#23-CM-0052, State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna

[Vince Williams]

Defendant Name: Vince Williams
Defendant Phone: 4299975
Defendant Address: Senora Rd. 1
(( Defendant Discord: HERE ))
Requested Attorney: Cyrus Raven

Charging Department: PD & SD

Date & Time of Incident(s): 06/MAR/2023 0000UTC
Charge(s):

• Racketeering
• Unlawful Assembly

Narrative:
I was wrongfully charged with the charges listed above

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I, Vince Williams, 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. ))

Defendant Name: James Eriksen
Defendant Phone: 4007070
Defendant Address: Power Street 2
(( Defendant Discord: HERE ))
Requested Attorney: Cyrus Raven

Charging Department: PD & SD

Date & Time of Incident(s): 06/MAR/2023 0000UTC
Charge(s):

• Racketeering
• Unlawful Assembly

Narrative:
I was wrongfully charged with the charges listed above

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I, James Eriksen, 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. ))

Defendant Name: Leah Lennox
Defendant Phone: -
Defendant Address: Tinsel Tower 201
(( Defendant Discord: HERE ))
Requested Attorney: Cyrus Raven

Charging Department: PD & SD

Date & Time of Incident(s): 06/MAR/2023 0000UTC
Charge(s):

• Racketeering
• Unlawful Assembly

Narrative:
I was wrongfully charged with the charges listed above

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I, Leah Lennox, 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. ))

Defendant Name: Rocky Bologna
Defendant Phone: -
Defendant Address: Eclipse Towers 73
(( Defendant Discord: HERE ))
Requested Attorney: Cyrus Raven

Charging Department: PD & SD

Date & Time of Incident(s): 06/MAR/2023 0000UTC
Charge(s):

• Racketeering
• Unlawful Assembly

Narrative:
I was wrongfully charged with the charges listed above

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I, Rocky Bologna, 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. ))

[Cyrus Raven]

San Andreas Judicial Branch Re: State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna "HERE FOR YOU | SAFE FOR YOU"

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• To whom it may concern,
  
  I, Deputy Chief Public Defender Cyrus Raven, will be representing the defendants, Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna, in this case. I have made myself aware of the contents of this case and have made contact with the defendants.
  
  Additionally, the defense requests this court case be activated as soon as it is received due to special circumstances as per the notice of receipt which will be submitted by the superior court. ''Be advised that the court system runs on a first-come, first-served basis and will only activate cases out of order for special circumstances.''.
  
  THREE of the four Defendants are owners of essential businesses as per the San Andreas State Government policy. [See: Business Competition Policy - Policy Document]. The reasoning or evidence behind these charges has not been disclosed at any point to the Defendants prior or at the time of their arrest.
  
  This places an undue burden on the Defendants and the San Andreas State Government. We argue that the severity of these charges in combination with the effect it has on the running of these essential businesses for the citizens of Los Santos and the business owners constitutes a special circumstance.
  
  Respectfully,
  
  
  
  Deputy Chief Public Defender
  San Andreas Judicial Branch
  5356160 — [email protected]

[Phillipe Sanchez]

Good afternoon,

On behalf of the LSPD, I’d like to quickly clarify a concern prior to us gathering all information applicable to the arrests listed above.

Is Vince appealing on behalf of all four listed? If so, how did the signatures of James, Leah and Rocky get obtained as they themselves did not make a submission. Please note the exact wording and format is exactly the same across each submission except for the name and signature.

I just want to have that cleared up to ensure the Los Santos Police Department isn’t complicit with forgery and/or the contempt of court before proceeding.

Kind Regards,
Deputy Chief Phillipe Sanchez

[Cyrus Raven]

San Andreas Judicial Branch Re: State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna "HERE FOR YOU | SAFE FOR YOU"

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• To whom it may concern,
  
  I can confirm, as legal council for all Defendants, that this appeal have been submitted with the consent of all listed parties.
  
  Respectfully,
  
  Cyrus Raven
  Deputy Chief Public Defender
  San Andreas Judicial Branch
  5356160 — [email protected]

[Robert Winejudge]

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

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NOTICE OF RECEIPT

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna

The court has hereby received and acknowledged the above case on the 6th of March, 2023.

The Superior Court of San Andreas has received your filing and the case is now pending activation. Be advised that the court system runs on a first-come, first-served basis and will only activate cases out of order for special circumstances.

During this time, the defendants are encouraged to reach out to a licensed defense attorney in order to prepare a proper defense, otherwise, a court-appointed attorney will be assigned to the case upon its activation.

The defendants are further encouraged to speak with an authorized individual at Rockford Hills City Hall, Mission Row Police Station, or Paleto Bay Sheriff's Office for official clarification on the specific charges received and their respective date and times, as once the case has been activated, any omitted charges will be considered abandoned and unable to be disputed within this case.



Court Clerk
San Andreas Judicial Branch
(909) 372-4223 — [email protected]

[Roderick Marchisio]

San Andreas Judicial Branch Re: State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna "HERE FOR YOU | SAFE FOR YOU"

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• To whom it may concern,
  
  The purpose of this notice is to inform you that as of this moment I, Roderick Marchisio, will be representing the State of San Andreas in all the proceedings pertaining to the underlying case.
  
  I will take it upon myself to reach out to the involved parties to collect and review all evidence in relation to the underlying case to ensure a proper and smooth continuation of this process.

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Respectfully,


Deputy Attorney General
San Andreas Judicial Branch
(909) 372-7719 — [email protected]

[Roderick Marchisio]

San Andreas Judicial Branch Re: State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna "HERE FOR YOU | SAFE FOR YOU"

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• To whom it may concern,
  
  First of all, the Prosecution would like to note the absolute absurdity of the request of the Defense to activate this case before all other received cases. The Courts of San Andreas, just like each and every other civilized court around the globe operate on a first-come, first-served basis to ensure that all parties are treated fairly and that cases are processed in a timely manner. Not only would an earlier activation and as such, an assignment of priority over other cases, be unfair to these other cases, an earlier activation also inherently creates the appearance of impropriety as well as displaying a bias and favoritism to these particular individuals. Further, an earlier activation of this case will also result in delays or backlogs for other received cases that have been pending for a longer period of time, which not only harms the procedural rights of the parties involved but also undermine public trust in the justice system. As such, this request clearly speaks for the character of and the motive that both the joint Defendants as well as their counsel have with this appeal.
  
  Further, as the Court is no doubt aware, in each and every court cases where signatures are involved, it is the procedural right of the other party to ask for these signatures to be verified to ensure that they are not forged. In fact, this is a very common practice in legal proceedings where signatures are used to indicate consent or agreement. As both the Court and Defense are very well aware, each party has the right to challenge any documents or evidence presented by the other party. In this respect, the Prosecution notes that these appeals are all copies of each other, even up to and lacking the proper punctuation.
  
  Additionally, the Prosecution notes the Defendant that submitted the appeal has also stated the following:

  I, Vince Williams, 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. ))

  In relation to the reply of the Defense counsel, the Prosecution notes this affirmation is very obviously not the verification of signatures to ensure these are not forged. In fact, it is merely a weak attempt to avoid the direct question that was asked. This only further speaks for the character of and the motive that both the joint Defendants as well as their counsel have with this appeal.
  
  Taking the aforementioned into account, the Prosecution formally challenges the authenticity of the signatures provided and hereby requests the Court for a court order to have a forensics expert examine the signatures and provide a report to determine the authenticity of these provided signatures.

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Respectfully,

Deputy Attorney General
Director of Public Notary
San Andreas Judicial Branch
(909) 372-7719 — [email protected]

[Cyrus Raven]

San Andreas Judicial Branch Re: State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna "HERE FOR YOU | SAFE FOR YOU"

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• To whom it may concern,
  
  This appeal was submitted as a combined appeal. All Defendants have provided their digital signatures to Mr. Williams after having agreed to the information provided in the aforementioned appeals format. This has now been confirmed twice by their counsel. The Defense is in no way interested nor forced to entertain the questions of the prosecution or any third-party. No more specifics will be given on this matter as it would fall under attorney-client privilege. We welcome the court to request that each Defendant respond to the docket confirming their submission. However, this would be highly unorthodox given the signed appeals by all Defendants.
  
  I will caution opposing counsel on future submissions to this court with vague speculation of ethical motives driving Defendants or their legal counsel. (E.g ''As such, this request clearly speaks for the character of and the motive that both the joint Defendants as well as their counsel have with this appeal.''). This is not only unprofessional, but not needed. Opposing counsel is free to argue against a motion without such remarks. In the future, similar behaviour will be met with a submission to the Bar Ethics Review Board for breach of the Code of Ethics.
  (See: I - General Principles, V - Relationship to the Adverse Party)
  
  The Defense has requested this case be activated under the special circumstances exception for the following reason:
  • The majority of the Defendants have had their businesses seized by the San Andreas State Government following an arrest where no reasoning was provided behind the charges given either before, during or after the arrest. This is a breach of the Constitution of San Andreas under the 5th Amendment as the Defendants have not had a chance to have their charges reviewed before having their properties seized.
    

    No person shall be compelled in any criminal case to be a witness against themself, nor be deprived of life, liberty, or property, without due process of law.

    Furthermore, these businesses are considered essential by the San Andreas State Government.
  The seizure of these businesses not only effects the Defendants but places a strain on the local population and their access to essential goods and services as these businesses remain closed. It is in the public interest that these businesses are kept up and running. We argue these combined factors constitute a ''special circumstance''.
  
  Respectfully,
  
  Cyrus Raven
  Deputy Chief Public Defender
  San Andreas Judicial Branch
  5356160 — [email protected]

[Judith Mason]

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

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NOTICE OF ACTIVATION

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna
#23-CM-0052

A Notice of Activation was entered in the above case on the 30th day of May, 2023.

The case of the State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna is hereby activated by this Court under #23-CM-0052.

Both the State and Defendant have adequate representation, however, primary counsel for the State is currently on an approved Leave of Absence. Once the Attorney General returns for duty or alternative counsel is assigned, the Order for Discovery will be issued.

In the meantime, however, the court will review the submissions made by both parties and will soon render a decision on the formal challenge of the authenticity of the signatures provided in the initial case submission.



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

[Cyrus Raven]

San Andreas Judicial Branch Re: #23-CM-0052, State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna "HERE FOR YOU | SAFE FOR YOU"

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• Honorable Judith Mason,
  
  
  The Defense requests the court order the prosecution division to assign a co-counsel for this case so initial discovery can be submitted and reviewed. The Attorney General's LOA is indefinite at this time, as such it would be a breach of the Defendants' 6th Amendment rights to delay this case indefinitely until the AG's return.
  
  
  Respectfully,
  
  Cyrus Raven
  Chief Public Defender
  San Andreas Judicial Branch - Command
  5356160 — [email protected]

  ---

[Antonio McFornell]

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

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MOTION FOR DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Vince Williams et al.
#23-CM-0052

A Motion for Discovery was filed in the above case on the 9th of June, 2023

The State of San Andreas, by and through the undersigned attorney, filed this Motion for Discovery, and presents the following as evidence;

• Exhibit #1: SD Arrest Report
  Spoiler

  

  ARREST REPORT
  

  MUGSHOT

  SUSPECT 1 DETAILS

  • 
    
    
    Full Name: Leah Lennox
    Telephone Number: 594-5926
    Licenses Revoked: No
    Charges:
    • GF18 - Racketeering
    • NM03 - Unlawful Assembly
    
    How did the suspect plea to the above charges?
    Suspect pleaded not guilty to all charges.
    Additional Details (Suspect's vehicle, etc.) :
    N/A

  MUGSHOT

  SUSPECT 2 DETAILS

  • 
    
    
    Full Name: Charlie McHoe
    Telephone Number: 506-1371
    Licenses Revoked: No
    Charges:
    • WF03 - Possession of Illegal Firearms/Weapons
    • GF18 - Racketeering
    • NM03 - Unlawful Assembly
    
    How did the suspect plea to the above charges?
    Suspect pleaded guilty to all charges.
    Additional Details (Suspect's vehicle, etc.) :
    N/A

  MUGSHOT

  SUSPECT 3 DETAILS

  • 
    
    
    Full Name: Vladimir Petrenco
    Telephone Number: 344-8651
    Licenses Revoked: No
    Charges:
    • GF11 - Grand Theft Auto
    
    How did the suspect plea to the above charges?
    Suspect pleaded guilty to all charges.
    Additional Details (Suspect's vehicle, etc.) :
    N/A

  MUGSHOT

  SUSPECT 4 DETAILS

  • 
    
    
    Full Name: James Eriksen
    Telephone Number: 400-7070
    Licenses Revoked: No
    Charges:
    • GF18 - Racketeering
    • NM03 - Unlawful Assembly
    
    How did the suspect plea to the above charges?
    Suspect pleaded guilty to all charges.
    Additional Details (Suspect's vehicle, etc.) :
    N/A

  MUGSHOT

  SUSPECT 5 DETAILS

  • 
    
    
    Full Name: Matty Kozlov
    Telephone Number: 479-1108
    Licenses Revoked: No
    Charges:
    • GF11 - Grand Theft Auto
    
    How did the suspect plea to the above charges?
    Suspect pleaded guilty to all charges.
    Additional Details (Suspect's vehicle, etc.) :
    N/A

  MUGSHOT

  SUSPECT 6 DETAILS

  • 
    
    
    Full Name: Vince Williams
    Telephone Number: 429-9755
    Licenses Revoked: No
    Charges:
    • GF18 - Racketeering
    • NM03 - Unlawful Assembly
    
    How did the suspect plea to the above charges?
    Suspect pleaded guilty to all charges.
    Additional Details (Suspect's vehicle, etc.) :
    N/A

  MUGSHOT

  SUSPECT 7 DETAILS

  • 
    
    
    Full Name: Rocky Bologna
    Telephone Number: 302-1065
    Licenses Revoked: No
    Charges:
    • GF18 - Racketeering
    • NM03 - Unlawful Assembly
    
    How did the suspect plea to the above charges?
    Suspect pleaded guilty to all charges.
    Additional Details (Suspect's vehicle, etc.) :
    N/A

  
  
  VEHICLES INVOLVED

  • Vehicle A: Black Tezeract, L/P: *UNKNOWN*, R/O *UNKNOWN*

  
  
  DEPUTY DETAILS

  • Full Name: Oscar Black
    Badge Number: 20596
    Callsign: 3-Z-10

  
  
  INCIDENT DETAILS

  • Date of Arrest: 2023-03-05
    Deputies Involved: Captain Luka Rosselli (Initating), Investigator II Oscar Black (Initating), LSSD SED, LSPD METRO & GND
    
    Provide details of the incident leading up to the arrest
    • On the 6th March, 2023, I was involved in a 10-1 at Paleto Station and changed my frequency to a different one so it was quiet, however, this wasn't the case and I begun hearing a bunch of other voices talking loudly. I quickly made my way over to Luka Rosselli and informed him, we then informed the 10-1 lead that we were clearing to work on this. Both myself and Luka Rosselli got into an unmarked cruiser and begun driving towards the city. At first, the frequency was quiet, people came and went and often talked about if anything was happening, and nothing was. The frequency began to pickup after a rival member had fell injured, they attempted to interfere with his medical aid by lock picking his bike, searching it, and generally attempting to search the man, this however didn't happen due to the individual being treated quickly, and getting back quickly so his bike couldn't be tampered with.
      
      Thirty (30) minutes later I heard on the frequency that they were contacted by the Cartel, and were informed to find a vehicle around a certain area and to deliver it to them for a prize. The prize was not specified, however the location and vehicle was; a Black Tezeract was hidden around the city inside of a garage that opens. We called SED to TAC-3, but were only met with one (1) operator. We made the wise choice to switch to J-TAC 2, to get the LSPDs GND, and METRO involved. We briefed the whole J-TAC of what was happening, and what our plan was. I kept listening in, and hearing that it wasn't only the Russians that get this message, every other gang does and they're all competing for the same thing. After hearing this, we knew that the Russians may not get the vehicle, and we might not get anything in return, however, this changed when one of the Russian individuals shouted that they found the car, and all the other members on the shared frequency asked for the location, they stated the vehicle was in a small garage near the Vespucci Beach Clothing store. Marked as Clothing Store 8/16 on the GPS. Both myself and Luka Rosselli made our way down in a Black 10F Widebody, acting as if we're the allies of their gang. We found them hiding in an alleyway with high-end vehicles, and one individual lockpicking the vehicle. We quickly drove away, and waited for them to state they had opened it, fortunately they opened it quickly, and started the car with a screwdriver even quicker.
      
      After they had started the vehicle, they messaged the Cartel via their personal cell-phone and received a location. They stated the location via their frequency many times, giving myself ample opportunities to find out where it was. We found the location before the Russians, and drove-by, the members of the Cartel were seen in a Black SUV Limo, standing in-front awaiting the delivery of the stolen vehicle. The Cartel didn't think anything of us, and instead waved us by and we continued. The Russians were deciding on a route to take when delivering the vehicle, and figured the best route would be as follows; Follow north on Bay-city incline, and merge onto the Del Perro Fwy, continue along the Freeway until you can merge onto La Peurta Fwy for a short amount of time then following the off-ramp towards Olympic Fwy to follow down towards Popular St. As they were on the final stretch on Olympic Fwy, we found them and parked behind them. We then witnessed tehv vehicle drive into the secluded meeting spot, and exchange words with the Cartel. Many other Russians arrived, four (4) in a Black Buffalo STX, and another four (4) in a Black Jugular, of which two (2) of them from each vehicle were armed with a Pistol .50. The vehicles were informed to leave, and they drove away, only the stolen vehicle remained. The conversation lasted a few minutes before the Russians dismounted from the vehicle, and letting the Cartel check the vehicle out. During this time, a man with a Black Denim Jacket, and a White Undershirt (later identified as Rocky Bologna) got into the vehicle, confirming it's vadility and searched the trunk. They all began to keep talking, and a man in Black Jumper, with Blue Frizzy hair (later identified as Charlie McHoe) searched the trunk and removed a duffel-bag, the contents were unknown but he approached the two (2) Russians and attempted to hand the duffel-bag over, however they didn't as they got spooked. They ran away, both Russians ran to the main road, and all five (5) of the Cartel got into the Black SUV Limo and proceeded to drive off.
      
      Both Russians were apprehended by SED, and were arrested for Grand Theft Auto. The LSPDs METRO pulled over the Black SUV Limo and had all occupants step out. I requested the vehicle to be searched, and the duffel-bag was found. Upon searching the contents of the bag, we found out it contained two (2) AK-47s with two-hundred (200) ammo each, totalling in four-hundred (400) ammo for the AK-47s. After finding this, we searched all individuals but found nothing off concern. They were all detained, and brought to Mission Row holding cells where charges were being discussed.
      
      Charges were discussed as follows; Charlie McHoe receives WF03 - Possession of Illegal Firearms/Weapons for holding the duffel-bag containing both heavy-weaponry, Rackateering & Unlawful Assembely. After deliberating with Associate Justice Judith Mason, we figured that all these charges descriptions match the crime that happened, and fit the situation perfectly. One-by-one, they were removed from the cells and placed inside of a room to process them by taking their mugshots, and applying charges. This processed happened seven (7) times. Both the LSSD & LSPD had organised a convoy there, the convoy went smoothly, we took up both lanes so no interference could happen and they were all brought inside of the gates within DOC.

  
  EVIDENCE DETAILS

  • Exhibit A: AK-47 w/ 200 bullets, Serial Number - 1678055510441
    Exhibit B: AK-47 w/ 200 bullets, Serial Number - 1678055517715
    Exhibit C: **Both body-cam & dash-cam from Oscar Black would be attached showcasing all the events unfold**
    
    Photo of the evidence in the locker (if applicable)

    

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  ARRESTING DEPUTY SIGNATURE
  
  

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• Exhibit #2: Witness Statement - Oscar Black
  Spoiler

  

  

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

  Case Information

  • Case Number: Case Number
    Incident Date: 06/MAR/2023

  Witness Information

  • Name: Oscar Black
    Date of Birth: 12/05/1995
    Phone Number: 299-1811
    Occupation: Los Santos Sheriff's Department, Investigator II

  Witness Statement

  • I a few other deputies on duty were involved in a 10-1, I swapped frequencies and found myself on an active frequency. The gang was unknown but was later revealed as Russians. I remained on the frequency, whilst Captain Luka Rosselli sat in the passenger seat, ready to call units at any given moment. We traveled throughout the city, attempting to locate them, and found them. Nothing much was happening so we let them be until one of their members shouted that the cartel had messaged them. They started the cartel looking for the car, and they'd messaged all gangs within the city with the task of locating it and bringing it to a specific location for a prize. They started the prize can range from weapons to cash, or other valuable items.
    
    We called both SED & METRO to assist, and we told them what we were going to do. Everyone was on-board, and we prepared to intervene when the deal was happening. The Russians found the car, lockpicked it, and hotwired it. The vehicle in question was a Black Tezeract, an electric car worth up to millions of dollars. The Russians texted the cartel and said we have the car. The cartel replied back almost instantly, giving them a meeting location. We arrived at the location to find a Black SUV Limo with a few people standing outside of it suits. We remained around the area and found the Russians entering the area, exchanging a few words with the cartel. The Russians dismounted the car, and one of the members from the cartel (later identified as Rocky Bologna) stepped inside the car, sitting in the driver's seat, and rummaging through both the glovebox and trunk. One individual from the cartel retrieved a duffel bag from the trunk of the Limo, then attempted to hand it over to the Russians, but they were spooked by LSPD units before we could do so. They attempted to run away, but we caught both Russians & the Black SUV Limo. All occupants of the Limo were detained, and METRO units searched the vehicle, finding the bag and opening it up. The bag had two (2) AK-47s with two-hundred bullets each. Charlie McHoe was charged for the firearms as he was seen with the bag, and the others were charged with unlawful assembly & racketeering as they were also involved with the trade-off where the cartel receives the stolen super worth millions, whereas the Russians receive heavy-weaponry where it can be used to harm other people.
    
    **Both body cam & dash-cam of this incident would be attached, showing all events unfold.**
    
    ► Show Spoiler

    

  Witness Affirmation

  • I, Oscar Black, 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,
    
    
    Oscar Black
    Investigator II
    Los Santos Sheriff's Department
    
    Date: [07/MAR/2023]

  
  

• Exhibit #3: Witness Statement - Jeff Dayton - Deputy who confiscated the weapons
  Witness Statement from Deputy Jeff Dayton

  

  

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

  Case Information

  • Case Number: []
    Incident Date: [05/MAR/2023]

  Witness Information

  • Name: [Jeff Dayton]
    Date of Birth: [11/Sep/2023]
    Phone Number: [370-9616]
    Occupation: [Deputy Sheriff]

  Witness Statement

  • [Jeff Dayton, On March 5th, 2023 I received a Special Enforcement Detail pager alert. I got changed into my gear and joined the tac channel where operations were being discussed. I joined Sgt Solicetto's unit and rode with him to the city. During the drive down we were advised by Investigators Oscar Black and Luka Rosselli that they had heard radio chatter of a possible situation going on involving gangs in the city, Russians, and Cartel members. We were advised to stage in the city and await further instructions which is what we done. Information was given by Investigator Rosselli that the Cartel had offered a "prize" for the delivery of a specific vehicle per radio transmissions. It was relayed over tac that the Russians had acquired the wanted vehicle and were En Route to a specific location under Olympic Fwy at Popular St to meet the Cartel for an exchange. We were advised that the russians were leaving from the said exchange location as well as the black SUV Limo that was believed to be transporting the Cartel members. We were advised to move in on the Limo and conduct a traffic stop. We got all occupants out of the vehicle and searched them. I was advised to search the person sitting in the back on the passenger side of the Limo which was Charlie Mchoe. During the search of Mchoe I removed a black bag from his person and inside the bag was two Assault Rifles. One containing 200rnds and one containing 100rnds. I gave the bag containing the rifles to Investigator Black for evidence processing. All suspects were arrested and transported to Mission Row PD and detained in cells while command staff went over charges for all individuals. After charges were set we transported four of the arrestees in our SED TARV to DOC where they were handed over to DOC guards for booking. Our unit went back in service from call. ]

  Witness Affirmation

  • I, [Jeff Dayton], 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,
    
    
    [Jeff Dayton]
    [Title, Deputy Sheriff III]
    [Organization, Los Santos County Sheriff Department]
    
    Date: [05/Mar/2023]

  

• Exhibit #4: Bodycamera Footage - Jimmy Solicetto
  Witness Statement from Sergeant Jimmy Solicetto

  

  

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

  Case Information

  • Case Number: N/A
    Incident Date: 05/MAR/2023

  Witness Information

  • Name: Jimmy Solicetto
    Date of Birth: 29/APR/96
    Phone Number: 263-7251
    Occupation: Deputy, Los Santos County Sheriff's Department

  Witness Statement

  • I recall being paged for an Operation that a few of us were involved in. SIB + DB were working on a case, I don't quite know the details. My job on this Operation was to simply guide the SED team to ensure the safety of everyone involved. When my unit entered closer to the area where the situation was going down, I was told to pull over the limousine and conduct a 10-55. As soon as DB + SIB gave me the go, we pulled out the individuals of the vehicle and cuffed them on the side. We later processed them at Mission Row where they were then transported to DOC.

  Witness Affirmation

  • I, Jimmy Solicetto, 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,
    
    
    Jimmy Solicetto
    Sergeant,
    Los Santos County Sheriff's Department
    
    Date: 10/MAR/2023

  
  

  **Attatched Bodycamera Footage from Jimmy Solicetto**

  ((
  
  https://www.youtube.com/watch?v=d_ltMoRC59w
  ((This video is from another deputy's POV, however, it covers what Jimmy Solicetto's bodycamera recording would have gathered))
  ))

• Exhibit #5: Witness Statement - Deputy Jordan Smoke
  
  Witness Statement from Deputy Jordan Smoke

  

  

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

  Case Information

  • Case Number: [Case Number]
    Incident Date: [05/03/2023]

  Witness Information

  • Name: [Jordan Smoke]
    Date of Birth: [24/05/1993]
    Phone Number: [338-4373]
    Occupation: [Sheriff's Deputy]

  Witness Statement

  • [While off duty, I received a notification on my SED pager. I drove to the Department in Paleto Bay and geared up in active uniform. I proceeded with checking the Tac Radio frequencies until I found the one being used. I was notified by units already "in the area" that there was a situation that may involve a possible shipment being delivered to multiple individuals by members of the Cartel.
    
    I deployed a vehicle and proceeded with linking up with Sgt. Jimmy Soliecetto and his Delta unit, where I parked my cruiser and joined his unit. We scrambled around the city multiple times, waiting for the correct moment and the word from other units to move in. After approximately 30 minutes of scrambling locations around the city, to the best of my knowledge, Alpha unit advised that a black patriot limo was going to be involved in this exchange supposedly taking place.
    
    At this time, units forming a parimeter began forming a tighter and tighter parimeter around the stated area of this vehicle, approximately a 2km parimeter. The Alpha unit or a undercover unit advised that an exchange just took place involving multiple people in the black Patriot and two individuals in red t-shirts. The word to move in was initiated, in which our unit did. The black Patriot Limo was seen leaving the area and a traffic stop was performed on the vehicle. After speaking with the individuals in the black Patriot, the individuals were asked to step out of their vehicle and line up on the sidewalk.
    
    All individuals involved were detained and frisked by individual units per individual due to current investigative purposes. I was tasked with frisking and identifying Leah Lennox. Lennox was read her rights and was advised of what was going on. During the frisk, no illegal items were found.
    
    After a brief conversation amongst SED and Investigators, it was determined that we would load up the individuals involved and transport them to Mission Row Presinct to conduct the rest of the investigation in a more safe and secure location. After transporting individuals to Mission Row, SED was asked to wait with the Tarv to assist with transport to the Department of Corrections Facility if needed.
    
    After waiting for approximately 45 minutes at Mission Row, my unit was tasked with loading, securing, and transporting 4 potential suspects from Mission Row to the Department of Corrections facility. After transporting the individuals to the Department of Corrections Facility, SED was given authorization to clear.
    
    ]

  Witness Affirmation

  • I, [Jordan Smoke], 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,
    
    
    [Jordan Smoke]
    [Deputy Sheriff III]
    [Sheriff's Department]
    
    Date: [07/03/2023]

  

• Exhibit #6: Witness Statement - Luka Rosselli
  
  Witness Statement - Luka Rosselli

  

  

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

  Case Information

  • Case Number: [Case Number]
    Incident Date: 05/03/2023

  Witness Information

  • Name: Luka Rosselli
    Date of Birth: 23/06/1994
    Phone Number: 2735722
    Occupation: Sheriff Deputy

  Witness Statement

  • On the Date of 5 May 2023, I was attending a 10-1 at Paleto station, when I was approached by my Investigator Oscar Black, stating that he had stumbled on an active Frequency, where people are actively speaking of committing criminal activity all over the city. I dropped out of the 10-1 and drove down with the Investigator to the city, we chased them around following Radio callouts eventually arriving at a location where they decided to picklock a Black BF400. As we were driving around the area getting their plates, as they were not shy from wearing their Gang outfit, Red red turtleneck, and black pants. One of them starts shouting over the radio, stating that they had a message from the "Cartel" to find a vehicle in exchange for a reward, which they later discussed was a 100K in cash and Heavy weapons, they made no mention of quantity so we assumed a shipment of them. The vehicle they stated was a Black "Tezeract" parked inside an openable unlocked garage and they went on the hunt, their radio went extremely active, as everybody looked for it. We switched to an undercover vehicle and started following them around based on their radio callouts. They at some point also stated that every gang is also looking for the vehicle, and whichever finds it gets the reward, they also kept talking about a meeting at the docks. We had patrolled around and had PD on Jtac at this point assisting with Air, as well as gathering all Metro, and SED available to be close. After a long period of driving around, they eventually said that they had found the vehicle, near a clothing store down at Vespucci. We knew the call was valid as they started scrambling for picklocks and a screwdriver. Air was high and overlooking the area, as we drove around carefully due to the large presence of gangs around the area where the vehicle was parked. The meeting location "Under Olympic Freeway by popular" at this point had just been said over the radio, we drive towards the location to check it out, driving next to the train tracks to avoid detection we spotted a Limo parked right under the freeway, and at this point, we assumed this was the exact location, so we marked it and relayed the information. We then kept on driving around the area when the vehicle had just been called to be on the move to the location by PD. Shortly after we spot it on the freeway off-ramp, we made a U-turn and parked on the Off-ramp, sure enough, the vehicle made a few turns and parked right where the Black Limo was. Two individuals in Red over Black got out, and a few other vehicles parked right behind, all in Red over Black, The exact Russian outfit. After a short conversation with the people that got out of the Limo, they relayed over the Radio that the Cartel wanted all but the people that brought the car to leave, and so they did, leaving only the 2 individuals that brought the car there. A man wearing a black leather Jacket walked around the vehicle as they continued to talk, looking over it before stepping inside. he then made his way out and spoke to the Female on the scene. The female made her way to the Limo and came back followed by an individual in a black hoodie, the individual in the black hoodie prior to walking to the Tezeract reached to grab something out of the back of the Limo, then he walked to the Tezeract with a bag on hand. Once he reached the two individuals in red, something spooked them and they all ran back to the Limo and drove off. Two individuals in red walked out, just to be detained alongside a BF400 that attempted to pick them up by PD/SED. The Limo was pulled over by PD, SED, DB, and METRO as we went to switch vehicles, and kept relaying the information on the person carrying the Bag, and all the callouts were made about the meeting with this group called "Cartel" Once the individual with the bag was detained, in the bag there were Two Automatic Rifles Ak47s and later was determined 300 Rifle Bullets.
    The rest of the group was detained and transported to Mission row, where they had been processed and transported to DOC.

  Witness Affirmation

  • I, Luka Rosselli, 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,
    
    
    Luka Rosselli
    Captain
    Los Santos County Sheriff's Department
    
    Date: 10/03/2023

  

• Exhibit #7: LSPD CCTV - Recovered black vehicle
  Spoiler

  

• Exhibit #8: Witness Statement - Detective Cyrus Carver
  Detective C. Carver's Statement

  

  

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

  Case Information

  • Incident Date: [05/MAR/2023]

  Witness Information

  • Name: [Cyrus Carver]
    Date of Birth: [16/AUG/1990]
    Phone Number: [452-1940]
    Occupation: Police Detective - Los Santos Police Department

  Witness Statement

  • Detective Cyrus Carver was called to a joint operation by the Sheriffs Office regarding a gang operation that was ongoing at the time. Members of the sheriff's investigation unit were on a compromised gang frequency occupied by members of the Russian Mob organization. The investigators on SDs side heard that the Russians were tasked with retrieving a vehicle for a group they (the Russians) called "the Cartel". This name was used multiple times and was referenced often according to SD. Carver was undercover and wearing his civilian clothing alongside a mask to conceal his identity. Carver was driving his personal owned vehicle. SD Investigators continued pushing information through the tactical radio channels. After around 15 minutes of surveillance, the occupants of the radio frequency revealed excitedly that their organization had located the vehicle they were instructed to steal by "the Cartel". The Russians rushed to bring the vehicle (identified as a Tezeract supercar) to the drop-off location. The drop-off location was a pre-determined spot issued to them by members of "the Cartel". Once the Russians arrived with the vehicle, SD investigators had eyes on them the entire time. SD investigators informed the radio channel that the Russians made contact with individuals (the Cartel). The man later identified as Rocky Bologna entered the vehicle and checked the inside and the trunk of the stolen Tezeract. The man later identified as Charlie McHoe went into the trunk of a Patriot Stretch limo and removed a bag from the trunk. The transaction suddenly stopped as all parties rushed back into their respective vehicles and tried fleeing, law enforcement then moved in and took all the involved at the scene into custody. The Patriot Strech limo was stopped on the corner of the street and the occupants taken into custody. AK47 style assault rifles were found inside the bag that Charlie removed from the limo. Once charged with their crimes, all of them minus Leah Lennox pled guilty to their charges, thus admitting their guilt to the Deputies.

  Witness Affirmation

  • I, Cyrus Carver, 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,
    
    
    Cyrus Carver
    Detective
    Los Santos Police Department
    
    Date: [17/MAR/2023]

  

Deputy Attorney General
San Andreas Judicial Branch

[Judith Mason]

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

---

COURT DECISION

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna
#23-CM-0052

A decision was reached in the above case on the 10th day of June, 2023.

To be clear for the record, the court has acted in accordance with previously established procedures of activating cases on a first-come first-served basis, and did not activate this case out of order due to the special circumstances presented by the defense.

The court would like to acknowledge the submission made by the representative from the Los Santos Police Department, however, would further state that a submission such as the one presented on the public docket would be better suited as a private communication between the Los Santos Police Department and the Prosecution Division of the Judicial Branch, as the Los Santos Police Department is not a direct party in this criminal case, nor is the representative a bar licensed attorney authorized to present legal arguments on the public docket.

When it comes to the formal challenge by the prosecution in regards to the authenticity of the signatures provided in the initial case submission, the court will be accommodating to the challenge by requiring that each of the additional defendants ( @James Eriksen @Leah Lennox @Rocky Bologna ) post on the public docket confirming that they are disputing the charges as outlined in the initial submission by Vince Williams. This should not be an overly burdensome task considering each of the named defendants appear to actively maintain an account on the government website with previous submissions relating to their aforementioned business holdings.

With the Motion for Discovery now having been presented by the Acting Attorney General, the court will officially submit the Order for Discovery in case any further submissions have not yet been presented. Should the prosecution no longer need the remainder of the 7-day window to submit additional motions, the court would request confirmation that they wish to proceed and would waive the remainder of the opportunity to submit additional motions.

To summarize, this case is now pending the affirmations from James Eriksen, Leah Lennox, and Rocky Bologna that they do, indeed, dispute the charges mentioned - the court will require the submissions to be made within 5 days of this notice.



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

[Judith Mason]

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

---

ORDER FOR DISCOVERY

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna
#23-CM-0052

A court order was entered in the above case on the 10th day of June, 2023.

The case of #23-CM-0052, State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna 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.



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

[Rocky Bologna]

I, Rocky Bologna, confirm I am appealing the charges as per the initial appeal submission

[James Eriksen]

yes i james eriksen confirms

[Leah Lennox]

I, Leah Lennox, affirm my intention to continue disputing these charges.

[Antonio McFornell]

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

---

• Dear Justice Mason,
  
  The Prosecution strongly urges the reconsideration of the decision concerning the prosecution's challenge to the authenticity. It is crucial to emphasize that the mere ratification of a forged signature by the victim should not serve as a basis for deeming the initial forgery as lawful or right.
  
  In cases involving the forgery of signatures, null/void consent, and the commission of a crime, the examination and assessment of these matters must be conducted at the time of their occurrence, not retrospectively. However, we are deeply concerned by the unjust and procedurally flawed opportunity given to the presumed defendants, allowing them to rectify their wrongdoing or obtain sanitizing consent subsequent to the alleged forgery and/or fraud. This opportunity was presented after the signatures were initially provided by the person who has now filed this criminal appeal.
  
  Allowing this case to progress with the other defendants who did not originally file this appeal would establish an alarming, dangerous and detrimental precedent. It would essentially convey the message that the Superior Court of San Andreas is willing to allow defendants to retroactively 'fix' their unlawful acts, thereby evading proper trial and accountability.
  
  It is essential to uphold the integrity of the judicial system by recognizing that the ratification of a forged signature should not undermine the initial illegality or unlawfulness of the act. The principle of justice demands that each defendant be held accountable for their actions at the time they were committed, without granting them the privilege of circumventing prosecution through later or subsequent ratification. Failing to acknowledge this fundamental principle would, again, set a dangerous precedent and undermine the very essence of our justice system.
  
  With this in mind, we respectfully request that you reconsider before moving forward with this proceeding.
  
  Best regards,
  
  
  Deputy Attorney General
  Director of the San Andreas Bar Association
  San Andreas Judicial Branch
  (909) 553-8869 — [email protected]

[Cyrus Raven]

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

---

• Honorable Judith Mason,
  
  For the record, we have formally confirmed all Defendant's wish to continue with this appeal on multiple occasions. This has been confirmed a total of three times by myself prior to activation and the court now has confirmation directly from the Defendants after activation.
  
  Respectfully,
  
  Cyrus Raven
  Chief Public Defender
  San Andreas Judicial Branch - Command
  5356160 — [email protected]

  ---

[Cyrus Raven]

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

---

MOTION TO SUPPRESS

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna
#23-CM-0052

A Motion to Suppress was filed in the above case on the 19th of June, 2023.

The Defendants, Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna, by and through the undersigned attorney, filed this Motion to Suppress, and request to following be suppressed from evidence;

• Exhibit #1: SD Arrest Report
  Requested Evidence to Suppress:
• Any mention of guilty/not-guilty plea as per previous precedent (See: #23-CM-0038, State of San Andreas v. Shawn Morningstar
  . It should be noted that none of my clients has admitted any guilt, despite what the arrest report claims.
  

  On the 6th March, 2023, I was involved in a 10-1 at Paleto Station and changed my frequency to a different one so it was quiet, however, this wasn't the case and I begun hearing a bunch of other voices talking loudly. I quickly made my way over to Luka Rosselli and informed him, we then informed the 10-1 lead that we were clearing to work on this. Both myself and Luka Rosselli got into an unmarked cruiser and begun driving towards the city. At first, the frequency was quiet, people came and went and often talked about if anything was happening, and nothing was. The frequency began to pickup after a rival member had fell injured, they attempted to interfere with his medical aid by lock picking his bike, searching it, and generally attempting to search the man, this however didn't happen due to the individual being treated quickly, and getting back quickly so his bike couldn't be tampered with. - Relevance
  
  Thirty (30) minutes later I heard on the frequency that they were contacted by the Cartel, and were informed to find a vehicle around a certain area and to deliver it to them for a prize. The prize was not specified, however the location and vehicle was; a Black Tezeract was hidden around the city inside of a garage that opens. We called SED to TAC-3, but were only met with one (1) operator. We made the wise choice to switch to J-TAC 2, to get the LSPDs GND, and METRO involved. We briefed the whole J-TAC of what was happening, and what our plan was. I kept listening in, and hearing that it wasn't only the Russians that get this message, every other gang does and they're all competing for the same thing. After hearing this, we knew that the Russians may not get the vehicle, and we might not get anything in return, however, this changed when one of the Russian individuals shouted that they found the car, and all the other members on the shared frequency asked for the location, they stated the vehicle was in a small garage near the Vespucci Beach Clothing store. Marked as Clothing Store 8/16 on the GPS. Both myself and Luka Rosselli made our way down in a Black 10F Widebody, acting as if we're the allies of their gang. We found them hiding in an alleyway with high-end vehicles, and one individual lockpicking the vehicle. We quickly drove away, and waited for them to state they had opened it, fortunately they opened it quickly, and started the car with a screwdriver even quicker. - Lack of foundation and hearsay - No evidence has been provided to assert any criminal group identity. In this instance, the only statements used to prove the matter of fact stated is out of court statements, which are inadmissible under the hearsay rule.
  
  After they had started the vehicle, they messaged the Cartel via their personal cell-phone and received a location. They stated the location via their frequency many times, giving myself ample opportunities to find out where it was. We found the location before the Russians, and drove-by, the members of the Cartel were seen in a Black SUV Limo, standing in-front awaiting the delivery of the stolen vehicle. The Cartel didn't think anything of us, and instead waved us by and we continued. The Russians were deciding on a route to take when delivering the vehicle, and figured the best route would be as follows; Follow north on Bay-city incline, and merge onto the Del Perro Fwy, continue along the Freeway until you can merge onto La Peurta Fwy for a short amount of time then following the off-ramp towards Olympic Fwy to follow down towards Popular St. As they were on the final stretch on Olympic Fwy, we found them and parked behind them. We then witnessed tehv vehicle drive into the secluded meeting spot, and exchange words with the Cartel. Many other Russians arrived, four (4) in a Black Buffalo STX, and another four (4) in a Black Jugular, of which two (2) of them from each vehicle were armed with a Pistol .50. The vehicles were informed to leave, and they drove away, only the stolen vehicle remained. The conversation lasted a few minutes before the Russians dismounted from the vehicle, and letting the Cartel check the vehicle out. During this time, a man with a Black Denim Jacket, and a White Undershirt (later identified as Rocky Bologna) got into the vehicle, confirming it's vadility and searched the trunk. They all began to keep talking, and a man in Black Jumper, with Blue Frizzy hair (later identified as Charlie McHoe) searched the trunk and removed a duffel-bag, the contents were unknown but he approached the two (2) Russians and attempted to hand the duffel-bag over, however they didn't as they got spooked. They ran away, both Russians ran to the main road, and all five (5) of the Cartel got into the Black SUV Limo and proceeded to drive off. - Lack of foundation, Speculation - Use of ''cartel'' and ''russians'' without proper foundation being established as well as being more prejudicial than probative.
  
  Both Russians were apprehended by SED, and were arrested for Grand Theft Auto. The LSPDs METRO pulled over the Black SUV Limo and had all occupants step out. I requested the vehicle to be searched, and the duffel-bag was found. Upon searching the contents of the bag, we found out it contained two (2) AK-47s with two-hundred (200) ammo each, totalling in four-hundred (400) ammo for the AK-47s. After finding this, we searched all individuals but found nothing off concern. They were all detained, and brought to Mission Row holding cells where charges were being discussed. - Lack of foundation, Speculation - Use of ''russians'' without proper foundation being established as well as being more prejudicial than probative.
  
  Charges were discussed as follows; Charlie McHoe receives WF03 - Possession of Illegal Firearms/Weapons for holding the duffel-bag containing both heavy-weaponry, Rackateering & Unlawful Assembely. After deliberating with Associate Justice Judith Mason, we figured that all these charges descriptions match the crime that happened, and fit the situation perfectly. One-by-one, they were removed from the cells and placed inside of a room to process them by taking their mugshots, and applying charges. This processed happened seven (7) times. Both the LSSD & LSPD had organised a convoy there, the convoy went smoothly, we took up both lanes so no interference could happen and they were all brought inside of the gates within DOC. - Relevance, lack of foundation and hearsay - No statement by Chief Mason has been given and as such asserting that a Judge has already agreed with all the charges added would constitute hearsay and cast doubt on the impartiality of the ruling Judge.

  • Detailed Reasoning: Please see red text above for explanation.

• Exhibit #2: Witness Statement - Oscar Black
  Requested Evidence to Suppress:

  I a few other deputies on duty were involved in a 10-1, I swapped frequencies and found myself on an active frequency. The gang was unknown but was later revealed as Russians. I remained on the frequency, whilst Captain Luka Rosselli sat in the passenger seat, ready to call units at any given moment. We traveled throughout the city, attempting to locate them, and found them. Nothing much was happening so we let them be until one of their members shouted that the cartel had messaged them. They started the cartel looking for the car, and they'd messaged all gangs within the city with the task of locating it and bringing it to a specific location for a prize. They started the prize can range from weapons to cash, or other valuable items. - Hearsay, Lack of foundation - The statements made were made out of court and are being used to prove the matter of fact asserted.
  
  We called both SED & METRO to assist, and we told them what we were going to do. Everyone was on-board, and we prepared to intervene when the deal was happening. The Russians found the car, lockpicked it, and hotwired it. The vehicle in question was a Black Tezeract, an electric car worth up to millions of dollars. The Russians texted the cartel and said we have the car. The cartel replied back almost instantly, giving them a meeting location. We arrived at the location to find a Black SUV Limo with a few people standing outside of it suits. We remained around the area and found the Russians entering the area, exchanging a few words with the cartel. The Russians dismounted the car, and one of the members from the cartel (later identified as Rocky Bologna) stepped inside the car, sitting in the driver's seat, and rummaging through both the glovebox and trunk.One individual from the cartel retrieved a duffel bag from the trunk of the Limo, then attempted to hand it over to the Russians, but they were spooked by LSPD units before we could do so. They attempted to run away, but we caught both Russians & the Black SUV Limo. All occupants of the Limo were detained, and METRO units searched the vehicle, finding the bag and opening it up. The bag had two (2) AK-47s with two-hundred bullets each. Charlie McHoe was charged for the firearms as he was seen with the bag, and the others were charged with unlawful assembly & racketeering as they were also involved with the trade-off where the cartel receives the stolen super worth millions, whereas the Russians receive heavy-weaponry where it can be used to harm other people. - Lack of foundation, Speculation - Use of ''cartel'' and ''russians'' without proper foundation being established as well as being more prejudicial than probative. Use of the word ''spooked'' is speculative and speaks to the state of mind of the Defendants and others involved, something the witness has no way of accurately asserting and the use of which prejudices this court.

  • Detailed Reasoning: Please see red text above for explanation.

• Exhibit #3: Witness Statement from Deputy Jeff Dayton
  Requested Evidence to Suppress: Entire Exhibit
  • Detailed Reasoning: Incomplete, Invalid or Incorrect Format - Witness was born in the future (See: DOB provided)

• Exhibit #5: Witness Statement - Deputy Jordan Smoke
  Requested Evidence to Suppress:

  While off duty, I received a notification on my SED pager. I drove to the Department in Paleto Bay and geared up in active uniform. I proceeded with checking the Tac Radio frequencies until I found the one being used. I was notified by units already "in the area" that there was a situation that may involve a possible shipment being delivered to multiple individuals by members of the Cartel. - Lack of foundation, Speculation - Use of ''Cartel'' without proper foundation being established as well as being more prejudicial than probative.
  
  I deployed a vehicle and proceeded with linking up with Sgt. Jimmy Soliecetto and his Delta unit, where I parked my cruiser and joined his unit. We scrambled around the city multiple times, waiting for the correct moment and the word from other units to move in. After approximately 30 minutes of scrambling locations around the city, to the best of my knowledge, Alpha unit advised that a black patriot limo was going to be involved in this exchange supposedly taking place. - Speculation, Hearsay - Speculative statement made by someone else besides witness and used to prove the matter of fact asserted.
  
  At this time, units forming a parimeter began forming a tighter and tighter parimeter around the stated area of this vehicle, approximately a 2km parimeter. The Alpha unit or a undercover unit advised that an exchange just took place involving multiple people in the black Patriot and two individuals in red t-shirts. The word to move in was initiated, in which our unit did. The black Patriot Limo was seen leaving the area and a traffic stop was performed on the vehicle. After speaking with the individuals in the black Patriot, the individuals were asked to step out of their vehicle and line up on the sidewalk.
  
  All individuals involved were detained and frisked by individual units per individual due to current investigative purposes. I was tasked with frisking and identifying Leah Lennox. Lennox was read her rights and was advised of what was going on. During the frisk, no illegal items were found.
  
  After a brief conversation amongst SED and Investigators, it was determined that we would load up the individuals involved and transport them to Mission Row Presinct to conduct the rest of the investigation in a more safe and secure location. After transporting individuals to Mission Row, SED was asked to wait with the Tarv to assist with transport to the Department of Corrections Facility if needed.
  
  After waiting for approximately 45 minutes at Mission Row, my unit was tasked with loading, securing, and transporting 4 potential suspects from Mission Row to the Department of Corrections facility. After transporting the individuals to the Department of Corrections Facility, SED was given authorization to clear.

  • Detailed Reasoning: Please see red text above for explanation.

• Exhibit #6: Witness Statement - Luka Rosselli
  Requested Evidence to Suppress:

  On the Date of 5 May 2023, I was attending a 10-1 at Paleto station, when I was approached by my Investigator Oscar Black, stating that he had stumbled on an active Frequency, where people are actively speaking of committing criminal activity all over the city. I dropped out of the 10-1 and drove down with the Investigator to the city, we chased them around following Radio callouts eventually arriving at a location where they decided to picklock a Black BF400. As we were driving around the area getting their plates, as they were not shy from wearing their Gang outfit, Red red turtleneck, and black pants. One of them starts shouting over the radio, stating that they had a message from the "Cartel" to find a vehicle in exchange for a reward, which they later discussed was a 100K in cash and Heavy weapons, they made no mention of quantity so we assumed a shipment of them. The vehicle they stated was a Black "Tezeract" parked inside an openable unlocked garage and they went on the hunt, their radio went extremely active, as everybody looked for it. We switched to an undercover vehicle and started following them around based on their radio callouts. They at some point also stated that every gang is also looking for the vehicle, and whichever finds it gets the reward,they also kept talking about a meeting at the docks. We had patrolled around and had PD on Jtac at this point assisting with Air, as well as gathering all Metro, and SED available to be close. After a long period of driving around, they eventually said that they had found the vehicle, near a clothing store down at Vespucci. We knew the call was valid as they started scrambling for picklocks and a screwdriver. Air was high and overlooking the area, as we drove around carefully due to the large presence of gangs around the area where the vehicle was parked. The meeting location "Under Olympic Freeway by popular" at this point had just been said over the radio, we drive towards the location to check it out, driving next to the train tracks to avoid detection we spotted a Limo parked right under the freeway, and at this point, we assumed this was the exact location, so we marked it and relayed the information. We then kept on driving around the area when the vehicle had just been called to be on the move to the location by. Shortly after we spot it on the freeway off-ramp, we made a U-turn and parked on the Off-ramp, sure enough, the vehicle made a few turns and parked right where the Black Limo was. Two individuals in Red over Black got out, and a few other vehicles parked right behind, all in Red over Black, The exact Russian outfit. After a short conversation with the people that got out of the Limo, they relayed over the Radio that the Cartel wanted all but the people that brought the car to leave, and so they did, leaving only the 2 individuals that brought the car there. A man wearing a black leather Jacket walked around the vehicle as they continued to talk, looking over it before stepping inside. he then made his way out and spoke to the Female on the scene. The female made her way to the Limo and came back followed by an individual in a black hoodie, the individual in the black hoodie prior to walking to the Tezeract reached to grab something out of the back of the Limo, then he walked to the Tezeract with a bag on hand. Once he reached the two individuals in red, something spooked them and they all ran back to the Limo and drove off. Two individuals in red walked out, just to be detained alongside a BF400 that attempted to pick them up by PD/SED. The Limo was pulled over by PD, SED, DB, and METRO as we went to switch vehicles, and kept relaying the information on the person carrying the Bag, and all the callouts were made about the meeting with this group called "Cartel" Once the individual with the bag was detained, in the bag there were Two Automatic Rifles Ak47s and later was determined 300 Rifle Bullets.
  The rest of the group was detained and transported to Mission row, where they had been processed and transported to DOC. - Hearsay, Speculation and Lack of Foundation - Highlighted statements are either speculative by the witness with lack of foundation or they are out of court statements

  • Detailed Reasoning: Please see red text above for explanation.

• Exhibit #8: Witness Statement - Detective Cyrus Carver
  Requested Evidence to Suppress:

  Detective Cyrus Carver was called to a joint operation by the Sheriffs Office regarding a gang operation that was ongoing at the time. Members of the sheriff's investigation unit were on a compromised gang frequency occupied by members of the Russian Mob organization. The investigators on SDs side heard that the Russians were tasked with retrieving a vehicle for a group they (the Russians) called "the Cartel". This name was used multiple times and was referenced often according to SD. Carver was undercover and wearing his civilian clothing alongside a mask to conceal his identity. Carver was driving his personal owned vehicle. SD Investigators continued pushing information through the tactical radio channels. After around 15 minutes of surveillance, the occupants of the radio frequency revealed excitedly that their organization had located the vehicle they were instructed to steal by "the Cartel". The Russians rushed to bring the vehicle (identified as a Tezeract supercar) to the drop-off location. The drop-off location was a pre-determined spot issued to them by members of "the Cartel". Once the Russians arrived with the vehicle, SD investigators had eyes on them the entire time. SD investigators informed the radio channel that the Russians made contact with individuals (the Cartel). The man later identified as Rocky Bologna entered the vehicle and checked the inside and the trunk of the stolen Tezeract. The man later identified as Charlie McHoe went into the trunk of a Patriot Stretch limo and removed a bag from the trunk. The transaction suddenly stopped as all parties rushed back into their respective vehicles and tried fleeing, law enforcement then moved in and took all the involved at the scene into custody. The Patriot Strech limo was stopped on the corner of the street and the occupants taken into custody. AK47 style assault rifles were found inside the bag that Charlie removed from the limo. Once charged with their crimes, all of them minus Leah Lennox pled guilty to their charges, thus admitting their guilt to the Deputies. - Hearsay, Speculation and Lack of Foundation - Highlighted statements are either speculative by the witness with lack of foundation or they are out of court statements. Witness references multiple times what ''SD'' did or saw without any first-hand knowledge themselves. Speculative statements on what ''gangs'' were involved, if any.

  • Detailed Reasoning: Please see red text above for explanation.

Cyrus Raven
Chief Public Defender
San Andreas Judicial Branch - Command
5356160 — [email protected]

[Cyrus Raven]

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

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MOTION FOR CONTINUANCE

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna
#23-CM-0052

A Motion for Continuance was filed in the above case on the 19th of June, 2023.

The Defendants, Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna, by and through the undersigned attorney, filed this Motion for Continuance, and the reasoning for request is as follows;

• Reasoning: Further time to collect evidence
  • Detailed Explanation: We require more time to potentially gather a crucial witness statement and other evidence for this case.

Cyrus Raven
Chief Public Defender
San Andreas Judicial Branch - Command
5356160 — [email protected]

[Cyrus Raven]

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

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MOTION FOR DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna
#23-CM-0052

A Motion for Discovery was filed in the above case on the 21st of June, 2023

The Defendants, Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna, by and through the undersigned attorney, filed this Motion for Discovery, and present the following as evidence;

• Exhibit #9: Witness Statement - Charlie Mchoe
  Spoiler

  

  

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

  Case Information

  • Case Number: #23-CM-0052
    Incident Date: Around 6th March approximately at midnight

  Witness Information

  • Name: Charlie Mchoe
    Date of Birth: 01/JAN/2000
    Phone Number: 506-1371
    Occupation: Unemployed

  Witness Statement

  • I, Charlie Mchoe, will be taking responsibility for my actions as they were mine alone and no one elses fault. The weapons in the bag were mine and mine alone. I brought these weapons with me (without my friends knowing) so I could store them somewhere more secure later. My friends had no idea what was in the bag as I never told them and they were never able to check what was inside of the bag. I had already owned these weapons for a long time and was just planning to store them somewhere more secure. The claim that these weapons were meant for some sort of transaction is categorically false and simply not true.

  Witness Affirmation

  • I, Charlie Mchoe, 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 coersion. ((I affirm that all information submitted has been obtained via In-Character means.))
    
    Signed,
    
    Charlie Mchoe
    Date: 19/JUNE/2023

  
  

Cyrus Raven
Chief Public Defender
San Andreas Judicial Branch - Command
5356160 — [email protected]

[Judith Mason]

Document 1 | Filed 04/JUL/2023 | Page 1 of 1

IN THE SUPERIOR COURT
FOR THE STATE OF SAN ANDREAS

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• Docket Number:
  #23-CM-0052
  Date Filed:
  04/JUL/2023
  Violations:
  GF18 - Racketeering
  NM03 - Unlawful Assembly
  State of San Andreas
  
  v.
  
  Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna

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PLEA AGREEMENT

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• Pursuant to the case of State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna; Deputy Attorney General Tony McFornell, Chief Public Defender Cyrus Raven, and the defendants, Vince Williams, James Eriksen, Leah Lennox and Rocky Bologna, have entered into agreement, the terms of which are as follows;
  
  1. Current Charges
     1. NM03 - Unlawful Assembly
  2. Former Charges
     The state shall pursue the current charges listed above, in place of the original charges listed below:
     1. GF18 - Racketeering
     2. NM03 - Unlawful Assembly
  3. General Provisions
     • The defendants agree to plead no contest to the Current Charges outlined in Section I. The State waives the right to pursue the Former Charges outlined in Section II in regards to this particular incident. The defendants will not be required to pay court fees or associated appeal fees.
  4. Waiver of Rights
     • It is CRITICAL that you read this section of the plea agreement thoroughly. By signing this document, the defendants agree to surrender certain rights, notably; the defendants may not further appeal charges agreed to within this plea bargain.
       
       This agreement may not be terminated at the discretion of an defendant, the defendant's counsel, nor the prosecution; it may only be terminated by the presiding judge under strict guidelines set forth by the Supreme Court of San Andreas.
       
       By signing this document, the defendants is pleading no contest to the charges outlined in Section I and these charges may not be challenged at a later date.
  
  
  Tony McFornell
  Deputy Attorney General Tony McFornell
  San Andreas Judicial Branch
  Date Signed: 6/JUL/2023
  
  Cyrus Raven
  Chief Public Defender Cyrus Raven
  San Andreas Judicial Branch
  Date Signed: 04/07/2023
  
  Vince Williams
  Vince Williams
  Defendant
  Date Signed: 04/07/2023
  
  James Eriksen
  James Eriksen
  Defendant
  Date Signed: 05/07/2023
  
  Leah Lennox
  Leah Lennox
  Defendant
  Date Signed: 04/07/2023
  
  Rocky Bologna
  Rocky Bologna
  Defendant
  Date Signed: 06/07/2023
  
  Judy Mason
  Honorable Judith Mason
  San Andreas Judicial Branch
  Date Signed: 07/JUL/2023

[Judith Mason]

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

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ISSUANCE OF VERDICT

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna
#23-CM-0052

A decision was reached in the above case on the 7th day of July, 2023.

The case of #23-CM-0052, State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna has been resolved.

The previously submitted plea agreement has been offered by the prosecution, signed by the defendants and their attorney, and is hereby accepted by the court. Within the full details of the agreement, the prosecution agrees to waive the right to pursue the charge of GF18 - Racketeering in exchange for no contest pleas from all four defendants on the charge of NM03 - Unlawful Assembly.

It is with the above considerations that I issue the following verdict:

• On the count of NM03 - Unlawful Assembly, I find the defendant, Vince Williams, guilty.

• On the count of NM03 - Unlawful Assembly, I find the defendant, James Eriksen, guilty.

• On the count of NM03 - Unlawful Assembly, I find the defendant, Leah Lennox, guilty.

• On the count of NM03 - Unlawful Assembly, I find the defendant, Rocky Bologna, guilty.

In accordance with Judicial Branch policy, the defendants are entitled to compensation in the amount of $15,000 each for fines paid and time served for the Racketeering charge, which can be obtained by speaking with a judge at City Hall, located at 1 Rockford Drive.



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