Eclipse Government

Colt Daniels wrote: ↑03 Nov 2021, 03:30

Motion to Compel Discovery

San Andreas Judicial Branch
Motion to Compel Discovery

Honorable : Bret Hyland

• We the defense in the case below are requesting the disclosure of the following material by opposing counsel, please find a detailed reason as to our request below.

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  Felix Noonham vs. The LSPD
  Assigned Court Case Number: N/A
  Requesting Party: Defense
  Party Members: Felix Noonham, Colt Daniels

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  Discovery from: The LSPD
  
  Type of Discovery: Document Request
  • The Detective Bureau Case-File used to detain the appellant.
  Detailed reasoning:
  • This case-file will show the legitimacy of the detention of my client & the entirety of the case is based on if the LSPD had probable cause to detain and search my client and his vehicle.

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  Thank you for your consideration.

Sincerely

District Criminal Defense Attorney
San Andreas Judicial Branch
(909) 402-9713 — [email protected]

Colt Daniels wrote: ↑09 Dec 2021, 04:33

Motion to Compel Discovery

San Andreas Judicial Branch
Motion to Compel Discovery

Honorable : Judith Mason

• We the defemse in the case below are requesting the disclosure of the following material by opposing counsel, please find a detailed reason as to our request below.

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  Felix Noonham vs. The LSPD
  Assigned Court Case Number: 21-10-29-AP-013
  Requesting Party: Defense
  Party Members: Felix Noonham, Colt Daniels

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  Discovery from: LSPD
  
  Type of Discovery: Document Request
  • Bodycam Footage, Officer Statements, Arrest Report, & Situation Report.
  Detailed reasoning:
  I would like to see the footage of how the situation unfolded and what reasoning the detectives gave Mr. Noonham to detain him and search his person and property. I would also like to have statements from the detectives and officers involved explaining their interpretations of what took place during this situation. I would also like to see all reports filed as a result of this arrest (Arrest Report and Situation Report) to see if it includes any information that would be useful to the case.

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  Thank you for your consideration.

Sincerely

District Criminal Defense Attorney
San Andreas Judicial Branch
(909) 402-9713 — [email protected]

Jason Steel wrote: ↑26 Feb 2022, 18:00

Motion for Discovery

San Andreas Judicial Branch
Motion for Discovery

Honorable Judith Mason,

• We the Respondent in the case below are presenting our discovery to the court.

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  Felix Newnham v. Police Department
  Assigned Court Case Number: #21-10-29-AP-013
  Requesting Party: Defendant
  Party Members: Police Captain II Jason Steel, Police Detective I Grace Steel

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  Exhibit #1: LSPD
  Type of Discovery: Physical Evidence
  • Written report submitted by a sworn officer about their interaction with the appellant a short amount of time before the incident being appealed.
  Spoiler

  All Information from the Discovery This evidence is highly relevant as it occurred a short amount of time prior to the incidents that are being disputed by the appellant, and it shows the individuals disposition to flee from law enforcement, information which other officers, including Detective Steel and Captain Steel would've had access to.

  • 
    

    Los Santos Police Department TRAFFIC STOP REPORT "TO PROTECT AND SERVE"

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    • TRAFFIC STOP DETAILS
      • Location: Bay City Avenue
        Narrative: Reckless Operation
        Additional Units: 23-S-2
        Approx. Time and Date: 23/OCT/2021, 20:20

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      VEHICLE DETAILS
      • Vehicle Driver: Felix Noonham
        Vehicle Owner: Felix Noonham
        License Plate: F3LIX
        Vehicle Model: Issi Sport
        Vehicle Color: Silver
        Vehicle Passengers (If Applicable): N/A

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      TRAFFIC STOP OUTCOME
      Please add a "X" all relevant areas. When issuing a citation, license suspension (length), or charge, amend "Specify" inside the parenthesis.
      
      
      • Action Taken:
        [ ] Verbal Warning
        [ ] Citation (Specify)
        [ ] Demerit
        [X] License Suspension (2 days)
        [X] Charge (VM03 - Reckless Operation of a Road or Marine Vehicle)
      • Stop Verdict:
        At approximately 2015 I pulled over an individual in silver/gray Issi Sport for flying down the Bay City Avenue whilst going 158 km/h. I was suggested by an SAM unit to arrest the individual for reckless operation, considering the speed and the amount of road he was airborne. I informed individual to step out of the vehicle since he is being under arrest. After hearing those words, Felix Noonham decided to disobey my direct orders and felony evade from the scene. We initiated a pursuit in TAC 1 & requested for a high speed unit. The pursuit continued for around 20 minutes throughout the city and on Del Perro Freeway. After driving recklessly for quit a bit, suspect collided with a building and was arrested by first arriving units.
    
  Exhibit #2: LSPD
  Type of Discovery: Physical Evidence
  • Picture of the appellant on the scene of his arrest on the 23rd of October, wearing extremely similar (if not identical) clothing as the day when he was searched by the defendants.
  Spoiler

  All Information from the Discovery This is supporting evidence for Exhibit #1, showcasing the defendants clothing was not a one-time fluke but a uniform that he wore proudly whenever he committed crimes against the the penal code, and which he was wearing during the incident which is being appealed.

  • 

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Sincerely,


Jason Steel
Police Captain II, Los Santos Police Department

Jason Steel wrote: ↑26 Feb 2022, 18:08

Motion to Compel Discovery

San Andreas Judicial Branch
Motion to Compel Discovery

Honorable Judith Mason,

• We the Respondent in the case below are requesting the disclosure of the following material by opposing counsel, please find a detailed reason as to our request below.

  ---

  Felix Newnham v. Police Department
  Assigned Court Case Number: #21-10-29-AP-013
  Requesting Party: Defendant
  Party Members: Police Captain II Jason Steel, Police Detective I Grace Steel

  ---

  Discovery from: Plaintiff
  
  Type of Discovery: Deposition
  • We would like the plaintiff to clearly admit or refute the fact that, at the time of the events, he was affiliated with a criminal organization.
  Detailed reasoning: [Provide a detail explanation as to the relevance of the discovery request]
  • The plaintiff failed to address the accusation that he is affiliated with a criminal organization, and we believe that it is highly relevant when his initial statement is attempting to paint him as a regular citizen whom is just minding his own business, when in actuality, he was armed with a loaded firearm, with a suppressor in his possession and was sporting the uniform of a criminal organization. We believe that his membership in a criminal organization is highly relevant to the narrative being pushed by the plaintiff and we would like him to speak on record about it.

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Sincerely,


Jason Steel
Police Captain II, Los Santos Police Department

Dakota Macaw wrote: ↑26 Feb 2022, 19:00

Motion to Suppress

San Andreas Judicial Branch
Motion to Suppress

Honorable Judith Mason,

• We the Appellant in the case below are requesting that certain evidence be inadmissible in court.

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  Felix Newnham v. Police Department
  Assigned Court Case Number: #21-10-29-AP-013
  Requesting Party: Appellant
  Party Members: Felix Newnham, Dakota Macaw

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  Requested Evidence to Suppress: Exhibit #1 "Written report submitted by a sworn officer about their interaction with the appellant a short amount of time before the incident being appealed."

  ---

  Detailed explanation:
  The Appellant's previous history with law enforcement is inconsequential to the search and or seizure of the appellant's property or person. Whether or not an individual has a criminal history or not does not change the inherent protections that all citizens may enjoy when conducting their day-to-day activities. Criminal history is not admissible as sufficient probable cause, and although there are many precautions that the Police Department and law enforcement in general may take when confronting repeat-offenders, they may not conduct searches and or seizure without valid probable cause.
  

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Sincerely,


Attorney Dakota Macaw
San Andreas Judicial Branch
(909) 419-3141 — [email protected]

Dakota Macaw wrote: ↑26 Feb 2022, 22:03

Motion to Compel Discovery

San Andreas Judicial Branch
Motion to Compel Discovery

Honorable Judith Mason,

• Firstly I would like to concur with the respondent's request for a hearing and look forward to meeting in hearing soon.
  
  Before this though, we the Appellant in the case below are requesting the disclosure of the following material by opposing counsel, please find a detailed reason as to our request below.

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  Felix Newnham v. Police Department
  Assigned Court Case Number: #21-10-29-AP-013
  Requesting Party: Appellant
  Party Members: Dakota Macaw, Felix Newnham

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  Discovery from: LSPD
  
  Type of Discovery: Physical Evidence
  • We the Appellant Request the firearm and all related contraband that was allegedly found in Mr. Newnham's vehicle to be submitted to evidence.
  Detailed reasoning:
  • As the charges that are being appealed are based off of this exact evidence, proof of their existence (and clarification of any serial numbers) will be necessary to continue with the case.

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Sincerely,


Attorney Dakota Macaw
San Andreas Judicial Branch
(909) 419-3141 — [email protected]

Jason Steel wrote: ↑27 Feb 2022, 00:51

Motion for Discovery

San Andreas Judicial Branch
Motion for Discovery

Honorable Judith Mason,

• We the Respondent in the case below are presenting our discovery to the court.

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  Felix Newnham v. Police Department
  Assigned Court Case Number: #21-10-29-AP-013
  Requesting Party: Apellant/Plaintiff
  Party Members: Police Captain II Jason Steel, Police Detective I Grace Steel

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  Exhibit #1: LSPD
  Type of Discovery: Physical Evidence
  • Written report submitted by a sworn officer about the firearm being entered into evidence, including serial number information, as requested.
  Spoiler

  All Information from the Discovery The evidence was requested by the appellant.

  • 
    Pistol .50 / Hawk & Little

    

    • Ammunition (.50): x25 / .50 AE
    • Modifications: Suppressor
    • Serial Number: Scratched off
    • Person in Possession: Felix Noonham - 4861466
    • Weapon Outcome: Destroyed : Illegal

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Sincerely,


Jason Steel
Police Captain II, Los Santos Police Department

Jason Steel wrote: ↑04 Mar 2022, 23:57

Motion for Summary Judgment

San Andreas Judicial Branch
Motion for Summary Judgment

Honorable Judith Mason,

• We the Respondent in the case below are requesting a summary judgment.

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  Felix Newnham v. Police Department
  Assigned Court Case Number: #21-10-29-AP-013
  Requesting Party: N/A
  Party Members: Jason Steel, Grace Steel, Sai Modi

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  Reasoning: The evidence when taken together shows that the actions taken by law enforcement were lawful beyond a reasonable doubt.

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  Detailed explanation:
  A large amount of evidence, which is dated, was presented to yourself and the opposing counsel, showing the legal basis for the actions of the officers that day. It is our belief that when reviewed, they objectively show that no unlawful actions took place on that day. As the appellant already confirmed that the pistol and suppressor were found in his motorbike, and with the legality of the search being clearly proven, any other esoteric, circumstantial and speculative claims are not relevant, in our opinion, and are to be taken as beyond the scope of this appeal. We are already to expand on this verbally during a hearing, if your honor deems it acceptable.

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  Thank you for your consideration.

Sincerely,


Jason Steel
Police Captain II, Los Santos Police Department