#25-AP-0003 Cyrus Raven v. State of San Andreas

[Cyrus Raven]

Appellant Name: Cyrus Raven
Appellant Attorney(s): Cyrus Raven

Trial Docket Number: 24-CM-0020
Presiding Trial Judge: Bret Hyland
Notice of Appeal Filed:

• [ ] Before Verdict
  [X] After Verdict

Reason for Notice of Appeal:

• [ ] Motion to be overturned
  [ ] Errors in the trials procedure
  [X] Errors in the judge's interpretation of the law
  [ ] New evidence proving appellants innocence

Grounds for Appeal: (Maximum 150 words)

• The Defense is filling this appeal on the belief there were errors in the Superior Court Judge's interpretation of GF09 - Embezzlement.
  
  The guilty verdict was issued on two incorrect assumptions surrounding GFO9:
  
  • Ownership - The penal code specifies that embezzlement occurs when there is a fraudulent misappropriation of funds or property "owned by someone else. The Defendant was given a donation and ownership was transferred to the Defendant the moment the funds left the bank accounts of Vince Williams and James Eriksen.
  • Intent - The Defense argues there was a misinterpretation of the spirit of the law by the Superior Court Judge. The Defense argues the intent behind GF09 is to criminalize the misuse of funds by an individual/entity owned by another individual/entity. (e.g Government Agencies using treasury funds for non-government related spending or a shareholder using company funds for unauthorized personal use). The Defendant owned the money and had legal control over it.
    
    The above combined with the two witness statements from the donors makes it clear the Defendant was acting in good faith absent any rules, laws or.regulations surrounding campaign donations when the funds were mixed with his personal wealth and further asserts no evidence was provided of campaigns funds being used for personal purchases only that personal purchases were made sometime after the campaign.

[Hope Kant]

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

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• Petitioner
  
  Thank you for your submission to the Court of Appeals. As I have a clear conflict of interest on the above case, due to the overlap of my previous position within the Prosecution division, this case will not be activated at the moment. However, we will be looking to assign a Justice to the case in due time. Thank you for your patience.
  
  Respectfully,
  
  
  Branch Administrator
  San Andreas Judicial Branch
  505-9925 — [email protected]

[Joseph Horton]

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

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NOTICE OF ACTIVATION

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IN THE SAN ANDREAS COURT OF APPEALS

Cyrus Raven v. State of San Andreas
#25-AP-0003

A Notice of Activation was entered in the above appeal on the 7th day of December, 2025.

• The case of Cyrus Raven v. State of San Andreas is hereby activated by this Court under #25-AP-0003.
  
  The Court will not be ordering either party to present an initial brief at this time, as the Court will leave this case in recess until both the appellant and opposing party counsel provide notice to this Court that they are ready to proceed. The Court requests that the appellant, or their Counsel, provide notification to this Court within the next thirty (30) days. Once notice is provided, the Court requests that the opposing party provide their notification subsequently.
  
  If the Court does not receive notice within thirty (30) days, the Court will review the case to understand if any extensions may be required to this timeframe.
  
  So ordered,
  
  
  Superior Court Justice
  San Andreas Judicial Branch
  274-6959 — [email protected]

[Joseph Horton]

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

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• Concerned parties,
  
  The Court acknowledges that it has been over the thirty (30) day window it originally gave; however, given the duration that this case was previously not activated, the Court will grant one final thirty (30) day window for the appellant to reach out to the Court.
  
  Respectfully,
  
  Superior Court Justice
  San Andreas Judicial Branch
  274-6959 - [email protected]

[Rowin Lawson]

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

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MOTION FOR VOLUNTARY DISMISSAL WITH PREJUDICE

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
#25-AP-0003

A Motion for Involuntary Dismissal with Prejudice was filed in the above case on the 9th day of March, 2026.

The State of San Andreas, by and through the undersigned attorney, filed this Motion for Involuntary Dismissal, and the reasoning for request is as follows;

• Reasoning: The prosecution would like to urge the courts to consider a dismissal in regard to this appeal. As can be seen on the docket, the appellant has been unreachable by the court. Justice Horton gave notice of a final (30) day window for the appellant to contact the court. That was (57) days ago, The prosecution again urges the court to dismiss this appeal.

Rowin Lawson
Deputy Attorney General
San Andreas Judicial Branch
451-9939 - [email protected]

[Hugh Allgood]

San Andreas Judicial Branch
Personal Email
"EQUAL JUSTICE UNDER LAW"

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• Dear Honorable Horton & Attorney General Lawson,
  
  This appeal was filed by Mr. Raven, on his own accord. It should be noted, I was the attorney who represented him at trial (I represented Mr. Raven under my former law office, Allgood Law).
  
  Given my recent appointment as Chief Public Defender, I would be willing to represent Mr. Raven in this capacity - although Mr. Raven is apparently unreachable, if the Court is so willing.
  
  Respectfully,
  
  
  Chief Public Defender
  San Andreas Judicial Branch
  235-6076 - [email protected]

[Joseph Horton]

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

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• Prosecution and defense counsel,
  
  The Court acknowledges the response from Mr. Allgood and appreciates the offer.
  
  The Court was slated to dismiss this appeal due to a lack of representation and response from the appellant; however, given the unique circumstances of Mr. Allgood being the previous counsel on the original docket, the Court will accept the offer of representation.
  
  With that being said, the Court will allow fourteen (14) days for the appellant to present their initial brief. If additional time is required, please file an appropriate Motion for Continuance.
  
  Respectfully,
  
  
  Associate Justice
  San Andreas Judicial Branch
  274-6959 - [email protected]

[Hugh Allgood]

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

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• Honorable Justice Horton and pertaining parties,
  
  First off, the Defense would like to thank Justice Horton for allowing me to respond to this appeal in Mr. Raven's absence, and counsel would like to apologize to the Court for the unresponsiveness on Mr. Raven's behalf.
  
  As the appellant articulated in the grounds for appeal, this appeal comes on Judge Bret Hyland finding the appellant guilty of GF09 - Embezzlement, following a bench trial in the Superior Court of San Andreas on November 3rd, 2024.
  
  In the reasonings given for the verdict, Judge Hyland mentioned the reason for the verdict was the funds donated to Mr. Raven were given to him to use in his campaign bid for the Law Review Committee (LRC) and the specific donations were provided by two individuals, Vince Williams and James Eriksen and were to be used for the advancement of Mr. Raven's political career. But instead, the funds were used to purchase multiple properties and vehicles. It's important to mention and note, Mr. Raven was successful in getting elected to the LRC in December 2022 (State's exhibit #1).
  
  Defense counsel wishes to point this Court to review Defense exhibits #1 and #2, filed on May 11th, 2024, as these are written statements obtained directly from Mr. Williams and Mr. Eriksen, the individuals Mr. Raven was convicted of misappropriating funds from. Both individuals confirm the funds received by Mr. Raven were donations that Mr. Raven received during his campaign for political office. Mr. Eriksen states the donation was intended to support Mr. Raven, and was not a payment for any other services or goods. Mr. Williams states the donation was provided in the hopes of Mr. Raven using it for his political career, and states "no conditions were imposed on Mr. Raven for receiving the donation." In State's exhibit #12, Mr. Raven confirms a portion of this money was in-fact used for his political campaign, with approximately $200,000 used for Weazel advertisements and the rest kept in reserves, in the event these funds were needed for other campaign expenses. In Mr. Raven's own words, a Comet S2 was purchased after the LRC campaign. There is no other information provided by Mr. Raven, or within the State's case of when any other purchases were made, either during or after the LRC campaign.
  
  As the appellant articulated and defense counsel affirms, embezzlement only occurs with the misappropriation of someone else's money or property. The money at issue here was received by the appellant as a donation. Therefore, the money was property of Mr. Raven, and therefore the only person who can claim the funds were misappropriated would be Mr. Raven himself.
  
  In further support of this argument, Mr. Williams and Mr. Eriksen both stated there were no conditions imposed on the receipt of money, such as a claim of the money being "loaned" to Mr. Raven, or entrusted to Mr. Raven to be spent in any specific manner, or remaining proceeds to be returned upon the conclusion of Mr. Raven's LRC election. In fact, Mr. Raven stated one of the purchases the State contends is embezzlement of funds occurred after Mr. Raven was elected to the LRC. The State did not provide any evidence of Mr. Williams or Mr. Eriksen demanding any portion of their funds back from Mr. Raven or of claiming Mr. Raven making any unauthorized purchases (both Mr. Williams and Mr. Eriksen did not claim any complaints with how their donations were spent either).
  
  It is also important to note, an important element of the charge of embezzlement that the State must prove in order to find someone guilty is the misappropriation of someone else's money or property. In order to prove this claim, there must be a complaining party. Directly speaking, in order for Mr. Raven to be found guilty of misappropriating the $1,000,000, a) the State must prove the money was property of either Mr. Williams or Mr. Eriksen, and b) that either party claimed their property was misappropriated. The State can prove neither. Neither Mr. Williams nor Mr. Eriksen are complaining parties, and importantly, neither were a witness for the State. In fact, both in their sworn statements have provided information to the contrary.
  
  Counsel notes only recently did the LRC implement any kind of system of registering campaign donations, or setting any limits on such. Even in these regulations, which did not exist at the time of the events in question, there are no regulations on what happens with campaign donations at the conclusion of an election cycle. No such regulation existed then or now, and this is also supportive of what Mr. Raven did back in 2022 to not be unlawful or otherwise prohibited.
  
  For clarification, defense counsel believes Mr. Raven's campaign, and the donation received during the campaign, to merely be a distraction or "mud in the water". A donation is a donation. An easier way to look at this is to think of other situations where a donation is received and how such proceeds are used. To illustrate this point, if Defense counsel tells another citizen about their desire to buy a Kamacho, and that other citizen gives Defense counsel a sum of money to be used towards a Kamacho, is Defense counsel bound to use the money for such purchase? What if defense counsel, after test driving several vehicles, chooses instead to purchase a Terminus? Did Defense counsel just misappropriate the funds initially provided as a donation to buy a Kamacho? In order for this Court to uphold Mr. Raven's conviction for embezzlement, this Court must answer "yes" to this question.
  
  In summary - (1) a donation is a donation. Once a donation is made, the item or proceeds donated become the property of the recipient. In this present case, Mr. Raven received $1,000,000 from two individuals, and this money became Mr. Raven's property. (2) What someone does with their property, is not capable of being misappropriated. (3) The State failed to meet their burden of proof, due to the absence of a party complaining of their property misappropriated. (4) There were and are no regulations on how campaign donations are used, either during or after a campaign. And for these reasons, the appellant believes a clear finding of Judge Hyland misinterpreting the law must be made, and Mr. Raven's conviction should be reversed.
  
  
  Chief Public Defender
  San Andreas Judicial Branch
  505-9925 — [email protected]

[Joseph Horton]

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

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• Counsel,
  
  The Court appreciates the promptness of the appellant's appeal.
  
  Defense, please provide your opposing brief within the next fourteen (14) days. The Court is mindful of the large workload your Office faces, so please inform the Court if additional time is required at this point.
  
  Respectfully,
  
  
  Associate Justice
  San Andreas Judicial Branch
  274-6959 - [email protected]

[Hugh Allgood]

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

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• Honorable Justice Horton and pertaining parties,
  
  The respondent has not responded within 14 days, and the appellant would respectfully request a decision on this matter as is, considering the arguments of the appellant.
  
  
  Chief Public Defender
  San Andreas Judicial Branch
  505-9925 — [email protected]