#24-CM-0092 State of San Andreas v. Samuel Martin

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Michael Blaise
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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San Andreas Judicial Branch

Docket Notice
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Judge Fitzgerald and pertaining parties,

    The Prosecution will be objecting to the defense's deposition request, and the reasoning is as follows:

    There is no demonstrated necessity for conducting depositions in this case. 2 of the individuals (Tommy Bean and Aurora Harrison) named as deponents have already provided sworn witness statements to the court, have a documented preliminary meeting on the docket, and can be examined during the trial, allowing for the same evidentiary examination under the presiding Judge’s supervision, whereas no judge would be present for the defense's requested depositions.

    With specific regard to Emilia Thalmer, she is not intimately connected to the facts of the case. Her involvement is limited to providing intake and discharge records in compliance with a court-ordered subpoena. There is no indication that her testimony would provide any unique or probative information beyond the documentation already submitted.

    The Prosecution respectfully requests that the Court deny the motion for deposition.



    In addition: The Prosecution will be objecting to the defense's first subpoena request, on the grounds that the sought information has a high potential to be more prejudicial than probative.

    The request for evidence of Aurora Harrison’s and Tommy Bean’s alleged affiliations with a criminal organization is more prejudicial than probative. Introducing such information carries a significant risk of unfairly influencing the court against these witnesses without providing material value to the case at hand. The mere assertion of affiliation with a criminal organization does not inherently discredit their testimony or establish bias against the defendant, which the defense has stated is their intention with issuing this subpoena request.

    The Defense has failed to provide any evidence to substantiate the claim that the witnesses’ testimony is influenced by personal bias stemming from alleged affiliations. Speculative arguments are insufficient to justify the issuance of subpoenas for such materials.

    As such, the Prosecution requests that the court deny the Defense's subpoena request in its entirety.


    Lastly, the Prosecution will be objecting to the defense's second subpoena request, on the grounds of relevance.

    The Defense has fundamentally misunderstood the basis for the charge of GM25 - Possession/Unlawful Use of Government Equipment. The Prosecution is not asserting that Detective Martin unlawfully possessed the weapon, but rather that the weapon was used in the commission of a crime. Accordingly, a complete list of firearms that Police Captain Samuel Martin is authorized to possess and use as part of his duties with the Los Santos Police Department holds no probative value in this matter.

    Additionally, the Defense’s request to subpoena records regarding the number of vehicles impounded by Los Santos Police Department officers without the owner being subject to arrest is similarly irrelevant. The victim’s vehicle was not impounded, and no such allegations have been made in this case. In fact, as stated in Exhibit #2, the victim reported finding his vehicle down the road from Pillbox MD, far from the city impound.

    For these reasons, the Prosecution respectfully requests that the Court deny the Defense’s subpoena request in its entirety.




    Respectfully,

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    Deputy Attorney General
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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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. Samuel Martin
#24-CM-0092

A Motion to Suppress was filed in the above case on the 12th of February, 2025 .


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 #1: Witness Statement from Police Lieutenant II Elise Cavallera
    Requested Evidence to Suppress:
    Entire Exhibit.
    • Detailed Reasoning: Relevance.

      The events described by Lieutenant Elise Cavallera pertain to an unrelated incident involving a shootout at the Terminal and subsequent events around Legion Square. These details do not directly address or relate to the charges at issue in this case. The statement focuses on unrelated suspects, a deceased detective, and a recount of actions taken by Lieutenant Cavallera and others during the shootout.

      The defense has not demonstrated how this statement provides probative value to the case against Detective Samuel Martin. Its inclusion risks confusing the issues and prejudicing the court by introducing extraneous matters.

      For these reasons, the Prosecution respectfully requests that the court exclude this witness statement as irrelevant to the proceedings.

  • Exhibit #2: Arrest Report for Lacey Vincero
    Requested Evidence to Suppress:
    Entire Exhibit
    • Detailed Reasoning: Similar to Exhibit 1, this exhibit lacks any relevance to the case at hand. The arrest report pertains to charges unrelated to the case against Detective Samuel Martin. It primarily focuses on the possession charges and alleged conduct of Lacey Vincero. The details regarding her arrest, the weapons and substances found in her possession, and the charges brought against her do not have any direct bearing on the allegations against Detective Martin.

      The inclusion of this report risks distracting from the central issues of this case, as it does not offer probative value related to the charges being tried. Introducing evidence of unrelated criminal conduct only serves to confuse the matters at hand and is prejudicial to the proceedings.




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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Jason Steel »

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  • Honorable Judge Fitzgerald and pertaining parties,

    The Defense presents its thoughts in regards to the latest rebuttal to the Defense's motions.

    Deposition request for Aurora Harrison and Tommy Bean
    • The defense can not find any entry into the docket by the Prosecution that indicates either of them will be present at the trial and be made available for examination; if the prosecution intends to call them to trial, a witness list should be produced; in the absence of such, the defense would like the opportunity to obtain probative testimony from the only two known eye-witnesses just as the prosecution enjoyed, weeks before trial.
    Deposition request for Emilia Thalmer
    • Beyond the fact that Ms. Thalmer already accessed and further communicate discharge records for the situation in question; she is a medical expert that can provide further probative testimony into the state of one of the witnesses during the alleged incident.
    Collection of facts, pictures and other evidence of Aurora Harrison's and Tommy Bean's affiliation with a criminal organization. (colloquially known as a 'casefile')
    • The defense believes that the criminal affiliation of the two witnesses is just as important to establish as the prosecution's desire to establish my client as a law enforcement officer; respectfully, if this had been a request for prior charges, I would be inclined to agree with the prosecution, but the requested documents are probative of their continued and voluntary membership in an organization at odds with the one of my client. It is clearly indicative of a professional bias, which was a question opened by the Prosecution and his witness; if the prosecution poses a question, surely they can not also suppress the answer to the question.
    A complete list of firearms that Police Captain Samuel Martin is permitted to possess and use as part of his duties with the Los Santos Police Department.
    • The Prosecution has perhaps fundamentally misunderstood the Penal Code, to wit, GM-25; it is our opinion that there is no charge for unlawful use of government equipment, despite the name of it, the actual criteria for issuance of the charge is clear in its wording.
      State Government wrote:Possessing, being within immediate control of, or using unlawfully obtained Government Equipment, including but not limited to: Stingers, Tazers, Radio Jammers, GPS Jammers, Radios tuned to a Government Encrypted Frequency, and Police Megaphones.
      Unless the Prosecution is ready to drop the charge, the requested document is probative towards the actual penal code definition, and not the definition that the Prosecution made-up.
    The number of vehicles impounded by Los Santos Police Department officers without the owner being subject to arrest.
    • The prosecution is once again casting its own opinion and acting as if that is the letter of law, the charge of Grand Theft Auto is very strict and with no qualifiers or exceptions.
      State Government wrote:Taking someone else's vehicle without consent.
      If it is not a breach of this charge to impound a person's vehicle without consent when they are not subject to arrest, then it is not a breach of this charge to take a person's vehicle in the performance of your duties for any other reason. If it is always a breach of charge to take a person's vehicle without consent, then the Defense feels that our client is the victim of selective prosecution. Either way, the information is probative to the matter at hand, according to the penal code and charges filed by the Prosecution.

  • Very Respectfully,
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    Jason Steel
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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San Andreas Judicial Branch

Docket Notice
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Judge Fitzgerald and pertaining parties,

    The Prosecution will offer one final rebuttal to the Defense's most recent motions:

    Regarding Deposition request for Aurora Harrison and Tommy Bean:

    The defense has prematurely raised concerns regarding the witness list. Exhibits #2 and #3 clearly indicate my intent to call both witnesses to the stand. Historically, the court has permitted the filing of a witness list much later in the docket process. As of the filing of this rebuttal, it remains my intention to call both witnesses to testify at trial. Any attempt to seek a deposition at this stage would effectively circumvent the presence of a presiding judge during the examination process, which is neither appropriate nor necessary in this instance.

    Regarding Deposition request for Emilia Thalmer:

    Medical records are highly protected under privacy laws, and any details regarding the witness's physical condition would likely fall within these protections. Furthermore, there is no evidence to suggest that Ms. Thalmer was physically present at Pillbox Medical Center. Based on the email correspondence, it appears she merely reviewed intake and discharge records in compliance with the subpoena issued by Honorable Judge Fitzgerald earlier in this case and subsequently relayed that information to the prosecution.

    ((Context: No medical RP was done on Aurora. Alt-RP was acquired to simply check logs for what time the individual was scriptly healed at MD.))


    Regarding Collection of facts, pictures and other evidence of Aurora Harrison's and Tommy Bean's affiliation with a criminal organization. (colloquially known as a 'casefile'):

    The Prosecution maintains that the requested documents regarding the alleged criminal affiliation of the two witnesses are irrelevant to this case. have a high potential to be more prejudicial than probative, and should not be admitted.

    The defense's assertion that the Prosecution "opened the question" of bias is a mischaracterization. The Prosecution's reference to bias was in response to the defense’s unsubstantiated claims and does not justify a fishing expedition into the witnesses' alleged affiliations.

    Secondly, the defense's comparison between establishing the defendant’s role as a law enforcement officer and investigating the witnesses’ alleged affiliations is flawed. The defendant’s status as a law enforcement officer is directly tied to the charges and facts of the case. Conversely, alleged organizational affiliations of the witnesses do not inherently prove bias or bear directly on the facts in dispute. Such claims require specific evidence linking the alleged affiliation to the witnesses’ testimony in this case, which the defense has failed to provide.

    Finally, the defense’s request risks introducing irrelevant and prejudicial material into the proceedings. Allegations of affiliation with a criminal organization would serve only to inflame emotions and distract from the central issues, rather than illuminate them. The court must prioritize evidence that is probative and not prejudicial, and the defense's request fails to meet this standard.


    Regarding A complete list of firearms that Police Captain Samuel Martin is permitted to possess and use as part of his duties with the Los Santos Police Department:

    The Prosecution respectfully disagrees with the defense’s interpretation of GM-25 and asserts that the defense has failed to grasp the spirit and intent of the law as outlined in the Penal Code.

    The charge of GM-25 - Possession/Unlawful Use of Government Equipment is not merely about the possession of unlawfully obtained government equipment, but also its unlawful use. The Prosecution contends that the evidence will show that the government equipment in question (Captain Martin's Department-issued Firearm), whether lawfully obtained or not, was used in a criminal manner inconsistent with lawful duties, thereby satisfying the criteria for GM-25.

    The defense’s focus on possession as the sole determinant of the charge ignores the broader implications of “use” as stated in the law. The Penal Code clearly seeks to criminalize both the possession and misuse of such equipment, ensuring accountability for individuals who misuse their authority or equipment for unlawful purposes, regardless of how they obtained it.

    The requested document is irrelevant to the issue at hand. The Prosecution has not alleged that the equipment in question was unlawfully obtained, and thus a subpoena for records related to the possession or authorization of the equipment has no probative value in this case. The focus should remain on whether the defendant misused the equipment, which is the actual basis of this charge.

    The spirit of GM-25 is to prevent the misuse of government equipment in ways that violate public trust and the law. The Prosecution urges the court to interpret the statute in alignment with its intent and reject any attempts to narrow its scope arbitrarily.

    Regarding The number of vehicles impounded by Los Santos Police Department officers without the owner being subject to arrest:

    The Prosecution respectfully disagrees with the defense’s interpretation of the Penal Code and finds their argument both legally flawed and factually unsupported.

    First, the defense has failed to provide any evidence that Mr. Martin was using the vehicle in question for lawful duties at the time it was taken. The mere fact that he is a law enforcement officer does not create a blanket exemption for any and all actions involving private property. Law enforcement personnel are not immune to charges of Grand Theft Auto when taking a vehicle without consent unless such actions are explicitly justified under the law and necessary for the performance of their duties, such as a lawful impound.

    Furthermore, the defense’s comparison to the impounding of a vehicle by law enforcement is wholly inapposite. The impounding of vehicles is a regulated process governed by specific legal standards, procedures, and justification. It is a lawful administrative act, often tied to violations of traffic laws or investigations. By contrast, forcibly taking a vehicle at gunpoint, regardless of the individual’s occupation, only creates another aggravated distinction.




    Respectfully,

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    Deputy Attorney General
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Jason Steel »

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  • Honorable Judge Fitzgerald and pertaining parties,

    The Defense feels it utmost important to make it clear its stance on how charges work in the penal code; as this is a fundamental issue in the before-filed motion.

    Grand Theft Auto in Los Santos
    • The Prosecution has arbitrarily drawn a personal line that they seek to enforce with the powers of their office, that is not how the law works or should work; the mere notion that the Prosecution feels it is their prerogative to invent and enforce personal exceptions for felony charges is preposterous. The defense fully maintains and will continue to maintain unless otherwise told by His Honor that we will be following the penal code as written and published for all citizens to read here; and not the penal code as imagined by Prosecutor Blaise.

      Prosecutor Blaise has quite literally hallucinated a number of exceptions that do not exist or are not outlined anywhere in the penal code; there is no exception stated in the penal code, and Prosecutor Blaise can not pick and choose what exceptions are convenient to his case at this time; if the charge stated something to the effect of "unless otherwise reasonable" or "unless in the performance of their duties", then, we could debate what that entails; but the penal code makes absolutely no exceptions, and they can not be added now retroactively; to do so, would be the definition of ex post facto prosecution, and completely unconstitutional.
      Penal Code wrote:Taking someone else's vehicle without consent.
    GM25 - Possession/Unlawful use of Government Equipment
    • The Defense does not subscribe to the Prosecution's world view that charges are whatever they feel at the moment; The Defense understands charges to work under the following model: NAME and DESCRIPTION. There are a number of charges where the name does not match the description necessarily, and this does not give prosecution carte blanche to enforce whatever they feel the description should be; instead The Prosecution should use the Judicial Branch's seat in the LRC to push for amendments.
      Penal Code wrote:NM07 - Prostitution, Pimping or Pandering
      From the aforementioned name, you might believe that Pimping is against the penal code; however, when examining the actual factors for charging someone with NM07, you will see that Pimping is not against the law. i.e. the practice of having someone do sex work on your behalf in exchange for protection.
      NM07 Description wrote:The practice or occupation of engaging in sex with someone for payment.
      If Prosecutor Blaise believes that they would be able to charge someone with Pimping just because it's in the name, then we simply have different views of the law, and we will require His Honor to settle this.

      The Defense continues to maintain that GM25 does not provide any avenue for prosecution due to unlawful use of government equipment; only unlawful possession may be prosecuted under the current definition.
      Penal Code wrote:Possessing, being within immediate control of, or using unlawfully obtained Government Equipment, including but not limited to: Stingers, Tazers, Radio Jammers, GPS Jammers, Radios tuned to a Government Encrypted Frequency, and Police Megaphones
      The correct reading of the aforementioned definition in the English language is as follows:
      • Possessing unlawfully obtained Government Equipment, including but not [..]
      • Being within immediate control of unlawfully obtained Government Equipment, including but not [..]
      • Using unlawfully obtained Government Equipment, including but not [..]
      Any other reading is strictly incorrect by the rules of grammar, and would constitute a change in the meaning behind the law, rendering this prosecution an ex post facto prosecution, prohibited by the Constitution of San Andreas.

  • Very Respectfully,
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    Jason Steel
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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San Andreas Judicial Branch

Docket Notice
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Judge Fitzgerald and pertaining parties,

    In a complete misunderstanding of the legal concept of the Spirit of the Law vs. the Letter of the Law, Attorney Steel has now accused me of "hallucinating" exceptions to the penal code. I am terribly confused. Does Mr. Steel hope that I go back and charge every single LSPD officer who has ever impounded a vehicle due to demerits leading to the license suspension of an individual? If this is what the court wishes, I will begrudgingly do so!

    I am not going to entertain this form of bickering by offering it an actual response. Respectfully, Attorney Steel seems to have an extremely intense vested interest in the success of his coworker and client that has led to his unprofessional behavior on the docket. Whether the court wishes to address this is none of my concern, but I, personally, will not be continuing this back-and-forth, especially when the arguments have degraded into Mr. Steel's angry explanation of how the penal code should be read based on his apparent frustrations.

    The Bar Ethics Review Board exists if you believe that I have "arbitrarily drawn a personal line that I seek to enforce with the powers of my office."

    The prosecution will now await the presiding Judge's ruling on the pending motions.


    Respectfully,

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    Deputy Attorney General
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Jason Steel »

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  • Honorable Judge Fitzgerald and pertaining parties,

    The Defense would like to provide a rebuttal to the prosecution's motion to suppress Witness Statement from Police Lieutenant II Elise Cavallera and Arrest Report for Lacey Vincero after the previous motions have had a ruling from Your Honor.
    • The reasoning for this is that almost all exhibits/motions are currently pending a decision from Your Honor and we would like to provide a coherent argument for their admission without referencing exhibits that could possibly become suppressed.

  • Very Respectfully,
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    Jason Steel
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Maximilian Fitzgerald »

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San Andreas Judicial Branch

"EQUAL JUSTICE UNDER LAW"

  • Esteemed Prosecution and Defence,

    The Court has been watching the lengthy exchanges and observes that the quality of the recent filings has devolved into bickering and personal reproach. I will not permit such unprofessional conduct in my proceedings. Both the Prosecution and Defense are reminded that spirited advocacy does not entitle counsel to make ad hominem attacks or use argumentative language that distracts from the substance of the legal issues at hand.

    Henceforth, I order both parties to refrain from further personal exchanges or accusations in this matter. Should counsel wish to submit additional arguments, they must do so succinctly, professionally, and focused on relevant points of law or fact. Any continued deviation from these standards may prompt the Court to consider disciplinary measures, including restrictions on filings or referral to the Bar Ethics Review Board.

    All pending motions will be taken under advisement, and rulings will be issued after 3 days after the final responses from you both.

    With the Highest Regard,

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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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Docket Notice
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  • Honorable Judge Fitzgerald and pertaining parties,

    In the absence of further motions, the Prosecution will rest and await the court's decision on pending motions.

    Respectfully,

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    Deputy Attorney General
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Jason Steel »

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  • Honorable Judge Fitzgerald and pertaining parties,

    The Defense would like to provide a rebuttal to the prosecution's motion to suppress two exhibits.

    Exhibit #1: Witness Statement from Police Lieutenant II Elise Cavallera
    • The Defense finds the witness testimony extremely relevant to the indictment as it provides context around the actions of my client in or around the time of the alleged events by the indictment; the witness statement provides direct probative value as to where my client was, why he was there and what his actions were, including his presence at the very place that the indictment alleges he was at (hospital).
    Exhibit #2: Arrest Report for Lacey Vincero
    • The Defense finds a perfect parallel between its exhibit and the exhibit submitted by the prosecution, and allowed by Your Honor, specifically, the records of the prosecution's witness records; it provides evidence that the testimony in Exhibit #1 is true, at least in part, and it has no way of being prejudicial as the person arrested is not a witness nor a victim in this case.

  • Very Respectfully,
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Jason Steel »

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  • Honorable Judge Fitzgerald and pertaining parties,

    In the absence of any further motions from the prosecution, defense will rest and await Your Honor's rulings on the submitted motions.

  • Very Respectfully,
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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San Andreas Judicial Branch

Docket Notice
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Judge Fitzgerald and pertaining parties,

    Regarding Exhibit #1 – Witness Statement from Police Lieutenant II Elise Cavallera

    Your Honor, while the defense seeks to connect this witness statement to the incident underlying the indictment, it is important to note that the statement lacks any specific time reference. In contrast, the prosecution has provided a precise time and date for the alleged incident, which occurred between 1:25 AM and 1:30 AM on December 25, 2024.

    The witness statement does reference the date of December 25, 2024, but it fails to include a specific timeframe for the events described. Therefore, it can only be established that the incident outlined in the witness statement occurred within a 24-hour window of the alleged incident. The defense has not demonstrated that this incident took place within the same timeframe as the events in question. As such, the prosecution respectfully submits that this exhibit should be dismissed on the grounds of irrelevance.

    Regarding Exhibit #2 – Arrest Report for Lacey Vincero

    The defense has submitted this arrest report as a corroborative document to Exhibit #1. However, the arrest report fails to include any reference to a specific time. Moreover, the report lists the date as December 24, 2024, which is inconsistent with both the date referenced in the witness statement submitted by the defense and the date of the incident underlying the indictment. Consequently, this arrest report cannot be considered relevant evidence in this case, whether intended to corroborate Exhibit #1 or otherwise.

    Given the arguments outlined above, the Prosecution respectfully reiterates its request for both exhibits to be suppressed in full on the grounds of irrelevance.

    The Prosecution will refrain from submitting further rebuttals and awaits the Court’s decision.



    Respectfully,

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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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San Andreas Judicial Branch

Docket Notice
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Judge Fitzgerald and pertaining parties,

    As requested by the presiding Judge, please find Alex Crail's sworn statement regarding the Prosecution's Exhibit 1 below.
    Sworn Statement - Alex Crail

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    San Andreas Judicial Branch

    Official Witness Statement
    "EQUAL JUSTICE UNDER LAW"
    Case Information
    • Case Number: Case Number
      Incident Date: 27/DEC/2024
    Witness Information
    • Name: Alex Crail
      Date of Birth: 22/JAN/2001
      Phone Number: ###-####
      Occupation: Junior Paramedic LSEMS
    Witness Statement
    • I was on duty at LSEMS at the time when Mr. Blaise approached me to get the footage from our security cameras for a case he was working on, Mr. Blaise showed me his government ID and i retrieved the CCTV and handed it to Mr. Blaise as only supervisors and above have access to the CCTV (to my knowledge) and the evidence was never tampered with, i handed Mr. Blaise the SD card for the CCTV and he went straight to city hall
    Witness Affirmation
    • I, Alex Crail, 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,

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      Alex Crail
      Junior Paramedic LSEMS
      Organization, if applicable

      Date: 13/FEB/2025
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    Respectfully,

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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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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. Samuel Martin
#24-CM-0092

A Witness List was filed in the above case on the 17th of February, 2025.
  • The State of San Andreas, by and through the undersigned attorney, filed this Witness List, designating the following list of individuals as witnesses, who may be called to the stand.

    Name of Witness:
    Tommy Bean
    Type of Witness: (eye, fact, expert, or other type of witness)
    Eye Witness
    Relevance to the case:
    Mr. Bean is the victim of the alleged offenses.


    Name of Witness:
    Aurora Harrison
    Type of Witness: (eye, fact, expert, or other type of witness)
    Eye Witness
    Relevance to the case:
    Ms. Harrison directly observed the incident in question.



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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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San Andreas Judicial Branch

Docket Notice
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  • Honorable Judge Fitzgerald and pertaining parties,

    The Prosecution respectfully informs the Court that the appeal in question has been denied by the Court of Appeals. Accordingly, the Prosecution now awaits the presiding judge's ruling on the pending motions.

    Respectfully,

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    Deputy Attorney General
    San Andreas Judicial Branch
    (909) 552-8150 — [email protected]
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Maximilian Fitzgerald »

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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. Samuel Martin
#24-CM-0092

A decision was reached in the above case on the 23rd day of February, 2025.


Motion to Suppress Exhibit #1: CCTV Footage - Pillbox MD - 12.25.24

As mentioned previously, it is the burden of the defence to substantiate claims of tampering or breaks of chain of custody. It is the courts belief that in it's current form, the CCTV footage is admissible, and the statement by Mr. Crail reaffirms this. Also, Prior cases have allowed acquired CCTV footage to be admissible without a thorough chain of custody published. Therefore the motion to suppress Exhibit #1 is denied.
((This is more about what's logistically viable within RP for CCTV.))

Motion to compel discovery of defendants bodycam

The fifth amendment protects individuals from being compelled to provide testimonial evidence against themselves. Physical/real evidence such as DNA, fingerprints, photographs, or recordings of external events is generally not deemed as testimonial. Bodycam footage is more akin to recording of external events rather than statements made by the defendant. As for the arguments about the fourth amendment rights, bodycamera footage belongs to the law enforcement agency and not the individual police officer. Also, due to the footage being part of official duties, has a reduced privacy interest.
In conclusion, due to the latter aspect of my explanation, the motion to compel discovery is denied. A subpoena request for the footage will be reviewed after this decision instead.

Motion to stay pending appeal

The appeal has been denied therefore as will the motion to stay.

Deposition requests

Given the clear intent by both sides to wish to have all individuals called to trial as witnesses to be questioned, and that the prosecution has formally submitted a witness list for 2 of the individuals this deposition request is denied. Ms Emilia Thalmer has no substantiative justification for being deposed or a witness therefore she will not be required to be a witness as this case is not about the injuries Ms Harrison sustained and Ms Thalmer was merely providing a statement of the medical information being released from the LSEMS and her role is purely administrative in this case.

Subpoena request for casefiles

The Court has considered the Defense’s request to subpoena “casefiles” or other evidence purportedly showing Ms. Harrison’s and Mr. Bean’s affiliations with a criminal organization. While the Defense argues these materials would demonstrate bias against Mr. Martin, such a request amounts to a speculative inquiry that risks introducing irrelevant or unduly prejudicial material. Without concrete evidence linking alleged affiliations directly to the witnesses’ testimony in this specific incident, the probative value is minimal, and the potential for unfair prejudice is considerable. Accordingly, the Court denies the subpoena request for Ms. Harrison’s and Mr. Bean’s casefiles.
Subpoena request for list of firearms Samuel Martin is permitted to use

The Court recognizes that Captain Martin’s status as a law enforcement officer generally includes authorization for certain department-issued firearms. However, the central question concerning the government-equipment charge is not whether its possession was officially approved as the prosecution has not raised any concerns regarding whether the weapon possession was unlawful and therefore the court has no doubt at this stage to this question. As such, a detailed list of all firearms he is permitted to use does not bear materially on whether the specific alleged use in this incident was lawful. Therefore, the Court denies this subpoena request as lacking sufficient relevance to the charges at hand.

Subpoena request for number of vehicles impounded by LSPD without owner being subject to arrest

The Defense seeks data on impounded vehicles to argue that taking a vehicle without the owner’s consent is a common police practice. The Court finds that this statistical information, standing alone, does not address the discrete legal question of whether Mr. Martin’s actions amounted to Grand Theft Auto under the circumstances alleged. General impound procedures differ substantially from the charged conduct, and allowing a broad inquiry into unrelated impounds would risk confusion of the issues. The Court therefore denies the subpoena request for LSPD impound statistics until such a time the defence can provide a concrete link between the actions of the defendant and the law enforcement practice of impounding vehicles.

Motion to suppress Exhibit #1: Witness Statement from Police Lieutenant II Elise Cavallera

Although the Prosecution contends that Lieutenant Cavallera’s statement describes a separate incident, the Court finds sufficient overlap in the date and circumstances to render the testimony relevant. This statement establishes that the Defendant, was actively engaged in law-enforcement operations on or around December 25, 2024, and moved to the Pillbox Hospital mentioned in the indictment. While not an exact minute-by-minute account of the alleged crime, the statement supports the Defense’s argument about Mr. Martin’s whereabouts and activities leading up to or shortly after the alleged wrongdoing.

Additionally, it is plausible that a large-scale shootout or near-continuous series of events could have contributed to Martin’s state of mind, physical condition, or other circumstances surrounding the timeframe in which he is charged. Hence, any concern that the statement might confuse the issues is outweighed by its probative value: It places the Defendant on duty, at or near Pillbox, in a timeframe arguably close to the alleged offense. The Court will therefore deny the motion to suppression of the entire exhibit.

Motion to suppress Exhibit #2: Arrest Report for Lacey Vincero

The Prosecution contends that Ms. Vincero’s arrest is unrelated to the alleged theft and assault. The Court, however, recognizes that the Defense introduced this exhibit in part to verify Lieutenant Cavallera’s testimony. The arrest report corroborates her statement that Ms. Vincero had been encountered, disarmed, and arrested in close proximity to the timeline described by Cavallera, albeit with a slight discrepancy of stated dates.

Because the arrest report references Ms. Vincero’s involvement in the same cluster of events (the shootout, injuries, and subsequent transport to the same medical facility), it can help paint a broader picture of the scene that day, particularly if the Defense suggests that Martin’s presence at Pillbox or his actions there were consistent with standard policing amid extraordinary criminal unrest. Therefore, it has at least some relevance to the defense theory. Any remaining concerns about accuracy or conflicting dates go to the weight of the evidence rather than its admissibility. Therefore the motion to suppress this exhibit in it's entirety is denied.

It is worth noting on the final 2 decisions that the risk of confusion or prejudice is where the fact-finder could be misled or confused by the details of the events. As the fact-finder of this case, I am utilizing discretion to allow them to be introduced to the case . I appreciate the Prosecution’s position that Lieutenant Cavallera’s statement and the arrest report of Ms. Vincero may not directly address the central allegations. However, given that both documents reference activities occurring on or about the date in question and appear to involve the Defendant’s movements or surroundings, I find they could shed light on the broader context. While I acknowledge the risk of confusion, I believe that thorough cross-examination and a careful scope of inquiry will sufficiently mitigate those concerns, allowing any probative value these exhibits might hold to be properly evaluated.


Respectfully,

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San Andreas Judicial Branch
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Jason Steel »

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WITNESS LIST


IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Samuel Martin
#24-CM-0092

A Witness List was filed in the above case on the 24th of February, 2025.
  • The Defendant, Samuel Martin, by and through the undersigned attorney, filed this Witness List, designating the following list of individuals as witnesses, who may be called to the stand.

    Name of Witness:
    Cyrus Carver
    Description:
    Expert Witness
    Witness Agency:
    Los Santos Police Department


  • Very Respectfully,
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    Jason Steel
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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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. Samuel Martin
#24-CM-0092


The Prosecution formally objects to the recently filed witness list submitted by the Defense.

Both the Prosecution and Defense are required to establish the relevance of each witness to the case, as demonstrated in the format used in the Prosecution's witness list. Furthermore, precedent set during the denial of a motion to suppress by the Honorable Justice Antonio McFornell in State of San Andreas v. Cortez Rivera (#24-CM-0061) outlined the minimum expectations for the designation of an expert witness. Simply designating an individual as an "Expert Witness" without providing context is insufficient to justify their inclusion at trial. At this time, the Defense has failed to provide the necessary narrative to support the relevance of their witness.


Respectfully,

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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Jason Steel »

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  • Honorable Judge Fitzgerald and pertaining parties,

    The Defense would like to provide a rebuttal to the prosecution's motion to suppress a witness/witness list.

    I have been unable to find a single example of either prosecution or defense filing an objection against a witness list (i.e. the desire to present someone as a witness). The "precedent" provided by the prosecution refers to a witness statement, not a physical witness — we find this to be an extremely big difference because unlike in a witness statement, the prosecution will have the ability to cross examine the witness and to have any objections heard on the spot. We consider this to be fundamentally different than a written witness statement, which is, by nature, not interactive.

    However, in the interest of Justice, and a transparent proceeding, we would like to make it clear to the court that Police Detective III Cyrus Carver is a career law enforcement officer, starting his career six years ago. Police Detective III Cyrus Carver is a Police Supervisor, which empowers the officer to judge and take corrective actions against subordinates whom violate departmental procedures. This qualifies him to provide insights on what are common acts taken by peace officers, providing probative value in the form of common police procedures and standards.

    Echoing the Honorable McFornell's conclusion in the unrelated precedent, we believe that if the prosecution would like to object to the validity of his statements, they should do so during trial proceedings, instead of attempting to exclude his testimony entirely.

  • Very Respectfully,
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    Jason Steel
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Maximilian Fitzgerald »

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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. Samuel Martin
#25-CM-0092

A decision was reached in the above case on the 25th day of February, 2025.


It is important for the record to show why a witness is being offered, however, challenges to the inclusion of a witness should typically be resolved during trial rather than at the pretrial stage. While the prosecution raises a point about the sufficiency of the expert designation, the defense has provided adequate additional context regarding Detective Carver’s background. The court finds that Carver’s experience and supervisory role provide a reasonable basis for his expert opinion on standard police procedures.

Regarding precedent in #24-CM-0061, This situation involved a written statement and the arguments were on the admissibility of said exhibit. As Mr Carver has made no statement, if the prosecution has concerns about the qualifications of Mr Carver or the relevance of his testimony when it happens, those concerns can be fully aired during trial when he is subject to cross-examination. Weight or admissibility of his testimony can be further argued in court and I will take concerns into consideration if relevant in a similar fashion to how #24-CM-0061 was handled.

Therefore the objection to this witness list is overruled.

Respectfully,

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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Michael Blaise »

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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. Samuel Martin
#24-CM-0092

A Motion for Discovery was filed in the above case on the 6th of March, 2025.


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


  • Exhibit #7: Captain Samuel Martin Bodycam Footaqe
    *
    Samuel Martin responds with another detective to an active shootout. Upon arriving close to the scene (terminal) a vehicle was spotted leaving the shootout. A pursuit of the vehicle was started by Samuel Martins unit. The evading vehicle started to shoot at the chasing police unit close to Lower Power Street/ Main City Parking.

    Samuel Martin ran from Lower Power Street into the parking between Lower Power Street and Elgin Ave. An unknown suspect entered from Lower Power into the parking lot. Samuel ran onto Elgin Ave and attempted to take cover behind a pole but was shot by multiple directions.

    Samuel got injured. Elise and Breacher arrived on scene. Elise shot down a suspect that was north trying to hide behind a scene. Breacher took Samuel in his patrol car to pillbox. Elise can be heard calling for backup, Breacher drives away from pillbox leaving Samuel behind.

    A vehicle arrives at pillbox.. ((Can watch the clip to see what happens at pillbox))


    Bodycam.mp4


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San Andreas Judicial Branch
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Maximilian Fitzgerald »

Document 1 | Filed 08/MAR/2025 | Page 1 of 1

IN THE SUPERIOR COURT
FOR THE STATE OF SAN ANDREAS



  • Docket Number:
    24-CM-0092
    Date Filed:
    08/MAR/2025
    Violations:
    GF11 - Grand Theft Auto
    WF01 - Assault with a Deadly Weapon
    GM25 - Possession/Unlawful use of Government Equipment
    State of San Andreas

    v.

    Samuel Martin


PLEA AGREEMENT


  • Pursuant to the case of State of San Andreas v. Samuel Martin; Deputy Attorney General Michael Blaise, Private Defense Attorney Jason Steel, and the defendant, Samuel Martin, have entered into agreement, the terms of which are as follows;
    1. Current Charges
      1. GM13 - Criminal Threats
      2. WM01 - Unlawful Brandishing of a Firearm or Weapon
      3. GM25 - Possession/Unlawful use of Government Equipment
    2. Former Charges
      The state shall pursue the current charges listed above, in place of the original charges listed below:
      1. GF11 - Grand Theft Auto
      2. WF01 - Assault with a Deadly Weapon
      3. GM25 - Possession/Unlawful use of Government Equipment
    3. General Provisions
      • The defendant agrees to plead guilty to the Current Charges outlined in Section I. The State waives the right to pursue the Former Charges outlined in Section II in regards to this particular incident. The defendant will not be required to pay court fees or associated appeal fees.
    4. Waiver of Rights
      • It is CRITICAL that you read this section of the plea agreement thoroughly. By signing this document, the defendant agrees to surrender certain rights, notably; the defendant may not further appeal charges agreed to within this plea bargain.

        This agreement may not be terminated at the discretion of an defendant, the defendant's counsel, nor the prosecution; it may only be terminated by the presiding judge under strict guidelines set forth by the Supreme Court of San Andreas.

        By signing this document, the defendant is pleading guilty to the charges outlined in Section I and these charges may not be challenged at a later date.


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    Deputy Attorney General Michael Blaise
    San Andreas Judicial Branch
    Date Signed: 02/MAR/2025

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    Private Defense Attorney Jason Steel
    San Andreas Judicial Branch
    Date Signed: 08/MAR/2025


    Samuel Martin
    Defendant
    Date Signed: 08/MAR/2025

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    Honorable Maximilian Alexander Fitzgerald III
    San Andreas Judicial Branch
    Date Signed: 08/MAR/2025
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Re: #24-CM-0092 State of San Andreas v. Samuel Martin

Post by Maximilian Fitzgerald »

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San Andreas Judicial Branch

Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

ISSUANCE OF VERDICT


IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Samuel Martin
#24-CM-0092

A the above case was resolved on the 08th day of March, 2025.


A Plea Agreement was filed by the Prosecution and accepted by the court. Within the agreement, the defendant pled guilty to the charges of GM13 - Criminal Threats, WM01 - Unlawful Brandishing of a Firearm or Weapon, and GM25 - Possession/Unlawful use of Government Equipment.

It is with the above considerations that I issue the following verdict:
  • On the count of GM13 - Criminal Threats, I find the defendant, Samuel Martin, guilty.
  • On the count of WM01 - Unlawful Brandishing of a Firearm or Weapon, I find the defendant, Samuel Martin, guilty.
  • On the count of GM25 - Possession/Unlawful use of Government Equipment, I find the defendant, Samuel Martin, guilty.


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