San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"
MOTION TO COMPEL DISCOVERY
IN THE SUPERIOR COURT OF SAN ANDREAS
State of San Andreas v. Joe Ryan
#26-BT-0056
A Motion to Compel Discovery was filed on 11/JUL/2026.
The Defendant, appearing self-represented, respectfully asks the Court to order production of the following discovery:
- Requested Discovery: All available bodycam footage from Police Cadet Jonathan Martin, Police Officer III Jonathan Norton, and Police Officer III Rafael Mendoza relating to this incident, pursuit, arrest, search, seizure of evidence, and placement of the GF10 - Grand Theft charge.
- Reasoning: The arrest report identifies these officers as being involved in the incident and relies upon a single cadets observations to support the disputed charge. The requested footage is necessary to review what each officer personally observed, the circumstances of the arrest and search, what items were allegedly recovered from the Defendant, and whether the footage supports or contradicts the narrative and photographs submitted by the State.
- Requested Discovery: All available bodycam footage from any other Police Department or Sheriff's Department officer involved in the incident whose observations or actions are relied upon to support GF10 - Grand Theft.
- Reasoning: The defence appreciates that this is a broad request, however, the arrest report states that both the Los Santos Police Department and Los Santos Sheriff's Department were involved, that visual contact was lost and later regained, and that the Defendant allegedly was able to dismantle an ATM before officers regained visual contact. Footage from any officer relied upon for those claims is necessary to establish what was personally observed, when visual contact was maintained or lost, and the factual basis connecting the Defendant to the alleged Grand Theft offence.
- Requested Discovery: Bodycam footage showing the Defendant's arrest, frisk and also the recovery, handling, or recording of any property allegedly seized from the Defendant.
- Reasoning: The State relies upon property allegedly being found during the frisk of the defendant to support the charge of GF10 - Grand Theft. The requested footage is necessary to determine what was recovered, where it was recovered from, who recovered it, and whether the submitted photographs accurately represent the property allegedly seized from the Defendant during this incident.
- Requested Discovery: If any of the requested bodycam footage does not exist, was not recorded, was not retained, is corrupted, or is otherwise unavailable for any reason the defence requests written confirmation identifying the unavailable footage and the reason it cannot be produced.
- Reasoning: The Defendant respects that some of the requested discovery is quiet broad and a period of time has passed so if the bodycam footage is unable, the defence requests confirmation of whether the relevant footage exists before trial so that the absence or unavailability of that evidence can be properly considered by the defence when assessing the reliability and completeness of the State's case.
All the requested material is directly relevant to the disputed charge, the arrest and search, the alleged recovery of evidence, and any evidence beneficial to the defence.
The defence would also like to respectfully request that, as the Court has begun the scheduling process, this motion be resolved and that any available footage be disclosed before a Notice of Trial is issued. The Defendant would also like to respectfully request a reasonable opportunity and period of time to review any footage or statements that may be presented if this motion is granted alongside any necessary motions or arguments that may be presented before the Court considers any submissions as final.
Self-Represented Defendant
Joe Ryan
