Jonathan Mcstone v. Sheriff's Department | Docket #21-12-27-AP-023

[IamBOBBY]

San Andreas Judicial Branch [SAJB] Appeals Court "HERE FOR YOU | SAFE FOR YOU"

Personal Information:

DEFENDANTS NAME: Jonathan Mcstone
DEFENDANTS PHONE: 297-4048
DEFENDANTS ADDRESS: No permanent residency
ATTORNEY NAME: Hugh R. Allgood
ATTORNEY PHONE: N/A

General Information:

OFFICERS NAME: N/A
RANK: N/A
BADGE NUMBER: N/A
ATTORNEY NAME: N/A
ATTORNEY PHONE: N/A

Incident Information:

DATE AND TIME OF INCIDENT(s): 27th December, 2021

CHARGES BEING APPEALED: Felony Evasion

DEFENDANTS STORY/OPENING STATEMENTS: I had just awoken up and taken my vehicle out of the paid parking in the city. I decided I was going to make some money so I chose to mine in the county. I proceeded to the store located behind the LS Bank in order to purchase a burger and a bottle of water and the plan was to get a pickaxe there. Before I was able to purchase said pickaxe a few sheriffs ran into the store and pointed weapons at me and ordered me to the ground, I was then placed in cuffs with no questions being asked and nothing being properly explained and taken to the prison.
(any evidence attached must pertain to or somehow involve the situation)

Signed,
Jonathan Mcstone

[Sai Modi]

San Andreas Judicial Branch Re: Jonathan Mcstone | (27/DEC/2021) "HERE FOR YOU | SAFE FOR YOU"

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• Your Honor,
  
  My name is Sai Modi and I will be acting as counsel for the Los Santos Sheriff's Department in this case. I am familiarizing myself with the case and will be reaching out to the client to gather more information.

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Respectfully,


Sai Modi
State Attorney
San Andreas Judicial Branch
364-9436

[Hugh Allgood]

San Andreas Judicial Branch Re: Jonathan Mcstone charge appeal "HERE FOR YOU | SAFE FOR YOU"

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• San Andreas Appellate Court,
  
  I, Hugh R. Allgood, will represent Mr. Mcstone in this appeal. I will be meeting with Mr. Mcstone soon to go over this case and will be ready to proceed at the courts discretion.
  
  From
  
  
  Hugh R. Allgood
  State Attorney
  San Andreas Judicial Branch

[Roy Judge]

San Andreas Justice Department RE: Jonathan McStone v. Sheriff's Department | Docket #21-12-27-AP-023 "HERE FOR YOU | SAFE FOR YOU"

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• To whom it may concern,
  
  I am Appellant Judge Roy Duke-Judge and I will be the presiding judge on this case. This case is now marked as ACTIVE. You will now have (7) Seven Days to submit any evidence and motions to the court. Once that is done, I will send appropriate notices of action and a hearing will be scheduled.

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• From
  
  Appellant Judge Roy Duke-Judge
  San Andreas Judicial Branch
  San Andreas Government

[Hugh Allgood]

Motion to Compel Discovery

San Andreas Judicial Branch
Motion to Compel Discovery

Honorable : Roy Duke-Judge

• We the appellant in the case below are requesting the disclosure of the following material by opposing counsel, please find a detailed reason as to our request below.

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  Jonathan Mcstone v. Sheriff's Department
  Assigned Court Case Number: 21-12-27-AP-023
  Requesting Party: Appellant
  Party Members: Jonathan McStone (through Senior Attorney Hugh R. Allgood)

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  Discovery from: Los Santos County Sheriff's Department
  
  Type of Discovery: Deposition & Document Request
  • Document Request: Arrest report for this arrest
  • Witness statements from the arresting officer and any Officers involved in the placing of charges upon my client.
  Detailed reasoning: [Provide a detail explanation as to the relevance of the discovery request]
  • Mr. McStone was charged with felony evading after being arrested within a store. As Mr. McStone stated, no questions were asked of him and there is really no explanation as to why he was charged with felony evading. Penal code VF01 stated felony evading is, "Evading police with the use of any vehicle including standard road vehicles, off road vehicles, and bicycles." From discussions with Mr. McStone, Mr. McStone is adamant he was not in a vehicle at the time of his arrest. Therefore, the appellant is requesting this discovery to explain the reasoning for the charges as placed by the Sheriff's Department.

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  Thank you for your consideration.

Sincerely

Senior Attorney Hugh R. Allgood
Attorney for appellant

[Roy Judge]

San Andreas Justice Department RE: Jonathan McStone v. Sheriff's Department | Docket #21-12-27-AP-023 "HERE FOR YOU | SAFE FOR YOU"

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• To whom it may concern,
  
  I would like to make it known that this case is currently pending counsels return from sanctioned leave and will continue in due course, we request that involved parties remain patient in the meantime.

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• Thank you,
  
  Appellant Judge Roy Duke-Judge
  San Andreas Judicial Branch
  San Andreas Government

[Albert Lewis]

San Andreas Judicial Branch Person Email "HERE FOR YOU | SAFE FOR YOU"

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• Greetings Your Honor,
  
  I would like to inform the court that I will be taking over primary lead on this case. My. Modi will be my secondary. Mr. Modi has handed me all the documents and evidence for this trial and I am prepared to proceed at the courts discretion.

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• Respectfully,
  
  Albert "Big Al" Lewis
  State Attorney
  San Andreas Judicial Branch
  464-6046

[Albert Lewis]

Discovery

San Andreas Judicial Branch
Discovery

Honorable Roy Duke-Judge,

• We the consel for Los Santos Sheriff's Department in the case below are presenting our discovery to the court.

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  Jonathan McStone v. Los Santos Sheriff's Department
  Assigned Court Case Number: 21-12-27-AP-023
  Requesting Party: Appellant
  Party Members: Jonathan McStone (through Senior Attorney Hugh R. Allgood)

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  Exhibit #1: Arrest Report
  Type of Discovery: Deposition & Document Request
  Spoiler

  All Information from the Discovery

  • ARREST REPORT
    

    MUGSHOT

    SUSPECT 1 DETAILS

    • 
      Full Name: Jonathan McStone
      Licenses Revoked: Yes
      • Driver
      Charges:
      • VF01 - Felony Evading
      How did the suspect plea to the above charges?
      Suspect pleaded guilty to all charges.
      Additional Details (Suspect's vehicle, etc.) :
      Blue Sentinel.

    DEPUTY DETAILS

    • Full Name: Madison Hall
      Badge Number: 11516
      Callsign: 12-R-17

    INCIDENT DETAILS

    • Date of Arrest: 2021-12-27
      Deputies Involved: Pierce Hardy & others.
      
      Provide details of the incident leading up to the arrest
      • My unit was driving north bound past Legion Square, when we noticed a blue vehicle driving incredibly fast. We chased the vehicle and took it to TAC, before he stopped outside a grocery store behind Los Santos bank. We got the man on gunpoint and arrested him without and complications.

    EVIDENCE DETAILS

    • Exhibit A: N/A.

    ARRESTING DEPUTY SIGNATURE
    
    

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  Exhibit #2: Interview with Officer Madison Hall
  Type of Discovery: Deposition & Document Request
  Spoiler

  All Information from the Discovery

  • 
    

    
    San Andreas Judicial Branch
    Official Witness Statement
    "HERE FOR YOU | SAFE FOR YOU"
    Case Information
    • Case Number: 21-12-27-AP-023
      Incident Date: 27/DEC/2021
    Witness Information
    • Name: Madison Hall
      Date of Birth: 03/MAY/1999
      Phone Number: 344-2375
      Occupation: Police Officer in Los Santos Police Department
    Witness Statement
    • [During a patrol, myself and my partner saw a vehicle drive past us by the parking lot in the city. The vehicle drove past us in a high speed, probably about 150+ km/h. The vehicle didn't stop for approximately 20-30 seconds, and therefore we called it in for a pursuit. The vehicle finally stopped at the Zeta Store, behind Los Santos bank. The suspect jumped out the vehicle after parking the vehicle on the sidewalk, and ran inside the store. He was given demands, and put in custody inside the store. Mr McStone was confused and stated he didn't rob the store, which we explained wasn't the reason for the arrest. We explained that we chased the suspect and he failed to stop to lights and sirens. He got charged for felony evading and brought to DOC by another unit.]
    Witness Affirmation
    • I, [Madison Hall], 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,
      
      
      [Madison Hall]
      [Police Officer II]
      [Los Santos Police Department]
      
      Date: [5/MAR/2022]
    

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Sincerely,


Albert "Big Al" Lewis
State Attorney
San Andreas Judicial Branch

[Hugh Allgood]

Exigent Ex-Parte Motion

Honorable Duke-Judge,

I am filing two exigent motions in tandem in reference to this case; a motion to suppress and a motion for involuntary dismissal. You will find both motions attached below:

Motion to Suppress

Motion to Suppress

San Andreas Judicial Branch
Motion to Suppress
"HERE FOR YOU | SAFE FOR YOU"

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Honorable : Duke-Judge

• We the appellant in the case below are requesting that certain evidence be inadmissible in court.

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  Assigned Court Case Number: 21-12-27-AP-023
  Requesting Party: Appellant
  Party Members: Jonathan Stone (Appellant) vs. Los Santos County Sheriff's Department (respondent)

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  Requested Evidence to Suppress: Statement from Madison Hall and the arrest report for Jonathan Mcstone

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  Detailed explanation:
  Counsel for the Los Santos County Sheriff's Office is intending on submitting evidence which was disclosed in violation of the proscribed discovery process. Honorable Duke-Judge began the period for discovery on 1/FEB/2022, and gave both sides 7 days to present any evidence and motions. I filed a timely motion for discovery on 5/FEB/2022. The discovery period closed on 7/FEB/2022.
  
  Within the contested evidence released, the statement from Madison Hall (who is now listed as a Police Officer?) is dated 5/March/2022. This statement was collected well beyond the discovery period closing. Furthermore, the evidence contained within the arrest report was also provided to myself and my client beyond the discovery closing, and only in response to a hearing which we are trying to schedule to hear the facts and determine the next course of action. Counsel for the Los Santos Sheriff's Department have had ample time to provide this information in response to my motion, and have not done so.

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  Thank you for your consideration.

Sincerely

Senior Prosecuting Attorney
Attorney for Jonathan Mcstone

Motion for involuntary dismissal

Motion for Involuntary Dismissal

San Andreas Judicial Branch
Motion for Involuntary Dismissal
"HERE FOR YOU | SAFE FOR YOU"

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Honorable : Duke-Judge

• We the appellant in the case below are requesting an involuntary dismissal from the court, please find the reason for it below.

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  Assigned Court Case Number: 21-12-27-AP-023
  Requesting Party: Appellant
  Party Members: Jonathan Stone (Appellant) vs. Los Santos County Sheriff's Department (respondent)

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  Involuntary Dismissal: Failure to turn over evidence in a timely manner

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  Detailed explanation:
  As detailed in the motion to suppress, counsel for the Los Santos County Sheriff's Department did not respond to appellant's motion for discovery for over a month. Hence the reason this evidence is being requested for suppression, should this motion for involuntary dismissal fail.

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  Thank you for your consideration.

Sincerely

Senior Prosecuting Attorney
Attorney for Jonathan Mcstone

[Roy Judge]

San Andreas Justice Department Re: Jonathan Mcstone v. Sheriff's Department | Docket #21-12-27-AP-023 "HERE FOR YOU | SAFE FOR YOU"

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• Dear Counsel,
  
  It seems as though revelant parties will be available Wednesday 9th at 8pm, as such I request that we meet in chambers so that I may hear the presented motions. After motions have been heard and deliberations made we will proceed.

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• From
  
  Appellant Judge Roy Duke-Judge
  San Andreas Judicial Branch
  San Andreas Government

[Sai Modi]

San Andreas Judicial Branch Re: Jonathan Mcstone v. Sheriff's Department | Docket #21-12-27-AP-023 "HERE FOR YOU | SAFE FOR YOU"

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• Your Honor,
  
  I would like to withdraw myself as co-counsel for this case and allow Counselor Lewis to resume as the only prosecutor for this particular case.
  
  I wish both parties good luck.

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Respectfully,


Sai Modi
Prosecuting Attorney
Prosecution Divison
San Andreas Judicial Branch
364-9436

[Roy Judge]

San Andreas Justice Department RE: Jonathan Mcstone v. Sheriff's Department | Docket #21-12-27-AP-023 "HERE FOR YOU | SAFE FOR YOU"

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• After a preliminary hearing on 09/03/2022, the court heard motions for supression and for involuntary dismissal in the case of Jonathan Mcstone v. Los Santos County Sheriffs Department and the following was ruled:
  
  • The court denies the motion for suppression due to it being rendered inconsequential by the courts ruling on the motion for involuntary dismissal
  • The court grants the motion for involuntary dismissal due to the evidence not being submitted in a timely manner by original counsel. Despite the court going through internal changes at the time of the discovery period, this is not the defendants burden to bear and the case should be ruled as any under normal circumstances would.

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• From
  
  Appellant Judge Roy Duke-Judge
  San Andreas Judicial Branch
  San Andreas Government

[Roy Judge]

Form 3.0.5 - Issuance of Verdict

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

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ISSUANCE OF VERDICT - 21-12-27-AP-023

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IN THE APPEALS COURT OF SAN ANDREAS

Jonathan Mcstone v. Los Santos County Sheriffs Department
21-12-27-AP-023
CHARGES BEING APPEALED:
Felony evasion

A verdict was entered in the above case on the 9th day of March, 2022.

• The case of 21-12-27-AP-023 - Jonathan Mcstone v. Los Santos County Sheriffs Department has hereby been resolved.
  
  On the charge of VF01 - Felony Evasion, the defendant is hereby found not guilty.
  
  After a lengthy discussion between counsel in chambers, the motion for involuntary dismissal was granted for the following reasons: The evidence was not submitted in a timely manner by original counsel. Despite the court going through internal changes at the time of the discovery period, this is not the defendants burden to bear and the case should be ruled as any under normal circumstances would.
  
  The case is now closed.
  
  • CHARGES BEING APPEALED:
    VF01 - Felony Evasion
  
  
  
  Appellate Judge
  Appeals Court
  San Andreas Judicial Branch