby, myself and rose were not the ones who discovered it. We were instructed to place the charge on the defendant by a detective that was on scene. To my recollection I can not remember who it was, I believe it was a PD detective but I very well could be wrong. Charges were placed on their behalf by myself, who took over getting people charged, getting deputies assigned to suspects, and getting us moved from Catfish to MD. Any other further inquiries to myself, I will do my best to answer, but being this was over 2 weeks ago it is very difficult to remember the complete ins and outs of the situation.]

  Witness Affirmation

  • I, [Vince Taylor], affirm that the above statement is true to the best of my knowledge and belief. I affirm that this statement has been made voluntarily, made without promise of reward, and made not under threat, force, or coercion. ((I affirm that all information submitted has been obtained via In-Character means.))
    
    Signed,
    
    [Vince Taylor]
    [Master Deputy]
    [Los Santos Sheriffs Department]
    
    Date: [05/MAY/2025]

  

Terence Williams
Attorney General
San Andreas Judicial Branch
234-9321 — [email protected]

[Bobby Versace]

Bobby Versace
Private Defence Attorney
"Better Call Bobby"

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MOTION TO SUPPRESS

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Samuel Wheeler
#24-BT-0091

A Motion to Suppress was filed in the above case on the 19 of May, 2025.

The Defendant, by and through the undersigned attorney, filed this Motion to Suppress, and requests to following be suppressed from evidence;

• Exhibit 2: Witness Statement, Deputy Sheriff Trainee Aurora Rose
  Requested Evidence to Suppress:Highlighted Section

  • Exhibit #2: Witness statement - Deputy Sheriff Trainee Aurora Rose

    

    

    
    San Andreas Judicial Branch
    Official Witness Statement
    "HERE FOR YOU | SAFE FOR YOU"

    Case Information

    • Case Number: [Case Number]
      Incident Date: [01/JAN/2000]

    Witness Information

    • Name: [Aurora Rose]
      Date of Birth: [11/NOV/1995]
      Phone Number: [562-6573]
      Occupation: [Deputy Sheriff Trainee]

    Witness Statement

    • [Hello and good morning. The evening started off with myself and my partner Deputy Taylor patrolling together, during our patrol there was a radio call from Deputy Carter advising of his conducting of a traffic stop on the defendant. He requested K9 to be on scene and as a result of this, the defendant evaded. As there was already multiple units, myself and Taylor did not respond until we heard of shots being fired. The pursuit ended and concluded in catfish, where myself and Taylor were last on scene. I noticed the defendant on the ground injured and in need of BLS and no other deputies were attending to him, so I cuffed him, read his rights and quickly attended to providing him BLS. Once this was done, I concluded patting him down and identifying him. He was in possession of Marijuana Blunts which warranted my charging of Possession while armed. After this, I was approached by a PD Detective informing of me of drugs that were retrieved from the defendant, and was asked to charge with the other possession charge, I re-confirmed this with the detective on scene, as well as my partner Deputy Taylor and placed the charge as a result of their instructions. Sadly I am not able to recall the name of the detective involved, but do remember he was within PD. The defendant was then assisted by MD where he was then taken to Paleto MD for further treatment and and moved into our cruiser for transportation to DOC.]

    Witness Affirmation

    • I, [Aurora Rose], affirm that the above statement is true to the best of my knowledge and belief. I affirm that this statement has been made voluntarily, made without promise of reward, and made not under threat, force, or coercion. ((I affirm that all information submitted has been obtained via In-Character means.))
      
      Signed,
      
      
      [Aurora Rose]
      [Deputy Sheriff Trainee]
      [Los Santos Sheriff Department]
      
      Date: [06/MAY/2025]

    
    

  
  

  • Detailed Reasoning: I believe the section highlighted in blue to be speculation and/or hearsay, Deputy Sheriff Trainee Aurora Rose has stated that she was not on scene during the traffic stop, therefore did not witness the events of it, so to definitively say that the defendants fled the scene as a result of the K9 being called, has to be speculation, or something that she was told, which would be hearsay as she did not witness it herself.

Private Defence Attorney
Better Call Bobby
344-6745 — [email protected]

[Bobby Versace]

Bobby Versace
Private Defence Attorne
"Better Call Bobby"

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MOTION TO COMPEL DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Samuel Wheeler
#25-BT-0091

A Motion to Compel Discovery was filed in the above case on the 19 of May, 2025.

The Defendant, by and through the undersigned attorney, filed this Motion to Compel Discovery, and requests as follows;

• Requested Discovery: Body Camera Footage - Deputy Sheriff Trainee Aurora Rose
  • Detailed Reasoning: This evidence is crucial to the case. My client does not believe he was ever read his rights which would make any evidence found during the searching of his person invalid, as the search would have violated the Miranda Rights. I request this evidence so that we can verify whether or not my client was read his rights.

Private Defence Attorney
Better Call Bobby
344-6745 — [email protected]

[Terence Williams]

San Andreas Judicial Branch Docket Notice "HERE FOR YOU | SAFE FOR YOU"

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• Honorable Judge Yukimura and pertaining parties,
  
  The Prosecution will not issue a formal objection to the contents of defense counsel's Motion to Suppress, as the motion itself is a breach of trial procedure. As outlined in the press release regarding the recent changes to the state court system, bench trials are not subject to motions on the docket, but rather during a pre-trial hearing or during trial itself. As such, we argue that the motion should be rejected on the principle of wrongful filing and instead be brought up at either of the above-mentioned options.
  
  In addition, regarding defense counsel's subpoena request, the Prosecution requested bodycam footage from the involved officers at the beginning of our investigation, as we do for all our investigations. However, we did not receive any footage on account of its lack of availability.
  
  Regards,
  
  Terence Williams
  Attorney General
  San Andreas Judicial Branch
  234-9321 — [email protected]

[Bobby Versace]

Bobby Versace
Private Defence Attorne
"Better Call Bobby"

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Honourable Judge Yukimura and pertaining parties,

The Defence finds the Officer involved being unable to provide any form of bodycam footage distressing to say the least. My Client believes that his fundamental right to having his Miranda Rights read to him has been violated and that the search thereafter was done illegally. This is especially troubling as, if this is to be the case, the Deputies witness statement would have serious reliability issues, and any evidence they found during the searching of my client would have to be voided due to the illegality of its finding.

The Defence would like to kindly request that the prosecution attempt to source bodycam footage again, as every Officer or Deputy should have a bodycam worn when on duty.

Regards,

Private Defence Attorney
Better Call Bobby
344-6745 — [email protected]

[Terence Williams]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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OBJECTION

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Samuel Wheeler
#25-BT-0091

An Objection was filed in the above case on the 21st of May, 2025.

The State of San Andreas, by and through the undersigned attorney, filed this objection and requests that the following be denied;

• Motion being objected to:
  Defense counsel's recent Motion to Compel Discovery
  
  • Detailed Reasoning: The Miranda Rights is a customarily given notification addressing criminal suspects', detainees', and/or arrestees' constitutional right to silence and protection from self-incrimination. The Miranda rules specifically apply to the use of testimonial evidence in criminal proceedings as a result of a questioning or interrogation of a criminal suspect. There is no testimonial evidence involving the defendant in this case, there is only physical evidence and eyewitness testimony from the involved deputies.
    
    Whether or not the defendant had their Miranda Rights read to them is immaterial to this case as there is no testimony-based evidence presented. As such, the Prosecution is requesting that the motion be denied due to a lack of foundation and relevance.

Terence Williams
Attorney General
San Andreas Judicial Branch
234-9321 — [email protected]

[Bobby Versace]

Bobby Versace
Private Defence Attorney
"Better Call Bobby"

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MOTION FOR VOLUNTARY DISMISSAL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Samuel Wheeler
#25-BT-0091

A Motion for voluntary dismissal was filed in the above case on the 26of May, 2025.

The Defendant, by and through the undersigned attorney, filed this Motion for voluntary dismissal, and the reasoning for request is as follows:

Reasoning: Defendant no longer wishes to contest

Detailed Explanation: After further discussion, my client no longer wishes to contest his charges.




Private Defence Attorney
Better Call Bobby
344-6745 — [email protected]

[Hope Kant]

San Andreas Judicial Branch Docket Notice "HERE FOR YOU | SAFE FOR YOU"

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• Prosecution and defense counsel,
  
  The defenses motion for voluntary dismissal is granted. However the courts would like to note that they can simply request to enter a guilty plea. Whenever an individual contests a criminal charge in the Superior Court, they are essentially entering a 'not guilty' plea. When they make the decision to no longer move forward, they enter a guilty plea.
  
  Respectfully,
  
  Associate Justice
  Branch Administrator
  San Andreas Judicial Branch
  505-9925 — [email protected]