#24-CM-0078, State of San Andreas v. Alistair Kon (Vespucci)

[Alistair Vespucci]

Defendant Name: Alistair Vespucci
Defendant Phone: 315-6876
Defendant Address: N/A
(( Defendant Discord: steakhappy))
Requested Attorney: N/A

Charging Department: LSPD

Date & Time of Incident(s): 01/APR/2024 15:45
Charge(s):

• Attempted Burglary

Narrative:
I was unlawfully arrested and would like to appeal this charge.

---

I, Alistair Vespucci, 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. ))

[Antonio McFornell]

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. Alistair Vespucci

The court has hereby received and acknowledged the above case on the 2nd of April, 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]

[Terence Williams]

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. Alistair Vespucci

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

I, Terence Williams, a 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.


Terence Williams
Prosecuting Attorney
San Andreas Judicial Branch
(909) 234-9321 — [email protected]

[Hope Kant]

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

---

• Parties,
  
  This is to serve as an unfortunate notice to all parties. While, this case does come second in line for activation. In order to maintain impartiality and uphold the integrity of the judicial process, I believe it is in the best interest of all parties that I step aside from this case. Another qualified individual will be assigned to ensure that the proceedings continue without any potential for bias.
  
  Respectfully,
  
  
  Superior Court Judge
  Branch Administrator
  San Andreas Judicial Branch
  505-9925 — [email protected]

[Maximilian Fitzgerald]

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. Alistair Kon
#24-CM-0078

A Notice of Activation was entered in the above case on 16th of November, 2024.

The case of the State of San Andreas v. Alistair Kon is hereby activated by this Court under #24-CM-0078.

At this time the State has adequate representation, however, the Defendant is still seeking representation. 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.


Respectfully,


Superior Court Judge
San Andreas Judicial Branch
☎ 1-000-000
✉ [email protected]

[Clara Lopez]

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. Alistair Kon


A Notification of Counsel was filed in the above case on the 15/NOV/2024

I,Clara Lopez, a Public Defender with the San Andreas Judicial Branch, will be representing the defendant, Alistair Kon in the underlying case.

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


Public Defender
San Andreas Judicial Branch
(909) 495-1265 — [email protected]

[Maximilian Fitzgerald]

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. Alistair Kon
#24-CM-0078

A court order was entered in the above case on 16th of November, 2023.

The case of #23-CM-0078, State of San Andreas v. Defendant is hereby opened and acknowledged by the Court.

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

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

So ordered,


Superior Court Judge
San Andreas Judicial Branch
☎ 1-000-000
✉ [email protected]

[Bruce Tubby]

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. Alistair Kon

A Notification of Counsel was filed in the above case on the 16th of November, 2024.

I, Bruce Tubby, a Junior Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant, Alistair Kon in the underlying case.

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


Junior Public Defender
San Andreas Judicial Branch
(909) 494-8268 — [email protected]

[Malik Freeman]

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. Alistair Kon (Vespucci)

A Notification of Counsel was filed in the above case on the 17th of November, 2024.

I, Malik Freeman, a Junior 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 Co-Counsel and will await further instruction from the Presiding Judge.



Malik Freeman
Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 494-7867 — [email protected]

[Terence Williams]

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. Alistair Kon (Vespucci)
#24-CM-0078

A Motion for Discovery was filed in the above case on the 17th of November, 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 - Alistair Vespucci, 01/APR/2024

  

  

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

  
  

  ---

  MUGSHOT

  • SUSPECT DETAILS
    • 
      Full Name: Alistair Vespucci
      Phone Number: 3156876
      Licenses Suspended: No
      Officers Involved:
      • Police Officer III Matteo Ellis
      • Police Cadet Johnson Hilts
      • Police Officer II Ben Masseria
      • Police Officer III Heath Tegans
      • Police Officer III Mark Payne
      • Police Lieutenant I Samuel Martin
      • Deputy Chief Lex Roth
      Charges:
      • Attempted GF15 - Burglary
      • GM19 - Face Concealment (b)
    INCIDENT NARRATIVE
    • Incident Date: 01/APR/2024
      
      Explain what happened, sufficient detail must be given to justify the placed charges, videos could be provided.
      • A call was received from a homeowner on Normandy Dr. that someone is breaking into the house.
        
        Unit 21-A-12 which consisted of Officer Matteo Ellis and Cadet Johnson Hilts were the first on the scene where they saw a masked man standing in front of the doors of the house that the call was made. Officers approached the man and told him to get on his knees. Suspect noted to the officers "it is my house" and few seconds later "wait, this is not my house".
        Cadet Hilts read the Miranda Rights and patted the man down and found lockpicks - suspect identified as Alistair Vespucci.
        Detectives arrived on the scene and found a black kamacho that was parked behind the property - R/O Alistair Vepucci
        Later Mr. Vespucci changed his statement and said he was there to check the house if it is for sale or not.
        **Attached Bodycam**
        ((RP of the body cam))
    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: Mask
        Exhibit B: 4 lockpicks
        
        
        Legal Possessions:
        Exhibit A: Clothing - cap, wrist chain, necklace, gloves, watch
        Exhibit B: gps
        Exhibit C: radio
        Exhibit D: water
        
        
        Photograph of Possessions (MANDATORY)

        

  
  Exhibit #2: Witness Statement - Police Lieutenant Jonathan Willowick

  

  

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

  Case Information

  • Incident Date: 11/APR/2024

  Witness Information

  • Name: Jonathan Willowick
    Date of Birth: 09/AUG/1987
    Phone Number: 413-4102
    Occupation: Police Lieutenant II, Los Santos Police Department

  Witness Statement

  • My time with the Los Santos Police Department, particularly in the Detective Bureau over several years, has exposed me to numerous incidents of car break-ins and home invasions. Almost always when suspects are apprehended at these scenes, they are found with lockpicks in their possession, as well as broken lockpicks scattered around the crime scene doors. Criminals rely on these tools as essential assets for their illicit activities, regardless of the type of lock they aim to breach.

  Witness Affirmation

  • I, Jonathan Willowick, 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,
    
    
    Jonathan Willowick
    Police Lieutenant II
    Los Santos Police Department
    
    Date: 11/APR/2024

  
  Exhibit #3: Witness Statement - Police Officer III Matteo Ellis

  

  

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

  Case Information

  • Incident Date: 01/APR/2024

  Witness Information

  • Name: Matteo Ellis
    Date of Birth: 17/JUL/1995
    Phone Number: 3597-7960
    Occupation: Police Officer III, Los Santos Police Department

  Witness Statement

  • On 01/APR a call was received from a house owner at Normandy Drive saying that he thinks someone broke into his house.
    
    Our Unit 21-A-12 that consisted of Officer Matteo Ellis and Cadet Johnson Hilts were near LSC at the time of the call and straight away responded to the call and took us only a few minutes to get to the scene where we saw a masked man in front of the door, once he noticed us he turned back, touched his radio and seemed to change his frequency, just before saying something over the radio.
    
    He was ordered to get on his knees to which he replied along the lines ''this is my house, this is my house'' few moments later he stated ''wait, this is not my house, huh''. Cadet Hilts read Miranda Rights and performed a pat down, the suspect was identified as Alistair Vespucci, a few lockpicks where found in his possession.
    
    Officers Heath Tegans and Ben Masseria approached the door to enter the house and check if anyone else was there, although the house was still locked but the lock was broken.
    
    Officer Mark Payne, requested detectives to come to the scene which Chief Lex Roth and Lieutenant Samuel Martin arrived on scene, while we were discussing the whole situation Alistair Vespucci changed story once more and said that he was just seeing if the house is for sale.
    
    Chief Lex Roth found Kamacho that belonged to Alistair Vespucci, illegaly parked just behind the property. Lieutenant Samuel Martin advised that due to the whole situation charges applies for attempted burglary.
    
    Alistair Vespucci was arguing that he never had a lockpick as he bought bobby pins from the shop, as that's what cashier said it was.
    
    ((Body Camera RP))
    **Attached Bodycam Footage**

  Witness Affirmation

  • I, Matteo Ellis, 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,
    
    
    Matteo Ellis
    Police Officer III
    Los Santos Police Department
    
    Date: 06/APR/2024

  
  Exhibit #4: Witness Statement - Police Cadet JohnsonHilts

  

  

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

  Case Information

  • Incident Date: 01/APR/2024

  Witness Information

  • Name: Johnson_Hilts
    Date of Birth: 27/Mar/1995
    Phone Number: 3176432
    Occupation: Cadet, Los Santos Police Department

  Witness Statement

  • Everything is greatly explained in the arrest narrative. I cannot add anything else to it, apart from that I truly believe that me and officer Ellis made a right decision looking at the surroundings of the arrest. I am adding the original arrest statement here and I fully stand by it.
    
    A call was received from a homeowner on Normandy Dr. that someone is breaking into the house.
    Unit 21-A-12 which consisted of Officer Matteo Ellis and Cadet Johnson Hilts were the first on the scene where they saw a masked man standing in front of the doors of the house that the call was made. Officers approached the man and told him to get on his knees. Suspect noted to the officers "it is my house" and few seconds later "wait, this is not my house".
    Cadet Hilts read the Miranda Rights and patted the man down and found lockpicks - suspect identified as Alistair Vespucci.
    Detectives arrived on the scene and found a black kamacho that was parked behind the property - R/O Alistair Vepucci
    Later Mr. Vespucci changed his statement and said he was there to check the house if it is for sale or not.

  Witness Affirmation

  • I, Johnson_Hilts, 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,
    
    
    Johnson_Hilts
    Cadet
    Los Santos Police Department
    
    Date: 06/APR/2024
  Exhibit #5: MDC record - Alistair Kon

  
  
  
  
  
  

---

Terence Williams
Attorney General
San Andreas Judicial Branch
(909) 234-9321 — [email protected]

[Bruce Tubby]

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. Alistair Kon (Vespucci)
#24-CM-0078

A Motion to Suppress was filed in the above case on the 21st of November, 2024.

The Defendant, Alistair Kon (Vespucci), by and through the undersigned attorney, filed this Motion to Suppress, and requests the following be suppressed from evidence;

• Exhibit 5: MDC Record, LSPD
  Requested Evidence to Suppress:

  Exhibit #5: MDC record - Alistair Kon

  
  
  
  
  
  

  • Detailed Reasoning: The defence believes the MDC report bears no relevance to the case in question due to the timeframes of the historic charges. As you can see on the MDC record, the burglaries are within a small time frame of one another and then no charges are present for 7 months; this evidence gives the assumption that the defendant has not had any room for change and does not allow for any recovery by the defendant.

• Exhibit #1: Arrest Report, LSPD
  Requested Evidence to Suppress:

  Exhibit #1: Arrest Report - Alistair Vespucci, 01/APR/2024

  

  

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

  
  

  ---

  MUGSHOT

  • SUSPECT DETAILS
    • 
      Full Name: Alistair Vespucci
      Phone Number: 3156876
      Licenses Suspended: No
      Officers Involved:
      • Police Officer III Matteo Ellis
      • Police Cadet Johnson Hilts
      • Police Officer II Ben Masseria
      • Police Officer III Heath Tegans
      • Police Officer III Mark Payne
      • Police Lieutenant I Samuel Martin
      • Deputy Chief Lex Roth
      Charges:
      • Attempted GF15 - Burglary
      • GM19 - Face Concealment (b)
    INCIDENT NARRATIVE
    • Incident Date: 01/APR/2024
      
      Explain what happened, sufficient detail must be given to justify the placed charges, videos could be provided.
      • A call was received from a homeowner on Normandy Dr. that someone is breaking into the house.
        
        Unit 21-A-12 which consisted of Officer Matteo Ellis and Cadet Johnson Hilts were the first on the scene where they saw a masked man standing in front of the doors of the house that the call was made. Officers approached the man and told him to get on his knees. Suspect noted to the officers "it is my house" and few seconds later "wait, this is not my house".
        Cadet Hilts read the Miranda Rights and patted the man down and found lockpicks - suspect identified as Alistair Vespucci.
        Detectives arrived on the scene and found a black kamacho that was parked behind the property - R/O Alistair Vepucci
        Later Mr. Vespucci changed his statement and said he was there to check the house if it is for sale or not.
        **Attached Bodycam**
        ((RP of the body cam))
    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: Mask
        Exhibit B: 4 lockpicks
        
        
        Legal Possessions:
        Exhibit A: Clothing - cap, wrist chain, necklace, gloves, watch
        Exhibit B: gps
        Exhibit C: radio
        Exhibit D: water
        
        
        Photograph of Possessions (MANDATORY)

        

  

  • Detailed Reasoning: The Mask and Lockpicks are not illegal to have on possession of a person and should not be listed under 'illegal possessions' on the arrest report.

• Exhibit 2: Witness Statement, Lieutenant Jonathan Willowick
  Requested Evidence to Suppress:

  Exhibit #2: Witness Statement - Police Lieutenant Jonathan Willowick

  

  

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

  Case Information

  • Incident Date: 11/APR/2024

  Witness Information

  • Name: Jonathan Willowick
    Date of Birth: 09/AUG/1987
    Phone Number: 413-4102
    Occupation: Police Lieutenant II, Los Santos Police Department

  Witness Statement

  • My time with the Los Santos Police Department, particularly in the Detective Bureau over several years, has exposed me to numerous incidents of car break-ins and home invasions. Almost always when suspects are apprehended at these scenes, they are found with lockpicks in their possession, as well as broken lockpicks scattered around the crime scene doors. Criminals rely on these tools as essential assets for their illicit activities, regardless of the type of lock they aim to breach.

  Witness Affirmation

  • I, Jonathan Willowick, 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,
    
    
    Jonathan Willowick
    Police Lieutenant II
    Los Santos Police Department
    
    Date: 11/APR/2024

  

  • Detailed Reasoning: The entire witness statement bears no relevance to the case in question and is listed as a witness statement but provides no witness to the events that have occured, instead comes across as an expert statement.

Junior Public Defender
San Andreas Judicial Branch
(909) 494-8268 — [email protected]

[Bruce Tubby]

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

---

NOTIFICATION OF RECUSAL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Alistair Kon

A Notification of Recusal was filed in the above case on the 23rd of November, 2024.

I, Bruce Tubby, a Junior Public Defense Attorney with the San Andreas Judicial Branch, will no longer be representing the Defendant, Alistair Kon in the underlying case and will be Recusing myself as requested by the defendant.


Junior Public Defender
San Andreas Judicial Branch
(909) 494-8268 — [email protected]

[Clara Lopez]

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

---

AMENDMENT FOR THE MOTION TO SUPPRESS

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Alistair Kon (Vespucci)
#24-CM-0078

An Amendment for the Motion to Suppress was filed in the above case on the 24th of November, 2024.

The Defendant, Alistair Kon (Vespucci), by and through the undersigned attorney, using his 5th and 14th amendment right for Due Process Clause filed this Amendment for the Motion to Suppress, and requests the following be suppressed from evidence;

• Exhibit 5: MDC Record, LSPD
  Requested Evidence to Suppress:

  Exhibit #5: MDC record - Alistair Kon

  
  
  
  
  
  

  • Detailed Reasoning: The introduction of prior charges unrelated to the current case serves only to prejudice the jury against the defendant. These charges occurred over seven months ago and bear no relevance to the facts of the present case. Hence there is no relevance.

• Exhibit #1: Arrest Report, LSPD
  Requested Evidence to Suppress:

  Exhibit #1: Arrest Report - Alistair Vespucci, 01/APR/2024

  

  

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

  
  

  ---

  MUGSHOT

  • SUSPECT DETAILS
    • 
      Full Name: Alistair Vespucci
      Phone Number: 3156876
      Licenses Suspended: No
      Officers Involved:
      • Police Officer III Matteo Ellis
      • Police Cadet Johnson Hilts
      • Police Officer II Ben Masseria
      • Police Officer III Heath Tegans
      • Police Officer III Mark Payne
      • Police Lieutenant I Samuel Martin
      • Deputy Chief Lex Roth
      Charges:
      • Attempted GF15 - Burglary
      • GM19 - Face Concealment (b)
    INCIDENT NARRATIVE
    • Incident Date: 01/APR/2024
      
      Explain what happened, sufficient detail must be given to justify the placed charges, videos could be provided.
      • A call was received from a homeowner on Normandy Dr. that someone is breaking into the house.
        
        Unit 21-A-12 which consisted of Officer Matteo Ellis and Cadet Johnson Hilts were the first on the scene where they saw a masked man standing in front of the doors of the house that the call was made. Officers approached the man and told him to get on his knees. Suspect noted to the officers "it is my house" and few seconds later "wait, this is not my house".
        Cadet Hilts read the Miranda Rights and patted the man down and found lockpicks - suspect identified as Alistair Vespucci.
        Detectives arrived on the scene and found a black kamacho that was parked behind the property - R/O Alistair Vepucci
        Later Mr. Vespucci changed his statement and said he was there to check the house if it is for sale or not.
        **Attached Bodycam**
        ((RP of the body cam))
    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: Mask
        Exhibit B: 4 lockpicks
        
        
        Legal Possessions:
        Exhibit A: Clothing - cap, wrist chain, necklace, gloves, watch
        Exhibit B: gps
        Exhibit C: radio
        Exhibit D: water
        
        
        Photograph of Possessions (MANDATORY)

        

  

  • Detailed Reasoning: The defense would like to suppress this arrest report in its entirety. The reasons are as follows.
    • The arrest report references a 911 call alleging a potential break-in. However, the prosecution has not provided a transcript, recording, or verification of the call. Without the transcript or any supporting evidence, the information derived from this 911 call constitutes hearsay and cannot be used as the sole basis for establishing probable cause.
    • The report lists "lockpicks" as illegal possessions. The defendant asserts that these were bobby pins, which are legal and commonly used items. The characterization of these items as "illegal" is both factually incorrect and prejudicial, leading to an improper portrayal of the defendant's actions and intentions.
    • The report references the defendant’s changing explanations about his presence at the property. This speculative narrative lacks corroborating evidence and should not be considered as it unfairly biases the defendant's statements without context.

• Exhibit 2: Witness Statement, Lieutenant Jonathan Willowick
  Requested Evidence to Suppress:

  Exhibit #2: Witness Statement - Police Lieutenant Jonathan Willowick

  

  

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

  Case Information

  • Incident Date: 11/APR/2024

  Witness Information

  • Name: Jonathan Willowick
    Date of Birth: 09/AUG/1987
    Phone Number: 413-4102
    Occupation: Police Lieutenant II, Los Santos Police Department

  Witness Statement

  • My time with the Los Santos Police Department, particularly in the Detective Bureau over several years, has exposed me to numerous incidents of car break-ins and home invasions. Almost always when suspects are apprehended at these scenes, they are found with lockpicks in their possession, as well as broken lockpicks scattered around the crime scene doors. Criminals rely on these tools as essential assets for their illicit activities, regardless of the type of lock they aim to breach.

  Witness Affirmation

  • I, Jonathan Willowick, 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,
    
    
    Jonathan Willowick
    Police Lieutenant II
    Los Santos Police Department
    
    Date: 11/APR/2024

  

  • Detailed Reasoning: The defense would like to suppress this exhibit in its entirety. Lieutenant Willowick’s statement does not address the specific facts of the case but instead provides a general overview of lockpicks being used in prior unrelated incidents. This "expert opinion" is irrelevant to the matter at hand, as it does not establish any link between the defendant’s alleged possession of bobby pins and the commission of a crime. The statement is also more prejudicial than probative, as it aims to draw a connection between general criminal behavior and the defendant without any direct evidence.

Respectfully,

Public Defender
San Andreas Judicial Branch
(909) 495-1265 — [email protected]

[Clara Lopez]

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. Alistar Kon (Vespucci)
#24-CM-0078

A Motion for Discovery was filed in the above case on the 24th of November, 2023.

The Defendant, Alistar Kon, by and through the undersigned attorney, filed this Motion for Discovery, and presents the following as evidence;

• Exhibit #6: Store Inventory of Bobby Pins
  Spoiler

  

The Defense is in possession of photographic evidence depicting how bobby pins appear in the inventory display of the store where the defendant allegedly purchased the items in question. This image is submitted to establish that the items found in the defendant’s possession were bobby pins and not lockpicks, as alleged by the prosecution. The attached photograph demonstrates the visual characteristics of bobby pins as listed and sold in the store inventory, which is material to the defense’s argument that no criminal intent was involved in the defendant’s possession of these items.

The purpose of the discovery is as follows:

• The photographic evidence clarifies the appearance of bobby pins in their intended commercial context, supporting the claim that the defendant purchased these items for lawful use.
• The Defense contends that the arresting officers misidentified the bobby pins as lockpicks. This evidence is critical in demonstrating the absence of any tools specifically designed for illegal lockpicking activities.
• Submitting this evidence ensures transparency and allows the Court to make a fully informed determination regarding the matter.

Respectfully,

Public Defender
San Andreas Judicial Branch
(909) 495-1265 — [email protected]

[Terence Williams]

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

---

OBJECTION

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Alistair Kon (Vespucci)
#24-CM-0078

An Objection was filed in the above case on the 24th of November, 2024.

The State of San Andreas, name, by and through the undersigned attorney, filed this objection, and requests the following be stricken from the record;

• Statement being objected to: Defense's Motion to Suppress filed by Public Defender Clara Lopez
  
  • Detailed Reasoning: The Prosecution filed its Motion for Discovery on 17/NOV/2024. Opposing counsel is then afforded approximately three (3) days to respond, as per protocol. This response came in the form of a Motion to Suppress filed by Public Defender Bruce Tubby on 22/NOV/2024, five (5) days after the Prosecution's discovery. A day later, on day six (6) following discovery, counsel recuses themselves. Another day later, on day seven (7), counsel filed an amended Motion to Suppress.
    
    The Defense is in breach of procedure by initially filing their Motion to Suppress two (2) days overdue and then filing an amended Motion to Suppress seven (7) days overdue, more than double the time they would normally have been provided to respond. The Defense has had ample time to file their own motions in response to the Prosecution's discovery, and they did so on 22/NOV/2024. The Prosecution requests the presiding judge to dismiss the recent motion on these grounds, similar to how the Prosecution was denied the chance to provide an amended brief in the appeal of #24-AP-0003, State of San Andreas v. Kevin Reyes.
    
    The Prosecution requests that the presiding judge decide on this objection and which motion will be allowed to stand before filing our rebuttal.

Terence Williams
Attorney General
San Andreas Judicial Branch
(909) 234-9321 — [email protected]

[Clara Lopez]

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

---

REBUTTAL

---

Dear Parties

The defense would like to bring attention to the prosecution that the court ordered the motion for discovery on November 16th, 2024 allowing the prosecution 7 days to provide a motion for discovery.

The prosecution then filed their motion for discovery on November 17th, 2024, upon posting their motion there was nothing stating giving a timeframe for the time the defense has to post a motion to suppress

This led to the defense posting their first motion on November 22nd, 2024

The counsel who posted their motion was asked to recuse themself from the case leaving Attorney Lopez to make an amendment to the motion to suppress on November 24th, 2024.

The defense asserts that since there was no court response since the motion for discovery the defense should be able to file motions until the court reaches a decision.


Respectfully,

Public Defender
San Andreas Judicial Branch
(909) 495-1265 — [email protected]

[Maximilian Fitzgerald]

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. Alistair Kon (Vespucci)
#24-CM-0078

A decision was reached in the above case on the 24th day of November, 2024.

The court may have been more lenient if it was an entirely new attorney on the case after recusal, however, due to both being already on the case, I will not be allowing the amendment to suppress. The court pending a decision does not forego procedure, which Volume IV, section 3 of the handbook outlines the timeframe in which defense and prosecution should respond.

The court, in an effort to balance procedural precedent and fairness, will be lenient with the first motion of suppression and allow it to remain even though it was late. The court is now awaiting prosecution's rebuttal to the first motion to suppress.

Moving forward, I hope all motions and responses are within the 3-day (72-hour) window of the time of the post as leniency may not be given without a just explanation for the delay.


Respectfully,


Superior Court Judge
San Andreas Judicial Branch
☎ 1-000-000
✉ [email protected]

[Terence Williams]

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

---

Rebuttal

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Alistair Kon (Vespucci)
#24-CM-0078

A Rebuttal was filed in the above case on the 24th of November, 2024.

The State of San Andreas, by and through the undersigned attorney, presents a rebuttal to the recent motion;

• Exhibit #1: Arrest Report - Alistair Vespucci, 01/APR/2024
  No quoted objection
  The Defense argues that masks and lockpicks are not illegal to have in your possession and that they should not be labelled as 'illegal possession' in the report. The mask was seized as illegal contraband as the defendant was wearing it at the time of their arrest and thus charged with GM19 - Face Concealment (b). The lockpicks were seized as illegal contraband due to their association with the defendant's arrest for the charge of GF15 - Attempted Burglary.

• Exhibit #2: Witness Statement - Police Lieutenant Jonathan Willowick
  Regarding relevance
  The reason this witness statement seems like an expert witness statement is because it is just that. Captain Willowick is a decorated officer who has served in the Los Santos Police Department's Detective Bureau for nearly five (5) years, the last two and a half (2.5) as the Commanding Officer of the bureau's Major Crimes Division. The witness' experience gives them unparalleled knowledge of typical criminal behavior and their analysis of the usage of lockpicks during burglaries presents context to understand the witness' relevance in this matter.

• Exhibit #5: MDC record - Alistair Kon
  Regarding relevance
  The Defense argues that the defendant's record of previous burglaries lacks relevance due to the general timeframe, citing a seven-month (7) period without additional charges, presumably since 26/MAR/2024 until now. This is because charges placed on a defendant's record after the filing of a case cannot be used as evidence after the fact. The Prosecution will argue that the defendant's record is proof of a pattern of behavior consistent with the current charges, suggesting a pattern of intent, motivation, and method that is relevant to the case.

Terence Williams
Attorney General
San Andreas Judicial Branch
(909) 234-9321 — [email protected]

Malik Freeman
Junior Prosecutor
San Andreas Judicial Branch
(909) 494-7867 — [email protected]

[Maximilian Fitzgerald]

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. Alistair Kon (Vespucci)
#24-CM-0078

A decision was reached in the above case on the 24th day of November, 2024.

Exhibit #1: Arrest Report - Alistair Vespucci, 01/APR/2024

The prosecution is correct in their statement that because the individual was wearing the mask at the time of the alleged crime, it would make it an illegal item. The same applies to lockpicks potential use in an alleged burglary.

Therefore Exhibit #1 will remain unsuppressed.

---

Exhibit #2: Witness Statement - Police Lieutenant Jonathan Willowick

The defense correctly argues that this statement comes across as expert testimony. While expert testimony is admissible when it aids the court in understanding evidence or determining a fact in issue, this particular statement fails to meet that standard. Lieutenant Willowick's statement does not provide specific analysis or conclusions tied to the facts of this case. Instead, it offers generalizations about criminal behavior that lack direct relevance to the defendant or the circumstances of the incident.

Therefore, Exhibit #2 is suppressed due to its lack of relevance.

---

Exhibit #5: MDC record - Alistair Kon

The prosecution is correct with the timeframe, anything after the filing of the case is irrelevant and would not have any kind of consideration for the case. We also need to keep in mind the timeframe in which this case took to get to activation, the dates on the MDC records are within an adequate timeframe of the contested charge, and the timeframe between then and now is not a factor.

The court will rule that this exhibit will remain unsuppressed, but this will not come without conditions. This exhibit can not be used to show a person's bad character or propensity to commit the alleged crimes, as that would be prejudicial. This exhibit may only be used to argue Intent, Method, and/or Motive with relevance to the case. During arguments at trial, I will keep in mind the prejudicial vs probative value of this exhibit and relevant arguments tied to it.

---

The court will now be awaiting any response from the prosecution on the defence's motion for discovery.

Respectfully,


Superior Court Judge
San Andreas Judicial Branch
☎ 1-000-000
✉ [email protected]

[Terence Williams]

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. Alistair Kon (Vespucci)
#24-CM-0078

A Motion to Suppress was filed in the above case on the 24th of November, 2024.

The State of San Andreas, by and through the undersigned attorney, filed this Motion to Suppress, and requests to following be suppressed from evidence;

• Exhibit #6: Store Inventory of Bobby Pins
  Requested Evidence to Suppress:

  The Defense is in possession of photographic evidence depicting how bobby pins appear in the inventory display of the store where the defendant allegedly purchased the items in question. This image is submitted to establish that the items found in the defendant’s possession were bobby pins and not lockpicks, as alleged by the prosecution. The attached photograph demonstrates the visual characteristics of bobby pins as listed and sold in the store inventory, which is material to the defense’s argument that no criminal intent was involved in the defendant’s possession of these items.
  
  The purpose of the discovery is as follows:
  
  The photographic evidence clarifies the appearance of bobby pins in their intended commercial context, supporting the claim that the defendant purchased these items for lawful use.
  The Defense contends that the arresting officers misidentified the bobby pins as lockpicks. This evidence is critical in demonstrating the absence of any tools specifically designed for illegal lockpicking activities.
  Submitting this evidence ensures transparency and allows the Court to make a fully informed determination regarding the matter.
  

  • Detailed Reasoning: The Defense's discovery, which is incorrectly labeled as it it the Defense's first exhibit and not their sixth, is more prejudicial than probative. The Defense is testifying throughout the entire exhibit, making statements as to the defendant's intentions and motive, which should be reserved for trial and not discovery so as to not sway the judge's perception of the defendant's guilt before trial. The entire statement in the exhibit has no place being part of discovery, as arguments of the nature presented by the Defense should be presented during trial. If the Defense wants to testify and provide a statement to the court, they can get the defendant to provide a witness statement.
    ((Additionally, the "misidentification" of bobby pins as lock picks is nonsensical, as it is the same item.))

Terence Williams
Attorney General
San Andreas Judicial Branch
(909) 234-9321 — [email protected]

Malik Freeman
Junior Prosecutor
San Andreas Judicial Branch
(909) 494-7867 — [email protected]

[Clara Lopez]

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

---

REBUTTAL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Alistair Kon (Vespucci)
#24-CM-0078

A Rebuttal was filed in the above case on the 25th of November, 2024.

The Defendant, Alistair Kon, by and through the undersigned attorney, presents a rebuttal to the recent motion;

The Prosecution’s claim that “The Defense’s discovery, which is incorrectly labeled as it is the Defense’s first exhibit and not their sixth,” holds no relevance to the present motion and serves no purpose other than an attempt to inject unnecessary criticism into these proceedings. The numerical labeling of the exhibit does not affect its validity, probative value, or admissibility. This is a trivial point that detracts from the substantive arguments before the Court.

The Defense objects to the Prosecution’s Motion to Suppress on the following grounds:

• The photographic evidence in question is directly material to the Defense’s argument that the items found in the Defendant’s possession were bobby pins, not lockpicks. This distinction is crucial in determining whether any criminal intent existed. Suppressing this evidence would deny the Court the ability to consider relevant and objective material that supports the Defendant’s claim of lawful behavior.
• The Prosecution’s assertion that the Defense is “testifying” through this exhibit misunderstands the purpose of discovery. The exhibit provides a factual basis, a photographic depiction of a store inventory listing bobby pins, to clarify the commercial context of the items in question. This does not constitute testimony but rather serves as a foundational piece of evidence to challenge the Prosecution’s allegations. It is within the Court’s discretion to weigh the probative value of this evidence at trial, but it should not be excluded at this stage.
• The Prosecution’s argument that this evidence is “more prejudicial than probative” is unfounded. The photograph is a neutral, factual representation of an inventory display and does not inherently sway the Court in favor of either party. Its purpose is to illustrate an objective fact, not to introduce prejudicial characterizations or assumptions. The Defense has not engaged in any attempt to improperly influence the Court’s perception of the Defendant’s guilt or innocence.
• Suppressing this evidence would unfairly hinder the Defense’s ability to present a complete and robust argument in favor of the Defendant. The Prosecution’s Motion to Suppress seeks to limit the Defense’s case by prematurely excluding evidence that is vital to the core of the argument. This would constitute a denial of due process and the Defendant’s right to a fair trial.

For these reasons, the Defense respectfully requests that the Court deny the Prosecution’s Motion to Suppress and allow Exhibit #6 to remain as part of the evidence presented in this case. The exhibit is both relevant and admissible, and its inclusion ensures a transparent and fair judicial process.

((Saying that bobby pins and lock picks are the same item is not true. You can buy a bobby pin from the store and use them as a lock pick. Or you can find a criminal NPC around the map and actually buy a lock pick illegally. While the bobby pin shows up as a lock pick in our inventory it should not take away from the fact that ICly the defendant bought a bobby pin from the store and such will look like a bobby pin once found on the person.))

Respectfully,

Public Defender
San Andreas Judicial Branch
(909) 495-1265 — [email protected]

[Maximilian Fitzgerald]

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. Alistair Kon (Vespucci)
#24-CM-0078

A decision was reached in the above case on the 25th day of November, 2024.

Exhibit #6: Store Inventory of Bobby Pins

The defence should not be testifying in the way they did accompanying this exhibit. As a result, the text accompanying the exhibit is not regarded as part of discovery, these arguments should be saved for court.

The image may remain due to it's potential relevance to the case as Exhibit #3: Witness Statement - Police Officer III Matteo Ellis already establishes that the defendant made claim as to the potential source of the items found on his person.

(( I have consulted with senior staff, and it is established that bobby pins and lockpicks are treated as identical items once in inventory, as there is no way to distinguish their source. To promote engaging roleplay, I will allow the argument that the items were purchased as bobby pins. However, this does not override the IC understanding that bobby pins are commonly repurposed as lockpicks. ))

---

The court will now afford both sides a maximum of 3 days for any further motions before we move forward with the case.


Respectfully,


Superior Court Judge
San Andreas Judicial Branch
☎ 1-000-000
✉ [email protected]

[Maximilian Fitzgerald]

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. Alistair Kon (Vespucci)
#24-CM-0078

An attempt to schedule was made and recorded by the court on 30th of November, 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. When the scheduling tool has been completed by either party, please post on the docket stating as such.

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 continue to attempt to schedule the proceeding or seek alternative avenues to conclude the case.

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.


Respectfully,


Superior Court Judge
San Andreas Judicial Branch
☎ 1-000-000
✉ [email protected]

[Clara Lopez]

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

---

WITNESS LIST

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Alistiar Kon
#24-CM-0078

A Witness List was filed in the above case on the 1st of December, 2024.

• The defense designates the following list of individuals as witnesses, who may be called to the stand.
  
  Name of Witness:
  Alistair Kon
  Description: (party, fact witness, expert, other)
  Defendant
  Witness Agency:
  N/A
  
  
  Name of Witness:
  Olivia Vespucci
  Description: (party, fact witness, expert, other)
  Defendants Wife
  Witness Agency:
  N/A

Respectfully,

Public Defender
San Andreas Judicial Branch
(909) 495-1265 — [email protected]

[Maximilian Fitzgerald]

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. Alistair Kon (Vespucci)
#24-CM-0078

A trial date was set on the above case on 03rd of December, 2024.

In accordance with the availability reported by both parties in response to the Notice of Scheduling, this trial shall take place at 19:00 PM on 14th of December, 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 cancellation 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
San Andreas Judicial Branch
☎ 1-000-000
✉ [email protected]