#24-CM-0063, State of San Andreas v. Saint Valentine

Post by **Saint Valentine** » 28 Feb 2024, 22:24

Defendant Name: Saint Valentine
Defendant Phone: 279-8771
Defendant Address: Private
(( Defendant Discord: saintv2.0 ))
Requested Attorney: Lisa Winter

Charging Department: LSPD

Date & Time of Incident(s): 28/02/2024 20:15
Charge(s):

Attempted SF02 - Murder of a Gov

Narrative:
I have been incorrectly charged by said department and wish to appeal said charges.

I, Saint Valentine, 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. ))

Post by **Lisa Winter** » 28 Feb 2024, 23:13

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

NOTIFICATION OF COUNSEL

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine

A Notification of Counsel was filed in the above case on the 28th of February, 2024

I, Lisa Winter, a Public Defender with the San Andreas Judicial Branch, will be representing the Defendant, Saint Valentine in the underlying case.

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

Lisa Winter
Senior Defense Attorney
San Andreas Judicial Branch
(909) 233-5420 — [email protected]

Post by **Antonio McFornell** » 02 Mar 2024, 18:09

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

NOTICE OF RECEIPT

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine

The court has hereby received and acknowledged the above case on the 2nd of March, 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.

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

Post by **Paige Enora** » 01 Sep 2024, 12:42

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

NOTIFICATION OF COUNSEL

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine

A Notification of Counsel was filed in the above case on the 1st of September 2024.

I, Paige Enora, a Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant(s), Saint Valentine 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) 369-9671 —[email protected]

Post by **Antonio McFornell** » 03 Sep 2024, 16:51

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

NOTICE OF ACTIVATION

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine
#24-CM-0063

A Notice of Activation was entered in the above case on the 3rd of September, 2024.

The case of the State of San Andreas v. Saint Valentine is hereby activated by this Court under #24-CM-0063.

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,

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

Post by **Michael Blaise** » 03 Sep 2024, 18:47

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

NOTIFICATION OF COUNSEL

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine

A Notification of Counsel was filed in the above case on 03/SEP/2024.

I, Michael Blaise, 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 Primary Counsel and will await further instruction from the Presiding Judge.

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

Post by **Carlton Ellery** » 03 Sep 2024, 19:09

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

NOTIFICATION OF COUNSEL

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine

A Notification of Counsel was filed in the above case on 03/SEP/2024.

I, Carlton Ellery, 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 and will await further instruction from the Presiding Judge.

Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 593-3137 — [email protected]

Post by **Antonio McFornell** » 03 Sep 2024, 19:43

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. Saint Valentine
#24-CM-0063

A court order was entered in the above case on the 3rd of September, 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,

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

Post by **Michael Blaise** » 03 Sep 2024, 20:24

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

MOTION FOR DISCOVERY

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine
#24-CM-0063

A Motion for Discovery was filed in the above case on the 3rd of September, 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 - Saint Valentine, 28/FEB/2024
Los Santos Police Department
ARREST REPORT
"TO PROTECT AND TO SERVE"

MUGSHOT
- SUSPECT DETAILS
  
  Full Name: Saint Valentine
  Phone Number: 2798771
  Licenses Suspended: No
  Officers Involved:
  
  Police Officer III Peter Macburry
  
  Police Sergeant II John Keys
  
  Charges:
  
  Attempted SF02 - Murder of a Gov. Employee
  
  WM02 - Possession of a Class 1 Firearm
  
  WM03 - Criminal Use of Weapon Modifications
  
  GM19 - Face Concealment (b)
  
  INCIDENT NARRATIVE
  
  Incident Date: 28/FEB/2024
  
  Explain what happened, sufficient detail must be given to justify the placed charges, videos could be provided.
  
  While on patrol, a Backup call came in from a SWAT Unit in regards a Gang Related Shots Fired situation. After arriving on scene, it was seen, that at first the SWAT Unit saw one CSB-affiliated suspect with a shotgun on his back and tried to block him in, to which the suspect reported by opening fire on the SWAT Units. Quickly afterwards, some Backup from CSB arrived - a 3 Stacked Kamacho, consisting of Dillon Bing, Barrie Bonga and Saint Valentine. Saint Valentine was one of the two suspects, who dismounted the vehicle and opened fire on officers, but was quickly neutralized. He was masked throughout the whole ordeal. (SF02, GM19)
  
  After I arrived on scene, I cuffed, mirandized, disarmed my suspect - Saint Valentine and afterwards treated him. A Pistol .50 with a Supressor was found on his body. (WM02, WM03)
  
  He was then transported by MD to Lower Pillbox, from where DOC Tarv picked all the suspects up and he was transported to DOC, where he is currently serving his time. His belongings are at MRPD.
  
  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:
  Exhibit A: 1x Pistol .50
  Exhibit B: 1x Suppressor
  Exhibit C: 1x Mask
  Exhibit D: 57x .50 AE Rounds
  
  Legal Possessions:
  Exhibit A: 3x Pieces of Clothing
  Exhibit B: 1x Radio
  Exhibit C: 1x GPS
  Exhibit D: 1x Crowbar
  
  Photograph of Possessions (MANDATORY)

Exhibit #2: Evidence - Saint Valentine's illegal possessions and personal belongings

Exhibit #3: Witness Statement - Sergeant II John Keys
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"

Case Information
- Incident Date: 28/FEB/2024
Witness Information
- Name: John Keys
  Date of Birth: 22/SEP/1991
  Phone Number: 221-3082
  Occupation: Sergeant II, Los Santos Police Department
Witness Statement
- I remember this situation pretty good. I do not remember in detail who did what 100% by name.
  
  It all started with myself and Officer Andollini patroling when we saw a Scout parked close to El Rancho Blvd. A man was behind the Scout and started to open fire upon myself and Officer Andollini. We both dismounted and armed with carabines the man was pretty fast taken down. Myself called MD right after he was down.
  After 10-15 seconds we started to hear motor sounds an suddenly a Kamacho almost ran me over and 2 men jumped out from the vehicle. The driver tried to pull out a shotgun, and he was pretty much instantly taken down and the passanger was shot down last. The third passanger Barrie Bonga complied at all times and was seated in the car, he only came out when told to by myself and officer Andollini.
Witness Affirmation
- I, John Keys, 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,
  
  John Keys
  Sergeant II
  Los Santos Police Department
  
  Date: 05/MAR/2024

Exhibit #4: Witness Statement - Police Officer III Peter Macburry
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"

Case Information
- Incident Date: 28/FEB/2024
Witness Information
- Name: Peter Macburry
  Date of Birth: 23/AUG/1993
  Phone Number: 553-8950
  Occupation: Police Officer III, Los Santos Police Department
Witness Statement
- On the Day of February 28th, while on Patrol, I have received a Backup call from a SWAT Unit, spearheaded by Officer Keys. Upon arriving, I have seen a Shootout scene with 1 deceased Suspect, 2 suspects that were incapacitated and 1 in cuffs, but un-injured. Upon arriving, I got assigned Saint Valentine - one of the Suspects that were incapacitated and began watching over his treatment.
  
  Upon being treated by the Medical Department, I asked for Sergeant Keys' version of the story, to which he responded after checking his bodycam footage, that Saint Valentine, after discharging his firearm, managed to get a few shots off into Sergeant Keys' Kevlar vest, before being neutralized, therefore I charged him with Attempted Murder.
  
  The suspects were then transported to DOC by a Tarv. For a full incident report, a Gang-Related Incident Report, made by me, can be checked out.
Witness Affirmation
- I, Peter Macburry, 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,
  
  Peter Macburry
  Police Officer III
  Los Santos Police Department
  
  Date: 7/MAR/2024

Exhibit #5: LSPD Gang-Related Incident Report, 28/FEB/2024
Los Santos Police Department
Gang-Related Incident Report
"TO PROTECT AND TO SERVE"
- INDIVIDUALS INVOLVED
  Please fill in the names of the individuals present, split in groups based on clothing.
  
  CSB--------------------------------
  
  John Doe
  
  Barrie Bonga
  
  Saint Valentine
  
  Dillon Bing
- INCIDENT DETAILS
  Please fill in the details of the incident with as much detail as willing.
  
  Date of Incident: 28/FEB/2024 20:53
  Location of Incident: El Rancho Blvd
  Summary of the Incident: While on patrol, a Backup call came in from a SWAT Unit in regards a Gang Related Shots Fired situation. After arriving on scene, it was seen, that at first the SWAT Unit saw one CSB-affiliated suspect, later identified as Dillon Bing, who entered a dark alleyway. After following, the unit found the suspect fiddling in his trunk. The Unit called in GND, because of his apparent Gang Affiliation, as seen from his clothes and because the RO of the Scout was Dillon Bing and tried to block him in, to which the suspect responded by trying to ram through the unit. When that didn't work out, the suspect dismounted and opened fire on the SWAT Unit with a Pistol .50. He was quickly neutralized, but not before he called in for Backup through his Radio. Quickly afterwards, some Backup from CSB arrived - a 3 Stacked Kamacho, consisting of Dillon Bing, Barrie Bonga and Saint Valentine. Later deceased John Doe and Saint Valentine dismounted the Vehicle and both started brandishing their weapons - a Pump Shotgun and a Pistol .50 as follows. Saint Valentine managed to get some shots off, the later deceased John Doe didn't, as the SWAT Unit neutralized them quickly. Barrie Bonga remained in the vehicle and capitulated on his own. After the incident was cleaned up the following illegal merchandise was found:
  
  1x Pump Shotgun [John Doe]
  
  4x Pistol .50 [John Doe, Dillon Bing, Saint Valentine, Barrie Bonga]
  
  1x Carbine Rifle [Dillon Bing]
  
  1x Bullpup Rifle [Barrie Bonga]
  
  2x Armor [Barrie Bonga, Dillon Bing]
  
  5x Suppressors [Barrie Bonga (2x), Dillon Bing, Saint Valentine, John Doe]
  
  1x Extended Clip [Barrie Bonga]
  
  2x Grips [Barrie Bonga, Dillon Bing]
  
  2x Marihuana [John Doe, Dillon Bing]
  
  The Suspects were then transported to Lower Pillbox to be treated, from where they were taken by HVT Transport, supplied by DOC.
- WITNESSES AND OTHER OPTIONAL INFORMATION
  Please fill in who witnessed the incident and any other evidence you might have.
  
  Incident Witnesses: Police Officer III Peter Macburry, Police Sergeant II Alex Sorvanis, Police Officer III+1 Luca Andollini, Police Sergeant II John Keys, Police Detective III Samuel Martin, Police Detective I Marcus Kayne, Police Captain III Jaxon Nash, Police Captain III Jessica Nash, Police Officer II Murphy Azalea
  Photos Taken: Evidence 1 , Evidence 2 , Evidence 3 , Evidence 4 , Evidence 5 , Evidence 6 , Evidence 7
  Bodycamera Evidence: (( Bodycam RP ))

Exhibit #6: Gang incident crime scene photos

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

Post by **Carlton Ellery** » 04 Sep 2024, 00:35

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

MOTION FOR SUMMARY JUDGEMENT

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine
#24-CM-0063

A Motion for Summary Judgement was filed in the above case on the 4th September, 2024.

The State of San Andreas, name, by and through the undersigned attorney, filed this Motion for Summary Judgement, and the reasoning for request is as follows;

Reasoning: Your Honor, it is the submission of the prosecution that the facts of this case are indisputable.

On the 28th of February 2024 the LSPD Special Weapons and Tactics Units (SWAT) called for additional units after becoming embroiled in a firefight linked to Gang Violence.

The original officers on scene identified a suspect who was believed to be gang affiliated at the time (CSB) due to their clothing and possession of a shotgun which was clearly visible to the officers. The suspect was accompanied by a vehicle (Vapid Scout) to which officers attempted to blockade due it's affiliation with the gang in question.

The officers attempted to blockade the Scout at the scene and prevent the vehicle from leaving. At this point, the suspect left the vehicle and fired upon officers before calling for backup from his accomplices.

A short period later, the defendant in this case arrived in a Kamacho vehicle accompanied by two accomplices, Mr. John Doe and Mr. Barrie Bonga.

The defendant then exited the vehicle, with Mr. John Doe brandishing a shotgun and the defendant brandishing a .50 Calibre Pistol before opening fire repeatedly towards law enforcement officers.

Officers of the LSPD then returned fire and the defendant was incapacitated shortly after his accomplices.
- Detailed Explanation: Evidence submitted includes:
  - Eye witness statements from Law Enforcement officers who were present at the scene. These corroborate the above submission, placing the defendant at the scene and confirming his repeated use of the .50 Calibre firearm to attempt to kill government employees in the course of their work.
  - Statements from an officer who attended at the scene and was responsible for the defendants care after they were treated by medical personnel.
  - Body Camera footage of the scene supporting the defendant attacking Police Sergeant II Keys by firing his pistol at the body of Police Sergeant Keys before hitting his armoured vest.
  - Photographs of the scene supporting the above.
  - .50 Calibre Pistol and Suppressor recovered on scene from the defendant upon his lawful arrest.
It is our submission that these facts of the case will be near impossible for the defendant to dispute and that the only determination left to be made is on how the situation outlined in this case applies to the law.

Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 593-3137 — [email protected]

Post by **Margot Rousseau** » 04 Sep 2024, 09:02

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

NOTIFICATION OF COUNSEL

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/SEP/2024.

I, Margot Rousseau, a Defense Attorney with the San Andreas Judicial Branch, will be representing the defendant, Saint Valentine, in the underlying case.

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

Junior Defense Attorney
San Andreas Judicial Branch
(909) 293-8398 — [email protected]

Post by **Margot Rousseau** » 04 Sep 2024, 10:07

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

MOTION TO COMPEL DISCOVERY

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine
#24-CM-0063

A Motion to Compel Discovery was filed in the above case on the 04th of September, 2024.

Defendant, Saint Valentine, by and through the undersigned attorney, filed this Motion to Compel Discovery, and requests as follows;

Requested Discovery: Bodycam Footage: Sergeant II John Keys
- Detailed Reasoning: The prosecutions case, as it stands, is founded exclusively on the fact that a bodycam allegedly captured Saint Valentine firing his gun at an officer. We therefore request that this crucial piece of evidence be brought into evidence.
In the highlighted portion of Peter Macburry's testimony, Macburry affirms that he charged Saint Valentine exclusively based on what he witnessed on Sergeant Key's bodycam footage.
Exhibit #4: Witness Statement - Police Officer III Peter Macburry
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"

Case Information
- Incident Date: 28/FEB/2024
Witness Information
- Name: Peter Macburry
  Date of Birth: 23/AUG/1993
  Phone Number: 553-8950
  Occupation: Police Officer III, Los Santos Police Department
Witness Statement
- On the Day of February 28th, while on Patrol, I have received a Backup call from a SWAT Unit, spearheaded by Officer Keys. Upon arriving, I have seen a Shootout scene with 1 deceased Suspect, 2 suspects that were incapacitated and 1 in cuffs, but un-injured. Upon arriving, I got assigned Saint Valentine - one of the Suspects that were incapacitated and began watching over his treatment.
  
  Upon being treated by the Medical Department, I asked for Sergeant Keys' version of the story, to which he responded after checking his bodycam footage, that Saint Valentine, after discharging his firearm, managed to get a few shots off into Sergeant Keys' Kevlar vest, before being neutralized, therefore I charged him with Attempted Murder.
  
  The suspects were then transported to DOC by a Tarv. For a full incident report, a Gang-Related Incident Report, made by me, can be checked out.
Witness Affirmation
- I, Peter Macburry, 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,
  
  Peter Macburry
  Police Officer III
  Los Santos Police Department
  
  Date: 7/MAR/2024

Once again, the bodycam is mentionned in the prosecutions motion for summary judgment, as highlighted below.
Motion for Summary Judgement
Carlton Ellery wrote: ↑04 Sep 2024, 00:35

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

MOTION FOR SUMMARY JUDGEMENT

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine
#24-CM-0063

A Motion for Summary Judgement was filed in the above case on the 4th September, 2024.

The State of San Andreas, name, by and through the undersigned attorney, filed this Motion for Summary Judgement, and the reasoning for request is as follows;

Reasoning: Your Honor, it is the submission of the prosecution that the facts of this case are indisputable.

On the 28th of February 2024 the LSPD Special Weapons and Tactics Units (SWAT) called for additional units after becoming embroiled in a firefight linked to Gang Violence.

The original officers on scene identified a suspect who was believed to be gang affiliated at the time (CSB) due to their clothing and possession of a shotgun which was clearly visible to the officers. The suspect was accompanied by a vehicle (Vapid Scout) to which officers attempted to blockade due it's affiliation with the gang in question.

The officers attempted to blockade the Scout at the scene and prevent the vehicle from leaving. At this point, the suspect left the vehicle and fired upon officers before calling for backup from his accomplices.

A short period later, the defendant in this case arrived in a Kamacho vehicle accompanied by two accomplices, Mr. John Doe and Mr. Barrie Bonga.

The defendant then exited the vehicle, with Mr. John Doe brandishing a shotgun and the defendant brandishing a .50 Calibre Pistol before opening fire repeatedly towards law enforcement officers.

Officers of the LSPD then returned fire and the defendant was incapacitated shortly after his accomplices.

Detailed Explanation: Evidence submitted includes:

Eye witness statements from Law Enforcement officers who were present at the scene. These corroborate the above submission, placing the defendant at the scene and confirming his repeated use of the .50 Calibre firearm to attempt to kill government employees in the course of their work.

Statements from an officer who attended at the scene and was responsible for the defendants care after they were treated by medical personnel.

Body Camera footage of the scene supporting the defendant attacking Police Sergeant II Keys by firing his pistol at the body of Police Sergeant Keys before hitting his armoured vest.

Photographs of the scene supporting the above.

.50 Calibre Pistol and Suppressor recovered on scene from the defendant upon his lawful arrest.

It is our submission that these facts of the case will be near impossible for the defendant to dispute and that the only determination left to be made is on how the situation outlined in this case applies to the law.

Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 593-3137 — [email protected]
- Requested Discovery: GSR Test Results: Results for Saint Valentine
  - Detailed Reasoning: The defense asks for the evidence that a gunshot residue test was performed on Saint Valentine to determine if Saint Valentine had in fact fired a gun, as part of the crime scene investigation. As highlighted in Sergeant Key's testimony below, the suspect with the shotgun was never able to fire his shotgun in his attempt to withdraw it. Therefore, there would be no cross-contamination should a GSR test be done.
Exhibit #3: Witness Statement - Sergeant II John Keys
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"

Case Information
- Incident Date: 28/FEB/2024
Witness Information
- Name: John Keys
  Date of Birth: 22/SEP/1991
  Phone Number: 221-3082
  Occupation: Sergeant II, Los Santos Police Department
Witness Statement
- I remember this situation pretty good. I do not remember in detail who did what 100% by name.
  
  It all started with myself and Officer Andollini patroling when we saw a Scout parked close to El Rancho Blvd. A man was behind the Scout and started to open fire upon myself and Officer Andollini. We both dismounted and armed with carabines the man was pretty fast taken down. Myself called MD right after he was down.
  After 10-15 seconds we started to hear motor sounds an suddenly a Kamacho almost ran me over and 2 men jumped out from the vehicle. The driver tried to pull out a shotgun, and he was pretty much instantly taken down and the passanger was shot down last. The third passanger Barrie Bonga complied at all times and was seated in the car, he only came out when told to by myself and officer Andollini.
Witness Affirmation
- I, John Keys, 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,
  
  John Keys
  Sergeant II
  Los Santos Police Department
  
  Date: 05/MAR/2024
- Requested Discovery: Bullet Casings: .50 pistol
  - Detailed Reasoning: We the defense request that the bullet casings be compelled into discovery as this is crucial evidence towards whether or not the gun was fired.
- Requested Discovery: Results of inspection: .50 pistol
  - Detailed Reasoning: We the defense request that the information on whether the gun was properly inspected be compelled into discovery as this is crucial evidence towards whether or not the gun was fired. More specifically, whether the gun received a touch test to determine if it was warm or not.
  We, the defense, therefore request the submission of the bodycam footage as the charge was placed after viewing said bodycam footage.

Junior Defense Attorney
San Andreas Judicial Branch
(909) 293-8398 — [email protected]

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

Post by **Paige Enora** » 04 Sep 2024, 10:43

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. Saint Valentine
#24-CM-0063

A Motion to Suppress was filed in the above case on the 4th of September, 2024.

The Defendant, Saint Valentine, by and through the undersigned attorney, filed this Motion to Suppress, and requests to following be suppressed from evidence;

Exhibit 4: Witness Statement - Police Officer III Peter Macburry.
Requested Evidence to Suppress:
Exhibit #4: Witness Statement - Police Officer III Peter Macburry
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"

Case Information

Incident Date: 28/FEB/2024

Witness Information

Name: Peter Macburry
Date of Birth: 23/AUG/1993
Phone Number: 553-8950
Occupation: Police Officer III, Los Santos Police Department

Witness Statement

On the Day of February 28th, while on Patrol, I have received a Backup call from a SWAT Unit, spearheaded by Officer Keys. Upon arriving, I have seen a Shootout scene with 1 deceased Suspect, 2 suspects that were incapacitated and 1 in cuffs, but un-injured. Upon arriving, I got assigned Saint Valentine - one of the Suspects that were incapacitated and began watching over his treatment.

Upon being treated by the Medical Department, I asked for Sergeant Keys' version of the story, to which he responded after checking his bodycam footage, that Saint Valentine, after discharging his firearm, managed to get a few shots off into Sergeant Keys' Kevlar vest, before being neutralized, therefore I charged him with Attempted Murder.

The suspects were then transported to DOC by a Tarv. For a full incident report, a Gang-Related Incident Report, made by me, can be checked out.

Witness Affirmation

I, Peter Macburry, 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,

Peter Macburry
Police Officer III
Los Santos Police Department

Date: 7/MAR/2024
- Detailed Reasoning: The highlighted portion of this statement should be suppressed because it constitutes hearsay, is speculative, and is based on information outside Officer Macburry's personal knowledge. He is testifying about events he did not witness firsthand, which is particularly problematic since the body camera footage he references is not part of the evidence before this Court.
  
  Under the rules of evidence, hearsay is defined as an out-of-court statement introduced to prove the truth of the matter asserted, and it is generally inadmissible unless it falls within a recognized exception. In this case, Officer Macburry’s testimony is based on what Officer Keys allegedly said, making it hearsay.
  
  Moreover, this statement reflects Officer Macburry’s interpretation of evidence that has not been presented, and thus, it is not valid evidence. Therefore, it should be excluded.

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

Junior Defense Attorney
San Andreas Judicial Branch
(909) 293-8398 — [email protected]

Post by **Margot Rousseau** » 04 Sep 2024, 10:43

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

Honorable Judge Tony McFornell and pertaining parties,

The prosecution requests a Motion of Summary Judgement on the grounds that the facts of the case are indisputable. However, the defense finds that not enough facts have been presented, and the few facts that have been shared are in dispute.

The Prosecution argue that "Body Camera footage of the scene support(s) the defendant attacking Police Sergeant II Keys by firing his pistol at the body of Police Sergeant Keys before hitting his armoured vest." as a fact. Yet are still yet to see any evidence that said bodycam footage even exists. PO III Peter Macburry indicates that the sole reason given for the charge was due to this footage.

We the defense argue that the facts remain disputable and request that the motion be dismissed.

Junior Defense Attorney
San Andreas Judicial Branch
(909) 293-8398 — [email protected]

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

Post by **Michael Blaise** » 04 Sep 2024, 16:38

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

Honorable Justice McFornell and pertaining parties,

The prosecution opposes the motion to suppress the highlighted portion of Officer Peter Macburry's witness statement. The defense argues that the statement should be suppressed on the grounds of hearsay and speculation. However, the prosecution contends that the statement is admissible for the following reasons:

Officer Macburry’s statement regarding Sergeant Keys’ account of events provides important context to the actions taken by law enforcement. Officer Macburry relied on information provided by a fellow officer during the course of his duties, which informed his decision to charge the defendant with Attempted Murder. This is not speculative, but rather a procedural necessity where officers in the field must communicate to ensure accurate responses to criminal activity.

Sergeant Keys, the original source of the information, was present at the scene and had direct knowledge of the events, as documented in his own statement (Exhibit 3). The information relayed to Officer Macburry was based on firsthand observations made by Sergeant Keys.

It is standard practice for officers to share information during the course of an investigation. The statement in question reflects Officer Macburry's duty to gather relevant details to accurately document the incident and apply appropriate charges. Suppressing this statement would undermine the collaborative nature of police work, where communication is key to ensuring justice.

Given these points, the prosecution respectfully requests that the Court deny the motion to suppress this portion of Officer Macburry's statement.

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

Post by **Paige Enora** » 04 Sep 2024, 22:25

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

Honorable McFornell and Pertaining parties,

On behalf of the defense, I respectfully request the opportunity for a final statement regarding the motion to suppress, as we are the initiating party.

The prosecution has not adequately addressed the crucial issues of hearsay and the speculative nature of the statement in question. Officer Macburry’s statement about Sergeant Keys' account clearly falls under hearsay, as it involves an out-of-court statement being used to prove the truth of the matter asserted. The prosecution’s argument that this was part of routine police procedure does not override the rules governing admissible evidence. The fact that officers may share information during an investigation does not exempt these statements from scrutiny under the hearsay rule. This rule exists to prevent unreliable information from being presented as evidence.

Furthermore, Officer Macburry was not present at the events he describes; his testimony is entirely based on what Sergeant Keys told him. This introduces speculation, as Officer Macburry cannot personally confirm the accuracy or context of Sergeant Keys’ observations. The prosecution’s claim that this is standard practice does not change the fact that Officer Macburry’s testimony lacks firsthand knowledge, making it speculative and inappropriate for consideration.

Given that the prosecution has not demonstrated that the statement in question falls under any recognized exception to the hearsay rule, we respectfully request that it be suppressed.

Respectfully,

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

Junior Defense Attorney
San Andreas Judicial Branch
(909) 293-8398 — [email protected]

Post by **Michael Blaise** » 07 Sep 2024, 01:38

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

Honorable Justice McFornell and pertaining parties,

The prosecution will respect the defense's request for their final statement and choose to rest at this time. We will await further instruction from the judge.

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

Post by **Antonio McFornell** » 09 Sep 2024, 16:21

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

Parties,

Given the numerous motions presented on the docket, the Court will no longer accept more submissions in regards to these. It will now study them in group and render a single decision that addresses all the motions presented within the next 72 hours.

Best regards,

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

Post by **Antonio McFornell** » 14 Sep 2024, 18:02

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. Saint Valentine
#24-CM-0063

A decision was reached in the above case on the 14th day of September, 2024.

On the 3rd of September the Prosecution filed a motion for summary judgment on the grounds that the facts of the case were undisputed. Most specifically, the Prosecution argued that the facts of the case were "near impossible for the defendant to dispute", and cited that the evidence submitted so far had included:

Eye witness statements from Law Enforcement officers who were present at the scene. These corroborate the above submission, placing the defendant at the scene and confirming his repeated use of the .50 Calibre firearm to attempt to kill government employees in the course of their work.
Statements from an officer who attended at the scene and was responsible for the defendants care after they were treated by medical personnel.
Body Camera footage of the scene supporting the defendant attacking Police Sergeant II Keys by firing his pistol at the body of Police Sergeant Keys before hitting his armoured vest.
Photographs of the scene supporting the above.
.50 Calibre Pistol and Suppressor recovered on scene from the defendant upon his lawful arrest.

The defense opposed the motion, arguing that facts were disputed, and the prosecution used evidence that wasn't present on the docket as foundation to their motion. The Court notes that the submission contesting this specific Motion was submitted after two other motions presented by the defense, which are of paramount importance to the determination the Court has to make in regard to the Motion for Summary Judgment.

The first of the two remainder Motions consists of a Motion to Compel Discovery made on September 4th, where the Defense requested Bodycamera evidence that was mentioned in numerous exhibits, yet not included in the initial discovery. Furthermore, the defense also requested GSW Test Results, bullet casing evidence and results of weapon inspection. The Court believes that the evidence requested is reasonable, and thus will grant the Motion. Nonetheless, the Court understands that if specific tests -Weapon inspection, bullet casings and GSR- were not performed at the time of the events, performing them on the date this decision is issued might be outside of the possibilities of the arresting department, and thus failing to reasonably produce the evidence will and cannot be interpreted as failing to adhere or follow to a Court order.

The second Motion presented was a Motion to Suppress, particularly statements regarding the bodycamera footage and the statements made by Sergeant Keys being hearsay and speculative, based on information outside of Officer Macburry's personal knowledge, most specifically Sergeant Key's bodycamera footage. The Court will deny the Motion to Suppress in whole, given that it attempts against the principle of good faith, most specifically the prohibition of inconsistent behavior with one's acts. To the Court, it becomes clear that the defense's request is incoherent with their own acts, as they are demanding evidence be introduced in the docket utilizing Officer Macburry's witness statement as grounds for a previously filed Motion, but subsequently they request the same specific portion of the Witness Statement to be suppressed. In sum, it is contradictory that evidence that is used to sustain a Motion to Compel Discovery -and thus, is NOT CHALLENGED and in the eyes of the Court, the defense considers to be valid and clear from vices- is then challenged by the same party that utilized it previously in a subsequent Motion to Suppress.

It is with these considerations that I hereby:

Grant the Motion to Compel Discovery, and thus order the Prosecution to produce within the next 7 days the evidence requested. If it becomes impossible, the Prosecution must inform the Court the reasons that make them unable to do so.
Deny the Motion for Summary Judgment.
Deny the Motion to Suppress.

So ordered,

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

Post by **Michael Blaise** » 20 Sep 2024, 16:02

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

Honorable Justice McFornell and pertaining parties,

Following the court's decision regarding the defense's motion for discovery, the prosecution attempted to obtain these pieces of evidence. Unfortunately, this proved impossible. This is due to the following factors:
- The officer whom the bodycam footage belonged to is no longer employed with the department.
- The second mainly involved officer is additionally no longer employed with the department, making it impossible to confirm whether or not a GSR test or a touch test was conducted, as well as whether or not bullet casings were taken from the scene.
The prosecution will await further instruction from the judge.

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

Post by **Carlton Ellery** » 20 Sep 2024, 16:15

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

MOTION TO AMEND

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint. Valentine
#24-CM-0063

A Motion to Amend was filed in the above case on the 20th of September, 2024.

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

Original Charges
- Attempted SF02 - Murder of a Government Employee

Amended Charges
- Attempted SF02 - Murder of a Government Employee
- NM03 - Unlawful Assembly

Detailed Explanation: Your Honor,

It is the submission of the prosecution that after careful review the defendant has clearly committed Unlawful Assembly. As per the requirements of the offence subject to the San Andreas Penal Code the defendant has:
- Gathered together with accomplices to do something illegal
- The defendant & accomplices were clearly disobedient to law enforcement instruction
It is after review of the wide array of evidence available in this case that the prosecution has arrived at this conclusion and we submit that there is a strong case to answer.

The collaborative nature of this offending would not be punished properly simply by a conviction for the original offence. With respect your honor, the inclusion of this charge would accurately reflect the totality of the defendants conduct when accompanied with Attempted Murder.

Carlton Ellery
Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 593-3137 — [email protected]

Post by **Antonio McFornell** » 24 Sep 2024, 15:04

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

Parties,

The Court hereby takes notice of the Motion to Amend and will consider the merits of the modified charges before issuing the final verdict.

With no pending matters, the Court will promptly present the first Notice of Scheduling.

Best regards,

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

Post by **Antonio McFornell** » 24 Sep 2024, 15:06

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

NOTICE OF SCHEDULING

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine
#24-CM-0063

An attempt to schedule was made and recorded by the court on 24th of September, 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 make one more attempt to schedule. Should this second attempt fail, a docket Trial will be ordered 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,

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

Post by **Antonio McFornell** » 28 Sep 2024, 12:56

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

NOTICE OF TRIAL

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine
#24-CM-0063

A trial date was set on the above case on September 28th, 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 September 29th, 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,

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

Post by **Izaak Scott** » 28 Sep 2024, 15:12

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

NOTIFICATION OF COUNSEL

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Saint Valentine
#24-CM-0063

A Notification of Counsel was filed in the above case on September 28th, 2024.

I, Izaak Scott, a Public Defense Attorney with the San Andreas Judicial Branch, will be representing the defendant, Saint Valentine in the underlying case.

I will be taking the responsibility of Primary Counsel, alongside co-counsel Rousseau and will await further instruction from the Presiding Judge.

Chief Public Defender
San Andreas Judicial Branch
(909) 411-2330 — [email protected]

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