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Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 16 Jul 2024, 05:18
by Terence Williams
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 16 Jul 2024, 11:58
by Jay Wellberg

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"
MOTION TO COMPEL DISCOVERY
IN THE SUPERIOR COURT OF SAN ANDREAS
State of San Andreas v. Stelio Bathsheba
#24-CM-0024
A Motion to Compel Discovery was filed in the above case on the 15th of July, 2024.
The Defendant, Stelio Bathsheba, by and through the undersigned attorney, filed this Motion to Compel Discovery, and requests as follows;
- Requested Discovery: Witness Statement, Deputy Lester Conway
- Detailed Reasoning: The prosecution provided a witness statement from Deputy Conway, the defense would like the opportunity for him to provide responses to a few questions to clarify a few things. The questions are as followed:
- Questions Regarding the Incident and Arrest
- Can you describe the exact location and circumstances under which you first observed Mr. Bathsheba driving on the incorrect side of the highway?
- Did you see where Mr. Bathsheba was coming from?
- How long did it take you to make a U-turn and initiate the stop after you observed the infraction?
- Can you explain what you did, to conduct this traffic stop?
- Questions Regarding the Search and Evidence
- Can you confirm how many marked bills you found on Mr. Bathsheba during your search?
- When you found the bills, did you immediately believe that they were stolen?
If yes:
- How did you determine that these bills were stolen?
- Did the defendant tell you anything regarding where they got the bills from?
- Did you look into these claims?
If NO
- Why did you not look into the claims?
- Search of the Vehicle:
- You mentioned that another deputy searched Mr. Bathsheba’s bike. Were you present during that search?
- Can you tell us what was found in the bike when it was searched?
- Did you see with your own eyes, that there was packed cash inside of the bike before the other deputy told you there was?

Public Defense Attorney
San Andreas Judicial Branch
(909) 2956979 — [email protected][/list] 
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 16 Jul 2024, 23:21
by Bret Hyland

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. Defendant
#24-CM-0024
A decision was reached in the above case on the 16th day of July, 2024.
Defense, I have reviewed your questions and found the answers to most of these in evidence already submitted by the prosecution.
Can you describe the exact location and circumstances under which you first observed Mr. Bathsheba driving on the incorrect side of the highway
incorrect side of the highway on Senora Fwy, Exhibit #2
Did you see where Mr. Bathsheba was coming from?
Please provide additional information as to relevance,
How long did it take you to make a U-turn and initiate the stop after you observed the infraction?
Please provide additional information as to relevance
Can you explain what you did, to conduct this traffic stop?
Exhibit #2
Can you confirm how many marked bills you found on Mr. Bathsheba during your search?
"other deputy searched his bike and found 2 more stacks of the same marked bills" With 3 packs logged into evidence I would be inclined to believe 1 was found on the person based on the evidence Exhibit #2
When you found the bills, did you immediately believe that they were stolen?
It is my understanding that the traffic stop was conducted based on a traffic infraction, followed by an MDC run outlining outstanding fines, GM#16
You mentioned that another deputy searched Mr. Bathsheba’s bike. Were you present during that search?
After doing this I searched his person and found a stack of clearly marked bills. Whilst I was doing this the other deputy searched his bike and found 2 more stacks of the same marked bills which in total accounted for several thousand dollars worth of marked bills. Exhibit #2
Can you tell us what was found in the bike when it was searched?
After doing this I searched his person and found a stack of clearly marked bills. Whilst I was doing this the other deputy searched his bike and found 2 more stacks of the same marked bills which in total accounted for several thousand dollars worth of marked bills. Exhibit #2
Did you see with your own eyes, that there was packed cash inside of the bike before the other deputy told you there was?
Please provide additional information as to relevance
At this time I see no reason to collect additional information from the officer to answer the questions you have presented. Marked bills are typically flagged by law enforcement for monitoring, thus these would be assumed stolen as a bank would not issue marked bills to the general populace during a bank transaction.

Superior Judge
San Andreas Judicial Branch
(909) 225-3056 — [email protected] 
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 18 Jul 2024, 23:47
by Jay Wellberg
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 20 Jul 2024, 23:02
by Terence Williams

San Andreas Judicial Branch
Docket Notice
"HERE FOR YOU | SAFE FOR YOU" |
- Honorable Judge Hyland and pertaining parties,
While the Judge on the case has already responded to the Defense's initial Motion to Compel, the Prosecution would like to give a final response.
Firstly, there is no need for the Defense to have the information regarding any extenuating circumstances, potential reasons for behaviour, or other contributory factors for the deputy to stop the defendant for reckless driving. This is covered under law enforcement officer (LEO) discretion, as is charging the defendant, and should rather be a point for the Defense to bring up in opening and closing arguments at trial.
Secondly, the question on timing between witnessing the traffic violation and the traffic stop hopes to set dangerous precedent, stating LEOs MUST pull over drivers for traffic violations in X amount of time from witnessing the violation as a question of "proper procedural conduct in prompt succession." LEOs have the discretion to investigate violations and crimes alike in any capacity, with no single precedent, procedure, nor constitutional right stating that LEOs are required to immediately seek to stop violations in action to apply charges accordingly.
Thirdly, the chain of custody has already been brought up by the Defense and then belabored and ruled upon by the presiding judge, stating it is an inconsequential argument. To continue to press a point already dismissed by the judge seeks to breach due process and goes against the "proper procedural conduct" the Defense seeks to protect.
Lastly, Defense counsel is more than able to question their defendant and provide a statement with their recount of events that would allow for them to find the whole context of the incident which they seem to be looking for. The Prosecution whole-heartedly objects to the notion that the Defense is trying to call a Prosecution witness to the stand, as it breaches ethical concerns of contact with the adverse party. Individuals are not compelled to testify in the State of San Andreas, testimony has to be given voluntarily, and for the Defense to suggest they will reach out to the Prosecution's witness is a breach of simple, judicial procedure.
Regards,

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

Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 20 Jul 2024, 23:11
by Jay Wellberg
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 23 Jul 2024, 22:09
by 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. Stelio Bathsheba
A Notification of Counsel was filed in the above case on 23/JUL/2024.
I, Michael Blaise, Prosecuting Attorney of the San Andreas Judicial Branch, will be representing the State of San Andreas in the underlying case.
I will be taking the responsibility of Co-Counsel alongside Acting Attorney General Terence Williams as Primary Counsel and will await further instruction from the Presiding Judge.

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

Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 24 Jul 2024, 23:25
by Bret Hyland

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. Stelio Bathseba
#24-CM-0024
A decision was reached in the above case on the 24th day of July, 2024.
You will be granted your request to submit your questions to the deputy under the assumption said officer is still under oath, a member of a department, you will be granted 1 week to collect your evidence and submit it as evidence to this case. Please take this as me showing you and your department respect in an effort to afford you the ability to present a reason for this request.
I realize I have been lacking in my responses to this case and this is partly why I am granting this, to provide you an opportunity to collect more evidence. During this time, whilst you are questioning the lead officer, I will also grant the prosecution an opportunity to question your defendant (within the constitutional rights afforded to them by the constitution).
Both sides have 1 week to submit their findings to the docket, should this not be logged into the file by then we will be moving to trial.
I have delayed this case to long as it is, and for that I apologize. Thus we will be holding this trial either the 3rd or the 4th. I will submit that to you the scheduling tool shortly.

Superior Judge
San Andreas Judicial Branch
(909) 225-3056 — [email protected] 
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 24 Jul 2024, 23:30
by Bret Hyland

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"
NOTICE OF SCHEDULING
IN THE SUPERIOR COURT OF SAN ANDREAS
State of San Andreas v. Stelio Bathseba
#24-CM-0024
An attempt to schedule was made and recorded by the court on 24th day of July 2024.
All parties in this case are encouraged to complete the following Scheduling Tool in an attempt to schedule a trial on the above case.
In the event all parties have overlapping availability the Presiding Judge will determine the best date and time to have a trial take place and post a Notice of Trial informing all of the upcoming proceeding.
In the event some or all parties do not have overlapping availability, the Presiding Judge will continue to attempt to schedule the proceeding or seek alternative avenues to conclude the case.
If either party has the intentions of calling a witness to the stand during the proceeding they must inform the court by filing a Witness List at the time of filing their availability. If no Witness List is filed before the Notice of Trial is filed you will be unable to call a witness during the proceeding.

Superior Judge
San Andreas Judicial Branch
(909) 225-3056 — [email protected] 
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 25 Jul 2024, 14:48
by Jay Wellberg
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 25 Jul 2024, 15:23
by Terence Williams
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 25 Jul 2024, 20:32
by Bret Hyland

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"
COURT NOTICE
IN THE SUPERIOR COURT OF SAN ANDREAS
State of San Andreas v. Stelio Bathseba
#24-CM-0024
A notice is issued pertaining to the above case on the 25th day of July, 2024.
Further clarification in response to the above Notices.
In no way am I authorizing or suggesting that the constitutional rights of the defendant be violated, but should your client wish to speak to the prosecution or lodge questions to the defendant I see no issue for this, your client should be advised of his rights, and perhaps consult his attorneys prior to submittal of his responses. If your client is willing to testify or speak at the trial, then this would be the preferred venue. Still, experience shows that typically defendants refuse to participate outside of attending and protesting verdicts, thus should the prosecution have questions they wish to present to your client, to add clarity to the trial I see no issue with this, within the confines of the constitution.
Defense, please note that your questions will also fall within the confines of the constitution and should you be questioning the prosecutions witness it is advised that the witness be afforded an attorney from the prosecutors office. It is also important to note that as stated by the prosecution, this witness is no longer employed by the Sheriff's office, and as such will no longer have access to information you may wish answered, procedures of the department, or documents that would be instrumental to refresh his memory. You shall ensure the prosecution is present for questioning should it occur in person.
Outcomes favorable, or not, or lack of answers caused by these actions will not delay the trial date, as both sides have been afforded ample time, especially considering the delays I put on the file, to get this done prior to this point.
The process for these questions of the witness and/or defendant will be as follows.
Both parties will submit their line of questions to this file, which will be reviewed by myself and the opposition, once approved, or modified, the parties will send these questions to the opposing council's witness/defendant, ensuring to CC the respective opposite council. The respondents will be requested to respond, failure to do so within 48 hours the respondent's counsel is to reach out to their respective party, and ask them to respond, providing evidence of this and any responses returned, to this file, this will repeat every 48hrs until a response is submitted, or until the 11:59pm, on the 1st day of August. Please note, I expect parties to conduct themselves in accordance with the Barr association, Barr licensing, Ethics board, and the constitution during this, failure to submit the responses from the clients will be subject to review.
Evidence collect from this will be permitted to the court during the trial, at which times objections will be heard, and ruled on at that time.
The second option and my preferred, would be for the witness/defendant to join us during court for questioning, and to provide his recount of the events, at which time it is advised their councils prepare them, and have a list of questions read for both witness and defendant. This option will allow for cross-examination, statements, and objections to be lodged during the trial.
Questions are to be submitted here within 24hours for review, we will approve within the 24hours following should a party fail to respond to the questions proposed by the opposing counsel, the questions will be submitted under the assumption that the opposing council has no objections to the questions.

Superior Judge
San Andreas Judicial Branch
(909) 225-3056 — [email protected] 
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 28 Jul 2024, 22:35
by Terence Williams
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 29 Jul 2024, 10:47
by Bret Hyland

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. Steilo Bathsheba
#24-CM-0024
A decision was reached in the above case on the 29th day of July, 2024.
Defense you have 12hours to submit your line of questioning for review, and 12hours to review prosecutions questions. Failure to submit your feedback, and or questions shall be a missed opportunity.
I will review the scheduling and put up some additional options, shortly.

Superior Judge
San Andreas Judicial Branch
(909) 225-3056 — [email protected] 
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 29 Jul 2024, 14:32
by Jay Wellberg

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"
Honorable Judge Hyland and pertaining parties,
The defenses questions remain the same as the motion for discovery,
► Show Spoiler
[*]Questions Regarding the Incident and Arrest
- Can you describe the exact location and circumstances under which you first observed Mr. Bathsheba driving on the incorrect side of the highway?
- Did you see where Mr. Bathsheba was coming from?
- How long did it take you to make a U-turn and initiate the stop after you observed the infraction?
- Can you explain what you did, to conduct this traffic stop?
[*]Questions Regarding the Search and Evidence
- Can you confirm how many marked bills you found on Mr. Bathsheba during your search?
- When you found the bills, did you immediately believe that they were stolen?
If yes:
- How did you determine that these bills were stolen?
- Did the defendant tell you anything regarding where they got the bills from?
- Did you look into these claims?
If NO
- Why did you not look into the claims?
[*]Search of the Vehicle:
- You mentioned that another deputy searched Mr. Bathsheba’s bike. Were you present during that search?
- Can you tell us what was found in the bike when it was searched?
- Did you see with your own eyes, that there was packed cash inside of the bike before the other deputy told you there was?

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

Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 29 Jul 2024, 15:10
by Bret Hyland

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. Steilo Bathsheba
#24-CM-0024
A decision was reached in the above case on the 29th day of July, 2024.
Defense, Prosecution, you both have 12hours to review the questions, should there be no responses, or no justification why the questions shouldn't be asked than these will be pushed to each team to distribute to their respective clients.

Superior Judge
San Andreas Judicial Branch
(909) 225-3056 — [email protected] 
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 30 Jul 2024, 21:31
by Terence Williams
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 30 Jul 2024, 22:16
by Bret Hyland
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 30 Jul 2024, 22:53
by Terence Williams

San Andreas Judicial Branch
Docket Notice
"HERE FOR YOU | SAFE FOR YOU" |
- Honorable Judge Hyland and pertaining parties,
Please find the Prosecution's witness' answers to the Defense's questions posted below.
Lester Conway wrote: ↑30 Jul 2024, 22:06
Can you describe the exact location and circumstances under which you first observed Mr. Bathsheba driving on the incorrect side of the highway?
Due to the time that has elapsed since the arrest, I cannot recall this information.
Did you see where Mr. Bathsheba was coming from?
The north.
How long did it take you to make a U-turn and initiate the stop after you observed the infraction?
Due to the time that has elapsed since the arrest, I cannot recall this information.
Can you explain what you did, to conduct this traffic stop?
Followed standard SD protocol for a traffic stop.
Can you confirm how many marked bills you found on Mr. Bathsheba during your search?
2 marked bills in his vehicle and 1 marked bill on his persons, as stated in my witness statement.
When you found the bills, did you immediately believe that they were stolen?
Yes.
How did you determine that these bills were stolen?
They were clearly marked with a dye pack.
Did the defendant tell you anything regarding where they got the bills from?
Due to the time that has elapsed since the arrest, I cannot recall this information.
Did you look into these claims?
Due to the time that has elapsed since the arrest, I cannot recall this information.
You mentioned that another deputy searched Mr. Bathsheba’s bike. Were you present during that search?
Yes.
Can you tell us what was found in the bike when it was searched?
2 marked bills, as stated in my witness statement.
Did you see with your own eyes, that there was packed cash inside of the bike before the other deputy told you there was?
Due to the time that has elapsed since the arrest, I cannot recall this information.
God bless and God speed,
Regards,

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

Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 30 Jul 2024, 23:22
by Jay Wellberg

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"
Honorable Judge Hyland and pertaining parties,
The defendant would like to and will be executing his 5th amendment right.

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

Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 30 Jul 2024, 23:59
by Bret Hyland
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 31 Jul 2024, 19:44
by Jay Wellberg

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"
MOTION TO STAY PENDING APPEAL
IN THE SUPERIOR COURT OF SAN ANDREAS
State of San Andreas v. Stelio Bathsheba
#24-CM-0024
A Motion to Stay Pending Appeal was filed in the above case on the 31st of July, 2024.
The Defendant, Stelio Bathsheba, by and through the undersigned attorney, filed this Motion to Stay Pending Appeal, and the reasoning for request is as follows;
- Reasoning: The Public Defense in this case has initiated an appeal within the San Andreas Court of Appeals following the latest Court Decision.

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

Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 01 Oct 2024, 03:14
by Hope Kant
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 04 Nov 2024, 20:48
by Luna McMillan
Re: #24-CM-0024, State of San Andreas v. Stelio Bathsheba
Posted: 07 Nov 2024, 11:30
by Luna McMillan