#24-CM-0084 State of San Andreas v. Ed Timpson & Dave Ward

[Ed Timpson]

Defendant Name: Ed Timpson, Dave Ward, Leo Marks & Gen Marks
Defendant Phone: 527-9966
Defendant Address:
(( Defendant Discord: NeillWilliamson ))
Requested Attorney:

Charging Department: Los Santos Sheriffs Department

Date & Time of Incident(s): 02/05/2024
Charge(s):

• Will need to recheck but disputing the murder charge as all 4 charged with murder of the same individual. Due to time running out, filing this in a rush for the courts.

Narrative:
We wish to dispute the charges against us

---

I, Ed Timpson, 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"

---

• To whom it may concern,
  
  Your submission to the Superior Court of San Andreas has been received. It is currently unclear whether only the petitioner (Ed Timpson) would like to dispute the charges or if all those named within the submission document (Dave Ward, Leo Marks & Gen Marks) wish to dispute the charges as outlined in this initial posting.
  
  All those disputing charges will be required to reply to this message with a government website account of their own by filling out the following form provided below. The form will offer another opportunity to provide a narrative if needed and contains the required affirmation that the specified individual wishes to be a co-defendant of the case.
  Live Form

  
  

  Defendant Name: Firstname Lastname
  Defendant Phone: ###-####
  Defendant Address: HERE
  (( Defendant Discord: HERE ))

  

  Supplementary Narrative:
  HERE
  
  
  

  ---

  I, Firstname Lastname, 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 I intend to be included as a co-defendant as indicated in the initial case submission. (( I affirm that all information submitted has been obtained via In-Character means. ))
  Formatting

  Code: Select all

  [img]https://i.imgur.com/hq6d7UW.png[/img]
  [img]https://i.imgur.com/6h9z9Jh.png[/img]
  [divbox=antiquewhite]
  [b]Defendant Name:[/b] Firstname Lastname
  [b]Defendant Phone:[/b] ###-####
  [b]Defendant Address:[/b] HERE
  [b][color=#0040FF](([/color] Defendant Discord:[/b] HERE [color=#0040FF][b]))[/b][/color]
  [/divbox]
  
  [img]https://i.imgur.com/wjDADzN.png[/img]
  [divbox=antiquewhite]
  [b]Supplementary Narrative:[/b]
  HERE
  
  
  
  [hr][/hr]
  I, [b]Firstname Lastname[/b], 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 I intend to be included as a co-defendant as indicated in the initial case submission. [b][color=#0000FF](([/color][/b] I affirm that all information submitted has been obtained via In-Character means. [b][color=#0000FF]))[/color][/b]
  [/divbox]

  As will be indicated in the future Notice of Receipt: the defendants are further encouraged to speak with an authorized individual at Rockford Hills City Hall, Mission Row Police Station, or Paleto Bay Sheriff's Office for official clarification on the specific charges received and their respective date and times, as once the case has been activated, any omitted charges will be considered abandoned and unable to be disputed within this case.
  
  Respectfully,
  
  
  Superior Court Judge
  San Andreas Judicial Branch
  (909) 553-8869 — [email protected]

[Dave Ward03]

Defendant Name: Dave Ward
Defendant Phone: 431-4962
Defendant Address: N/A
(( Defendant Discord: CheekyMunky ))

Supplementary Narrative:
I wish to dispute the charges against me

---

I, Dave Ward, 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 I intend to be included as a co-defendant as indicated in the initial case submission. (( 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. Ed Timpson et al. (Dave Ward)
The court has hereby received and acknowledged the above case on the 13th of May, 2024.

The Superior Court of San Andreas has received your filing and the case is now pending activation. The other mentioned defendants were provided ample time to express their desire to appear as co-defendants and only one did so. With that in mind, this case will be heard of State v. Timpson et al. (Ward). 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.



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

[Maximilian Fitzgerald]

San Andreas Judicial Branch

"EQUAL JUSTICE UNDER LAW"

---

• Esteemed Mr. Timpson & Mr. Ward,
  
  Prior to activation, can you please confirm that the charge(s) you are disputing are as follows:
  • Mr. Timpson - SF02 Murder of a Gov. Employee - 03/MAY/2024 00:03
  • Mr. Ward - SF02 Murder of a Gov. Employee - 02/MAY/2024 23:58
  With the Highest Regard,
  
  
  Superior Court Judge
  San Andreas Judicial Branch
  ☎ 1-000-000
  ✉ [email protected]

[Ed Timpson]

I confirm that I wish to dispute the charge: SF02 Murder of a Gov. Employee - 03/MAY/2024 00:03

[Dave Ward03]

I can confirm that I wish to dispute the charge: SF02 Murder of a Gov. Employee - 02/MAY/2024 23:58

[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. Ed Timpson & Dave Ward
#24-CM-0084

A Notice of Activation was entered in the above case on 03rd of December, 2024.

The case of the State of San Andreas v. Ed Timpson & Dave Ward is hereby activated by this Court under #24-CM-0084.

Both the State and Defendant in this case are still awaiting adequate representation. At this time the court will delay the Order for Discovery until adequate representation has been assigned for the Defendant and a State Prosecutor has been assigned to the case and both parties 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]

[Michael Blaise]

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. Ed Timpson & Dave Ward
#24-CM-0084

A Notification of Counsel was filed in the above case on the 3rd of December, 2024.

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

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



Lead Prosecutor
San Andreas Judicial Branch
552-8150 — [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. Ed Timpson & Dave Ward
#24-CM-0084

A Notification of Counsel was filed in the above case on the 4th of December, 2024.

I, Malik Freeman, a Prosecutor 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.



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"

---

NOTIFICATION OF COUNSEL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Ed Timpson & Dave Ward


A Notification of Counsel was filed in the above case on the 5th of December 2024

I,Clara Lopez, a Public Defender with the San Andreas Judicial Branch, will be representing the defendant, Ed Timpson & Dave Ward 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. Ed Timpson & Dave Ward
#24-CM-0084

A court order was entered in the above case on 05 of December, 2024.

The case of #23-CM-0084, State of San Andreas v. Ed Timpson & Dave Ward 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]

[Michael Blaise]

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. Ed Timpson & Dave Ward
#24-CM-0084

A Motion for Discovery was filed in the above case on the 5th of December, 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: Recovered Bodycam

  Recovered_Bodycam.mp4
  
  Exhibit #2: Cpt. Reno Dashcam

  
  
  
  Exhibit #3: Helicam

  
  
  
  
  
  Exhibit #4: Arrest Report - Leo Marks

  

  

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

  
  

  ---

  MUGSHOT

  • SUSPECT DETAILS
    • 
      Full Name: Leo Marks
      Phone Number: 5221857
      Licenses Suspended: Yes
      Officers Involved:
      • Police Officer II Charles Williams
      • Police Cadet Engjell Trey
      • Police Sergeant II Joseph Sanchez
      • Police Lieutenant II Elise Cavallera
      • Police Lieutenant I Samuel Martin
      Charges:
      • WM02 - Possession of a Class 1 Firearm
      • VF01 - Evading an Officer
      • GM19 - Face Concealment (b)
      • WF02 - Shooting from a Vehicle (Drive-By) of a Gov. Employee
      • VF04 - Felony Public Endangerment
      • SF02 - Murder of a Gov. Employee
    INCIDENT NARRATIVE
    • Incident Date: 03/MAY/2024
      
      Explain what happened, sufficient detail must be given to justify the placed charges, videos could be provided.
      • The Sheriffs Department requested the Los Santos Police Department to join JTAC 1 as it was a Code 1 situation of shots being fired at Sheriff Deputies. The situation stemmed from a vehicle being pulled over as it was believed to be potentially stolen. As the Sheriff Deputy called for backup on a 10-66, there were shots fired from the vehicle at the Deputy, killing them right there and then. A pursuit carried out and multiple units arrived on scene, very quickly. Officer Williams and Cadet Engjell Trey were the closest unit to the vehicle when it TC'd and both suspects exited. They had firearms withdrawn and there was a call from the highest ranking officers from both departments to open fire. Once suspect was shot a few too many times and ended up being deceased, whereas the other was Leo Marks and he was saved on scene by Officer Williams' BLS treatment and a fast response from the medical department. Once the suspect was stable, they were transported to upper pillbox and then to the Department of Corrections by Officer Williams and his ADAM partner Cadet Engjell Trey. The two officers processed him and suspended his drivers and truckers licenses. All charges apart from Possession of a Class 1 Firearm (placed by Officer Charles Williams) were placed by Noah Carlisle from the Sheriff's Department.
    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: Pistol .50
        Exhibit B: Black Skeletal Mask
        
        
        Legal Possessions:
        Exhibit A: Black Gloves
        Exhibit B: Empty Water
        Exhibit C: Knife
        Exhibit D: Black Tucked T-Shirt
        Exhibit E: Consaw
        Exhibit F: Wrench
        Exhibit G: Lug Wrench
        Exhibit H: Black Saggy Beanie
        Exhibit I: Radio
        Exhibit J: Screwdriver
        
        
        Photograph of Possessions (MANDATORY)

        

  
  
  Exhibit #5: Arrest Report - Dave Ward

  

  ARREST REPORT
  

  MUGSHOT

  SUSPECT 1 DETAILS

  • 
    Full Name: Dave Ward
    Telephone Number: 4314962
    Licenses Revoked: Yes
    • Driver
    • Trucker
    Charges:
    • WM02 - Possession of a Class 1 Firearm
    • WM03 - Criminal Use of Weapon Modifications
    • GC04 - Face Concealment
    • VF01 - Evading an Officer
    • VF04 - Felony Public Endangerment
    • WF02 - Shooting from a Vehicle (Drive of a Gov. employee
    • WF01 - Assault with a Deadly Weapon of a Gov. employee
    • SF02 - Murder of a Gov. employee
    Additional Details (Suspect's vehicle, etc.) :

  VEHICLES INVOLVED

  DEPUTY DETAILS

  • Full Name: Leif Helgarson
    Badge Number: 25920
    Callsign: 2-D-22

  INCIDENT DETAILS

  • Date of Arrest: 2024-05-02
    Deputies Involved: Noah Carlile, Wiley Reno, Jett Jones, Trixie Bankshot, Martin Haswell, Multiple PD units
    
    Provide details of the incident leading up to the arrest
    • A deputy called out a 10-66 for a stolen vehicle. ALPHA was overhead but before ground units could respond two kamachos opened fire and killed the deputy. ALPHA was able to keep eyes on both vehicles until ground units could intercept. Both vehicles opened fire and one was disabled with one occupant dying on scene.
      
      My unit intercepted the second vehicle and exchanged gunfire with the occupants neutralizing all three. I took charge of one and BLSd and identified him as Dave Ward. He had an illegal .50 that had been recently fired on his person and it was suppressed.

  EVIDENCE DETAILS

  • Location of Evidence Locker: Sandy Station
    Exhibit A: .50 Pistol 1711429222452
    Exhibit B: Suppressor
    
    Photo of the evidence in the locker (if applicable)

    

    ---

  ARRESTING DEPUTY SIGNATURE
  Leif Helgarson
  

  ---

  
  
  Exhibit #6: Arrest Report - Gen Marks

  

  ARREST REPORT
  

  MUGSHOT

  SUSPECT 1 DETAILS

  • 
    Full Name: Gen Marks
    Telephone Number: 4021250
    Licenses Revoked: Yes
    • Driver
    • Trucker
    Charges:
    • VF01 - Evading an Officer
    • SF02 - Murder of a Gov. employee
    • GM19 - Face Concealment (b)
    • VF04 - Felony Public Endangerment
    • WF02 - Shooting from a Vehicle (Drive of a Gov. employee
    • WF01 - Assault with a Deadly Weapon of a Gov. employee
    • WM02 - Possession of a Class 1 Firearm
    • WM03 - Criminal Use of Weapon Modifications
    Additional Details (Suspect's vehicle, etc.) :

  VEHICLES INVOLVED

  • Vehicle A: Black kamacho

  DEPUTY DETAILS

  • Full Name: Trixie Bankshot
    Badge Number: 20598
    Callsign: 2-d-37

  INCIDENT DETAILS

  • Date of Arrest: 2024-05-02
    Deputies Involved: Noah Carlile, Wiley Reno, Jett Jones, Lief Helgarson, Martin Haswell, Multiple PD units
    
    Provide details of the incident leading up to the arrest
    • A deputy called out a 10-66 for a stolen vehicle. A kamacho rammed his car and opened fire and killed the deputy. Ground units intercepted and chased- both vehicles opened fire.
      We intercepted the second vehicle and exchanged gunfire, neutralizing all three targets. I took charge of Gen Marks and BLSed her, removed her mask and took care of getting her to DOC. She was given blanket charges and firearm charges.

  EVIDENCE DETAILS

  • Location of Evidence Locker: Sandy Station
    Exhibit A: .50 Pistol Serial 1679670436062
    Exhibit B: mask
    Exhibit C: supressor
    Exhibit D:
    
    Photo of the evidence in the locker (if applicable)

    

    ---

  ARRESTING DEPUTY SIGNATURE
  Trixie Bankshot
  

  ---

  
  
  SUPPRESSED - Exhibit #7: Officer Witness Statement - Commander Noah Carlile

  

  

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

  Case Information

  • Case Number: [UNKNOWN]
    Incident Date: [03/MAY/2024]

  Witness Information

  • Name: Noah Carlile
    Date of Birth: [04/APR/1990]
    Phone Number: [465-3333]
    Occupation: Command, Sheriff's Department

  Witness Statement

  • As per listed in both arrest reports provided and available, I stand by the statements and summaries made by Trixie Bankshot and Leif Helgarson. All charges placed were in accordance to on-scene witnesses and were correlated with person-by-person investigation after reviewing both body cameras and witnessed events.

  Witness Affirmation

  • I, Noah Carlile, 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,
    
    Noah Carlile
    Commander, Countywide Operations
    Sheriff's Department
    
    Date: 21/MAY/2024

  
  
  Exhibit #8: Officer Witness Statement - Captain Wiley Reno

  

  

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

  Case Information

  • Case Number: UNACTIVATED
    Incident Date: 02/05/2024

  Witness Information

  • Name: Wiley Reno
    Date of Birth: 23/MAY/1991
    Phone Number: 51997706
    Occupation: Sheriff's Captain

  Witness Statement

  • While getting ready for duty at Sandy Station, I heard a radio call come in from a deputy about a reported stolen vehicle near him. I did not head that way immediately as I assumed other units were on their way. Moments later I heard the deputy calling shots fired on his location and stating that he had been rammed by a Kamacho. I deployed a Kamacho from Sandy Station and headed to Senora FWY.
    
    While heading that way, I spotted two black Kamachos coming my way and turned around. One of the Kamachos was three times occupied and one of them was twice occupied. I attempted to maneuver to slow them down heavily, a maneuver I was initially successful in. I then tried making maneuvers to attempt to push the vehicles off the road as they were not yielding to my lights and sirens. At this point, passengers in the vehicle began opening fire on my Kamacho. Both kamachos had passengers who were firing upon my sheriff's kamacho.
    
    Although I was successful initially with slowing them down, the vehicles quickly pulled away as I had lost all my tires.
    
    After a long attempt at getting to the pursuit line, I eventually arrived at an already concluded scene on Mount Han Road. At this scene, I spotted a dead suspect on the side of the road as well as an injured Mr. Leo Marks. Officers gave me a brief run down of the scene and I helped move the scene on to Pillbox.

  Witness Affirmation

  • I, Wiley Reno, 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,
    
    
    Wiley Reno
    Captain
    Los Santos County Sheriff's Department
    
    Date: 23/MAY/2024

  
  Exhibit #9: Officer Witness Statement - Commander Noah Carlile

  

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

  Case Information

  • Case Number: [UNKNOWN]
    Incident Date: [03/MAY/2024]

  Witness Information

  • Name: Noah Carlile
    Date of Birth: [04/APR/1990]
    Phone Number: [465-3333]
    Occupation: Command, Sheriff's Department

  Witness Statement

  • • Please recount the events from the start of your involvement to the conclusion of your involvement from your perspective and only your perspective.
      
      My involvement began when we received the devastating news that a deputy had been killed on sight after conducting a 10-66 on a stolen car. The scene was chaotic, and emotions were high as we realized the severity of the situation. The deputy's bodycam footage became a critical piece of evidence. It clearly showed a kamacho along with the stolen car, which provided us with vital leads.
      
      In response, we initiated a radio TAC scene to coordinate our efforts. Our team quickly divided into two units to manage the emerging situations more effectively. As a member of the air unit, my primary responsibility was to keep both the kamacho and the stolen car in visual contact from the helicopter. This aerial surveillance was crucial in maintaining situational awareness and guiding ground units to the suspects' locations.
      
      Our helicopter maintained a continuous visual on both vehicles, relaying real-time updates to the ground units. This ensured that we never lost track of the suspects, and it provided the ground units with the necessary information to strategize their approach.
      
      My TAC was specifically tasked with handling the situation involving the kamacho, which was occupied by three individuals identified as responsible for shooting the deputy. We tracked the kamacho as it made its way into the city, a high-speed pursuit that kept everyone on edge. The suspects showed no signs of surrendering, continuing to shoot from the vehicle as they drove through the city streets.
      
      The chase reached a critical point when the kamacho crashed. The occupants immediately exited the vehicle, except for the driver, and began firing at law enforcement officers. This led to a tense and dangerous firefight. Our ground units responded with precision and control, returning fire and injuring all of the armed suspects.
      
      Once the immediate threat was neutralized, our ground units moved in to secure the scene. They provided Basic Life Support (BLS) to the injured suspects, ensuring they were stable enough to be taken into custody. The suspects were then cuffed, frisked, and thoroughly searched for any additional weapons or evidence. All items relevant to the investigation were carefully collected and documented.
      
      With the suspects under control and the scene secured, my next task was to ensure that all actions taken were accurately recorded and that the charges were correctly applied. I coordinated a round-robin review with other law enforcement officers who had been involved in the apprehension of the suspects. This involved reviewing the body camera footage and comparing notes with the officers who had direct contact with the suspects.
      
      During this process, we meticulously went through each charge, reading them back to the respective deputies or officers for confirmation. This step was crucial to ensure that the charges matched the suspects' actions and the evidence collected. It also helped to cross-verify the information, leaving no room for error in the documentation process.
      
      This thorough and methodical approach ensured that all suspects were correctly charged and that the case was solidly built. By the time we wrapped up the operation, we had a clear and comprehensive understanding of the events, the suspects' actions, and the evidence supporting their prosecution.
      
      In conclusion, my involvement in this operation was extensive and multifaceted, from aerial surveillance and tracking to coordinating the ground response and ensuring accurate documentation of charges. The combined efforts of our air and ground units were instrumental in bringing the situation to a controlled and just resolution, marking the end of my involvement in this critical incident.
    • Were you or any members of your unit shot at in this situation?
      
      This situation was 3 weeks ago, I cannot remember if they directly shot at us. All I can remember is that there was shots going into the vehicle in response to them crashing at the end of the pursuit.
    • Please make a statement as to why, from your perspective, the charges of VF01 - Evading an Officer, VF04 - Felony Public Endangerment, WF01 - Assault with a Deadly Weapon, WF02 - Shooting from a Vehicle (Drive-By). If you do not have information from your particular perspective for any of the charges, please just say so.
      
      Evading: They evaded law enforcement. Sirens on.
      
      Assault with a Deadly Weapon: A vehicle was used in form of assault, attempting to injure a unit on scene - I believe that charge was suggested by Captain Reno but cannot recall if it was for the initial ramming of the now-deceased deputy or if the vehicle was used as weapon in a later scene.
      
      FPE: Reckless driving in the city that would conclude a felony weight added to it. Hitting curbs, nearly hitting civilians, and shooting around populated areas.
      
      Drive-by: Barrels were warm, multiple on-scene witnesses that more than one gun was shooting and the auditory differentiating of multiple weapons at the same time was clear.

  Witness Affirmation

  • I, Noah Carlile, 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,
    
    Noah Carlile
    Commander, Countywide Operations
    Sheriff's Department
    
    Date: 25/MAY/2024

  
  Exhibit #10: Officer Witness Statement - Sergeant Leif Helgarson

  

  

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

  Case Information

  • Case Number: [Case Number]
    Incident Date: 2nd/May/2024

  Witness Information

  • Name: Leif Helgarson
    Date of Birth: 18/February/2000
    Phone Number: 446-5567
    Occupation: Sergeant LSSD

  Witness Statement

  • On the day in question a deputy made a standard radio callout for a 10-66 (felony traffic stop) for a reported stolen vehicle. ALPHA was overhead but before ground units could respond the deputy on scene reported two kamacho's approaching and that he was rammed. He then relayed shots fired and hit his panic button on his radio. ALPHA was overhead and watched the scene unfold and relayed to us that the deputy was unfortunately killed. ALPHA was able to keep eyes on both kamacho's as they fled the scene. One I was not involved with but it was called out over radio that it had crashed and gunfire was exchanged with one of the occupants unfortunately dying on scene while the other was taken into PD custody.
    
    My unit intercepted the second vehicle and exchanged gunfire with the vehicles occupants, Eventually occupants neutralizing all three with the assistance of other units on scene.. I personally took charge for one injured 10-15 and BLS'D him before identifying him as Dave Ward. The suppressed .50 found on his person was still hot from being recently fired. I personally charged him for the firearm and its illegal modification while all other charges were placed by the Commander of the TAC.

  Witness Affirmation

  • I, Leif Helgarson, 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,
    
    Leif Helgarson
    Leif Helgarson
    Sergeant
    Los Santos County Sheriffs Department
    
    Date: 24/May/2024

  
  Exhibit #11: Officer Witness Statement - Sergeant Jett Jones

  

  

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

  Case Information

  • Case Number: [Case Number]
    Incident Date: [XXXXXX]

  Witness Information

  • Name: Jett Jones
    Date of Birth: 01/AUG/1999
    Phone Number: 361-2422
    Occupation: Sergeant, Los Santos Sheriff's Department

  Witness Statement

  • I had limited involvement in this situation.
    From what I do recall, a late deputy had attempted to pull over a vehicle and called in a code-1 over the radio before going unresponsive. I remember pulling up to the scene down in the city in the industrial area near popular street where all the suspects from a kamacho were neutralized. I did not witness anything occur personally. I was simply there to provide scene support and keep Weazel News and the public a safe distance from the shooting.
    Because I was not physically present during the ambush on the fallen Deputy nor the shooting near popular street, I was not shot at myself.

  Witness Affirmation

  • I, Jett Jones, 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,
    
    Jett Jones
    Sergeant
    Los Santos Sheriff's Department
    
    Date: 25/MAY/2024

  
  
  SUPPRESSED - Exhibit #12: Officer Witness Statement - Master Deputy Trixie Bankshot

  

  

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

  Case Information

  • Case Number: I am unsure if it has a number yet
    Incident Date: 02/05/2024

  Witness Information

  • Name: Trixie Bankshot
    Date of Birth: 03/June/1991
    Phone Number: 597-3823
    Occupation: Master Deputy at the Sheriff's Department

  Witness Statement

  • I only vaguely recall this incident.
    
    I left Sandy Station in SED gear when a fellow deputy called out a 10-66, then shouted he was being rammed before transmission went silent. I know the chase was called into JTAC as a code 1.
    
    I do not think I was shot as I was several vehicles behind in the pursuit line. I remember firing on the vehicle but do not remember who I was in a unit with that day.
    
    I recall this being a 'blanket charge' situation.
    In my perspective the evading charge came because they were all actively fleeing us.
    The felony public endangerment came because they were actively shooting at officers as they fled in the city.
    The assault with a deadly weapon came from ramming the initial deputy's vehicle with their car.
    The drive-by came from shooting out the window of their car.
    
    
    I remember arresting Gen and BLSing her but I do not remember anything else about that day, including where it ended.
    
    I apologize, all my body cam footage gets erased after a week to keep my drives running smoothly.
    
    I do know this is not at all unlike Lost MC and they most often have guns and some anti-cop agenda. They were behind the kidnapping, torture and mutilation of a deputy not long ago so our interactions usually end in violence against officer charges.

  Witness Affirmation

  • I, Trixie Bankshot, 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,
    
    
    Trixie Bankshot
    Master Deputy
    LSSD
    
    Date: 23/May/2024

  
  
  
  Hope I could help!
  -Trixie
  

---

Lead Prosecutor
San Andreas Judicial Branch
(909) 552-8150 — [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. Ed Timpson & Dave Ward

A Notification of Counsel was filed in the above case on the 7th of December, 2024.

I, Bruce Tubby, a Junior Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendants, Ed Timpson & Dave Ward 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]

[Bruce Tubby]

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

---

MOTION FOR CONTINUANCE

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Ed Timpson & Dave Ward
#24-CM-0084

A Motion for Continuance was filed in the above case on the 8th of December, 2024.

The Defendant, name, by and through the undersigned attorney, filed this Motion for Continuance, and the reasoning for request is as follows;

• Reasoning: Time to get familiar with the case.
  • Detailed Explanation: The defence is asking for a 72 Hour Continuance to get familiar with the case and review the evidence submitted due to only having signed on as co-counsel on the 7th of December.

Junior Public Defender
San Andreas Judicial Branch
(909) 494-8268 — [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. Ed Timpson & Dave Ward
#24-CM-0084

A decision was reached in the above case on the 8th day of December, 2024.

Given the large amount of exhibits and new co-counsel, I will be accepting the motion of continuance. You have 72 hours from this decision to submit further motions.


Respectfully,


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"

---

MOTION TO SUPPRESS

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Ed Timpson & Dave Ward
#24-CM-0084

A Motion to Suppress was filed in the above case on the 10th of December, 2024.

The Defendants, Ed Timpson & Dave Ward, by and through the undersigned attorney, filed this Motion to Suppress, and requests the following be suppressed from evidence;

• Exhibit #4: Arrest Report - Leo Marks, LSPD
  Requested Evidence to Suppress:

  Entire Exhibit

  • Detailed Reasoning: Lack of Relevance, This arrest report is for Leo Marks, and neither defendants are mentioned within the report.

• Exhibit #6: Arrest Report - Gen Marks, LSSD
  Requested Evidence to Suppress:

  Entire Exhibit

  • Detailed Reasoning: Lack of Relevance, This arrest report is for Gen Marks, and neither defendants are mentioned within the report.

• Exhibit #7: Officer Witness Statement - Commander Noah Carlile
  Requested Evidence to Suppress:

  Entire Exhibit

  • Detailed Reasoning: This statement is more Prejudicial than Probative, No facts or evidence are provided within the witness statement; stating, "I stand by the statements and summaries made by Trixie Bankshot and Leif Helgarson.", is personal opinion and offers nothing of value to the case in question, only to add more weight to arrest reports.

• Exhibit #11: Officer Witness Statement - Sergeant Jett Jones
  Requested Evidence to Suppress:

  Entire Exhibit

  • Detailed Reasoning: This witness statement does not follow the correct format, instead of the incident date it just states [XXXXXX]. A precedence was set by Judge Daniels in case #22-CM-0036, State of San Andreas v. Hailee Joyce
    Precedence

    "Exhibit 3: Witness Statement - Luca Andollini however will not be allowed as it uses the incorrect witness format without the witness affirmation at the bottom. This ruling will set precedent that any testimony or witness statement must have the affirmation to be admissible in court."

• Exhibit #12: Officer Witness Statement - Master Deputy Trixie Bankshot
  Requested Evidence to Suppress:

  Entire Exhibit

  • Detailed Reasoning: This witness statement is speculation and hearsay, Master Deputy Bankshot states that, "I only vaguely recall this incident. and I remember arresting Gen and BLSing her but I do not remember anything else about that day, including where it ended.. Due to these statements, this whole statement becomes personal opinion/speculation and cannot be an accurate representation of what occured at the time.

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

[Michael Blaise]

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. Ed Timpson & Dave Ward
#24-CM-0084

A Rebuttal was filed in the above case on the 12th of December, 2024.

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

• Regarding Exhibits 4 and 6:
  
  The defense contends that Exhibits 4 and 6 lack relevance on the grounds that they are not arrest reports directly pertaining to the defendants. However, this argument misunderstands the purpose and probative value of these exhibits.
  
  Exhibits 4 and 6 are arrest reports documenting arrests of individuals who were involved in the incident in question and shared affiliations with the defendant. These reports provide critical context to the defendants' actions and behavior leading up to the arrest. Specifically, they help establish the broader framework of criminal activity within the same group and setting, thereby supporting the prosecution's theory of motive and intent.
  
  The relevance of these exhibits lies in their ability to show the circumstances surrounding the defendant's arrest. To dismiss such evidence solely because it does not directly pertain to the defendant would be to ignore its evidentiary value in providing context and corroborating the prosecution's case.
  
  Accordingly, the State respectfully asserts that Exhibits 4 and 6 should not be suppressed and should be admitted as evidence.

• Regarding Exhibit 7:
  
  The defense argues that Exhibit 7 is more prejudicial than probative, stating that it only offers "personal opinion and offers nothing of value to the case in question, only to add more weight to arrest reports." In their own words, the defense has described the exhibit's value: It is a statement from an on-scene officer that serves to corroborate the other exhibits, adding weight to them, as the defense acknowledges. While the defense may characterize this as "personal opinion," it is, in fact, a professional evaluation from a senior officer grounded in the review of evidence, including body camera footage and on-scene observations.
  
  Additionally, the potential for prejudice is minimal, as this statement merely reinforces existing evidence rather than introducing new allegations or independent conclusions. It aids in providing a comprehensive picture of the case without unduly influencing the judge.
  
  For these reasons, the State respectfully requests that the motion to suppress Exhibit #7 be denied.

• Regarding Exhibit 11:
  
  The defense references precedent set by Judge Daniels in case #22-CM-0036, correctly quoting:
  "Exhibit 3: Witness Statement - Luca Andollini however will not be allowed as it uses the incorrect witness format without the witness affirmation at the bottom. This ruling will set precedent that any testimony or witness statement must have the affirmation to be admissible in court."
  
  However, the defense has either misinterpreted or misapplied this precedent.
  
  A review of the Exhibit that established this precedent reveals that it involved a witness statement from Officer Luca Andollini, which was submitted on a format entirely outside the Court's Official Witness Statement Form and lacked the required witness affirmation statement. The precedent explicitly emphasizes the necessity of the witness affirmation statement for admissibility but does not address the absence of a date as grounds for exclusion.
  
  In the present matter, Exhibit 11 differs significantly. This statement is submitted on the Court's Official Witness Statement Form and contains a signed witness affirmation, fulfilling the core requirement established by Judge Daniels' precedent. While it is unfortunate that the document lacks a date at the top, this omission does not compromise its validity. Notably, the affirmation signature itself includes a date, further substantiating the document's reliability.
  
  Given these distinctions, the Prosecution asserts that Exhibit 11 adheres to admissibility standards, and as such, request that the motion to suppress regarding Exhibit 11 be denied.

• Regarding Exhibit 12:
  
  The Prosecution will not object to this piece of the defense's motion to suppress.

Lead Prosecutor
San Andreas Judicial Branch
(909) 552-8150 — [email protected]

[Bruce Tubby]

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. Ed Timpson & Dave Ward
#24-CM-0084

A Rebuttal was filed in the above case on the 12th of December, 2024.

The Defendants, Ed Timpson & Dave Ward, by and through the undersigned attorney, hereby submits this reply to the Prosecution’s response regarding the Motion to Suppress filed on the 12th of December, 2024. For the reasons set forth below, the Motion to Suppress should be granted.

• Regarding Exhibits 4 and 6:
  
  The Prosecution's claim that, "These reports provide critical context to the defendants' actions and behavior leading up to the arrest.", but nowhere in these arrest reports are the defendants mentioned, nor is there any context with regards to the charges being disputed, with relation to the defendants, with one arrest report lacking any quality and detail at all.
  
  Relevance is defined by "Evidence is considered relevant if it has any tendency to make a fact that is important to the case more or less probable than the fact would be without the evidence." The Defence would argue that firstly the arrest reports do not make the facts regarding this case more or less probable than it would be without the exhibits. Secondly there is a 'Best Evidence' argument; Why would the Prosecution provide arrest reports for other people when they can just provide the original arrest reports for both defendants?

• Regarding Exhibit 7:
  
  The Prosecution has grossly misunderstood the Defence's statement here; The Defence is stating that the Prosecution, by attempting to admit this Exhibit as evidence, is attempting to add more weight to the arrest reports and not that the Defence believes they do, as the Prosecution incorrectly assumed. In fact they change no facts within the arrest reports or witness statements, as stated by the Prosecution, "this statement merely reinforces existing evidence rather than introducing new allegations or independent conclusions", making it wholly irrelevant using the definition quoted above. Stating that this statement is not "personal opinion" is inferring that the Officer cannot be subject to human error or misjudgement and if this is a professional evaluation, which the Defence wholly disagrees with, then there is a lot of detail missing that would be expected of an evaluation.

• Regarding Exhibit 11:
  
  The Prosecution argues that this precedent is misused, suggesting it only pertains to the signing of statements. However, the Defence asserts that the integrity and completeness of a witness statement are needed for admissibility. The lack of an incident date compromises the document’s reliability and makes it difficult to exact the circumstances of the incident.

For the above reasons, the Defense respectfully requests that the court grant the Motion to Suppress Exhibits #4, #6, #7, and #11, as outlined in the original motion and supported by this reply. If the prosecution does not reply to this, we require no more say and are ready for a ruling on this suppression.


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

[Michael Blaise]

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

---

MOTION FOR CONTINUANCE

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Ed Timpson & Dave Ward
#24-CM-0084

A Motion for Continuance was filed in the above case on the 13th of December, 2024.

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


Reasoning: Retrieving Critical Evidence
Detailed Explanation: Due to a procedural error, the arrest report of Ed Timpson was not provided to the Prosecution. To ensure the Court has the complete context for ruling on the pending motion to suppress, the Prosecution respectfully requests a brief continuance of three days to obtain this crucial document. Once procured, the Prosecution seeks to have the motion to suppress considered in light of the additional context provided by the arrest report. Once this is provided, the prosecution will provide its final rebuttal to the motion.




Lead Prosecutor
San Andreas Judicial Branch
(909) 552-8150 — [email protected]

[Michael Blaise]

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

---

MOTION FOR VOLUNTARY DISMISSAL WITHOUT PREJUDICE

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Ed Timpson & Dave Ward
#24-CM-0084

A Motion for Voluntary Dismissal Without Prejudice was filed in the above case on the 16th of December, 2024.

The State of San Andreas by and through the undersigned attorney, filed this Motion for Voluntary Dismissal Without Prejudice, and the reasoning for the request is as follows;

• Reasoning: Lack of Arrest Report
  • Detailed Explanation: Due to the lack of an Arrest Report regarding Ed Timpson, the prosecution is submitting this motion to dismiss the case against Ed Timpson only. We will be moving forward with the case regarding Dave Ward.

Lead Prosecutor
San Andreas Judicial Branch
(909) 552-8150 — [email protected]

[Michael Blaise]

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

---

• Your Honor,
  
  The Prosecution believes its original arguments against the motion to suppress stand, and as such, will await the judge's ruling on both the motion to suppress and the motion for dismissal.
  
  Respectfully,
  
  
  Lead Prosecutor
  San Andreas Judicial Branch
  (909) 552-8150 — [email protected]

[Bruce Tubby]

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

---

• Your Honor,
  
  The Defence has no objections to the above dismissal.
  
  Respectfully,
  
  
  Junior Public Defender
  San Andreas Judicial Branch
  (909) 494-8268 — [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. Ed Timpson & Dave Ward
#24-CM-0084

A decision was reached in the above case on the 17th day of December, 2024.

The prosecution's Motion for Voluntary Dismissal without prejudice is hereby granted. The disputed charge of SF02 Murder of a Gov. Employee will be removed from the record of the Mr Ed Timpson.

The defendant should make their way to City Hall at their earliest convenience to have the change to their record noted as well as the payment of $40,500 returned to them for fines, time, and other expenses/inconveniences incurred from the contested charges.

---

Moving forward, this case will be recognised as #24-CM-0084 State of San Andreas v. Dave Ward.

---

As for the motions to suppress:

Exhibit #4 & #6

The court rules that these exhibits are relevant to the case as they provide contextual details about the alleged crimes of the defendant. Whilst the defence is correct in stating the "best evidence" rule, this does not prevent the use of supplementary evidence from the prosecution that offers probative value in establishing the circumstances surrounding the defendant’s alleged actions.

The arrest reports, though not directly implicating the defendant by name, are closely tied to the events and individuals involved in the same incident, and therefore, Exhibits #4 and #6 will not be suppressed.

Exhibit #7

The probative value of this exhibit is low as it lacks any specific details or independent analysis and therefore offering little more than an endorsement of existsing evidence. The court also believes this to be more prejudicial than probative as it is an attempt to give undue weight to other pieces of evidence with no new substantive content.

Corroborative evidence may serve as clarity for exhibits, but this statement merely reiterates. Therefore, the motion to suppress is granted on Exhibit #7

Exhibit #11

In the case #22-CM-0036, the statement was excluded due to it lacking an affirmation, which is fundamental to validate a witness statement. The omission of the incident date in exhibit #11 is not relevant to the aforementioned precedent and therefore the precedent will not be taken into account for this decision.

The court finds the absence of a date a procedural error that does not materially affect the admissibility of the statement itself. Whilst the incident date does provude sufficient temporal contaxt, the probative value of the statement is not impacted by it's omission. Therefore, Exhibit #11 will not be suppressed.

Exhibit #12

Due to no contest, the motion for Exhibit #12 to be suppressed is granted.

---

If you have any further motions or appeals please make it known, if not please confirm readiness for scheduling trial within the next 3 days.

Respectfully,


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

[Michael Blaise]

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

---

• Your Honor,
  
  The Prosecution is prepared for trial scheduling.
  
  Respectfully,
  
  
  Lead Prosecutor
  San Andreas Judicial Branch
  (909) 552-8150 — [email protected]