#22-CM-0017, State of San Andreas v. Frank Raven

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Frank Raven
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#22-CM-0017, State of San Andreas v. Frank Raven

Post by Frank Raven »

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Defendant Name: Frank Raven
Defendant Phone: 4138423
Defendant Address: N/A
(( Defendant Discord: )) ((White#4633))
Requested Attorney: N/A
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Charging Department: Los Santos Police Department
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Time & Date of Incident(s): 10/MAY/2022 22:00
Charge(s): GM05 - Receiving Stolen Property
Narrative:

I was next to my van unpacking some money at legion square after being paid for some counselling services. I was approached by an unmarked LSPD unit who parked in front of my van. Two officers dismounted, approaching me. One of them withdrew and brandished what looked like a small automatic SMG.

He asked me if I minded putting the knife down and stepping away, to which I asked why? He answered me, stating I was pick locking the van as he brought up his automatic weapon and aimed at me. I was extremely confused seeing as it was my van.
I stated to the Officers that I was not lock picking the van and complied, putting the knife away and facing the Officer closest to me.

Throughout the arrest I was compliant with both Officers, although I did at the time decline to answer any questions without a lawyer present, even then the Officer cuffing me insisted on arguing with me, asking me multiple times after if I had anything on me. He continued to do this after I explicitly stated that I refused to answer any questions that might incriminate me without a lawyer present.

The badges given at the time of arrest for the two initial officers were 15890 and 9280, additionally there was a detective briefly on scene who was initially called to collect prints, but after hearing me claim that the money was mine as it was given to me stated that it was clear cut and left. I did not request the badge number of the supervisor that was later called.

These officers then switched their focus to the singular pack of money on me that I was cutting open. I was arrested for possession of stolen goods even though the Officers were unable to prove this. I requested a supervisor on scene, asking how he knew beyond a reasonable doubt how the money was illegal and stolen to which the only answer given was that in his experience the only possible way to get packed money is through illegal means. Even more confused, I questioned him with regards to a hypothetical scenario where someone buys some tape and packs a few bands of cash together, to which his answer was that he does not know of a place in Los Santos where someone can buy tape, making such scenarios impossible in his mind.

At this point I was not only extremely confused but also considering whether I was having a mental breakdown given the answers given. From the officers being unable to give me a clear answer proving the money was obtained through illegal means to an officer stating that there is no such place in Los Santos that sells duct tape.

I would like this charge removed due to lack of evidence and I will also be seeking a reprimand for both Officers and the supervisor in question with regards to the use of force during the situation and investigative methods used. An IA will be submitted pending the outcome of this trial as I am aware that the court only deals with the matter of the charges.



I, [Frank Raven], 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. ))
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Re: State of San Andreas v. Frank Raven

Post by Rasheed Briggs »

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San Andreas Judicial Branch

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  • Your Honor,

    My name is Rasheed Briggs and I will act as counsel on behalf of the State of San Andreas in this case. I am familiarizing myself with the case and will be reaching out to the the relevant parties to gather more information.

    Respectfully,


    Prosecuting Attorney
    San Andreas Judicial Branch

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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Judith Mason »

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San Andreas Judicial Branch

Re: #22-CM-0017, State of San Andreas v. Frank Raven
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  • Parties,

    I am Associate Justice Judith Mason and I will be the presiding over this case in my courtroom. At this point in time, I will be assigning this case to docket number #22-CM-0017. As we currently do not have representation for the defendant, I will be reaching out to the Public Defense Division so that Mr. Raven is afforded his right to representation.

    Respectfully,

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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Frank Raven »

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Re: #22-CM-0017, State of San Andreas v. Frank Raven

  • Your honour (@Judith Mason),

    In the interest of getting this case underway as soon as possible, I would like to represent myself in this case and I am ready to proceed.

    Respectfully,

    Frank Raven
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Judith Mason »

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Re: #22-CM-0017, State of San Andreas v. Frank Raven
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  • Parties,

    Mr. Raven - Your response has been acknowledged by the court and you will be afforded your right to self-representation. At this point in time, I will point you in the direction of the Self-Representation Database, which will outline all of the information that you will need for the upcoming proceedings. If there is anything that is unclear once we get underway, I urge you to reach out to myself so that I may provide clarity.

    I will now be ordering discovery to be presented by the prosecution within seven days. Once the first Motion for Discovery has been presented by the prosecution, the defense may begin filing motions in response.

    Respectfully,

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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Judith Mason »

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San Andreas Judicial Branch

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#22-CM-0017
Presiding Judge: Judith Mason

ORDER FOR DISCOVERY


IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Frank Raven
#22-CM-0017

A court order was entered in the above case on 14 May, 2022.


The case of the State of San Andreas v. Frank Raven, #22-CM-0017 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.



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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Rasheed Briggs »

Motion for Discovery
San Andreas Judicial Branch
Motion for Discovery

Honorable Judith Mason,

  • We the Prosecution in the case below are presenting our discovery to the court.
    State of San Andreas v. Frank Raven[Defendant]
    Assigned Court Case Number: 22-CM-0017
    Party Members: Rasheed Briggs
    Exhibit #1: [Source of the Discovery] LSPD - Police Officer Jeff Babatunda
    Type of Discovery: Statement
    Spoiler
    All Information from the Discovery This is the personal statement of the first officer that provides information about the packed cash and the reason behind the arrest. The prosecution believes this statement to be extremely crucial towards our case due to the fact that the statement provides the cause and the reasoning behind the charge.
    Jeff Babatunda wrote: Wed May 18, 2022 10:18 pm The packed money found on the suspect was a small quantity and due to the incapability of receiving packed money from any legal sources we checked the contents of the bag, with it totalling a small amount of money, this was most likely from a store. The packed money was found within a plastic bag sealed as you would expect from an ATM or Store would have. The charges we placed would still suffice as the packed money is stolen property and he received said property, weather he knew it was stolen or not the goods are still stolen and the charge remains.

    Exhibit #2: [Source of the Discovery] LSPD - Ace Butoslav
    Type of Discovery: Physical Evidence
    Spoiler
    All Information from the Discovery This is a picture of the packed cash apprehended on the scene of the arrest. The packed cash as seen in the picture and also stated by Police officer Mr. Butoslav is crucial evidence that justifies the packed cash as contraband and stolen due to them containing the branding of the Bank that they were stolen from. The packed cash and all other evidence are currently in the possession of the LSPD.
    • Ace Butoslav wrote: Wed May 18, 2022 9:09 pm Image
      lspdlogo
      Los Santos Police Department
      "TO PROTECT AND TO SERVE"

      • Prosecutor,

        Here you can see the evidence we found on the scene about the Frank Raven case, together with the branding of the packed money.
        Evidence Picture
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        May the odds be ever in your favor.
        Sincerely,
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        Police Officer II Ace Butoslav

        Los Santos Police Department
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    Exhibit #3: [Source of the Discovery] LSPD - Sebastian Papadakis
    Type of Discovery: Personal Statement
    Spoiler
    All Information from the Discovery
    This is Mr. Papadakis personal statement which was recorded live. ((https://youtu.be/-5ekbmLj-hk))
Exhibit #4: [Source of the Discovery] LSPD
Type of Discovery: Official Document - Knowing your rights
Spoiler
All Information from the Discovery
This document provides necessary background information on probable cause and reasonable suspicion and is the official law used by our city and the LSPD.
Knowing your Rights & Due Process ((viewtopic.php?p=214585))



Sincerely,

Rasheed Briggs
Prosecution Attorney
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Last edited by Rasheed Briggs on Wed May 25, 2022 4:06 pm, edited 6 times in total.
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Frank Raven »

Motion to Compel Discovery
San Andreas Judicial Branch
Motion to Compel Discovery

Honorable Judge Judith Mason,

  • We the Defense 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.
    State of San Andreas v. Frank Raven
    Assigned Court Case Number: #22-CM-0017
    Requesting Party: Frank Raven
    Party Members: Frank Raven
    Discovery from: Los Santos Police Department

    Type of Discovery:
    1. Defendant's Arrest Report
    2. Written Statement - Arresting Officers' account of the arrest [Badge # 15890,9280] and Supervising Officer [Unknown Badge Number]
    3. Expert Testimony/Physical Evidence/Document corroborating the statement in Exhibit #1 ''The packed money found on the suspect was a small quantity and due to the incapability of receiving packed money from any legal sources we checked the contents of the bag, with it totalling a small amount of money, this was most likely from a store. The packed money was found within a plastic bag sealed as you would expect from an ATM or Store would have. '' and Exhibit #2 ''The packed cash as seen in the picture and also stated by Police officer Mr. Butoslav is crucial evidence that justifies the packed cash as contraband and stolen due to them containing the branding of the Bank that they were stolen from.''
    Detailed reasoning:
    1. This report is directly relevant to the arrest of the defendant and is a mandatory form that all Officers must fill after an arrest. This evidence goes towards building the defense's narrative of an unlawful search and seizure
    2. A direct account of what happened by each individual Officer involved in the arrest. These testimonies are being requested as they are directly related to the issue at hand of how each Officer initially perceived the scene and determined they would conduct an arrest on the defendant.
    3. This piece of evidence is highly relevant as the prosecution has presented Exhibit #1 and #2 which claims that the pack of money has a bank symbol on it, meaning it is stolen/contraband, claiming that it is impossible to have a pack of money legally.The Defense will proceed with a motion to suppress Exhibit #1 and #2 if no discovery from the prosecution is provided to set a foundation for the statements in said exhibits.


Sincerely,


Frank Raven
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Last edited by Frank Raven on Tue May 24, 2022 9:39 am, edited 1 time in total.
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Rasheed Briggs »

Motion for Continuance
San Andreas Judicial Branch
Motion for Continuance

Honorable Judith Mason,

  • We the Prosecution in the case below are requesting a Continuance for [7] days for the reason listed below.
    State of San Andreas v. Frank Raven
    Assigned Court Case Number: 22-CM-0017
    Detailed explanation:
    At this time we are requesting a continuance for the purpose of gathering evidence that Mr. Raven has requested. The prosecution is in the process of gathering more evidence about the cash and will be requesting bank statements, as well as analysis from the cash gathered from Mr. Raven from the LSPD. As such requests take more time than usual we request this continuance in order for us to ensure that we get the best possible evidence for request number 3. Furthermore the prosecution has contracted both of the officers, but one of them has not been able to provide a statement as of yet.


Sincerely,

Rasheed Briggs
Prosecution Attorney
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Judith Mason »

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Re: #22-CM-0017, State of San Andreas v. Frank Raven
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  • Parties,

    I will be granting the Motion for Continuance in order for the prosecution to prepare an additional Motion for Discovery to answer the Motion to Compel Discovery submitted by the defense.

    In seven (7) days, I will review the submitted discoveries to determine the next step for this case. If there are any further motions that are disputed, I will schedule a hearing to allow for oral arguments for and against the motions, if there are no disputed motions, then I will move forward with scheduling the trial.

    Respectfully,

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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Rasheed Briggs »

Motion to Compel Discovery
San Andreas Judicial Branch
Motion to Compel Discovery

Honorable Judith Mason,

  • We the Prosecution 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.
    State of San Andreas v. Frank Raven[Defendant]
    Assigned Court Case Number: 22-CM-0017

    Discovery from: Individual - Frank Raven

    Type of Discovery:
    • 1. Statement about the origin of the cash
      2. Proof of the tax being paid at the day that he received the packed cash
    Detailed reasoning:
    • Your honour, the prosecution is requesting that Mr. Raven provides the court with:

      [1] A written statement about the origin of the packed cash that was found in his possesion. We are requesting that Mr. Raven provides the Date, Time, and Person that he received this cash from. In his statement Mr. Raven also stated that ''I was next to my van unpacking some money at legion square after being paid for some counselling services.'' and for that reason we are requesting information about the type of counselling services that he provided as well as the person that was responsible for the transaction with Mr. Raven. This evidence directly helps the prosecution establish the origin of the cash and create a foundation on wether it came from legal or illegal means.

      [2] Evidence - Proof that Mr. Raven paid and reported the income to the Government of San Andreas at the time of the transaction as is required by our Laws after a sale of services. This evidence is requested as it provides the prosecution with proof about the legality of the transaction and will help the prosecution set a foundation for the statements in exhibits #1 and #2 as requested by Mr. Raven.


Sincerely,

Rasheed Briggs
Prosecution Attorney
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

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Motion to Suppress
San Andreas Judicial Branch
Motion to Suppress

Honorable Judge Judith Mason,

  • We the Defense in the case below are requesting that certain evidence be inadmissible in court.
    State of San Andreas v. Frank Raven
    Assigned Court Case Number: 22-CM-0017
    Requesting Party: Frank Raven
    Party Members: Frank Raven
    Requested Evidence to Suppress: Prosecution's Exhibit #2 (Physical Evidence - Items Retrieved During Arrest)
    Detailed explanation:
  • The defense objects to Exhibit #2 on the grounds that the items found on Mr. Raven were obtained during an unlawful search and seizure by Los Santos Police Department.

    The arresting officers who conducted the search of Mr Raven's person did so with no lawful grounding as they initially approached him under the suspicion of lock picking a vehicle. At the time of Mr. Raven's arrest he had no such lock pick or any other comparable device in his hands, making the initial reason to approach and subsequent search and seizure unlawful in nature, thus turning any seized items, including the packed money, into ''Fruit of the Poisonous Tree''.

    Furthermore, the original reason for detaining Mr. Raven should have been investigated by the Officers prior to any further arrests or searches took place, in this case, the Officers should have asked Mr. Raven for his ID and confirmed he was the owner of the van since they were suspicious of a crime unrelated avoiding unnecessary escalation.




Sincerely,

Frank Raven
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Frank Raven »

Motion to Compel Discovery
San Andreas Judicial Branch
Motion to Compel Discovery

Honorable Judge Judith Mason,

  • We the Defense 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.
    State of San Andreas v. Frank Raven
    Assigned Court Case Number: 22-CM-0017
    Requesting Party: Frank Raven
    Party Members: Frank Raven
    Discovery from: Los Santos Police Department

    Type of Discovery: Bodycam Footage #1
    • Bodycam Footage from Police Officer Jeff Babatunda
    Detailed reasoning:
    • The bodycam footage from Police Officer Jeff Babatunda is the best piece of evidence that can be provided to ensure that all testimonial accounts of the occurred event on the 10th of May are accurate and truthful and would provide the court with an unbias view of the events as they unfolded. Furthermore, bodycam usage is mandatory for all members of the Los Santos Police Department.
    Type of Discovery: Bodycam Footage #2
    • Bodycam Footage from Police Officer Sebastian Papadakis
    Detailed reasoning:
    • The bodycam footage from Police Officer Sebastian Papadakis is the best piece of evidence that can be provided to ensure that all testimonial accounts of the occurred event on the 10th of May are accurate and truthful and would provide the court with an unbias view of the events as they unfolded. Furthermore, bodycam usage is mandatory for all members of the Los Santos Police Department.
    Type of Discovery: Bodycam Footage #3
    • Bodycam Footage from Sergeant Bill Breacher
    Detailed reasoning:
    • The bodycam footage from Sergeant Bill Breacher is the best piece of evidence that can be provided to ensure that all testimonial accounts of the occurred event on the 10th of May are accurate and truthful and would provide the court with an unbias view of the events as they unfolded. Furthermore, bodycam usage is mandatory for all members of the Los Santos Police Department.


Sincerely,

Frank Raven
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Frank Raven »

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Re: #22-CM-0017, State of San Andreas v. Frank Raven

  • Your honour (@Judith Mason),
    • At this time the Defense is requesting a hearing on the Motion to Suppress.

      Detailed Reasoning:

      The outcome of this motion is a crucial pillar in our defense and will inform us of the next steps on our defense. As such we're requesting a hearing for this motion.

      To elaborate, the issue of improper search and seizure being brought up can determine whether these charges were ultimately applied correctly. If it is found that the search was legal and warranted then we plan on presenting further discovery to the court.

      However, if the motion to suppress is granted, the defense would instead submit to the court a motion for Summary Judgement
    Respectfully,

    Frank Raven
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Judith Mason »

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Re: #22-CM-0017, State of San Andreas v. Frank Raven
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Judith Mason »

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Re: #22-CM-0017, State of San Andreas v. Frank Raven
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  • Parties,

    Based on the responses to the scheduling tool, I will be setting this Motions Hearing for today at 9:30 PM, in just under three hours.

    Respectfully,

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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Judith Mason »

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Re: #22-CM-0017, State of San Andreas v. Frank Raven
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Frank Raven »

Motion for Involuntary Dismissal
San Andreas Judicial Branch
Motion for Involuntary Dismissal

Honorable @Judith Mason,

  • We the Defense in the case below are requesting an involuntary dismissal from the court, please find the reason for it below.
    State of San Andreas v. Frank Raven
    Assigned Court Case Number: #22-CM-0017
    Requesting Party: Frank Raven
    Party Members: Frank Raven
    Involuntary Dismissal:
    • Failure to Comply to Court Order & Unreasonable Delay
    • Perjury

    Detailed explanation:

    On the 30th of May 2022, a hearing was held for, but not limited to, three motions filled by the Defense, specifically.
    • Motion to Compel Discovery of Arrest Report, Officer Statements, and Expert Testimony
      Motion to Compel Discovery
      San Andreas Judicial Branch
      Motion to Compel Discovery

      Honorable Judge Judith Mason,

      • We the Defense 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.
        State of San Andreas v. Frank Raven
        Assigned Court Case Number: #22-CM-0017
        Requesting Party: Frank Raven
        Party Members: Frank Raven
        Discovery from: Los Santos Police Department

        Type of Discovery:
        1. Defendant's Arrest Report
        2. Written Statement - Arresting Officers' account of the arrest [Badge # 15890,9280] and Supervising Officer [Unknown Badge Number]
        3. Expert Testimony/Physical Evidence/Document corroborating the statement in Exhibit #1 ''The packed money found on the suspect was a small quantity and due to the incapability of receiving packed money from any legal sources we checked the contents of the bag, with it totalling a small amount of money, this was most likely from a store. The packed money was found within a plastic bag sealed as you would expect from an ATM or Store would have. '' and Exhibit #2 ''The packed cash as seen in the picture and also stated by Police officer Mr. Butoslav is crucial evidence that justifies the packed cash as contraband and stolen due to them containing the branding of the Bank that they were stolen from.''
        Detailed reasoning:
        1. This report is directly relevant to the arrest of the defendant and is a mandatory form that all Officers must fill after an arrest. This evidence goes towards building the defense's narrative of an unlawful search and seizure
        2. A direct account of what happened by each individual Officer involved in the arrest. These testimonies are being requested as they are directly related to the issue at hand of how each Officer initially perceived the scene and determined they would conduct an arrest on the defendant.
        3. This piece of evidence is highly relevant as the prosecution has presented Exhibit #1 and #2 which claims that the pack of money has a bank symbol on it, meaning it is stolen/contraband, claiming that it is impossible to have a pack of money legally.The Defense will proceed with a motion to suppress Exhibit #1 and #2 if no discovery from the prosecution is provided to set a foundation for the statements in said exhibits.


      Sincerely,


      Frank Raven
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    • Motion to Compel Discovery of Body Camera Footage
      Motion to Compel Discovery
      San Andreas Judicial Branch
      Motion to Compel Discovery

      Honorable Judge Judith Mason,

      • We the Defense 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.
        State of San Andreas v. Frank Raven
        Assigned Court Case Number: #22-CM-0017
        Requesting Party: Frank Raven
        Party Members: Frank Raven
        Discovery from: Los Santos Police Department

        Type of Discovery:
        1. Defendant's Arrest Report
        2. Written Statement - Arresting Officers' account of the arrest [Badge # 15890,9280] and Supervising Officer [Unknown Badge Number]
        3. Expert Testimony/Physical Evidence/Document corroborating the statement in Exhibit #1 ''The packed money found on the suspect was a small quantity and due to the incapability of receiving packed money from any legal sources we checked the contents of the bag, with it totalling a small amount of money, this was most likely from a store. The packed money was found within a plastic bag sealed as you would expect from an ATM or Store would have. '' and Exhibit #2 ''The packed cash as seen in the picture and also stated by Police officer Mr. Butoslav is crucial evidence that justifies the packed cash as contraband and stolen due to them containing the branding of the Bank that they were stolen from.''
        Detailed reasoning:
        1. This report is directly relevant to the arrest of the defendant and is a mandatory form that all Officers must fill after an arrest. This evidence goes towards building the defense's narrative of an unlawful search and seizure
        2. A direct account of what happened by each individual Officer involved in the arrest. These testimonies are being requested as they are directly related to the issue at hand of how each Officer initially perceived the scene and determined they would conduct an arrest on the defendant.
        3. This piece of evidence is highly relevant as the prosecution has presented Exhibit #1 and #2 which claims that the pack of money has a bank symbol on it, meaning it is stolen/contraband, claiming that it is impossible to have a pack of money legally.The Defense will proceed with a motion to suppress Exhibit #1 and #2 if no discovery from the prosecution is provided to set a foundation for the statements in said exhibits.


      Sincerely,


      Frank Raven
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    • Motion to Suppress Evidence Seized as a Result of a Search
      Motion to Suppress
      San Andreas Judicial Branch
      Motion to Suppress

      Honorable Judge Judith Mason,

      • We the Defense in the case below are requesting that certain evidence be inadmissible in court.
        State of San Andreas v. Frank Raven
        Assigned Court Case Number: 22-CM-0017
        Requesting Party: Frank Raven
        Party Members: Frank Raven
        Requested Evidence to Suppress: Prosecution's Exhibit #2 (Physical Evidence - Items Retrieved During Arrest)
        Detailed explanation:
      • The defense objects to Exhibit #2 on the grounds that the items found on Mr. Raven were obtained during an unlawful search and seizure by Los Santos Police Department.

        The arresting officers who conducted the search of Mr Raven's person did so with no lawful grounding as they initially approached him under the suspicion of lock picking a vehicle. At the time of Mr. Raven's arrest he had no such lock pick or any other comparable device in his hands, making the initial reason to approach and subsequent search and seizure unlawful in nature, thus turning any seized items, including the packed money, into ''Fruit of the Poisonous Tree''.

        Furthermore, the original reason for detaining Mr. Raven should have been investigated by the Officers prior to any further arrests or searches took place, in this case, the Officers should have asked Mr. Raven for his ID and confirmed he was the owner of the van since they were suspicious of a crime unrelated avoiding unnecessary escalation.




      Sincerely,

      Frank Raven
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    The Prosecution has failed to properly address the request within these motions in a timely manner. All the requested statements, expert testimony/foundational evidence establishing the packed cash as belonging to the bank and the request for the body camera footage are all paramount to the Defense's case and the longer we are without this evidence the longer the prosecution has to claim that a substantial amount of time has elapsed and thus are unable to provide the court with the evidence. As Your Honor stated, Police Officers are required to keep their body camera footage for a total of 30 days, we are now 5 days away from the 30 day period, which is of grave concern to the Defense.

    Lastly, with regards to Perjury, the prosecution actively lied during deliberations for the Motion to Suppress Evidence, claiming ''we already presented to the court that there was in fact a misdemeanour happening and that was face concealment'', later stating ''Your Honor, we have presented to the court the personal statements, which number 1 state that he was masked by Mr. Papadakis, so that is our evidence that we're using'' as a reason for why the Defendant was detained and had his possessions seized. However, after a thorough review of the evidence submitted within this case, including the video testimony by Police Officer Papadakis, the Defense could not find any corroborating evidence for such a statement. We believe the false statement made by the prosecution directly impacted the decision to withhold judgement on the Motion to Suppress Evidence.

    Given the combination of unreasonable delay/failure to comply with a court order and the prejudicial behaviour by the prosecution with a court order, the Defense requests the case be dismissed with prejudice.

    Thank you for your consideration.

Sincerely,

Frank Raven
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Rasheed Briggs »

Motion for Discovery
San Andreas Judicial Branch
Motion for Discovery

Honorable Judith Mason,

  • We the Prosecution in the case below are presenting our discovery to the court.
    State of San Andreas v. Frank Raven
    Assigned Court Case Number: 22-CM-0017
    Requesting Party: Defense
    Party Members: Frank Raven
    Exhibit #1: Fleeca Bank
    Type of Discovery:
    • Evidence - Camera Footage of the event
    Spoiler
    All Information from the Discovery
    Exhibit #2: Bodycam of Sebastian Papadakis
    Type of Discovery:
    • Physical evidence - USB stick of Sebastian Papadakis Bodycam
    Spoiler
    All Information from the Discovery
    • We are submitting the USB stick provided to us by Mr. Papadakis as evidence per the defenses request. ((Bodycam RP has been displayed, as well as the submition of it to the evidence, but actual footage of the event does not exist from his POV,
      ( https://imgur.com/d263YtB ) and logs from the time provided by admin ( https://imgur.com/mZVUlfG )))

Furthermore the Prosecution would like to officially OBJECT to the motion of INVOLUNTARY DISMISAL. Find our detailed explanation below.

1. Failure to Comply to Court Order & Unreasonable Delay

Response: The prosecution has faced some issues with obtaining the bodycam footage as well as the footage from the Bank as an alternative due to bad timing with Sergeant Bill Breacher, and the lack of bodycam footage from Jeff Babatunda as he is no longer employed by the LSPD. We would also like to state that at the time of the motion it had been less than 7 days from the last hearing and we believe that in light of the delicate nature of the evidence being collected the prosecution has not delayed in an unreasonable matter. In addition the bodycam footage provided to the prosecution by Officer Papadakis needed to be in a USB stick and for that reason timing had to work once again. Lastly, addressing the LSPD guidelines about bodycam footage, we would like to inform the court that all officers were informed from the start to keep their bodycam footage so any evidence that was required by them is in no danger of being deleted/altered in any way per the laws of San Andreas.

2. Perjury

Response: The prosecution was not under oath and was not testifying. The statements were truthful with the facts that were presented to the prosecution. (Please review minute 1:05-1:20 of Mr. Papadaki's personal statement which was presented to the court as evidence.). The prosecution at the time based its statements on the basis of the personal statement of the Officer. At this time and moment the prosecution wants to state that for the vast majority of the court cases the attorneys are not on the scene and base most of their statements from recolections, footage and other means. In this case the statements of the prosecution do not fall under the ''knowingly lying under oath'' category. Lastly the prosecution would like to quote a statement from the The American Bar Association’s Model Rules of Professional Conduct.
The American Bar Association’s Model Rules of Professional Conduct states that a lawyer “shall not knowingly make a false statement of material fact.”
With this in mind the prosecution did not knowingly make a false statement hence the objection to the claims of the defense as the client, in this case the officers, tell the prosecution their own version of the facts.


Sincerely,

Rasheed Briggs
Prosecution Attorney
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Last edited by Rasheed Briggs on Mon Jun 06, 2022 2:58 pm, edited 1 time in total.
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Frank Raven »

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Re: #22-CM-0017, State of San Andreas v. Frank Raven

  • Your honour Judith Mason,

    The Defense is still waiting for the following discovery to be presented by the prosecution as ordered in our last hearing.
    • Motion to Compel Discovery of Arrest Report, Officer Statements, and Expert Testimony
    • Motion to Compel Discovery of Body Camera Footage - Specifically Sergeant Bill Breacher + ex-Police Officer Jeff Babatunda
    In total, out of all the discovery that the prosecution was ordered to compile and submit by the court, only one exhibit has been provided, that being Officer Papadakis' bodycam footage.

    This goes to show the unreasonable delay by the prosecution as the Defense would argue that one week is enough to gather at the very least an arrest report, which according to the Los Santos Police Department's policies, should be submitted within 24 hours of the arrest and is a mandatory component of an arrest by every officer.

    Furthermore, addressing some of prosecutor @Rasheed Briggs points. Regardless of the intention and/or awareness of the facts at hand, it has now been revealed through the body camera footage provided by the Prosecution, that the defendant Frank Raven was in fact NOT wearing any face concealment at the time of his arrest, directly contradicting the argument provided during the motion to suppress evidence hearing and Officer Papadakis' initial video statement.

    As stated in the hearing, the prosecution's own
    Exhibit #4 - Official Document - Knowing your rights
    Rasheed Briggs wrote: Wed May 18, 2022 9:47 pm
    Motion for Discovery
    San Andreas Judicial Branch
    Motion for Discovery

    Exhibit #4: [Source of the Discovery] LSPD
    Type of Discovery: Official Document - Knowing your rights
    Spoiler
    All Information from the Discovery
    This document provides necessary background information on probable cause and reasonable suspicion and is the official law used by our city and the LSPD.
    Knowing your Rights & Due Process ((viewtopic.php?p=214585))



    Sincerely,

    Rasheed Briggs
    Prosecution Attorney
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    • ''The authority to search and seize applies when a misdemeanor or felony crime has been committed. (I.e. If you are caught committing Reckless Operation of a Motor/Marine Vehicles, a search and seizure is permitted.)''
    As such the Defense requests the motion to suppress evidence be granted in light of this new evidence, although we are of course open to further deliberations in a separate hearing if required by Your Honor.

    Respectfully,

    Frank Raven
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Rasheed Briggs »

Motion for Discovery
San Andreas Judicial Branch
Motion for Discovery

Honorable Judith Mason,

  • We the Prosecution in the case below are presenting our discovery to the court.
    State of San Andreas v. Frank Raven
    Assigned Court Case Number: 22-CM-0017
    Requesting Party: Defense
    Party Members: Frank Raven
    Before the prosecution submits further evidence we would like to state that as conversated in the hearing, the defence prefered that all evidence be submitted in one document with no edits. As explained in the previous motions the prosecution can only do so much to attain all evidence, specifically 3 body cam footage, 1 arrest report, find an officer willing to testify as an expert, and officer statements all under a week. As you may be aware in order to gather all of this evidence after a court hearing and present them in only one document does not show unreasonable delay in a time frame of less than a weak. The evidence provided on the previous motion was due to urgency by the defence and the prosecution is trying to work out timings with the police officers to attain the last pieces ordered by the court. At this moment I would also like to state that being present and awake at the same time as 3 police officers who have varying duty hours is not as simple as the defence makes it to be, thus the objection to the unreasonable delay claim. Additionally we would like to say that there was not a timeframe given to the prosecution on how long it has to obtain the evidence ordered by the court.

    Lastly the prosecution would like to state once more for the defence that the bodycam footage of Jeff Babatunda is NOT available and he is no longer employed by the LSPD

    Exhibit #1: [Source of the Discovery] LSPD - Arrest Report
    Type of Discovery: Arrest Report
    Spoiler
    All Information from the Discovery
    • This is the Arrest Report that was requested by the defence
      Sebastian Papadakis wrote: Mon Jun 06, 2022 8:43 pm
      Jeff Babatunda wrote: Tue May 10, 2022 10:21 pm Image
      Image

      Los Santos Police Department

      ARREST REPORT
      "TO PROTECT AND TO SERVE"

      MUGSHOT
      • SUSPECT DETAILS
        • Full Name: Frank Raven
          Phone Number: 4138423
          Licenses Suspended: No
          Officers Involved:
          • Police Officer III Jeff Babatunda
          • Police Officer III+1 Sebastian Papadakis
          Charges:
          • GM05 - Receiving Stolen Property
        INCIDENT NARRATIVE
        • Explain what happened, no need to provide too much detail, videos could be provided
          • Saw the 10-15 what appeared to be pick locking a vehicle, we approached and saw him armed with a knife, using our tazer and firearm we detained the suspect to find he was actually trying to open a bag of packed money. He was charged with the possession of the packed money.
        EVIDENCE DETAILS
        • Document the possessions confiscated from the arrested suspect.
          Legal possessions may be grouped and documented as "Legal Possessions". Illegal possessions must be documented individually, examples of documented illegal possessions are "Pistol .50" or "12 grams of Cocaine". Body camera footage may be attached as an evidence exhibit.
          • Exhibit A: Knife
            Exhibit B: Black Gloves
            Exhibit C: Black Mask
            Exhibit D: 1x Packed Money (Illegal)

            Photograph of possessions in evidence locker (if applicable)
            Image
      Image
    Exhibit #2: [Source of the Discovery] LSPD - Experts Testimonies
    Type of Discovery: Expert
    Spoiler
    All Information from the Discovery
    • The prosecution is presenting 3-6 high ranking police officers that are highly involved in financial fraud and financial cases for the LSPD, as experts that are willing to testify and provide their expert testimonies for the court. All of the experts have made themselves available for the defence and the prosecution and their testimonies will be asked in court.
      Xoza Shadow wrote: Mon Jun 06, 2022 9:44 pm Image
      Image

      Los Santos Police Department

      "TO PROTECT AND SERVE"

      • Greetings Rasheed Briggs,

        Per your request I have provided the below list of experts who have stated they are available to you.
        • Detective: Mikael Cowell
        • Detective: Sayaka Yukimura
        • Commander: Xoza Shadow
        Additionally I the below have also been included as experts who I trust would be able to assist, but unknown of their availability.
        • Assistant Chief: Elena Blake
        • Deputy Chief: Lex Roth
        • Deputy Chief: Phillipe Sanchez

      • Regards,

        Image Police Commander Xoza Shadow,
        Detective Bureau Command,
        Los Santos Police Department.
      Image

Lastly the evidence submitted by the prosecution we believe should be reviewed in a hearing, as we believe that a reasonable ruling for exhibit #2 can be reached after proper deliberations in a hearing. The prosecution also mentioned in the initial hearing that the reason behind the detainment was not based on only one factor and we believe that a court proceeding should take place in order to establish all of our points to the court. On a final note Sergeant Bill Breacher has been contacted and we are still awaiting for his response for the bodycam footage.

Sincerely,

Rasheed Briggs
Prosecution Attorney
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Frank Raven »

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Re: #22-CM-0017, State of San Andreas v. Frank Raven

  • Dear Prosecutor @Rasheed Briggs,

    ''Before the prosecution submits further evidence we would like to state that as conversated in the hearing, the defence prefered that all evidence be submitted in one document with no edits.''

    In the interest of moving this case along in a swift manner and to clarify. The Defense does not mind evidence/motions/exhibits being posted in separate replies or even edited into previous motions of discovery. All we asked in the previous hearing is that we are made aware of these edits as adding new exhibits does not notify us, making our ability to prepare significantly reduced.

    As such, feel free to post multiple replies whenever you get any new discovery, the Defense does not require these to be submitted all in one reply. Additionally, if you significantly edited a previous discovery motion with any new evidence, please post a reply informing us of this addition.

    Hope this clarifies everything.
    Respectfully,

    Frank Raven
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Judith Mason »

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San Andreas Judicial Branch

Re: #22-CM-0017, State of San Andreas v. Frank Raven
"HERE FOR YOU | SAFE FOR YOU"

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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Judith Mason »

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San Andreas Judicial Branch

Re: #22-CM-0017, State of San Andreas v. Frank Raven
"HERE FOR YOU | SAFE FOR YOU"

  • Parties,

    Based on the provided responses, I will be scheduling this hearing for 7:30 PM on 09/JUN/2022 (( UTC )).

    Respectfully,

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    Associate Justice
    San Andreas Judicial Branch
    (909) 257-9183 — [email protected]
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Re: #22-CM-0017, State of San Andreas v. Frank Raven

Post by Judith Mason »

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San Andreas Judicial Branch

Re: #22-CM-0017, State of San Andreas v. Frank Raven
"HERE FOR YOU | SAFE FOR YOU"

  • Parties,

    Due to scheduling concerns, I will be delaying the start of this hearing by 30 minutes, setting the new time for 8 PM on 09/JUN/2022 (( UTC )).

    Respectfully,

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