#22-CM-0003, State of San Andreas v. Brayden Rush

Post by **Brayden Rush** » 22 Oct 2021, 21:13

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

Personal Information:

DEFENDANTS NAME: Brayden Rush
DEFENDANTS PHONE: 2421223
DEFENDANTS ADDRESS: N/A
ATTORNEY NAME: Letov Vladislav
ATTORNEY PHONE: 4181478

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): October 21, 11:00 P.M EST

CHARGES BEING APPEALED:
Attempted Murder Of a government employee
Possession of an illegal firearm
Possession of weapon modification

DEFENDANTS STORY/OPENING STATEMENTS: I was heading to DOC with a friend to visit another friend who just recently been arrested. When I arrived on my bike I was caught in the crosshairs of a gun fight between SD and some other people. After I was hurt and on the ground someone came over to me and placed a gun on me and drove off. I was then brought into DOC by a guard until I was able to receive medical attention, it was when I got inside, the guard informed me that I was being charged.

Signed,
Brayden Rush

Post by **Hugh Allgood** » 30 Dec 2021, 05:04

San Andreas Judicial Branch
Re: Brayden Rush charge appeal
"HERE FOR YOU | SAFE FOR YOU"

San Andreas Appellate Court,

I, Hugh R. Allgood, will represent the Los Santos County Sheriff's Department in his appeal. I will be meeting with my clients 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

Post by **Colt Daniels** » 02 Jan 2022, 07:02

San Andreas Judicial Branch
Re: Brayden Rush v. Sheriff's Department | Docket #
"HERE FOR YOU | SAFE FOR YOU"

Mr. Rush,

Please understand that Counsellor Vladislav is no longer an employee here at the Judicial Bureau, thus you may seek new counsel or employ Mr. Vladislav yourself. Understand that currently there are no regulations in place for private attorneys outside of the Bar Licensing bureau and as such you are required to do your own due diligence when employing an attorney. To continue to permit him to represent, we require a signed, authenticated contract between both parties. You will be permitted 7 days to provide one.

If at the end of the 7 days provided we do not have said contract, a new attorney will be assigned to your case to represent you.

From

Appellate Judge
San Andreas Judicial Branch
(909) 402-9713 — [email protected]

Post by **Darby Adler** » 17 Jan 2022, 01:10

San Andreas Justice Department
Re: Brayden Rush v. Sheriff's Department | Docket #

"HERE FOR YOU | SAFE FOR YOU"

Appellant and respondent,

I will be the presiding judge on this case. This case is now marked as ACTIVE. Before any motions start getting submitted to the docket I would like both sides to have appropriate representation. I will be reaching out to Attorneys to find the Appellant such support. Once an Attorney has been assigned and that is made clear on the public docket I will then give each side (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.

Ahead of time for Counsel representing the appellant and the appellant themselves - please note that by undertaking a prima facie examination of your appeal, there is little detail for the basis of your appeal. I would expect a clear narrative to explain the allegations of the appeal that has been made, the basis of how you have come to such a position and what evidence would support them. This Court will not entertain frivolous claims and there is an ethical obligation on attorneys not to bring such.

Regards,

Darby Adler
Appellate Judge
San Andreas Judicial Branch
San Andreas Government

Post by **Darcy Valor** » 22 Feb 2022, 00:00

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

Honorable Darby Adler,

I will be representing Mr. Brayden Rush in this appeal. I have been in contact with my client and we are ready to proceed at the court's discretion.

Respectfully,

Attorney at Law Darcy Lafleur
San Andreas Judicial Branch
(909) 241-7634 — [email protected]

Post by **Darby Adler** » 06 Mar 2022, 19:44

San Andreas Justice Department
"HERE FOR YOU | SAFE FOR YOU"

Dear all,

Now we have appropriate representation I would ask the appellant to make the motions and requests it feels relevant to get this rolling.

From there, the State can respond as it would usually.

Sincerely,

Honorable Darby Adler
Appellate Judge
San Andreas Judicial Branch
San Andreas Government

Post by **Darcy Valor** » 06 Mar 2022, 19:55

Motion to Compel Discovery

San Andreas Judicial Branch
Motion to Compel Discovery

Honorable : Darby Adler

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.
Brayden Rush vs. Sheriff’s Department
Assigned Court Case Number: #21-10-22-AP-018
Requesting Party: Appellant
Party Members: Brayden Rush and Darcy Lafleur
Discovery from: Los Santos Sheriff’s Department and Department of Corrections

Type of Discovery: Physical Evidence/Document Request
- Document Request- Arrest Report of Brayden Rush from this incident on Oct. 22 2021
  Physical Evidence- Any bodycam/CCTV footage from the incident on DOC grounds that happened on Oct. 22 2021.
Detailed reasoning:
- The arrest report of Brayden Rush will give us more information on what led the Los Santos Sheriff’s Department to arresting Mr. Rush during the gunfight at the Department of Corrections.
  Any bodycam/CCTV footage that the Los Santos Police Department or Department Of Correction guards may have from this incident will help us with building our case.
Thank you for your consideration.

Sincerely

Attorney at Law D. Lafleur
San Andreas Judicial Branch

Post by **Hugh Allgood** » 07 Mar 2022, 03:49

San Andreas Judicial Branch
Re: Brayden Rush | Appeal Application
"HERE FOR YOU | SAFE FOR YOU"

San Andreas Court of Appeals,
- We the prosecution in the case below are presenting evidence to the court.
  Brayden Rush v. Los Santos Sheriff's Department
  Assigned Court Case Number: #21-10-22-AP-018
  Requesting Party: Respondent
  Party Members: Brayden Rush, Los Santos Sheriffs Department
  Honorable Adler,
  
  I have been informed, via e-mail, the arrest report for Mr. Rush does not exist. Therefore, there is no documentation to release to opposing counsel in this regard. See the below attachment
  E-mail from Master Deputy S. Lee in response to request for arrest report
  Steven Lee wrote: ↑30 Dec 2021, 20:22
  
  Los Santos County Sheriff's Department
  Personal Email
  "A TRADITION OF SERVICE"
  
  December 30th, 2021
  Dear State Attorney Hugh R. Allgood,
  
  sadly, I can not provide you a copy of the arrest report since it does not exist in our database. I believe that it would be at your best interest if you contacted Deputy W. Reno directly, but I can not promise you that he will respond to you immediately, since I've mentioned, he's currently on a two ( 2 ) week LOA.
  
  From
  
  Master Deputy Steven Lee
  Los Santos County Sheriff's Department
  I did obtain an official statement from the arresting deputy, Deputy W. Reno. See the attached statement.
  Witness Statement: Deputy Reno
  Wiley Reno wrote: ↑17 Jan 2022, 18:58
  
  San Andreas Judicial Branch
  Official Witness Statement
  "HERE FOR YOU | SAFE FOR YOU"
  
  Case Information
  
  Case Number: 21-10-22-AP-018
  Incident Date: [21/OCT/2021]
  
  Witness Information
  
  Name: [Wiley Reno]
  Date of Birth: [23/MAY/1991]
  Phone Number: [314-5473]
  Occupation: [Deputy Sheriff III]
  
  Witness Statement
  
  [On October 21st, 2021 during my Patrol I received a backup call from a unit up near the dancing disco store. The deputy informed us that there were a group of individuals wearing pink on pink bikes near the dancing disco store, at least one of which was armed. The deputy explained that they saw a silenced firearm on their hip. We quickly arrived on the scene and detained the individuals who we suspected. We attempted to efficiently clear those who were not being detained, but we weren't entirely successful. Eventually, units transported the individual in Pink to DOC.
  
  It is important to keep in mind this situation was before we were aware of the constant attacks on DOC by pink individuals, so we did not have sufficient protection for this transport that we should have. Upon arriving to DOC, the transport unit was fired upon and a shootout began between a couple of DOC guards and some individuals in pink. In this firefight, Mr. Rush was downed and I arrived as the sole unit on the CODE-1 scene at DOC, as units were tied up in the city with a pursuit. Upon arriving on the scene I saw Mr. Rush on the ground in pain with multiple gunshot wounds, along with a silenced Pistol .50 on his hip. Officer Alfonso Banker of the Department of Corrections explained to me that he had been involved in a shootout between DOC guards and the individuals in pink trying to release their comrade (Mr. Rush was wearing a full pink outfit). Mr. Rush adamantly decreed that he was not involved and that he was being shot at by the people in pink, not shooting at DOC. DOC requested I add the Attempted Murder of a Government Employee charge for this, which I did add.
  
  As for the firearm charge, when I arrived on the scene the Pistol .50 with the silencer was on Mr. Rush's hip and the only manipulation I did to it was take it off of his hip and place it in an evidence bag. It appeared to have 9 rounds discharged which only furthered my belief of DOC's testimony. Mr. Rush was transported to the hospital and then transported back to DOC. Upon his transport to DOC a CODE-1 was called by deputies on DOC grounds as Deputy Elijah Quinn was being held hostage by Mrs. Charlie Bankshot. Mrs. Bankshot negotiated with deputies for quite a while before the Sheriff's Department negotiators agreed to let those in pink go free in return for Deputy Quinn's release. Mr. Rush was released from my custody at this time, serving none of his time and exited DOC grounds on his bike. No further charges were added.
  
  Eventually, I believe he was arrested by the Los Santos Police Department, and no further charges came of this particular arrest. ]
  
  Witness Affirmation
  
  I, [Wiley Reno], 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,
  
  [Wiley Reno]
  [Deputy Sheriff III]
  [Los Santos Sheriff's Department]
  
  Date: [17/JAN/2022]
  Further, I did obtain two statements from former DOC Officer Alfonzo Banker. First, Mr. Banker did not recall the incident. However, when I informed him what the situation involved, Mr. Banker provided the follow-up statement.
  
  Statement 1 from Alfonzo Banker
  
  Alfonzo Banker wrote: ↑17 Jan 2022, 08:04 To be honest bro, I got no idea what this situation is pertaining to and if I did it was probably from such a long time ago that I wouldn't remember the details.
  
  Statement 2 from Alfonzo Banker
  
  Alfonzo Banker wrote: ↑19 Jan 2022, 00:55 From what I remember Brayden never shot his firearm. I was the one that BLSed him and handcuffed him while he was injured because of the illegal firearm on his person. I was also the one that initially identified him. I can say without a doubt that Brayden did not shoot at anybody, the fact that the firearm wasn't checked to see if it was still hot before charging him is a bit concerning to say the least. Hope my statement helps!
  
  From
  
  Hugh R. Allgood
  Senior Attorney
  San Andreas Judicial Branch

Post by **Darcy Valor** » 09 Mar 2022, 23:21

Motion for Summary Judgment

San Andreas Judicial Branch
Motion for Summary Judgment

Honorable Darby Adler,

We the Appellant in the case below are requesting a summary judgment.
Brayden Rush v. Los Santos Sheriff’s Department
Assigned Court Case Number: 21-10-22-AP-018
Requesting Party: Appellant
Party Members: Brayden Rush and Darcy Lafleur
Reasoning: We believe the evidence presented to court shows that the Pistol .50 was placed on Mr. Rush after he was shot.
Detailed explanation:
In the witness statement from Deputy Wiley Reno it states that 9 rounds were discharged from the Pistol .50, and upon his arrival to the scene Mr. Rush was on the ground in pain with multiple gunshot wounds. Deputy Reno stated as well that the only manipulation he did to the gun was take it off his hip and place it into an evidence bag. It was not further investigated for fingerprints, temperature of the gun, nor was there a GSR test conducted on Mr. Rush. This furthers our belief that the Pistol .50 was placed onto Mr. Rush by one of the attackers at DOC. The second statement from DOC Guard Alfonzo Banker, states that Mr. Rush never shot, and without a doubt Mr. Rush did not shoot anyone. With this we believe that a motion for summary judgment should be granted.
Thank you for your consideration.

Sincerely,

Attorney at Law
San Andreas Judicial Branch
(909) 241-7634 — [email protected]

Post by **Darcy Valor** » 14 Mar 2022, 20:15

Motion to Stay Pending Appeal

San Andreas Judicial Branch
Motion to Stay Pending Appeal

Honorable Darby Adler,

We the Defendant in the case below are requesting a stay pending appeal.
State of San Andreas v. Brayden Rush
Assigned Court Case Number: 21-20-22-AP-018
Requesting Party: Defense
Party Members: Brayden Rush and Darcy Lafleur
Reasoning: Errors in the trials procedures
Detailed explanation:
On October 22nd, 2021, my client Brayden Rush put in an application to appeal his charges. It is now March 14, 2022, and my client Mr. Rush has had his right to a speedy trial violated. It took months for Mr. Rush’s case to get counsel, then after both sides had counsel, it took two weeks for Judge Darby Adler to open the discovery phase, and it has been another week since Honorable Adler has said anything on the docket in regards to the motions. Darby Adler's inaction has delayed this case beyond a reasonable amount. This is a clear violation of my client's right to a speedy trial.

Thank you for your consideration.

Sincerely,

Darcy Lafleur
Public Defense Attorney

Post by **Hugh Allgood** » 14 Mar 2022, 20:45

San Andreas Judicial Branch
Re: State of San Andreas v. Brayden Rush
"HERE FOR YOU | SAFE FOR YOU"

San Andreas Superior Court Judge Adler,

From the prosecution standpoint, I wish to formally oppose defense counsel's motion for summary judgement.

First off, from the statement submitted by Deputy Reno, when he arrived the handgun was on Mr. Rush's hip, not simply laying on his body. I cannot reasonably fathom the alleged individual who discarded their weapon upon Mr. Rush would have taken the time to secure the firearm to Mr. Rush's belt/hip. This goes against logic. Therefore, I believe the charges for possession of an illegal weapon and weapon modification should stand.

Regarding the attempted murder of a government employee charge, Deputy Reno stated the firearm was missing 9 rounds of ammunition. Whether the gun was warm or not, this gun was used in the shootout with DOC. Although Mr. Rush claims the firearm was planted on him, as above, this goes against logic. Secondarily, I would like to point out once the Deputy was taken hostage, Mr. Rush was released from custody at the request of the hostage taker, who was wearing the same clothing as Mr. Rush. This is clear evidence that Mr. Rush is/was affiliated with whatever group was running around in pink, and therefore points to his motive for being involved in the shootout at DOC (which as Deputy Reno stated was in response to a member of this pink 'gang' being arrested and transported to DOC).

Former DOC Officer Banks is the only DOC officer listed in the case, but there were certainly other DOC officers there. Just because former Officer Banks did not see Mr. Rush firing his weapon, simply does not mean it did not occur. Deputy Reno was told by DOC (collectively) to place the charge of attempted murder of a government employee, which Deputy Reno investigated to support the charge (the firearm on Mr. Rush's HIP, not body, the missing rounds of ammunition, and Mr. Rush's later 'release' at the request of the pink 'gang' after a LSSD Deputy was taken hostage).

Therefore, I request the court respectfully deny this motion for summary judgement, and move this case to be set for trial.

Lastly, I am opposing defense counsel's motion to stay these proceedings, as there has not been a decision rendered by this court to be appealed.

Respectfully,

Senior Prosecuting Attorney
San Andreas Judicial Branch
(909) 235-6076 — [email protected]

Post by **Judith Mason** » 18 Mar 2022, 03:44

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

To whom it may concern,

In a recent decision that was been made in the San Andreas State Court of Appeals, a new trial has been ordered to take place due to errors in the previous trial's procedures.

In accordance with this order, I will be taking over as the Presiding Judge on this case, and furthermore, I will be referring this case down to the Superior Court of San Andreas under the title State of San Andreas v. Brayden Rush, with an updated case docket number of #22-CM-0003.

Immediately following this change, I will be ordering discovery for this case. This will require the prosecution to present the entirety of it's evidence within seven days, which is then to be followed by the submission of any relevant motions by either party. I thank your for your understanding regarding the requirement for your former motions to be submitted, but I want to ensure that this new trial is done by the books and completed in a timely manner. Thank you.

Respectfully,

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Post by **Judith Mason** » 18 Mar 2022, 03:47

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

#22-CM-0003
Presiding Judge: Judith Mason

ORDER FOR DISCOVERY

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Brayden Rush
#22-CM-0003

A court order was entered in the above case on 18 March, 2022.

The case of the State of San Andreas v. Brayden Rush, #22-CM-0003 is hereby opened and acknowledged by the Court.

The prosecution is hereby ordered to provide all evidence collected from the arresting Law Enforcement Agency and submit it to the Court via Motion for Discovery within seven days. If additional time is needed, the prosecution can file a Motion for Continuance.

Once evidence has been submitted to the official docket the defense can begin filing motions.

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Post by **Hugh Allgood** » 23 Mar 2022, 08:33

Motion for Discovery

San Andreas Judicial Branch
Motion for Discovery

Honorable Associate Justice Judith Mason,

We the prosecution in the case below are presenting our discovery to the court.
State of San Andreas v. Brayden Rush
Assigned Court Case Number: 22-CM-0003
Requesting Party: San Andreas Superior Court
Party Members: State of San Andreas through Senior Prosecuting Attorney Hugh R. Allgood, Brayden Rush through Public Defense Attorney Darcy Lafleur
Exhibit #1: LSSD
Type of Discovery:
- Deposition (Statement from Master Deputy Steven Lee)
Spoiler
Steven Lee wrote: ↑30 Dec 2021, 20:22

Los Santos County Sheriff's Department
Personal Email
"A TRADITION OF SERVICE"

December 30th, 2021
Dear State Attorney Hugh R. Allgood,

sadly, I can not provide you a copy of the arrest report since it does not exist in our database. I believe that it would be at your best interest if you contacted Deputy W. Reno directly, but I can not promise you that he will respond to you immediately, since I've mentioned, he's currently on a two ( 2 ) week LOA.

From

Master Deputy Steven Lee
Los Santos County Sheriff's Department
Exhibit #2: LSSD
Type of Discovery:
- Deposition (Statement from Deputy Wiley Reno)
Spoiler
Wiley Reno wrote: ↑17 Jan 2022, 18:58

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

Case Information

Case Number: 21-10-22-AP-018
Incident Date: [21/OCT/2021]

Witness Information

Name: [Wiley Reno]
Date of Birth: [23/MAY/1991]
Phone Number: [314-5473]
Occupation: [Deputy Sheriff III]

Witness Statement

[On October 21st, 2021 during my Patrol I received a backup call from a unit up near the dancing disco store. The deputy informed us that there were a group of individuals wearing pink on pink bikes near the dancing disco store, at least one of which was armed. The deputy explained that they saw a silenced firearm on their hip. We quickly arrived on the scene and detained the individuals who we suspected. We attempted to efficiently clear those who were not being detained, but we weren't entirely successful. Eventually, units transported the individual in Pink to DOC.

It is important to keep in mind this situation was before we were aware of the constant attacks on DOC by pink individuals, so we did not have sufficient protection for this transport that we should have. Upon arriving to DOC, the transport unit was fired upon and a shootout began between a couple of DOC guards and some individuals in pink. In this firefight, Mr. Rush was downed and I arrived as the sole unit on the CODE-1 scene at DOC, as units were tied up in the city with a pursuit. Upon arriving on the scene I saw Mr. Rush on the ground in pain with multiple gunshot wounds, along with a silenced Pistol .50 on his hip. Officer Alfonso Banker of the Department of Corrections explained to me that he had been involved in a shootout between DOC guards and the individuals in pink trying to release their comrade (Mr. Rush was wearing a full pink outfit). Mr. Rush adamantly decreed that he was not involved and that he was being shot at by the people in pink, not shooting at DOC. DOC requested I add the Attempted Murder of a Government Employee charge for this, which I did add.

As for the firearm charge, when I arrived on the scene the Pistol .50 with the silencer was on Mr. Rush's hip and the only manipulation I did to it was take it off of his hip and place it in an evidence bag. It appeared to have 9 rounds discharged which only furthered my belief of DOC's testimony. Mr. Rush was transported to the hospital and then transported back to DOC. Upon his transport to DOC a CODE-1 was called by deputies on DOC grounds as Deputy Elijah Quinn was being held hostage by Mrs. Charlie Bankshot. Mrs. Bankshot negotiated with deputies for quite a while before the Sheriff's Department negotiators agreed to let those in pink go free in return for Deputy Quinn's release. Mr. Rush was released from my custody at this time, serving none of his time and exited DOC grounds on his bike. No further charges were added.

Eventually, I believe he was arrested by the Los Santos Police Department, and no further charges came of this particular arrest. ]

Witness Affirmation

I, [Wiley Reno], 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,

[Wiley Reno]
[Deputy Sheriff III]
[Los Santos Sheriff's Department]

Date: [17/JAN/2022]
Exhibit #3: DOC
Type of Discovery:
- Deposition (Two statements from former Officer Alfonzo Banker)
Spoiler

Alfonzo Banker wrote: ↑17 Jan 2022, 08:04 To be honest bro, I got no idea what this situation is pertaining to and if I did it was probably from such a long time ago that I wouldn't remember the details.

Alfonzo Banker wrote: ↑19 Jan 2022, 00:55 From what I remember Brayden never shot his firearm. I was the one that BLSed him and handcuffed him while he was injured because of the illegal firearm on his person. I was also the one that initially identified him. I can say without a doubt that Brayden did not shoot at anybody, the fact that the firearm wasn't checked to see if it was still hot before charging him is a bit concerning to say the least. Hope my statement helps!

Sincerely,

Hugh R. Allgood
Senior Prosecuting Attorney

Post by **Judith Mason** » 27 Mar 2022, 02:13