#24-CM-0030 State of San Andreas v. Mike Luigi

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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

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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. Mike Luigi
#24-CM-0030

An Objection was filed in the above case on the 30th of December, 2024.


The State of San Andreas, by and through the undersigned attorney, filed this objection to a recent motion by the Defense;


  • Motion being objected to: Defense's Motion to Compel Discovery
    • Detailed Reasoning: The Defense has filed a Motion to Compel Discovery for the court to order the Prosecution to provide housing records for 13 Occupation Avenue between 1/MAR/2023 to 1/JUN/2023. Because the Defense has tried and been unable to obtain its own evidence does not mean that the Prosecution should be forced to seek the same evidence, which in this case is not already in its possession. If there is difficulty getting certain evidence, a subpoena or search warrant should be filed instead.



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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Hugh Allgood »

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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. Mike Luigi
#24-CM-0030

A Motion to Compel Discovery was filed in the above case on the 31st day of December, 2024.


The Defendant, Mike Luigi, by and through the undersigned attorney, filed this Motion to Compel Discovery, and requests as follows;


  • Requested Discovery: Any and all information (e.g statements, contracts, identities of persons who reached out, etc.) received by the prosecution in response to the Attorney General’s request for information.
    • Detailed Reasoning: In October 2024, the Attorney General released a public statement requesting members of the public who were under contract with, or previously were under contract with, Total Bankers to come forward with information pertaining these contracts. This became an issue of contention during the state-sanctioned delay where the State indicated the stay was necessary for them to fulfill their obligations as a prosecutor. However, despite this public release, which undoubtedly cost the taxpayers of San Andreas greatly, the prosecutor has not released any information from this venture. The Defense has information to believe several persons did in fact speak with the Attorney General (in fact, Defense Counsel was even approached by several individuals at City Hall asking for assistance in getting copies of contracts from Total Bankers), yet this information has not made it into discovery. The Defense believes this information could potentially contain exculpatory evidence, which the prosecution is bound to provide to the defense.





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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Hugh Allgood »

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Defense response
"Right Firm. Right Now"

  • Judge Fitzgerald ,

    To provide our one response to the prosecution’s objection to the defense motion to compel discovery - the defense cannot obtain these records via search warrant or subpoena. A search warrant only works/required to get information when the initiating party is the government. Defense has no lawful authority to apply for search warrants, which are effectively Court “permission” to search or seize something or someone. As far as a subpoena, effectively same rationale. Although a subpoena for records does seem to be an option for a defense attorney to follow, that process has so far not been made available to defense counsel having only recently been used by the prosecution in San Andreas. The format nor process for doing so has been made available to defense counsel or self-representation.

    The prosecution claims because they don’t have this information currently is a safe guard for them to having to provide it. This is unfair for the defendant, who constitutionally has a right to have compulsory process to get information or witnesses. Which traditionally in all of counsel’s time in the branch, came through a motion to compel discovery (which is why this format does in fact exist in the self-representation section, whereas the subpoena doesn’t)

    The motion does not have to be directed towards the Attorney General either - therefore the fact the prosecutor has it or doesn’t should not be a barrier to the Court ordering the disclosure through compulsion. The order, if granted, would be directed towards PHB, who would then be ordered to provide this information to the Defense per our request.

Respectfully,
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Hugh Allgood »

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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. Mike Luigi
#24-CM-0030

A Motion for Continuance was filed in the above case on the 31st day of October, 2024


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


  • Reasoning: counsel out of state
    • Detailed Explanation: As Defense notified the Court and opposing counsel a few days ago, Counsel is currently in Liberty City for the week ((vacation and currently only with mobile access which has proven to be very challenging to get formats and such for the forums)), and therefore to adequately respond to the order of the Court to provide additional discovery, Defense Counsel needs time to get back to his office in San Andreas as well as arrange a time with the Defendant to collect these additional emails. Therefore, Defense requests the Court give Defense until at least mid-week of the week of 5/Jan/2025 so counsel can appropriately address this matter.



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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

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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. Mike Luigi
#24-CM-0030

An Objection was filed in the above case on the 1st of January, 2025.


The State of San Andreas, by and through the undersigned attorney, filed this objection to a recent motion by the Defense;


  • Motion being objected to: Defense's Motion to Compel Discovery regarding the AG's Office's request for information
    • Detailed Reasoning: The Prosecution is not against sharing the information gained through the request made to the public in early October of last year, as has always been the plan. However, the Prosecution is objecting to releasing the identities of individuals who stepped forward, which didn't result in any actionable evidence such as the Defense requests. While allegedly intending to aid the Prosecution initially, these individuals never followed up on the Prosecution's request to bring any actionable evidence or make official statements. As such, the Prosecution believes it to be in the best interest of these individuals to keep their identity secret to protect their privacy. The individuals are all alleged clients of the defendant, who could go through their client list and reach out to potential witnesses privately.



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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Terence Williams »

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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. Mike Luigi
#24-CM-0030

A Motion for Discovery was filed in the above case on the 31st 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 #18: Total Bankers contract - Shawn Jo
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    SUPPRESSED - Exhibit #19: Total Bankers contract - Filip Wong
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    Exhibit #20: SAJB Public Notary standard loan contract
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    San Andreas Judicial Branch
    Vehicle Purchase Agreement
    "HERE FOR YOU | SAFE FOR YOU"



    Party 1- "Lender"

    • Name: Firstname Lastname
    • Date of Birth: DD/MMM/YYYY
    • Mailing Address:
    • Contact Information:
    Party 2- "Borrower"

    • Name: Firstname Lastname
    • Date of Birth: DD/MMM/YYYY
    • Mailing Address:
    • Contact Information:

    Loan Specifics
    • Loan Amount: $XX,XXX
    • Interest Rate (0%-80%): %XX
    • Total Amount Due: $XX,XXX
    • Repayment Date: DD/MMM/YYYY
    • Purpose of Loan:

    Collateral
    • Total Collateral Estimated Worth: $XX,XXX
    • Supporting Items & Collateral: Item 1 ($XX,XXX) | Item 2 ($XX,XXX) | Item 3 ($XX,XXX) | Item 4 ($XX,XXX) | Item 5 ($XX,XXX)

    Terms of Agreement
    1. Payment Plan:
      • The BORROWER agrees to pay the LENDER WEEKLY payments of $XX,XXX, Which will occur every WEEK until the contract is Terminated or COMPLETED.

        Missing a payment will result in notice being issued to the BORROWER by the LENDER of their failure to pay. It is the duty of the BORROWER to pay the LENDER the outstanding amount before the time of the next due payment. Failing to pay for a second time will result in the BORROWER being declared in DEFAULT as outlined in Section II. DEFAULT.

        If agreed to by both parties, the BORROWER may pay lump sum instalments, but these will not be classed as weekly payments paid in advance.
    2. Default:
      • If the BORROWER fails to pay TWO consecutive payments they will be placed into DEFAULT, After being placed in DEFAULT the LENDER has the right to seize the COLLATERAL.

        While the BORROWER is still in DEFAULT the LENDER retains this right. The BORROWER will no longer be in DEFAULT when they are able to reduce their number of outstanding missing payments to one or less

        Upon TERMINATION the LENDER may sell any COLLATERAL to cover any Outstanding payments and any excess money shall be returned to the BORROWER

        Any missed payments shall accrue an additional missed payment fee of $25,000 if not paid within 24 hours of the due date this missed payment shall be made paid by the BORROWER before the next due payment
    3. Collateral:
      • Any Collateral put forward shall be, upon the signature of this document, owned by the LENDER but in the possession and usage of the BORROWER

        Upon the payment of any missed payments plus any additional charges the COLLATERAL shall be returned as per the above written clause

        Upon TERMINATION of this contract the LENDER shall hold the right to Sell or dispose of any COLLATERAL in order to settle any outstanding fees

        Upon the COMPLETION of this contract the titles and ownership of the COLLATERAL shall be returned to the BORROWER
    4. Legal Fees:
      • If either party brings an Action to enforce their rights under this agreement, the prevailing party may recover its expenses (including reasonable attorneys' fees) incurred in connection with the Action and any appeal from the losing party.
    5. Termination:
      • This contract will be automatically TERMINATE upon the BORROWER being in DEFAULT for 1 WEEK any missed payments shall accrue an additional missed payment fee of $25,000 and any COLLATERAL can be disposed or sold to pay for outstanding payments

        This contract can also be TERMINATED if the amount is not paid by the Repayment Date
    6. Completion:
      • This contract will be considered complete upon the repayment of the full amount due with any interest or added costs
    7. Safety:
      • This agreement will pass to the benefit of, and be binding upon the respective heirs, executors, administrators and successors of the LENDER or the BORROWER
    8. Severability:
      • If any part of this agreement is found to be unenforceable, the rest of this agreement will remain enforceable while any section in question will become void.
    9. Jurisdiction:
      • This contract was drafted following the Penal Code and guidelines of the State of San Andreas, whose courts shall have sole jurisdiction over any and all disputes that may arise, subject to the Dispute Resolution Clause of this contract.
    10. Sales Tax:
      • In the State of San Andreas, failure to pay sales tax is a misdemeanour crime. The Lender will have the sole responsibility, upon receiving payments from the Tenant, to document both the receipt of the payments as well as their payment of the sales tax at City Hall.
    Signature:

    BORROWER NAME
    Borrower
    Date: DD/MMM/YYYY

    LENDER NAME
    Lender
    Date: DD/MMM/YYYY
    Exhibit 21: Maze Bank Central standard loan contract
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    Maze Bank Central

    Loan Contract
    "A Business for Better Business"

    This loan agreement is made and will be effective on DD/MMM/YYYY.

    The Borrower's Information
    • Full Name:
      • **REPLACE THIS TEXT**
      Loan Inquiry Form:
      • **PASTE HERE**
    The Lender's Information
    • Full Name:
      • Maze Bank Central
      Contact Details:
      • Phone Number: 5824080
        Mailing Address: San Andreas Ave. 3
        ((Discord ID: thunderboss#4746))

    Loan Details
    • The lended amount:
      • $
      Interest Percentage:
      • **ANSWER**
      Total loan amount:
      • $
      The loan is to be paid back in full:
      • **ANSWER**
      Supporting assets & collaterals:
      • **ASSET 1**
      • **ASSET 2**
      • **ASSET 3**

    Signatures

    • By signing this, you confirm that all the above details are correct and agree to the terms & conditions listed bellow.

      The borrower:
      • **Firstname Lastname**
        FNAME LNAME
      Maze Bank Central:
      • SIGNATURE
        Executive Officer - Samuele Colonna
      Shadow Corp. :
      • SIGNATURE
        Chief Technology Officer - Samuele Colonna

    • Terms, Conditions & Liabilities:
      This loan agreement constitutes the entire agreement between the borrower and the lender, and supersedes all prior agreements or understandings, whether written or oral. This includes, but is not limited to, any prior agreements or understandings that may have been made orally or in writing, or any prior versions of this loan agreement. This loan agreement contains the entire understanding of the parties with respect to the subject matter hereof and there are no promises, representations, or inducements other than those contained in this agreement.

      This loan agreement may not be amended or modified except in writing signed by both the borrower and the lender. Any attempts to alter or modify the terms of this agreement, whether orally or in writing, shall be null and void unless the amendment or modification is made in writing and signed by both parties. It is the responsibility of the borrower to carefully review the terms of this agreement before signing, and to seek legal counsel if necessary.

      This loan agreement may be signed by multiple individuals, in which case they shall be jointly responsible for paying the loan. Each of the undersigned represents and warrants that they are fully aware of the terms and conditions of this loan agreement, and they agree to be jointly and severally liable for the repayment of the total loan amount. In the event that any one of the borrowers fails to fulfill their obligations under this agreement, the other borrowers shall be fully responsible for satisfying the outstanding debt. The lender may seek to collect the full amount of the loan from any or all of the borrowers at their discretion. It is the responsibility of the borrowers to ensure that the loan is paid in a timely manner and in accordance with the terms of this agreement. The borrower shall also designate one primary contact who the loan will be issued to, and who shall be responsible for receiving and responding to all notices, requests, and other communications from the lender, as well as for providing updates or changes to the borrower's contact information.

      In the event of the borrower's death or deportation, all debts and liabilities under this loan agreement must be resolved prior to the execution of any estate or will transfers. The borrower's involvement in illegal activity that is funded by or conducted on a property owned or managed by Maze Bank Central or Shadow Corporation shall also be considered a default of this loan. Changing the borrower's name or identity will not absolve the borrower of their debt or responsibilities under this agreement. The borrower is not permitted to transfer any funds or assets funded by the loan to another individual or entity without prior approval from the lender. Any breach of this provision may result in the default of this loan contract and the lender may take any and all actions necessary to protect their interests.

      Maze Bank Central and Shadow Corporation reserve the right to terminate this loan at any time for any reason, and may request that the borrower immediately resolve all outstanding debts under this agreement with a discount of 10%.

      The borrower shall be responsible for the proper care and maintenance of any collaterals that are in the name of Maze Bank Central but are currently in the use of the borrower. This includes, but is not limited to, any fees or expenses associated with the collaterals, such as citations, maintenance services, and repairs. The borrower agrees to cover all such fees and expenses in full, without exception. Failure to do so may result in the borrower being in breach of this loan agreement.

      Maze Bank Central and Shadow Corporation, as the lender in this loan agreement, retain the right to inspect the property at any time, with or without prior notice, to ensure that the borrower is in compliance with the terms of this agreement. This inspection may include, but is not limited to, visual inspections of the interior and exterior of the property, as well as any and all improvements made to the property. The borrower hereby consents to such inspections and agrees to grant access to the property for the purpose of such inspections upon request.

      In the event of default on the loan, the borrower shall be responsible for paying a penalty of $50,000 in addition to the outstanding balance of the loan. Default is defined as the borrower's failure to make any required payment under this loan agreement within fourteen (14) days of the due date, or the borrower's breach of any other material term or condition of this agreement. The borrower agrees to pay all costs and expenses, including attorneys' fees, incurred by the lender in enforcing this loan agreement. The penalty shall be payable immediately upon default and shall be in addition to all other rights and remedies available to the lender under this agreement or at law or in equity.

    • REMINDER: Failing to pay back a loan, manipulating or acting maliciously with the trust placed in the borrower by this loan agreement or with the assets provided as collateral, is considered fraudulent, criminal, and may negatively impact the borrower's credit history and future business endeavors with Shadow Corporation and other financial institutions.
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    • Regards,
      SIGNATURE
      Samuele Colonna,
      Executive Officer
      Shadow Corporation,
      Maze Bank Central.
    Image[/spoil]

NB: The Prosecution has been forced to withdraw Exhibit #15: Mike Luigi Bank Records, as they Los Santos Bank has refused to cooperate with the Prosecution's investigation and failed to hand over the requested records.


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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Hugh Allgood »

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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. Mike Luigi
#24-CM-0030

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


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




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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Hugh Allgood »

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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. Mike Luigi
#24-CM-0030

A Motion to Suppress was filed in the above case on the 6th day of January, 2025.


The Defendant, Mike Luigi , by and through the undersigned attorney, filed this Motion to Suppress, and requests to following be suppressed from evidence;

  • Exhibits #18-21
    Requested Evidence to Suppress:
    Exhibits in their entirety
    • Detailed Reasoning: These exhibits have been submitted far beyond the initial period of discovery, including after the defense’s discovery period, and the prosecution has done so without proving justification of why this discovery is just now being provided. Furthermore, defense believes this information was perhaps obtained illegally (explained below).

      In 24-AP-001, the Court of Appeals reviewed this very same issue stating,

      When it comes to the late introduction of evidence that comes beyond the specifically allotted window for discovery outlined in the Order for Discovery, the court will chiefly examine whether or not the admission of the disputed evidence presents prejudicial circumstances against the adverse party. Additionally, the court must examine the circumstances which contributed to the delay in presentation of the evidence and evaluate the reasonableness of the explanation provided, taking into account the timing of the disclosure and it's proximity to the trial date in relation to the adverse party's ability to prepare an adequate defense in light of the late disclosure. Lastly, the court will review the importance of the exhibit as it relates to the general underlying case and whether disallowing the exhibit would present unfair circumstances against the disclosing party.


      In this specific case, as noted above, the prosecution has presented this discovery without explaining the delay in its introduction or any factors as to why this Court should allow it. As this Counsel has stated in previous motions, the investigation leading to this indictment started approximately 19 months ago. The evidence submitted in this latest discovery is undated, but (specific to the loan contracts submitted) does not appear to be recent loans between Total Bankers and individual clients. Allowing the introduction of this evidence at this stage will undoubtedly cause further delay on this case, considering a trial was likely close to he scheduled prior to its introduction as this Court has some motions to rule on and then it would be time to schedule a trial. Now the State has introduced more evidence, a) defense is making this motion which will now need to be considered before a trial can take place and b) it’s prejudicial to the Defendant as we have to consider whether or not to present additional discovery to counter it, especially considering the fact the prosecution waited until after defense discovery to present it.

      Additionally, defense counsel wishes to raise concerns with how this evidence was acquired. It is now believed the contracts submitted in this exhibit were obtained through a “leak” from a PD crime report or some other illegitimate means. Defendant has been in contact with PD (their employer) who confirmed this information was not released by PD. When notified of the possible leak, PD attempted to reach out to the Attorney General for clarification, and the Attorney General dismissively stated he wouldn’t go “into too many details” other than assuring PD this evidence was obtained “legitimately”. Due to opposing counsel not willing to explain where this information comes from, Defense Counsel cannot assure the Defendant’s Constitutional rights are upheld or, again, the reasoning for its late inclusion. ((There are also potential concerns of metagaming this information or leaking faction documents which could be an ooc corruption issue for the PD faction. There is also no RP proof submitted on the contract pictures showing how they were obtained (eg no proof of body camera, or proof of taking a copy of the contract at the time of signing.) proof of RP needs to be provided.))


  • Exhibit #2 & 3: Lincoln Burrows & Rue Lebaigue contracts & Exhibits 8 & 9: property warrant reports
    Requested Evidence to Suppress: Entire Exhibits
    • Detailed Reasoning: Same concerns regarding the legitimacy and legality of how this information was obtained. With the introduction of the new discovery, It is now also believed these previously admitted exhibits came from internal PD case files which were not released by PD through recognized court information request or court process (search warrant or subpoena).


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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Terence Williams »

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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. Mike Luigi
#24-CM-0030

A Rebuttal was filed in the above case on the 7th of January, 2025.


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

  • Exhibit #18: Total Bankers contract - Shawn Jo
    The contract in this exhibit was provided by Mr. Shawn Jo as a response to the Prosecution's request for information in early October, which was the exact evidence the Defense requested to compel from the Prosecution.
  • Exhibit #19: Total Bankers contract - Filip Wong
    The contract in this exhibit was provided by the Defense as a response to the signed subpoena served against the defendant and their company, Total Bankers.
  • Exhibits #20 and 21: SAJB Public Notary standard loan contract; Maze Bank Central standard loan contract
    These exhibits are probative evidence that provides a contextual narrative to support the Prosecution's case. The Prosecution will argue that these exhibits should be admissible on the same grounds previously used by the presiding judge to deny suppression requested by the Defense.

NB: Regarding the so-called late filing of these exhibits, there is no delay caused by this additional discovery as there has been no Notice of Scheduling filed, which was the concern of the appeal referenced by the Defense. Until such a notice is filed, the Defense has time to review the evidence. The court is already pending to decide on various other motions and this filing has caused no discernible delay. Furthermore, half the discovery posted was requested by the Defense. At the same time, the last exhibit was not provided to the Prosecution until mere hours before the discovery was posted, rendering it impossible to be filed sooner.


  • Exhibits #2 and 3: Total Bankers Contract - Lincoln Burrows; Total Bankers Contract - Rue Lebaigue
    The contracts in these exhibits were originally part of separate Los Santos Police Department case files used as evidence for search warrant applications. Search warrants, while signed by a judge, fall under the responsibility of the Office of the Attorney General, and as such are admissible to the court as evidence.
  • Exhibits #8 and #9: Avon Miller Warrant Reports; Ocean Dessrnt Warrant Reports
    The warrant reports in these exhibits are direct from the LSPD's patrol report database. It is not unknown but rather a common occurrence that law enforcement utilizes reports from other departments as evidence in their own cases. Furthermore, as the highest-ranking investigative unit and law enforcement officer in the state, besides the Board of Governors, it is the Attorney General's prerogative to have access to and use vital evidence gathered by local law enforcement for effective prosecution, as protected by the Constitution of San Andreas, Article III, Section 6.




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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Hugh Allgood »

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San Andreas Judicial Branch

Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

Rebuttal Response


IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Mike Luigi
#24-CM-0030

A Response to the Rebuttal was filed in the above case on the 8th of January, 2025.


The Defendant, by and through the undersigned attorney, presents a response to Prosecution's rebuttal to the Defense motion to Suppress;

  • Exhibit 18: While it is correct the Defense has requested information, such as this through discovery, it is evident this specific exhibit was not provided in response to the Defense motion as the prosecutor has in-fact objected to the Defense motion citing their belief the Court should not compel the prosecutor to disclose the identities of those who came forward in response to the October request for information. Nor has the Court ruled on that motion. Not to mention, the Defense does not believe the October press release only yielded exactly one response to the Attorney General The Defense maintains its previous arguments on this discovery. The State was required to turn over all evidence in the previous Order for Discovery, and this deadline came and went. The Prosecutor has not fulfilled the requirements in previous case precedence on late disclosures as articulated in our motion to suppress -- if the Prosecutor has had this information since October, why is it only just now being released?

    Exhibit 19: Defense confirms this information was submitted by the Defense in response to a subpoena. Defense still believes this falls under the same argument as above. The prosecution went through the trouble of getting a subpoena for records, we complied with this subpoena, but this information was not included in the prosecution's original discovery or shortly after. The prosecution provided their initial discovery on 19/Nov/2024, the Defense sent them this information on 20/Nov/2024. It's only now being introduced over a month later on the 31st of December, 2024. While the prosecutor claims the defense waited until hours before discovery to post, The Defense complied with the deadlines imposed by the Court on submitting the information pursuant to the subpoena and it doesn't excuse the fact the prosecutor then waited over a month to include it.

    Exhibit 20 and 21: The Defense did not raise an objection on grounds of lack of relevance, because of the previous Court ruling in this regard. Defense reaffirms it's objection on the grounds of it being a late submission, which is prejudicial to the Defendant who has already submitted their discovery and delays this case. The prosecutor claims that just because a notice of scheduling has been filed, there is no delay. This is simply untrue. The basic court process is; initial discovery by the prosecutor, a period for the defense to file any motions related to the discovery, the court rules on these motions, the defense submits their discovery (if they wish), the prosecutor can file any motions related, the court rules, and then the Court schedules a trial. In this matter, the prosecutor has effectively sent this case back multiple steps to the initial discovery, without providing any justifiable reason why it should occur -- other than 'well we haven't tried to schedule a trial yet'. We may never make it to trial if the prosecutor is just allowed to come and go as they please. The Court sets deadlines for a reason for the orderly administration of justice. From the perspective of the Defense, this is not proper procedure and the Prosecutor should not be allowed to come and go as they please with evidence. The Court has already recognized a process for submitting evidence beyond the initial discovery window, and the prosecutor has not followed this process in this case and therefore, this evidence should be suppressed per our request.

    Exhibit 2, 3, 8, 9: Same objection as above. If this information was effectively in possession of the Attorney General this whole time, then why is it just now being included? We still object to its use from a legal standpoint. The Attorney General is effectively using information submitted for an entirely different matter and is now using this information in a criminal case against the Defendant. As the 4th Amendment States - The Defense has a right to be secure in his papers and effects, and without a warrant, against unreasonable searches and seizures. The Defense has already attempted to argue the relevance of these exhibits, and the Court has indicated the evidence would not be suppressed on grounds of relevance, but the Court has granted the Defense the ability to make these arguments at trial, and therefore, we will reserve that argument for trial. However, what is happening here is the prosecutor is using the fact the Defendant uncovered illegal items in a seized property and did the right thing by turning this information over to the authorities against him. It only serves to discourage other like-minded individuals from doing so.

    The Defense rests its argument on this motion and respectfully awaits the Court decision.




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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

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. Mike Luigi
#24-CM-0030

A decision was reached in the above case on the 29th day of January, 2025.


Defense's Motion to Compel Discovery (Housing Records for 13 Occupation Avenue)
Ruling: DENIED
Reasoning: The defense has the ability to create subpoenas to obtain the requested housing records, as outlined in procedural guidelines (e.g., viewtopic.php?p=938284#p938284). The prosecution is not required to obtain evidence not already in its possession, and the defense has not demonstrated that subpoenas or other avenues have been fully exhausted.

Defense's Motion to Compel Discovery (Attorney General’s Request for Information)
Ruling: GRANTED IN PART, DENIED IN PART
Reasoning: The prosecution is required to disclose any substantive, actionable evidence or materials received in response to the Attorney General’s public request. Individuals who voluntarily provided actionable evidence do not have a reasonable expectation of privacy, and their identities should be disclosed alongside their submissions. However, identities of individuals who provided no actionable evidence or official statements should be redacted to protect their privacy unless the defense demonstrates a compelling need for this information. Speculative concerns about potential witness tampering cannot be used to deny disclosure.

Defense's Motion for Continuance
Ruling: GRANTED
Reasoning: The defense has demonstrated good cause for the continuance, as counsel’s temporary unavailability has made it impractical to respond to ongoing proceedings. However, we are long passed that so it is irrelevant at the current stage. So this motion is retroactively granted as there has been adequate time since the motion and this decision.

Exhibit #18 (Shawn Jo contract)
Ruling: ADMITTED
Reasoning: This exhibit was voluntarily provided by a third party, Shawn Jo, in response to the Attorney General’s October public request for information. While it was disclosed after the initial discovery deadline, the delay is excusable as the evidence was obtained through a public call for submissions and its disclosure does not disrupt the procedural timeline. Importantly, this exhibit aligns with evidence the defense itself previously sought to compel, further supporting its admissibility.

Exhibit #19 (Filip Wong contract)
Ruling: SUPPRESSED
Reasoning: Unlike Exhibit #18, this document was submitted by the defense itself in response to a prosecution subpoena over a month before it was disclosed. The prosecution had possession of this exhibit as early as November 20, 2024, but delayed its submission until December 31, 2024, without any valid explanation. This unjustified delay directly prejudices the defense by forcing them to reassess their strategy and potentially file additional motions, thereby disrupting the orderly progression of the case. As the prosecution’s delay was entirely avoidable and harmful to the defense’s preparation, this exhibit is excluded from evidence.

Exhibits #20 and #21 (Public Notary and Maze Bank Standard Loan Contracts)
Ruling: ADMITTED
Reasoning: These exhibits provide general contextual information about standard loan practices and are not directly tied to the defendant’s actions or specific transactions. Unlike Exhibit #19, these documents are independent from the defendant and do not require the defense to gather additional evidence or reassess their strategy. While they were submitted late, the delay does not prejudice the defense, as these exhibits are supplementary in nature, and the defense retains sufficient time to address or refute them before trial. The defense has also not raised any objections to their relevance, further supporting their admissibility.

Exhibits #2, #3, #8, and #9
Ruling: ADMITTED
Reasoning: The Constitution grants the Attorney General broad investigatory powers as the chief law enforcer of the state. The prosecution has jurisdiction over the national territory and can use evidence lawfully obtained by law enforcement. There is no substantive proof that these exhibits were obtained improperly or violate privacy rights. However, the court cautions the Attorney General to exercise care with confidential evidence in future cases to avoid compromising due process or individual rights.


Respectfully,

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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Hugh Allgood »

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San Andreas Judicial Branch

Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

SUBPOENA REQUEST


IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Mike Luigi
#24-CM-0030

A Subpoena Request was filed in the above case on the 29th of January, 2025.


Mike Luigi , by and through the undersigned attorney, respectfully requests the issuance of a subpoena for the following documents and/or testimony:

  • Documents/Information Requested: Housing Records for 13 Occupation Avenue between 1/MAR/2023 to 1/JUN/2023
    • Purpose/Reasoning for Subpoena: The State’s exhibit 1 is a contract entered into by Cody Monk for the property of 13 Occupation Avenue. The Defense reached out to Property & Housing Bureau (PHB) on 23/NOV seeking these records, but despite a 6/Dec response stating some sort of update on this request would be provided within 48 hours, PHB has not responded. The Defense notes the circumstances regarding the ownership and alleged seizure of this property is seemingly a large aspect of the State’s case, and therefore the Defense believes it is necessary for this information to be compelled by the Court so the Defense can have access to this information for its case. The Court in its latest filing, denied the Defense motion to compel this discovery, citing the newly implemented subpoena process that did not exist at the time of the Defense filing.




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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Maximilian Fitzgerald »

Does the prosecution dispute this subpoena request in any way?
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Terence Williams »

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San Andreas Judicial Branch

Docket Notice
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Judge Fitzgerald,

    The Prosecution does not object to the subpoena. However, we would request that any evidence as a result of this subpoena be filed under seal so as to protect the privacy of any individuals connected to the property, other than that of Cody Monk.

    Regards,
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    Terence Williams
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    San Andreas Judicial Branch
    234-9321 — [email protected]
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Maximilian Fitzgerald »

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San Andreas Judicial Branch

Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

SUBPOENA

TO: San Andreas State Government

YOU ARE HEREBY COMMANDED TO:
  • Produce the specified physical evidence as detailed below in a private email to Superior Court Judge Maximilian Alexander Fitzgerald III by 28/FEB/2025:
  • Housing Ownership Records for 13 Occupation Avenue between 1/MAR/2023 to 1/JUN/2023
((This will be pending a request to a senior admin so please be patient.))

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San Andreas Judicial Branch
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DISCLAIMER: Failure to comply with this court order may result in criminal charges, including but not limited to GF25 - Felony Contempt of Court, GM22 - Contempt of Court, GF16 - Tampering with Evidence, GM14 - Obstruction of Justice
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Maximilian Fitzgerald »

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San Andreas Judicial Branch

"EQUAL JUSTICE UNDER LAW"

  • Esteemed Prosecution & Defence,

    Let it be known that the subpoena has been fulfilled and the result can be found under seal.

    With the Highest Regard,

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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Terence Williams »

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San Andreas Judicial Branch

Docket Notice
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Judge Fitzgerald and pertaining parties,
    • Regarding the request for the AG's 'Request for Information'
      The Prosecution has already complied with the Defense's request in their Motion to Compel, by providing the loan contract from Mr. Shawn Jo in the latest discovery. A total of five (5) other individuals got in contact with the Attorney General's Office, however, none except Mr. Shawn Jo provided any actionable evidence or official statements. As ruled on by Your Honor, the Prosecution will not share the names of either of the five (5) other individuals who stepped forward.
    Regards,
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Hugh Allgood »

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Allgood Law

AG public information
"Right Firm. Right Now"

  • To all concerned,

    An “official statement” is presumably one in which it’s done on a witness form. We believe there is potential people gave information that is exculpatory in nature, but was not “official” enough. This can be due to a myriad of reasons that Defense will not publicly speculate on. However, we believe the Defendant should be entitled to the correspondences between the AG and themselves, even in redacted form.

    And the qualifier of “actionable evidence” can be misleading, as what the AG considers actionable is very different than what the defense does. For example, if someone contacted the AG to discuss a favorable experience with getting a loan from the Defendant, that information may not be “actionable” by the AG. But very much so to us. Therefore, we would respectfully ask for the correspondences with these 5 individuals, even if the AG wishes to keep their identities anonymous.

Respectfully,
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Maximilian Fitzgerald »

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San Andreas Judicial Branch

"EQUAL JUSTICE UNDER LAW"

  • Esteemed Mr. Williams & Mr. Allgood,

    The Court acknowledges that the prosecution’s definition of “actionable evidence” may be narrower than what is relevant to the defense. Given this potential discrepancy, I find merit in Mr. Allgood’s argument.

    Accordingly, Mr. Williams, I direct you to submit all undisclosed correspondences from the Attorney General’s Request for Information to the Court for review via an email to myself. I will personally examine these materials to determine whether any of the excluded submissions contain information that should be disclosed to the defense.

    Following this review, I will issue a ruling on what, if any, additional materials should be released, whether they should be subject to redaction, and whether they should be filed under seal to protect privacy interests.

    With the Highest Regard,

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    Superior Court Judge
    San Andreas Judicial Branch
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

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. Mike Luigi
#24-CM-0030

A decision was reached in the above case on the 31st day of January, 2025.


I have reviewed the 6 correspondences:
  1. Shawn Jo - Contract provided.
    • Already in evidence, no action needed.
  2. Person 2 - Undocumented verbal conversation, no contract provided.
    • The court denies the request for disclosure as there is no accurate way to represent them and no official statement or evidence was provided.
  3. Person 3 - Undocumented verbal conversation, no contract provided.
    • The court denies the request for disclosure as there is no accurate way to represent them and no official statement or evidence was provided.
  4. Person 4 - Via Email, no contract provided, and prosecution lost contact.
    • The court denies the request for disclosure as there is nothing relevant to the case.
  5. Person 5 - Via Email, no contract provided, consisted of a conversation that was largely questions to the attorney general about the case.
    • The court denies the request for disclosure as there was nothing relevant to the case.
  6. Person 6 - Via Email, claimed to have had multiple contracts but could not provide any.
    • The court denies the request for disclosure as it was prejudicial and speculative in nature and provided no evidence.



In summary: The court has determined that the withheld correspondences do not meet the threshold for disclosure due to a combination of factors, including the lack of official statements, absence of substantive evidence, irrelevance to the case, speculative or prejudicial nature, and instances where individuals were merely inquiring about the case rather than providing testimony.

Respectfully,

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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Terence Williams »

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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. Mike Luigi
#24-CM-0030

A Motion for Discovery was filed in the above case on the 31st of January, 2025.


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


  • ((Removed)) Exhibit #1: Total Bankers Contract - Cody Monk
    ((Removed under instruction of LFM.))
    Exhibit #2: Total Bankers Contract - Lincoln Burrows
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    Exhibit #3: Total Bankers Contract - Rue Lebaigue
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    Exhibit #4: BLB Total Bankers Audit Search Warrant and Results
    Search Warrant
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    San Andreas Judicial Branch

    "HERE FOR YOU | SAFE FOR YOU"

    • To:
      The Office of the Attorney General and the Business Licensing Bureau;

      You are hereby directed to conduct a search of Business Records - Loan Contracts for the following designated records:
      • Loan Contracts issued by Total Bankers
      [X] Any evidence of crimes in violation of the San Andreas Penal Law Article GM to SF included but not limited to:
      • BLB03 - Breach of Major Licensing Conditions
      • GM11 - Predatory Lending
      • GF07 - Felony Fraud
      • GF18 - Racketeering
      • DF05 - Manufacturing a Controlled Substance
      • DF01 - Possession of a Controlled Substance with Intent of Sales
      • DM05 - Possession of Drug Paraphernalia
      • DM03 - Possession of a Schedule III Controlled Substance
      • DM02 - Possession of a Schedule II Controlled Substance
      • WM02 - Possession of a Class 1 Firearm
      • WF03 - Possession of a Class 2 Firearm
      You are directed to execute this warrant between the hours of:
      • [ ] 06:00 - 21:00
      • [ ] 08:00 - 22:00 (Hours of Operation for the Bank of San Andreas)
      • [X] Any time day or night.
      You are being directed to send a copy of this warrant to the property owner once executed, and return a copy with all property seized pursuant there to your respective department without unnecessary delay. The court requires a copy be submitted to the warrant application for internal archive.



      This warrant is issued on 14/MAR/2024 and is effective for 7 days. Should an extension be required please submit a notice no less then 12 hours prior to this warrants closing.

      Best regards,

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      Director of the San Andreas Bar Association
      Clerk - Administrative Office
      San Andreas Judicial Branch
      (909) 553-8869 — [email protected]
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    Exhibit #5: Total Bankers Contract - Andy Tyrie
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    Exhibit #6: Andy Tyrie Witness Statement
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    San Andreas Judicial Branch
    Official Witness Statement
    "HERE FOR YOU | SAFE FOR YOU"
    Case Information
    • Case Number: [Case Number]
      Incident Date: [01/JAN/2000]
    Witness Information
    • Name: Andy Tyrie
      Date of Birth: REDACTED
      Phone Number: REDACTED
      Occupation: Law Review Committee, House Clerk
    Witness Statement
    • I contacted Mike Luigi along with a few other loan companies about getting a loan for $3,800,000, My first choice was Willowick as I knew him and he had offered doing a partnerships with another company as he had most of his money in active loans. Mike replied saying yes I can meet up and get you the full amount but it’s gonna be 50% interest as I would be paying it off in $100,000 instalments and he would need more money due to the fact of how long he would be out the money, I agreed as I loved the building the money was going to and didn’t wanna miss out on the opportunity due to where it is the size etc. We headed up to his office same day where he appeared to write the contract terms in front of me, I signed and he handed me the money we then drove to my apartment which he took as collateral until I had paid off the first $500,000, I still had access to the apartment just now ownership bearing in mind he had to get Rija Luigi to hold the apartment for him so for that duration the apartment on paper belonged to Rija Luigi that address was 99 Weazel Plaza. We then went to the building witch is 18 Eastbourne Way I bought the property and was told to hand the deed to Elise Cavallera as she would be holding it on behalf of him and he would be taking it as collateral in the event of failing to pay, I have since asked him for a copy of our contract of which I have had no response despite texting multiple times and I’m at a loss as to what I am meant to do in this whole situation. I got hit with $1,900,000 of interest alone for this and after the fact some of the other companies got back and stated it wouldn’t been somewhere around $600,000-$800,00 in interest from them
    Witness Affirmation
    • I, Andy Tyrie, 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,



      Andy Tyrie

      Date: 27/JUN/2023
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    ((Removed)) Exhibit #7: GOV CCTV Footage of Rija Luigi
    ((Removed under instruction of LFM.))
    Exhibit #8: Avon Miller Warrant Reports
    Mike Luigi wrote: 19 Apr 2023, 15:04 Image
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    Los Santos Police Department

    WARRANT REPORT
    "TO PROTECT AND TO SERVE"

    • SUSPECT DETAILS
      • Full Name: Avon Miller
        Phone Number: 3982150
        Officers Involved:
        • Police Sergeant II Mike Luigi
        Charges:
        • WF03 - Possession of Illegal Firearms/Weapons
        • WM03 - Possession of Weapon Modifications
        • DM03 - Possession of a Schedule III Controlled Substance
      INCIDENT NARRATIVE
      • Explain what happened, sufficient detail must be given to validate the justify the placed charges, videos could be provided.
        • Avon Miller's property 53 Carson Ave was seized by Total Bankers, evidence was found inside a locked safe within the property. Avon Miller was solely responsible for everything inside of the property. Evidence to this fact can be provided to courts if necessary.
        Method of Identification
        • License
      EVIDENCE DETAILS
      • Document the possessions confiscated from the arrested suspect.
        Illegal evidence must be documented individually, examples of documented illegal evidence are "Pistol .50" or "12 grams of Cocaine". 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 Evidence:
          Exhibit A: Pistol .50 - 1646797550029
          Exhibit B: Pistol .50 ammo x50
          Exhibit C: Silencer
          Exhibit D: Marijuana plant x31

          Photograph of possessions in evidence locker (if applicable)
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    Exhibit #9: Ocean Dessrnt Warrant Reports
    Mike Luigi wrote: 05 Apr 2023, 20:51 Image
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    Los Santos Police Department

    WARRANT REPORT
    "TO PROTECT AND TO SERVE"

    • SUSPECT DETAILS
      • Full Name: Ocean Dessrnt
        Phone Number: 5692689
        Officers Involved:
        • Police Sergeant I Mike Luigi
        • Police Officer I Luke Cortez
        Charges:
        • WF05 - Firearms Trafficking
        • WM03 - Possession of Weapon Modifications
        • DM05 - Possession of Drug Paraphernalia
        • GC06 - Possession of Cannabis
        • DM03 - Possession of a Schedule III Controlled Substance
      INCIDENT NARRATIVE
      • Explain what happened, sufficient detail must be given to validate the justify the placed charges, videos could be provided.
        • After Ocean Dessrnt failed to make payments on his loan, the property 16 Occupation Ave that was being used as collateral was seized by Total Bankers. Upon seizure a search of the property was conducted before re-sale with the illegal exhibits being found by myself, while off-duty and Officer Cortez who was called to the scene. Ocean Dessrnt signed a contract with Total Bankers stating he was responsible for everything within the property.
        Method of Identification
        • License
      EVIDENCE DETAILS
      • Document the possessions confiscated from the arrested suspect.
        Illegal evidence must be documented individually, examples of documented illegal evidence are "Pistol .50" or "12 grams of Cocaine". 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 Evidence:
          Exhibit A: Pistol .50 - Scratched
          Exhibit B: Pistol .50 - Scratched
          Exhibit C: Pistol .50 - Scratched
          Exhibit D: Pistol .50 - Scratched
          Exhibit E: Pistol .50 - 1580353077501
          Exhibit F: Pistol .50 - 1591524905525
          Exhibit G: Pistol .50 - 1588234680261
          Exhibit H: Pistol .50 - 1585345198820
          Exhibit I: Pistol .50 - 1587025151011
          Exhibit J: Micro SMG - 1601042045556
          Exhibit K: Assault Riffle - Scratched
          Exhibit L: Pump Shotgun - Scratched
          Exhibit M: SMG - Scratched
          Exhibit N: Silencer
          Exhibit O: Pistol .50 ammo x105
          Exhibit P: Pump Shotgun ammo x20
          Exhibit Q: Micro SMG ammo x100
          Exhibit R: Assault Rifle ammo x96
          Exhibit S: SMG ammo x104
          Exhibit T: Drug Table x2
          Exhibit U: Marijuana
          Exhibit V: Methadone x8

          Photograph of possessions in evidence locker (if applicable)
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    Exhibit #10: Mike Luigi Public Notary Initial Submission
    Mike Luigi wrote: 26 Jun 2023, 17:57 Image

    San Andreas Judicial Branch
    Contract Pre-Approval Submission Form
    "HERE FOR YOU | SAFE FOR YOU"
    Submission Information
    • Submitting Party: Total Bankers
      Type of Contract: Loan Agreement
      Approved Representatives of Submitting Party:
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    San Andreas Judicial Branch
    Loan Agreement
    "HERE FOR YOU | SAFE FOR YOU"
    Party 1 - "Total Bankers"
    • Name: Mike Luigi
      Date of Birth: 07/JAN/1997
      Mailing Address: 4 Calais Ave
      Contact Information: 381-5045 or [email protected]
    Party 2 - "Loanee"
    • Name: [Firstname Lastname]
      Date of Birth: [01/JAN/2000]
      Mailing Address: [## Streetname]
      Contact Information: [###-####]
    Collateral - "[Property/Vehicle]"
    • Street Address: [## Streetname]
      Type of Real Estate: [Residential/Commercial]
      [or/and]
      License Plate: [License Plate]
      Make/Model: [Make/Model]
    Terms of Agreement - "Agreement"
    I. LOAN TERMS
    • Total Bankers agree to provide a loan of [Amount] to the Loanee at an interest rate of [Percentage].

    II. PAYMENT TERMS
    • The Loanee agrees to pay Total Bankers a minimum of [Amount] by 13:00 every [Weekday] until the loan balance has been cleared.

      Missing a payment will result in notice being issued to the Loanee by Total Bankers of their non-payment, and it is the duty of the Loanee to pay Total Bankers the amount due before the time of the second payment. A second consecutive non-payment will result in the Loanee being declared in Default, as outlined in Section III.

    III. DEFAULT
    • If the Loanee has two missed payments during the contract period, they will be considered in Default. Upon Total Bankers' invocation of this Default status at a time deemed suitable by them, the right to seize the Collateral as delineated in Section IV becomes enforceable. It is essential to note that even after the collateral has been seized and forfeited, the Loanee's duty to clear the remaining loan balance remains, as the forfeiture of the collateral does not result in a reduction of the outstanding loan balance.

    IV. COLLATERAL
    • The Loanee will be putting up the following as Collateral, being made fully aware of the consequences of being found in Default:
      • Street Address: [## Streetname]
        Type of Real Estate: [Residential/Commercial]
        [or/and]
        License Plate: [License Plate]
        Make/Model: [Make/Model]

    V. SEVERABILITY CLAUSE
    • If any part of this Agreement is found to be unenforceable, the rest of this Agreement will remain enforceable while section in question will become void.

    VI. DISPUTE RESOLUTION CLAUSE
    • If a dispute arises out of or relates to this Agreement, and the dispute cannot be resolved by negotiations between the Parties, the Parties agree first to try in good faith to resolve the dispute via mediation before resorting to either arbitration or litigation.

    VII. JURISDICTION
    • This contract was drafted following the Penal Code and guidelines of the State of San Andreas, whose courts shall have sole jurisdiction over any and all disputes that may arise, subject to the Dispute Resolution Clause of this contract.

    VIII. TERMINATION
    • After the agreement is signed, this contract may only be terminated by the written consent of both Parties. This contract will also terminate upon the final payment by the Loanee to Total Bankers.
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    Exhibit #11: Public Notary Assessment Email
    Hope Kant wrote: 07 Jul 2023, 16:16 Image


    San Andreas Judicial Branch
    Personal Email

    "EQUAL JUSTICE UNDER LAW"

    • Dear Mr. Luigi,

      The Public Notary has taken time to review your contract.
      Our questions are as follows...
      • How do you/will you determine loan percentage? As you have not put a max or a minimum, the Public Notary division cannot sign off on the contract. Predatory Lending by our penal code is defined as "to loan money under unfair or fraudulent pretenses, often with the the outcome of violence should the contract not be fulfilled." That being said, pre-approving a loan with no defined percentage rate will not be something the Public Notary division allows. As an officer of the law, I'm sure you can understand that a high rate of interest can be qualified as "unfair pretenses".
      • Section 3: Default states, "It is essential to note that even after the collateral has been seized and forfeited, the Loanee's duty to clear the remaining loan balance remains, as the forfeiture of the collateral does not result in a reduction of the outstanding loan balance." This type of language is predatory by nature and goes against the very definition of Collateral. Collateral is to be used as a way for lenders to recoup money from a defaulted loan/rental payment/damages done. To not include the Collateral as money against the loan, means it isn't Collateral at all.
      • You will also need a clause like the following, "SALES TAX - In the State of San Andreas, failure to pay sales tax is a misdemeanor crime. The Seller will have the sole responsibility, upon receiving payments from the Buyer, to document both the receipt of the payments as well as their payment of the sales tax at City Hall." ((Does the script system you use automatically take out money for taxes? AKA does it go into your salary or automatically get put into your bank account. Cause if so, then putting the clause on the contract is just a formality. I'm not really familiar with the script))
      As it stands, your contract will not be notarized. The Public Notary feels, that in it's current state, it breaks our current laws and constitution. If the listed changes are made, the contract can be revisited and possibly approved. We look forward to hearing from you.

      Respectfully,

      Image
      Senior Prosecuting Attorney
      Notary Public
      San Andreas Judicial Branch
      (909) 321-2132 — [email protected]
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    Exhibit #12: Mike Luigi Response to Contract Assessment
    Mike Luigi wrote:07 Jul 2023, 17:12 Image

    Total Bankers

    We deal in security
    We sniff out profit

    • Senior Prosecuting Attorney Hope Kant,

      Thank you for the quick reply. Firstly, am I able to have a copy of the contract I submitted so I can amend accordingly?

      Loan Companies as authorized by the state have a maximum interest rate of 80% and loan size of $10,000,000. While we do not generally operate in these extremes these were the limitations put in place on loan companies. If there is a limit the Judicial Branch wishes to apply on top of this I would be happy to comply.

      Section 3 can be amended as you have noted, this does make sense.

      I do not see the need for a SALES TAX section as there is no sale taking place, simply a loan. Profit on the loan is directly transferred upon receival from the loan company to my personal salary meaning I am liable to pay up to 35% in taxes on the profits.

    • Best regards,
      Image
      Mike Luigi
      Chief Executive Officer
      Total Bankers
    Image
    Exhibit #13: Cody Monk and John G Interview
    Image



    San Andreas Judicial Branch

    Prosecution Department
    "EQUAL JUSTICE UNDER LAW"

    INTERVIEW TRANSCRIPT

    ((RP Proof))
    Image
    • **Recording begins**
      HK: Alright, so my name is Hope Kant. I am a senior prosecuting attorney with the Judicial Branch.
      CM: Nice to meet you.
      HK: Um, do you mind stating your names just for my record?
      CM: Cody Monk
      JG: John G
      HK: Okay, so, um, it is my understanding that you have gotten a loan with Total Bankers or have had a loan previously with total bankers, correct?
      CM: Yeah I still never received the property or anything, and it’s still being taken out of my paycheck every day. It’s annoying.
      HK: Okay, um, so, do you have any bodycam footage of the incident or anything like that? Um, let me look through my files to see if maybe there’s something on you previously too.
      CM: Wait, but what happened to this? Why was I called? If I may ask is- am I in trouble or-?
      HK: No, no, you were brought here to talk about the loan, like, because I believe them to be, like, wrongfully done so I’m trying to- to resolve this for you. It’s, like, no one’s done anything about this, and these loans are crazy.
      CM: Yeah, and Medi told me- Modi- whatever. He told me that these loans are not even validated or whatever. He does them out of his pocket or- and they’re very high percentage.
      HK: They are.
      CM: And he does it to newer people. He- and he does it to new people. At that time I was very new, and he- he takes that advantage. He says “oh it’s a good one” and bro-

      JG: Do you want to see the agreement copy? I should have it in my pocket. Hello?
      HK: Okay sorry. Um, yeah, I would. Like honestly everything that you have, um, would be great, um, cause I already have multiple people that have come to me with problems. So, I’m hoping to, like with enough people, that I can take him down and stop this for good.
      CM: Yeah, apparently I’m not the only case. I’m- I’m going to send- I’m going to ask Weazel News to make a newspaper about my case, cause my case was worse. He told me he’s going to arrest me off-duty, and he tracked me down with the phone.
      **Ruffling can be heard as a contract is given from John G to Hope Kant**
      JG: You can read it carefully.
      HK: Yeah, that’s perfect. So, that is literally what I needed for clear evidence of predatory lending, so thank you.
      Um, because- did he take your property?
      CM: Um, I don't have nothing access to it. I lost it after 1 week, and I still don’t have a home. So yeah, great.
      HK: Okay, okay, so he did take your property, and that hasn’t been deducted from your loan balance, correct?
      CM: Um, I still have the loan, and, um, I don’t have nothing to house. So, yeah.
      HK: Okay, um, alright, um, do you have any other- like do you have the bodycam footage or anything else?
      CM: Do you want the one where he tells me off duty he’s going to arrest me?
      JG: Yes we do.
      HK: Yeah, if possible. Yeah- I-
      literally everything you guys have. Um, just send it to me. Um I can give you- I’ll give you my text message or my text number so you can text me the links to all the footage or whatever that you have. I don’t know how you’ve saved it, so-
      CM: There I sent you the footage.
      **Pause**
      HK: Alright, perfect.
      **Pause**
      HK: Okay, so, I see that you sent me the contract being done. Do you have footage of him threatening you with arresting you for not paying it?
      CM: Yeah, look at the part two. If you want, I’ll tell you exactly the minute should look at one sec
      **Pause**
      HK: Okay yeah I will have to look through all of this.
      Um I really appreciate you talking with me and everything cause that is very helpful for me. I hope that through the criminal investigation, things like these will stop and that we can get your property returned to you. Um, because that would be the goal. Or at least the sum that you paid for it returned for you or at least the sum you’ve paid so far. Like we’ll figure out something. I’m hoping to get some restitution for the people he’s wronged. So, um-
      CM: Wait what happened though, like what has he been doing. Were we the only one?
      HK: No, there’s been multiple people, but I can’t really go into the investigation too much. Um, but I am glad that you guys came and talked to me. Um, cause this will help-
      CM: We reported this two months ago and they said oh perfect we’re going to open a case about this. Then another comes and says “oh Mike? There's no way Mike would do something like that. He's a good friend of mine. Just speak with him. He’s good.” Like we got so tired that everyone's friends with him in this judicial whatever, and nobody wanted to do anything. Apparently he’s pretty known and has power. So, yeah, we just gave up. We left the city. I left the city that time cause I was annoyed, but because of that-
      HK: Yeah- well- I- I- well I might know him and work with him that doesn’t mean that he is above the law, so-
      CM: Wait, I have a question. Okay I’ll tell you- I know you said you have to watch the whole part, but tell me just this one part tell me if this is *words*. I’ll tell you uh- in gmail which part. It’s like one minute.
      **Pause**

      HK: Yeah- um- I mean that’s arguably abuse of power, but I mean we’ll- I’ll go through the footage and I’ll see what I can do um cause this isn’t allowed um at all in any way shape or form. So we’ll figure it out. We’ll at least get some money hopefully sent back to you guys. And like work this out for you guys cause I’m really sorry this happened.
      CM: Yeah I mean, I mean we’re pretty- like there’s obviously damage has been done. If this goes through, I’d appreciate if I could get the property- or- cause that’s my original goal.
      HK: Yeah, I mean we’ll see what we can do. I can’t promise anything, but I am going to try and do my best to get this resolved.
      **Pause**
      HK: Alright, um, I do have everything I need. Obviously it’ll take me a while to go through all the footage, but I do appreciate you guys sitting down and talking to me. Um, this isn’t going to be like before, where it doesn’t get handled. I already have proof of other things and I’m working on getting this all put forward. So um we will hopefully take him down. Um-
      CM: What do you mean by taking him down?
      HK: Um, get him arrested? Um, for the crimes he committed? Um, stop him from doing these things to other people. You know, all of the above.
      CM: Yeah, but there’s a Weazel paper made about him.
      JG: Good to hear this.
      HK: Yeah, that’s why all this started is because we read the Weazel news article and have been looking into it since then.
      CM: Weazel asked for my side as well with this. They wanna share my story and the footage I have.
      HK: I mean you should let them to be fair. Um-
      CM: Wait isn’t he a high ranking offer or rich-
      HK: Yes he is.
      CM: That he can- so, technically, not much is going to happen to him is it. Cause usually those people, who are high ranking-
      HK: No, that’s not necessarily the case. Like I said before, the law is the law, and, if you break it, you should still have to pay for it.
      JG: It looks like cops are above law in this city. That’s what we feels like so far.
      CM: Wait with his contract, what’s wrong with the contract? Cause I don’t know how to read contracts very well, but with that contract he made. What’s bad about it, so I know in the future?
      HK: Um uh the- you shouldn’t agree to give over the property, like without it being considered collateral. Like the property wasn’t even written in as collateral. Like you just gave it to him essentially, um, and he paid for it, and now you have to pay money back for a property you don’t have.
      CM: Oh so he found a loophole in the system to do this.

      HK: No, it’s not that. It’s predatory lending. It’s just- you should never do that. That’s wrong.
      CM: Oh, it’s like in most cases, but he also put a very high percentage, and he knew I was new. I don’t know why he did that, but I don’t know about percentages, but he put me 35 or something. I heard that’s really bad or 40%
      HK: Um, I- on the contract it said 25.
      CM: Oh, yeah. 25, sorry. But-
      HK: Yeah, actually, 25 isn’t that bad.
      I’ve heard him do 50% before. So, 25 is really not that bad.
      CM: Yeah, I mean- yeah, he’s crazy if he did 50.
      HK: Yeah, I mean I’ll do my best like I said.
      **Recording ends**

    • Image
      Attorney General
      Director of Public Notary
      San Andreas Judicial Branch
      (909) 505-9925 — [email protected]
      DISCLAIMER: This message, including attachments, is confidential and may contain information protected by the attorney-client privilege or work product doctrine. If you are not the addressee, any disclosure, copying, distribution, or use of the contents of this message is prohibited.
    Image
    ((Removed)) Exhibit #14: John G Bodycam
    ((Removed under instruction of LFM.))
    Exhibit #15: Mike Luigi Bank Records - WITHDRAWN
    Withdrawn
    Exhibit #16: Cody Monk received messages
    Image
    Image
    Image
    Image
    Exhibit #17: Mike Luigi phone records
  • ((Removed)) Exhibit #18: Total Bankers contract - Shawn Jo
    ((Removed under instruction of LFM.))
    SUPPRESSED - Exhibit #19: Total Bankers contract - Filip Wong
    Image
    Image
    Exhibit #20: SAJB Public Notary standard loan contract
    Image

    San Andreas Judicial Branch
    Vehicle Purchase Agreement
    "HERE FOR YOU | SAFE FOR YOU"

    Party 1- "Lender"
    • Name: Firstname Lastname
    • Date of Birth: DD/MMM/YYYY
    • Mailing Address:
    • Contact Information:
    Party 2- "Borrower"
    • Name: Firstname Lastname
    • Date of Birth: DD/MMM/YYYY
    • Mailing Address:
    • Contact Information:
    Loan Specifics
    • Loan Amount: $XX,XXX
    • Interest Rate (0%-80%): %XX
    • Total Amount Due: $XX,XXX
    • Repayment Date: DD/MMM/YYYY
    • Purpose of Loan:
    Collateral
    • Total Collateral Estimated Worth: $XX,XXX
    • Supporting Items & Collateral: Item 1 ($XX,XXX) | Item 2 ($XX,XXX) | Item 3 ($XX,XXX) | Item 4 ($XX,XXX) | Item 5 ($XX,XXX)
    Terms of Agreement
    1. Payment Plan:
      • The BORROWER agrees to pay the LENDER WEEKLY payments of $XX,XXX, Which will occur every WEEK until the contract is Terminated or COMPLETED.

        Missing a payment will result in notice being issued to the BORROWER by the LENDER of their failure to pay. It is the duty of the BORROWER to pay the LENDER the outstanding amount before the time of the next due payment. Failing to pay for a second time will result in the BORROWER being declared in DEFAULT as outlined in Section II. DEFAULT.

        If agreed to by both parties, the BORROWER may pay lump sum instalments, but these will not be classed as weekly payments paid in advance.
    2. Default:
      • If the BORROWER fails to pay TWO consecutive payments they will be placed into DEFAULT, After being placed in DEFAULT the LENDER has the right to seize the COLLATERAL.

        While the BORROWER is still in DEFAULT the LENDER retains this right. The BORROWER will no longer be in DEFAULT when they are able to reduce their number of outstanding missing payments to one or less

        Upon TERMINATION the LENDER may sell any COLLATERAL to cover any Outstanding payments and any excess money shall be returned to the BORROWER

        Any missed payments shall accrue an additional missed payment fee of $25,000 if not paid within 24 hours of the due date this missed payment shall be made paid by the BORROWER before the next due payment
    3. Collateral:
      • Any Collateral put forward shall be, upon the signature of this document, owned by the LENDER but in the possession and usage of the BORROWER

        Upon the payment of any missed payments plus any additional charges the COLLATERAL shall be returned as per the above written clause

        Upon TERMINATION of this contract the LENDER shall hold the right to Sell or dispose of any COLLATERAL in order to settle any outstanding fees

        Upon the COMPLETION of this contract the titles and ownership of the COLLATERAL shall be returned to the BORROWER
    4. Legal Fees:
      • If either party brings an Action to enforce their rights under this agreement, the prevailing party may recover its expenses (including reasonable attorneys' fees) incurred in connection with the Action and any appeal from the losing party.
    5. Termination:
      • This contract will be automatically TERMINATE upon the BORROWER being in DEFAULT for 1 WEEK any missed payments shall accrue an additional missed payment fee of $25,000 and any COLLATERAL can be disposed or sold to pay for outstanding payments

        This contract can also be TERMINATED if the amount is not paid by the Repayment Date
    6. Completion:
      • This contract will be considered complete upon the repayment of the full amount due with any interest or added costs
    7. Safety:
      • This agreement will pass to the benefit of, and be binding upon the respective heirs, executors, administrators and successors of the LENDER or the BORROWER
    8. Severability:
      • If any part of this agreement is found to be unenforceable, the rest of this agreement will remain enforceable while any section in question will become void.
    9. Jurisdiction:
      • This contract was drafted following the Penal Code and guidelines of the State of San Andreas, whose courts shall have sole jurisdiction over any and all disputes that may arise, subject to the Dispute Resolution Clause of this contract.
    10. Sales Tax:
      • In the State of San Andreas, failure to pay sales tax is a misdemeanour crime. The Lender will have the sole responsibility, upon receiving payments from the Tenant, to document both the receipt of the payments as well as their payment of the sales tax at City Hall.
    Signature:
    BORROWER NAME
    Borrower
    Date: DD/MMM/YYYY
    LENDER NAME
    Lender
    Date: DD/MMM/YYYY
    Exhibit 21: Maze Bank Central standard loan contract
    Image

    Maze Bank Central

    Loan Contract
    "A Business for Better Business"

    This loan agreement is made and will be effective on DD/MMM/YYYY.

    The Borrower's Information
    • Full Name:
      • **REPLACE THIS TEXT**
      Loan Inquiry Form:
      • **PASTE HERE**
    The Lender's Information
    • Full Name:
      • Maze Bank Central
      Contact Details:
      • Phone Number: 5824080
        Mailing Address: San Andreas Ave. 3
        ((Discord ID: thunderboss#4746))

    Loan Details
    • The lended amount:
      • $
      Interest Percentage:
      • **ANSWER**
      Total loan amount:
      • $
      The loan is to be paid back in full:
      • **ANSWER**
      Supporting assets & collaterals:
      • **ASSET 1**
      • **ASSET 2**
      • **ASSET 3**

    Signatures

    • By signing this, you confirm that all the above details are correct and agree to the terms & conditions listed bellow.

      The borrower:
      • **Firstname Lastname**
        FNAME LNAME
      Maze Bank Central:
      • SIGNATURE
        Executive Officer - Samuele Colonna
      Shadow Corp. :
      • SIGNATURE
        Chief Technology Officer - Samuele Colonna

    • Terms, Conditions & Liabilities:
      This loan agreement constitutes the entire agreement between the borrower and the lender, and supersedes all prior agreements or understandings, whether written or oral. This includes, but is not limited to, any prior agreements or understandings that may have been made orally or in writing, or any prior versions of this loan agreement. This loan agreement contains the entire understanding of the parties with respect to the subject matter hereof and there are no promises, representations, or inducements other than those contained in this agreement.

      This loan agreement may not be amended or modified except in writing signed by both the borrower and the lender. Any attempts to alter or modify the terms of this agreement, whether orally or in writing, shall be null and void unless the amendment or modification is made in writing and signed by both parties. It is the responsibility of the borrower to carefully review the terms of this agreement before signing, and to seek legal counsel if necessary.

      This loan agreement may be signed by multiple individuals, in which case they shall be jointly responsible for paying the loan. Each of the undersigned represents and warrants that they are fully aware of the terms and conditions of this loan agreement, and they agree to be jointly and severally liable for the repayment of the total loan amount. In the event that any one of the borrowers fails to fulfill their obligations under this agreement, the other borrowers shall be fully responsible for satisfying the outstanding debt. The lender may seek to collect the full amount of the loan from any or all of the borrowers at their discretion. It is the responsibility of the borrowers to ensure that the loan is paid in a timely manner and in accordance with the terms of this agreement. The borrower shall also designate one primary contact who the loan will be issued to, and who shall be responsible for receiving and responding to all notices, requests, and other communications from the lender, as well as for providing updates or changes to the borrower's contact information.

      In the event of the borrower's death or deportation, all debts and liabilities under this loan agreement must be resolved prior to the execution of any estate or will transfers. The borrower's involvement in illegal activity that is funded by or conducted on a property owned or managed by Maze Bank Central or Shadow Corporation shall also be considered a default of this loan. Changing the borrower's name or identity will not absolve the borrower of their debt or responsibilities under this agreement. The borrower is not permitted to transfer any funds or assets funded by the loan to another individual or entity without prior approval from the lender. Any breach of this provision may result in the default of this loan contract and the lender may take any and all actions necessary to protect their interests.

      Maze Bank Central and Shadow Corporation reserve the right to terminate this loan at any time for any reason, and may request that the borrower immediately resolve all outstanding debts under this agreement with a discount of 10%.

      The borrower shall be responsible for the proper care and maintenance of any collaterals that are in the name of Maze Bank Central but are currently in the use of the borrower. This includes, but is not limited to, any fees or expenses associated with the collaterals, such as citations, maintenance services, and repairs. The borrower agrees to cover all such fees and expenses in full, without exception. Failure to do so may result in the borrower being in breach of this loan agreement.

      Maze Bank Central and Shadow Corporation, as the lender in this loan agreement, retain the right to inspect the property at any time, with or without prior notice, to ensure that the borrower is in compliance with the terms of this agreement. This inspection may include, but is not limited to, visual inspections of the interior and exterior of the property, as well as any and all improvements made to the property. The borrower hereby consents to such inspections and agrees to grant access to the property for the purpose of such inspections upon request.

      In the event of default on the loan, the borrower shall be responsible for paying a penalty of $50,000 in addition to the outstanding balance of the loan. Default is defined as the borrower's failure to make any required payment under this loan agreement within fourteen (14) days of the due date, or the borrower's breach of any other material term or condition of this agreement. The borrower agrees to pay all costs and expenses, including attorneys' fees, incurred by the lender in enforcing this loan agreement. The penalty shall be payable immediately upon default and shall be in addition to all other rights and remedies available to the lender under this agreement or at law or in equity.

    • REMINDER: Failing to pay back a loan, manipulating or acting maliciously with the trust placed in the borrower by this loan agreement or with the assets provided as collateral, is considered fraudulent, criminal, and may negatively impact the borrower's credit history and future business endeavors with Shadow Corporation and other financial institutions.
    Image
    • Regards,
      SIGNATURE
      Samuele Colonna,
      Executive Officer
      Shadow Corporation,
      Maze Bank Central.
    Image[/spoil]
((NB: Under instruction from LFM, Exhibits #1 and #14 have been removed, and all references to either the contract or bodycam footage in Exhibit #13 should have been crossed out similarly to the suppressed sections.))

Image
Terence Williams
Attorney General
San Andreas Judicial Branch
(909) 234-9321 — [email protected]
Image
Last edited by Terence Williams on 16 Feb 2025, 22:24, edited 1 time in total.
Maximilian Fitzgerald
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Maximilian Fitzgerald »

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San Andreas Judicial Branch

"EQUAL JUSTICE UNDER LAW"

  • Esteemed Prosecution and defence,

    Is there anything else either side wishes to raise to the court prior to finally getting to scheduling? Any decisions pending I have potentially missed, or any new motions you wish to raise? If not, please declare that you are ready for trial. You both have up to 7 days to respond before I schedule without your input.

    With the Highest Regard,

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    Superior Court Judge
    San Andreas Judicial Branch
    ☎ 1-000-000
    [email protected]
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Terence Williams
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Terence Williams »

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San Andreas Judicial Branch

Docket Notice
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Judge Fitzgerald and pertaining parties,

    ((Under instructions from LFM, Exhibits #7 and #18 have been removed.))

    Regards,
    Image
    Terence Williams
    Attorney General
    San Andreas Judicial Branch
    234-9321 — [email protected]
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Terence Williams
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Terence Williams »

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San Andreas Judicial Branch

Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

MOTION TO AMEND


IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Mike Luigi
#24-CM-0030

A Motion to Amend was filed in the above case on the 16th of February, 2025.


The State of San Andreas, by and through the undersigned attorney, filed this Motion to Amend, the original charges with the underlined amended charges.


  • Original Charges
    • 8x GM11 - Predatory Lending
    • GF06 - Blackmail
    • GF09 - Embezzlement
    • GF05 - Attempted Extortion

  • Amended Charges
    • 9x GM11 - Predatory Lending
    • GF06 - Blackmail
    • GF09 - Embezzlement
    • GF05 - Attempted Extortion

  • Detailed Explanation: The charges alleged against the defendant have been amended to reflect the totality of evidence provided in discovery since the filing of the indictment.


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Terence Williams
Attorney General
San Andreas Judicial Branch
234-9321 — [email protected]
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Re: #24-CM-0030 State of San Andreas v. Mike Luigi

Post by Hugh Allgood »

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Allgood Law

24-CM-0030
"Right Firm. Right Now"

  • Honorable Fitzgerald,

    Defense is ready to proceed to scheduling.

Respectfully,
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Owner/Attorney
Allgood Law
(909) 235-6076 — [email protected]

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