#24-CM-0051, State of San Andreas v. Aya Ryoshi

[Bonnie Ryoshi]

Defendant Name: Aya Ryoshi - Old name Bonnie Ryoshi
Defendant Phone: 542-6006
Defendant Address: Alta Apartments
(( Defendant Discord: ryoshi69 ))
Requested Attorney: David Coast

Charging Department: Los Santos Police Department

Date & Time of Incident(s): 09/FEB/2024 23:12
Charge(s):

• GM13 - Criminal Threats of a GOV. Employee
• VM03 - Reckless Operation of a Road or Marine Vehicle
• VF02 - Felony Hit and Run of a GOV. Employee
• GM04 - Resisting Arrest
• GM14 - Obstruction of Justice
• GM10 - Failure to Comply / Identify
• VM02 - Operating a Vehicle with a Suspended License
• SF04 - Kidnapping of a GOV. Employee

Narrative:

I spoke with David Coast about the situation, Providing a brief Explanation, I have a lot to explain in detail as well which may help.
I will not mention anything further here based off Unsure who can see this.

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I, Aya Ryoshi, 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. ))

[Judith Mason]

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. Aya Ryoshi

The court has hereby received and acknowledged the above case on the 11th day of February, 2024.

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 defendant is 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 defendant is 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.



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

[Jay Wellberg]

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

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Aya Ryoshi

A Notification of Counsel was filed in the above case on the 25th of July, 2024.

I, Jay Wellberg, a Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant(s), Aya Ryoshi in the underlying case.

I will be taking the responsibility of Primary Counsel and will await further instruction from the Presiding Judge.


Public Defense Attorney
San Andreas Judicial Branch
(909) 2956979 — [email protected][/list]

[Antonio McFornell]

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. Aya Ryoshi
#24-CM-0051

A Notice of Activation was entered in the above case on 25th of July, 2024.

The case of the State of San Andreas v. Aya Ryoshi is hereby activated by this Court under #24-CM-0051.

At this time the Defendant has adequate representation, however, a State Prosecutor has not been assigned to this case. At this time the court will delay the Order for Discovery until adequate representation has been assigned and they inform the court they are ready to proceed.

In accordance with guidelines set forth by the Supreme Court of San Andreas, this case shall require an in-person trial. Once all pretrial matters have been resolved, a Notice of Scheduling will be issued to arrange an appropriate time for trial.

So ordered,

Superior Court Justice
Director of the San Andreas Bar Association
San Andreas Judicial Branch
(909) 553-8869 — [email protected]

[Michael Blaise]

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

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Aya Ryoshi

A Notification of Counsel was filed in the above case on 25/JUL/2024.

I, Michael Blaise, a Prosecuting Attorney with the San Andreas Judicial Branch, will be representing the State of San Andreas in the underlying case.

I will be taking the responsibility of Primary Counsel and will await further instruction from the Presiding Judge.



Prosecuting Attorney
San Andreas Judicial Branch
(909) 552-8150 — [email protected]

[Antonio McFornell]

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

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ORDER FOR DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Aya Ryoshi
#24-CM-0051

A court order was entered in the above case on the 25th of July, 2024.

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.

So ordered,

Superior Court Justice
Director of the San Andreas Bar Association
San Andreas Judicial Branch
(909) 553-8869 — [email protected]

[Michael Blaise]

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. Aya Ryoshi
#24-CM-0051

A Motion for Discovery was filed in the above case on the 25th of July, 2024.

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

• Exhibit #1: Arrest Report - Aya Ryoshi, 09/FEB/2024

  

  

  Los Santos Police Department ARREST REPORT "TO PROTECT AND TO SERVE"

  
  

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  MUGSHOT

  • SUSPECT DETAILS
    • 
      Full Name: Aya Ryoshi
      Phone Number: 5426006
      Licenses Suspended: Yes
      Officers Involved:
      • Police Lieutenant II Mike Luigi
      • Police Lieutenant II Elise Cavallera
      • Police Captain III Jessica Nash
      • Police Captain III Jaxon Nash
      • Police Officer I Murphy Azalea
      • Police Detective I Hector Mayfield
      Charges:
      • SF04 - Kidnapping of a Gov. Employee
      • VM02 - Operating a Vehicle with a Suspended License
      • GM10 - Failure to Comply / Identify
      • GM14 - Obstruction of Justice
      • GM04 - Resisting Arrest
      • VF02 - Felony Hit and Run of a Gov. Employee
      • VM03 - Reckless Operation of a Road or Marine Vehicle
      • GM13 - Criminal Threats of a Gov. Employee
    INCIDENT NARRATIVE
    • Incident Date: 09/FEB/2024
      
      Explain what happened, sufficient detail must be given to justify the placed charges, videos could be provided.
      • Aya Ryoshi was identified by Officer G. Wood to have a suspended license after being identified at DOC. Aya Ryoshi was seen driving a vehicle at Mission Row picking up an Emilia Adams before driving down the street to a clothing store. Lieutenant M. Luigi pulled up behind a now parked Aya Ryoshi, vehicle information:
        Vehicle: ETR1
        Plate: EATMEOUT
        Owner: Aya_Ryoshi
        Phone Number: 5426006
        
        Lieutenant M. Luigi approached Aya Ryoshi who was currently sat within their vehicle. Lieutenant M. Luigi requested Aya Ryoshi to provide their drivers license. Aya Ryoshi stated, "Left my ID at prison, no guard would give my stuff back". Lieutenant E. Cavallera then entered Aya Ryoshi's vehicle as Lieutenant M. Luigi informed Aya Ryoshi that they would be getting a misdemeanor for driving without a license on their person. Aya Ryoshi then began to state, "I have a ID". Lieutenant M. Luigi then gave Aya Ryoshi multiple orders to exit the vehicle along with informing them force would be used if they continued to fail to comply. Aya Ryoshi continued to argue with the officer and refuse to comply with Lieutenant M. Luigi's lawful orders to exit the vehicle before then locking the vehicle with the officer inside.
        
        Aya Ryoshi continued to ignore orders from Lieutenant M. Luigi, before turning on the vehicle and driving off. As Aya Ryoshi drove off they struck Detective Mayfield, knocking him into the air. Lieutenant M. Luigi fired a single shot disabling the rear left tire of the vehicle. Aya Ryoshi continued to speed through the city at excessive rates of speed throughout incorrect lanes and over sidewalks. Aya Ryoshi eventually ended up at the marina near Shank Street, diving out of their vehicle as it rolled into the water. Aya Ryoshi continued by attempting to flee on foot before being tased and placed in handcuffs. Whilst being placed into a cruiser Aya Ryoshi approached Lieutenant M. Luigi and stated, "You know what add fucking criminal threats because when I get out I'm fucking slitting your neck open".
        
        Aya Ryoshi was transported to DOC by Officer Azalea.
    EVIDENCE DETAILS
    • Document the possessions confiscated from the arrested suspect.
      Possessions are to be documented individually, examples of documented illegal possessions are "Pistol .50" or "12 grams of Cocaine". Legal possessions that can be categorized may be grouped, eg. "Clothing" to describe all clothing items. Body camera footage/pictures may be attached as an evidence exhibit.
      
      Where possible, the serial number of each firearm seized as evidence should be noted.
      • Illegal Possessions:
        
        
        Legal Possessions:
        Exhibit A: Crowbar
        Exhibit B: Knife
        Exhibit C: Clothing x5
        Exhibit D: Radio
        Exhibit E: GPS
        
        
        Photograph of Possessions (MANDATORY)

        

  

• Exhibit #2: Witness Statement - Police Lieutenant II Elise Cavallera

  

  

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

  Case Information

  • Incident Date: 09/FEB/2024

  Witness Information

  • Name: Elise Cavallera
    Date of Birth: 15/MAY/1993
    Phone Number: N/A
    Occupation: Police Lieutenant II, Los Santos Police Department

  Witness Statement

  • 3-N-2 Police Lieutenant Mike Luigi and myself Police Lieutenant Elise Cavallera spotted Aya Ryoshi at Mission Row in her ETR after Officer Gary Wood called it in that they are driving with a suspended drivers license. 3-N-2 drove after the ETR1 and pulled it over by the clothing store.
    
    Driver Aya Ryoshi was still in the vehicle while passenger Emilia Adams was already in the clothing store. Lieutenant Luigi started conducting the traffic stop on the vehicle, as Lieutenant Luigi was discussing the location of Aya Ryoshi ID, I approached the vehicle at which the same time Emilia Adams ran to the vehicle, unlocked it and tried to get in the vehicle. I squeezed in the vehicle before Emilia Adams as I knew that the driver would be arrested for Operating a vehicle with suspended license and with the Emilia Adams back in the vehicle, the chance of the suspect evading was even higher.
    
    At the same time, Lieutenant Luigi was explaining to them that they are under arrest for Misdemeanor and to exit the vehicle.
    
    Emilia Adams was confused for a second or so but then tried to pull myself out of the vehicle, to which I resisted twice and then another officer took her away from the vehicle. Afterwards, Aya Ryoshi locked the vehicle.
    
    At this point, Lieutenant Luigi was giving Aya Ryoshi clear orders to exit the vehicle and both at tazer point of myself and Lieutenant Luigi she didn't comply, arguing back to Lieutenant Luigi. Then after a minute or so of arguing with the officer, she decided to turn on the engine and started to evade with myself in it. As she was driving off, she hit Detective Mayfield with her car, for which Lieutenant Luigi took one tire on her vehicle.
    
    She then evaded in the city for little bit untill she decided to do a handbrake turn in the Marina, jumping out while the vehicle was reversing in the water. I climbed out of the vehicle as while it was sinking and swam back to the shore. Another officer took over the arrest.
    
    SF04 - Kidnapping of a Gov. Employee
    - Drove off with me in the vehicle, even after multiple minutes or arguing and demands to get out of the vehicle
    VM02 - Operating a Vehicle with a Suspended License
    - Operating a vehicle with a suspended license
    GM10 - Failure to Comply / Identify
    - Not complying to multiple orders
    GM14 - Obstruction of Justice
    - Lying about having her ID on her
    GM04 - Resisting Arrest
    - Running on foot after dumping their vehicle into water
    VF02 - Felony Hit and Run of a Gov. Employee
    - Running over Detective Hector Mayfield
    VM03 - Reckless Operation of a Road or Marine Vehicle
    - Driving recklessly in the city
    GM13 - Criminal Threats of a Gov. Employee
    - Unknown

  Witness Affirmation

  • I, Elise Cavallera, 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,
    
    Elise Cavallera
    Elise Cavallera
    Police Lieutenant II
    Los Santos Police Department
    
    Date: 11/FEB/2024

  

• Exhibit #3: Witness Statement - Police Detective I Hector Mayfield

  

  

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

  Case Information

  • Incident Date: 09/FEB/2024

  Witness Information

  • Name: Hector Mayfield
    Date of Birth: 19/JUN/1994
    Phone Number: 554-7384
    Occupation: Detective I, Los Santos Police Department

  Witness Statement

  • Detective Mayfield had impounded a vehicle from a previous arrest, and was left at Mission Row without his cruiser. Detective Mayfield approached Lieutenant Mike Luigi and asked him if he could give him a ride back to his patrol vehicle. Lieutenant Luigi obliged and Detective Mayfield entered Lieutenant Luigi's cruiser.
    
    Shortly after the cruiser left Mission Row, Lieutenant Luigi spotted a vehicle outside of a clothing store on Sinner St. After being told the driver did not have a valid driver's license, Lieutenant Luigi put on his lights behind the vehicle to perform a traffic stop. Upon approaching the vehicle, the driver on the vehicle was argumentative with Lieutenant Luigi and claimed to not have their drivers license on them and claimed that DOC did not returned their drivers license. Lieutenant Luigi informed the person that they were going to be charged for driving without a license on their person, and their story changed stating they had their ID.
    
    The driver continued to refuse to identify themselves. As their passenger exited the clothing store, Lieutenant Elise Cavallera entered the passenger's seat of the vehicle in order to prevent the driver from evading while the traffic stop was taking place.
    
    After several minutes of arguing and several lawful orders to exit the vehicle and provide identification, Lieutenant Luigi attempted to forcibly remove the driver from the driver's seat. The driver resisted this attempt and immediately turned on his vehicle and fled the scene, striking me in the process with his moving vehicle.
    
    After this, a pursuit ensued of the vehicle. I was not present for any additional aspects of this scene. After I was struck by the vehicle, I returned on foot to Mission Row to patch up my cuts from being struck and headed off shift.
    
    Please see attached bodycam from the incident.
    
    Bodycam

    

  Witness Affirmation

  • I, Hector Mayfield, 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,
    
    
    Hector Mayfield
    Detective I
    Los Santos Police Department
    
    Date: 11/FEB/2024

  

• Exhibit #4: Witness Statement - Police Lieutenant II Mike Luigi

  

  

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

  Case Information

  • Incident Date: 09/FEB/2024

  Witness Information

  • Name: Mike Luigi
    Date of Birth: 07/JAN/1997
    Phone Number: 381-5045
    Occupation: Lieutenant II, Los Santos Police Department

  Witness Statement

  • My narrative has been provided within the arrest report, below is a more detailed reasoning for charges placed.
    
    VM02 - Operating a Vehicle with a Suspended License
    The initial reason for the stop was Officer G. Woods confirming that Aya Ryoshi had a suspended license shortly after being identified at DOC. This was also corroborated by Officer M. Azalea upon viewing Aya Ryoshi's license during the arrest and search.
    
    GM14 - Obstruction of Justice
    During the initial traffic stop on Sinner St, I requested Aya Ryoshi to provide their driver's license. Aya Ryoshi responded by stating that they had left their ID at the prison, claiming that no guard would return their belongings. Officer G. Woods immediately refuted this claim, confirming that Aya Ryoshi had indeed shown their license to Officer G. Woods at the front of DOC. Following a threat of arrest, Aya Ryoshi then admitted to having their ID. The charge was applied due to their initial attempt to deceive myself by lying about the status of their ID.
    
    GM10 - Failure to Comply / Identify
    I issued multiple orders to Aya Ryoshi to provide their ID, but they refused to do so. Furthermore, despite multiple orders to exit their vehicle as they were being placed under arrest, Aya Ryoshi failed to comply with any of these directives.
    
    GM04 - Resisting Arrest
    Aya Ryoshi abandoned their vehicle at the marina after using it to evade capture. While on foot, Aya Ryoshi persistently attempted to flee before being subdued with a taser and subsequently placed in handcuffs.
    
    SF04 - Kidnapping of a GOV. Employee
    Aya Ryoshi was inside their unlocked vehicle with the engine off during the traffic stop when Lieutenant E. Cavallera entered the passenger seat. Both Lieutenant E. Cavallera and I issued multiple orders for Aya Ryoshi to exit their vehicle. Aya Ryoshi locked their vehicle during the stop, at which point I warned them not to drive, emphasizing that it would be considered kidnapping of an officer. Despite this warning, Aya Ryoshi continued to argue with Lieutenant M. Luigi for approximately 3 minutes before starting the vehicle and attempting to evading.
    
    VF02 - Felony Hit and Run of a GOV. Employee
    When Aya Ryoshi decided to evade with their vehicle, they struck Detective Mayfield, causing the detective to be flung into the air and spin, ultimately landing on their head.
    
    VM03 - Reckless Operation of a Road or Marine Vehicle
    While evading, Aya Ryoshi proceeded to do so at excessive speeds despite having one rear tire missing. Aya Ryoshi drove recklessly, weaving through incorrect lanes and driving over sidewalks before eventually abandoning their vehicle, which rolled into the water.
    
    GM13 - Criminal Threats of a Gov. Employee
    Aya Ryoshi approached me and made a threatening statement, saying, "You know what, add criminal threats because when I get out, I'm going to slit your neck open."
    
    **MLUIGI_BODYCAM_09FEB2024**

  Witness Affirmation

  • I, Mike Luigi, 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,
    
    
    Mike Luigi
    Police Lieutenant II
    Los Santos Police Department
    
    Date: 13/FEB/2024

  

• Exhibit #5: Witness Statement - Police Officer III Gary Woods

  

  

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

  Case Information

  • Incident Date: 09/FEB/2023

  Witness Information

  • Name: Gary Woods
    Date of Birth: 14/JUL/1995
    Phone Number: 436-7720
    Occupation: Police Officer III (Metropolitan Division, D Platoon), Los Santos Police Department

  Witness Statement

  • I, Gary Woods under 4-L-27 callsign, on the day of 09/FEB/2023 has met Aya Ryoshi in front of Department of Corrections, after I have transported a suspect. After some time talking Aya Ryoshi was present in front of the entrance to Department of Corrections with her car ETR-1.
    
    Aya Ryoshi has showed me her license after I called Ms. Ryoshi by her old name Bonnie. Upon furhter inspection of the license that was provided to me, I have seen that the drivers license of Aya Ryoshi was suspended alongside the truckers license. Ms. Ryoshi was found by the unit at Clothing Store on Sinner St. after I have called out over the radio towards all unit to be on the lookout for the ETR-1 registered to Aya Ryoshi, because if found she is driving with suspended license.
    
    (( RP Proof of Bodycam on day of the incident))

    
    Further down, you can find the trimmed out part of my bodycam where it shows the license of Aya Ryoshi on the day of the incident.
    
    License of Aya Ryoshi

    
    (( I do not have a video footage of the same act as, I do not have capability to have any recording software opened while playing the game due to the PC limitations. If you do need further Bodycam RP of the event please let me know, I will be glad to provide it.

  Witness Affirmation

  • I, Gary Woods, 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,
    
    
    Gary Woods
    Police Officer III
    Los Santos Police Department
    
    Date: 17/FEB/2024

  

Prosecuting Attorney
San Andreas Judicial Branch
(909) 552-8150 — [email protected]

[Michael Blaise]

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

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MOTION TO AMEND

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Aya Ryoshi
#24-CM-0051

A Motion to Amend was filed in the above case on the 28th of July, 2024.

The State of San Andreas, by and through the undersigned attorney, filed this Motion to Amend, the original charges with the underlined amended charges.

• Original Charges
  • GM13 - Criminal Threats of a GOV. Employee
  • VM03 - Reckless Operation of a Road or Marine Vehicle
  • VF02 - Felony Hit and Run of a GOV. Employee
  • GM04 - Resisting Arrest
  • GM14 - Obstruction of Justice
  • GM10 - Failure to Comply / Identify
  • VM02 - Operating a Vehicle with a Suspended License
  • SF04 - Kidnapping of a GOV. Employee

• Amended Charges
  • GM13 - Criminal Threats of a GOV. Employee
  • VM03 - Reckless Operation of a Road or Marine Vehicle
  • VF02 - Felony Hit and Run of a GOV. Employee
  • GM04 - Resisting Arrest
  • GM14 - Obstruction of Justice
  • GM10 - Failure to Comply / Identify
  • VM02 - Operating a Vehicle with a Suspended License
  • SF04 - Kidnapping of a GOV. Employee
  • VF01 - Evading an Officer

• Detailed Explanation: Administrative issues caused the defendant to not have been charged with VF01 during their arrest and subsequent imprisonment. The various evidence exhibits all confirm that the defendant did indeed evade during the situation in question and as such, the Prosecution is requesting the charges be amended to correctly reflect the defendant's actions in the incident.

Prosecuting Attorney
San Andreas Judicial Branch
(909) 552-8150 — [email protected]

[Jay Wellberg]

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

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• Honorable Judge McFornell ,
  
  Your Honor, We would like to object to the prosecution's motion to amend the charges This amendment violates the lesser included offense doctrine. According to this doctrine, a defendant cannot be charged with both a greater offense and its lesser included offense, as the lesser offense is inherently part of the greater one. In this case, the charge of VM03 - Reckless Operation of a Road or Marine Vehicle already encompasses the elements of VF01 - Evading an Officer. As stated by Police Lieutenant II Mike Luigi, the defendant drove at excessive speeds, weaved through incorrect lanes, and drove over sidewalks, all while evading law enforcement. The reckless charge already includes attempting to elude a pursuing officer. Charging the defendant with both offenses would be redundant and a violation of the double jeopardy rule, as it would subject the defendant to multiple charges for the same reason in this event.
  
  
  Respectfully yours,
  
  
  Public Defense Attorney
  San Andreas Judicial Branch
  (909) 2956979 — [email protected]

[Michael Blaise]

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

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• Honorable Judge McFornell,
  
  
  The prosecution respectfully disagrees with the defense's objection to the motion to amend the charges based on the Lesser Included Offense Doctrine. The doctrine specifies that a lesser included offense consists of some, but not all, of the elements of the greater offense. While both VM03 - Reckless Operation of a Road or Marine Vehicle and VF01 - Evading an Officer pertain to unlawful driving behaviors, they contain distinct elements that justify separate charges.
  
  Elements of VM03 - Reckless Operation of a Road or Marine Vehicle: This charge addresses the intentional disregard for life and/or property through the operation of a vehicle. It focuses on the dangerous and hazardous manner of driving, such as excessive speeds, incorrect lane usage, and driving on sidewalks, which puts lives and property at risk.
  
  Elements of VF01 - Evading an Officer: This charge specifically pertains to the act of willfully fleeing or attempting to elude a pursuing law enforcement officer. It requires the element of an active attempt to evade the officer, which is not a necessary component of reckless driving.
  
  In this case, the incident narrative clearly describes separate actions that justify both charges:
  
  Reckless Operation: Aya Ryoshi drove at excessive speeds, weaved through incorrect lanes, and drove over sidewalks, demonstrating a clear disregard for the safety of others and property.
  
  Evading an Officer: Aya Ryoshi actively fled from officers, driving away after being stopped, which constitutes a willful attempt to evade law enforcement.
  
  
  Respectfully,
  
  
  Prosecuting Attorney
  San Andreas Judicial Branch
  (909) 552-8150 — [email protected]

[Jay Wellberg]

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

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• Honorable Judge McFornell ,
  
  As described by Police Lieutenant II Mike Luigi in his witness statement, they charged the defended with reckless for her acts during the alleged evasion, charging the defended with VF01 - Evading an Officer now would still be a breach of the double jeopardy rule since she was already charged with reckless for the offense. We have nothing further to add to this argument and will now await the courts decision.
  
  
  Respectfully yours,
  
  
  Public Defense Attorney
  San Andreas Judicial Branch
  (909) 2956979 — [email protected]

[Michael Blaise]

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

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• Honorable Judge McFornell,
  
  
  While one witness statement may loosely refer to the charge as being applied due to the defendant's actions while evading, the discovery as a whole shows that the defendant was charged due to two separate actions.
  
  Lastly, it could be argued that VM03 is not the lesser charge for VF01; rather, it would be the lesser charge of VF04 - Felony Public Endangerment.
  
  The prosecution has nothing further to add and will await the court's decision.
  
  
  Respectfully,
  
  
  Prosecuting Attorney
  San Andreas Judicial Branch
  (909) 552-8150 — [email protected]

[Paige Enora]

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

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Aya Ryoshi

A Notification of Counsel was filed in the above case on the 2nd of Aug 2024.

I, Paige Enora, a Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant(s), Aya Ryoshi in the underlying case.

I will be taking the responsibility of Co-Counsel and will await further instruction from the Presiding Judge.



Public Defense Attorney
San Andreas Judicial Branch
(909) 369-9671 —[email protected]

[Antonio McFornell]

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

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COURT DECISION

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Aya Ryoshi
#24-CM-0051

A decision was reached in the above case on the 3rd day of August, 2024.

The Court hereby accepts the Motion to Amend presented by the Prosecution. The Court believes that the arguments presented by the defense do not constitute Pre-Trial discussions but rather are a subject that has to be touched on during Trial arguments, and thus, the Court will evaluate them before casting a final verdict.

So ordered,

Superior Court Justice
Director of the San Andreas Bar Association
San Andreas Judicial Branch
(909) 553-8869 — [email protected]

[Antonio McFornell]

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

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NOTICE OF SCHEDULING

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Aya Ryoshi
#24-CM-0051

A second attempt to schedule was made and recorded by the court on 3rd of August, 2024.

All parties in this case are encouraged to complete the following Scheduling Tool in an attempt to schedule a trial on the above case.

In the event all parties have overlapping availability the Presiding Judge will determine the best date and time to have a trial take place and post a Notice of Trial informing all of the upcoming proceeding.

In the event some or all parties do not have overlapping availability, the Presiding Judge will initiate a docket trial to avoid further delays.

If either party has the intentions of calling a witness to the stand during the proceeding they must inform the court by filing a Witness List at the time of filing their availability. If no Witness List is filed before the Notice of Trial is filed you will be unable to call a witness during the proceeding.


So ordered,

Superior Court Justice
Director of the San Andreas Bar Association
San Andreas Judicial Branch
(909) 553-8869 — [email protected]

[Andrew Cuttings]

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

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Defendant

A Notification of Counsel was filed in the above case on 04/AUG/2024.

I, Andrew Cuttings, Prosecuting Attorney of the San Andreas Judicial Branch, will be representing the State of San Andreas in the underlying case.

I will be taking the responsibility of Co-Counsel alongside the Primary, Michael Blaise and will await further instruction from the Presiding Judge.


Junior Prosecutor
San Andreas Judicial Branch
(909) 520-7107 — [email protected]

[Antonio McFornell]

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

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NOTICE OF TRIAL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Aya Ryoshi
#24-CM-0051

A trial date was set on the above case on August 8th, 2024.

In accordance with the availability reported by both parties in response to the Notice of Scheduling, this trial shall take place at 05:30 PM on August 11th, 2024 at Rockford Hills City Hall, Carcer Way, Metro Los Santos, SA.

Both parties are ordered to be present in the Judges Chambers no later than 15 minutes prior to the above listed date for pretrial arrangements. If complications occur that must result in a delay or cancelation of the trial, you are ordered to inform the court no later than 12 hours prior to the above listed date.


So ordered,

Superior Court Judge
Director of the San Andreas Bar Association
San Andreas Judicial Branch
(909) 553-8869 — [email protected]

[Antonio McFornell]

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

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NOTICE OF TRIAL RESCHEDULING

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Aya Ryoshi
#24-CM-0051

A trial date was set on the above case on August 8th, 2024.

In accordance with the availability reported by both parties in response to the Notice of Scheduling, this trial shall take place at 10:00 PM on August 11th, 2024 at Rockford Hills City Hall, Carcer Way, Metro Los Santos, SA.

Both parties are ordered to be present in the Judges Chambers no later than 15 minutes prior to the above listed date for pretrial arrangements. If complications occur that must result in a delay or cancelation of the trial, you are ordered to inform the court no later than 12 hours prior to the above listed date.


So ordered,

Superior Court Judge
Director of the San Andreas Bar Association
San Andreas Judicial Branch
(909) 553-8869 — [email protected]

[Antonio McFornell]

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. Aya Ryoshi
#24-CM-0051

A decision was reached in the above case on the 11th of August, 2024.

On the 9th of February, Aya Ryoshi was seen driving a vehicle in close proximity to Mission Row. A police officer had become aware of the defendant's suspension of a driver's license, thus rendering her unable to legally operate a vehicle within the State of San Andreas. This circumstance prompted a traffic stop, which devolved in various attempts to have the defendant identify and eventually a police officer inserting themselves into the vehicle of the defendant, before fleeing from the location and initiating a police pursuit that ultimately led to the arrest of the defendant.

The prosecution argued that the defendant clearly was guilty of the alleged actions. Particularly, the sequence of the events provided a foundational narrative that included driving with a suspended license, failing to comply numerous lawful orders, striking a government employee, driving without the consent of the passenger officer and eventually evading. The Prosecution also presented numerous witness statements, some of them from the officers that were direct victims of the alleged crimes levied against the defendant.

The defense's argument focused on the alleged kidnapping, particularly stating that the Lieutenant placed herself into the vehicle and even refused multiple attempts to be removed from the defendant's vehicle by a third party. These actions, in eyes of the defense, indicated a clear volutnary action by the officer. Furthermore, the defense argued that the officer's accounts did not substantiate bodily injury, specially since the officer admitted to being able to walk back to Mission Row in his recollection of the events.

In regards to the criminal threats, the Court finds that the threat to Lt. Luigi according to the arrest report and the multiple witness statements provided, meet the criteria or definition as ordered in the Penal Code. The explicit nature of the threat—stating, "when I get out, I'm going to slit your neck open" demonstrates a clear and intentional threat of violence, which fulfills the criteria determined by the Penal Code.

In regards to the Reckless Operation of a Road or Marine Vehicle misdemeanor, the Court finds that the evidence has established that the defendant drove her vehicle in this manner. The witness accounts and the arrest report detail excessive speeds, erratic diriving, and maneuvers that involved driving over sidwalks and incorrect lanes, and also hitting or impacting a police officer, namely Detective Mayfield, which allows the court to conclude that the actions meet the definition of reckless operation under the penal code.

As for the Felony Hit and Run, the Court had to make special considerations. The crime of felony hit and run is described as causing an accident that resulted in bodily injury or death, and then the Penal Code presents three circumstances, which are exclusive in the regard that, with the commission of any of those three and the first condition -which is bodily injury or death-, the crime will be configured. During deliberation, the Court had to ask themselves: What constitutes bodily injury? The lack of description within the Penal Code and the Law led the Court to put itself at the task of determining the standard or interpretation of such expression. Does a slap on the wrist entail bodily injuries? Does a cut constitute bodily injury? Is an injury that leads to bleeding considered a bodily injury?

These questions have been taken into account by the Court, and given that no specific definition for the concept of bodily injury is offered in the Penal Code, the Court decided to look within the Penal Code itself for descriptions or otherwise circumstances that the Court should utilize to give meaning to the concept of Bodily Injury. During its search, the Court paid special attention to condition (a) of the Felony Hit and Run Charge. Particularly, the Court notes that it is described as:

• (a) Failing to remain on-scene with the victim and rendering aid where possible.

The Court believes that for bodily injury to be present or configured, the injury sustained must be substantial enough that it requires aid from a third party. In this particular case, it was proven through multiple sources, statements, recollections and testimony that Detective Mayfield may have been damaged and suffered cuts. However, he did not require a third party to render aid. He was able to walk himself back to his Headquarter, he was not escorted, not transported by EMS or the likes. With that in mind, the Court concludes that the Detective did not sustain any kind of aid-requiring damage. With these considerations in mind, then, the Court determines that the principal element of Felony Hit and Run -Sustaining bodily injuries or death- was not configured, and in that regard, the remainder description of the crime becomes irrelevant as the principal element of Felony Hit and Run must be configured in order to continue with the legal configuration of the conduct.

The Court has determined that the actions performed by the defendant constituted resisting arrest, given that she refused to exit the vehicle, locked it and subsequently fled from the scene, demonstrating a clear resistance to the ongoing arrest procedure. The arrest report and multiple witness statements corroborate her deliberate attempts to evade capture and her physical resistance to officers' commands, supporting this charge.

The Court also considers that the defendant Aya Ryoshi obstructed justice by providing false information about her ID status. Despite being asked to provide her ID, she initially lied about having left it at the prison. The deceitful behavior aimed at hindering the investigation fits the definition of obstruction of justice, and the charge must be upheld to that regard.
The defendant’s repeated failure to comply with the multiple lawful orders to provide identification and exit the vehicle also led the Court to conclude that her behavior fit the description of the crime as stated in the Penal Code. The consistent non-compliance with the orders provided by law enforcement were well-documented, undisputed and necessarily aligns with the criteria for said illegal conduct. It was also admitted and undisputed that the defendant was operating a vehicle without a valid (or otherwise unsuspended) license, and thus the charge was not a matter of deep deliberation. The same can be affirmed for the charge of Evading an Officer, as it was an undisputed matter backed up by the multiple statements provided and also the defense’s narrative.

Finally, the Court was tasked with determining whether the defendant kidnapped a government employee. In that regard, the Court had to ask: Was Lt. Ellise Cavallera kidnapped? In the eyes of the Court, the Lieutenant understood the risk of being trapped in the vehicle. She assumed that there would be a police chase, or rather, that the defendant would escape. The Court believes that the Lieutenatn recklessly put herself in a situation of risk. Our legal system cannot protect recklessness, and in this particular situation, the Court finds that the Lieutenant placed herself in a situation where there was a possible -and very certain- risk, which later on materialized or otherwise became a reality.

The Lieutenant had ample opportunity to leave the vehicle previous to the aforementioned risk materializing, being the risk the suspect fleeing from the scene with the Lieutenant inside the vehicle. The Court considered that there was no kidnapping, albeit it must make some considerations in that regard. It is understood and accepted that consent in this situation was initially given -as derived from the Lieutenant’s willing entry into the vehicle- and could have been revoked. However, the Court is unable to protect the removal of that consent after the Lieutenant had already consented to put herself in a riskful and reckless situation. The Court even asked itself the following question: Could the Lieutenant’s behavior be subject to the vice of entrapment? Did the Lieutenant entrap the defendant by placing herself in the vehicle, when she clearly knew the defendant was going to escape? However, the Court did not consider necessary to dive deeper into the matter of entrapment, given that it had been made clear that the Lieutenant recklessly exposed herself to a risk, which materialized and thus rendered the Court unable to find the defendant guilty of the alleged conduct.

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

• On the count of GM13 - Criminal Threats of a GOV. Employee, I find the defendant, Aya Rioshi, guilty.
• On the count of VM03 - Reckless Operation of a Road or Marine Vehicle, I find the defendant, Aya Rioshi, guilty.
• On the count of GM04 - Resisting Arrest, I find the defendant, Aya Rioshi, guilty.
• On the count of GM14 - Obstruction of Justice, I find the defendant, Aya Rioshi, guilty.
• On the count of GM10 - Failure to Comply / Identify, I find the defendant, Aya Rioshi, guilty.
• On the count of VM02 - Operating a Vehicle with a Suspended License, I find the defendant, Aya Rioshi, guilty.
• On the count of VF01 - Evading an Officer, I find the defendant, Aya Rioshi, guilty.
• On the count of SF04 - Kidnapping of a GOV. Employee, I find the defendant, Aya Rioshi, not guilty.
• On the count of VF02 - Felony Hit and Run of a GOV. Employee, I find the defendant, Aya Rioshi, not guilty.

So ordered,

Superior Court Justice
San Andreas Judicial Branch
(909) 553-8869 — [email protected]