Eclipse Government

Posted: **15 Mar 2022, 00:39**

Defendants Name: Harley Pavlovich
Defendants Phone: 4714790
Defendants Address: N/A
Requested Defender: Darcy Lafleur

Charging Department: Los Santos Police Department

Time & Date of Incident(s): 22/FEB/2022 22:40
Charge(s): GF16 - Tampering With Evidence
Narrative: If I recall, the narrative for this charge was the following:

I was sat on my BF400 at Legion Square, pulled over with my engine off, replying to a text message that came through to my phone. I was then surprised by Jason Steel & Grace Steel stepping out of their cruiser aiming heavy weapons at me and demanding I step off my vehicle, which I complied with.
I was then placed under arrest by Grace Steel, and my BF400 was searched, when a Pistol .50 was found in the storage compartment, and so I was charged with an Illegal Firearms charge.

I'm extremely confused why the 'Tampering with Evidence' charge was ever added to my file. I never touched any evidence nor attempt to hide this evidence from Jason Steel while they frisked and arrested me. I merely excercised my right to remain silent and did not make any comments about the evidence that was found.

I believe this charge was incorrectly placed on me, and would like it to be removed. This General Felony being incorrectly placed on me has also caused my request for a property and my business plans to be delayed, causing my investments in this business to be rendered useless.

I, Harley Pavlovich, hereby affirm that all information provided above is true and correct to the best of my knowledge, and understand that knowingly providing false information could result in additional charges and/or fines. ((I affirm that all information submitted has been obtained via In-Character means.))

Posted: **15 Mar 2022, 01:07**

San Andreas Judicial Branch

"HERE FOR YOU | SAFE FOR YOU"

Your Honor,

I will be counsel for Ms. Pavlovich, I have met with my client, and we are ready to proceed at the courts discretion.

Respectfully,

Darcy Lafleur
Public Defense Attorney
San Andreas Judicial Branch
(909) 241-7634 — [email protected]

Posted: **29 Mar 2022, 10:17**

San Andreas Judicial Branch
Re: State of San Andreas v. Harley Pavlovich
"HERE FOR YOU | SAFE FOR YOU"

Your Honor,

My name is Sai Modi and I will act as counsel on behalf of the State of San Andreas in this case. I am familiarizing myself with the case and will be reaching out to the the relevant parties to gather more information.

Respectfully,

Sai Modi
Senior Prosecuting Attorney
San Andreas Judicial Branch
364-9436

Posted: **13 Apr 2022, 22:15**

San Andreas Judicial Branch
Personal Email
"HERE FOR YOU | SAFE FOR YOU"

Your Honour,

My name is Ares Light and I will act as co-counsel to Mrs.Lafleur in this case. I am familiarizing myself with the case and ready to proceed at the courts discretion.

Respectfully,

Student At Law
San Andreas Judicial Branch
(909) 354-7387 — [email protected]

Posted: **15 Apr 2022, 04:45**

San Andreas Judicial Branch
Re: #22-CM-0008, State of San Andreas v. Harley Pavlovich
"HERE FOR YOU | SAFE FOR YOU"

Parties,

As we now have representation appointed for both the prosecution and defense, I will be opening this case under docket number #22-CM-0008. Immediately following this message, I will be ordering discovery from the prosecution, requiring that all evidence be submitted within 7 days. Once evidence has been submitted to the Court, the defense may begin submitting motions in response.

Respectfully,

Chief Justice
San Andreas Judicial Branch
(909) 402-9713 — [email protected]

Posted: **15 Apr 2022, 04:47**

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

#22-CM-0008
Presiding Judge: Colt Daniels

ORDER FOR DISCOVERY

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#22-CM-0008

A court order was entered in the above case on 15 April, 2022.

The case of the State of San Andreas v. Harley Pavlovich, #22-CM-0008 is hereby opened and acknowledged by the Court.

The prosecution is hereby ordered to provide all evidence collected from the arresting Law Enforcement Agency and submit it to the Court via Motion for Discovery within seven days. If additional time is needed, the prosecution can file a Motion for Continuance.

Once evidence has been submitted to the official docket the defense can begin filing motions.

Chief Justice
San Andreas Judicial Branch
(909) 402-9713 — [email protected]

Posted: **18 Apr 2022, 05:50**

Motion for Discovery

San Andreas Judicial Branch
Motion for Discovery

Honorable Colt Daniels,

We the Prosecution in the case below are presenting our discovery to the court.
State of San Andreas v. Harley Pavlovich
Assigned Court Case Number: #22-CM-0008
Requesting Party: N/A
Party Members:
Exhibit #1: LSPD Arrest Report
Type of Discovery:
- Document
Spoiler
All Information from the Discovery [Provide a detail explanation as to the relevance of the discovery request]
- Jason Steel wrote: ↑22 Feb 2022, 23:01
  
  Los Santos Police Department
  ARREST REPORT
  "TO PROTECT AND SERVE"
  
  MUGSHOT
  SUSPECT DETAILS
  
  Full Name: Harley Pavlovich
  Phone Number: 4714790
  Licenses Suspended: N/A
  Officers Involved:
  Police Captain II Jason Steel
  
  Police Detective II Eleanor Quinn
  
  Police Detective I Grace Steel
  
  Police Officer II Joshua Fellows (not on scene)
  
  Charges:
  
  Failure to pay Fines (was already present from Officer J. Fellows)
  
  Possession of an Illegal Firearm
  
  Possession of a Controlled Substance While Armed
  
  Tampering with Evidence
  
  INCIDENT NARRATIVE
  
  Explain what happened, no need to provide too much detail, videos could be provided
  
  The suspect was operating a motorbike while clearly carrying a firearm in her waistline, we engaged our lights and sirens to pull her over and inquire about the firearm, prior to pulling over she opened the storage compartment in the motor vehicle and placed the firearm inside. She was then arrested at gunpoint and the firearm recovered successfully.
  
  EVIDENCE DETAILS
  
  Document the possessions confiscated from the arrested suspect.
  Legal possessions may be grouped and documented as "Legal Possessions". Illegal possessions must be documented individually, examples of documented illegal possessions are "Pistol .50" or "12 grams of Cocaine". Body camera footage may be attached as an evidence exhibit.
  
  Exhibit A: Pistol .50 cal with 56 bullets, loaded
  Exhibit B: 4x Marijuana Seeds
  Exhibit C: 3x Marijuana Plants
  
  Photograph of possessions in evidence locker (if applicable)
Exhibit #2: LSPD Bodycam footage
Type of Discovery:
- Physical Evidence
Spoiler
All Information from the Discovery [Provide a detail explanation as to the relevance of the discovery request]
- Jason Steel wrote: ↑17 Apr 2022, 19:44 bodycamera footage (( proof of RP ))

Sincerely,

Sai Modi
Senior Prosecuting Attorney

Posted: **21 Apr 2022, 21:51**

Motion to Compel Discovery

San Andreas Judicial Branch
Motion to Compel Discovery

Honorable Colt Daniels,

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.
State of San Andreas v. Harley Pavlovich
Assigned Court Case Number: #22-CM-0008
Requesting Party: Defense
Party Members:
Discovery from: LSPD

Type of Discovery:
- Physical Evidence - Bodycam Footage
Detailed reasoning: [Provide a detailed explanation as to the relevance of the discovery request]
- We the Defense are requesting any more bodycam in relation to this case. The bodycam provided just showed the very beginning of the traffic stop. We would like to request an extended version or any other bodycam of the entire situation from the initial stop to the arrest.

Sincerely,

Darcy Lafleur
Public Defense Attorney
San Andreas Judicial Branch
(909) 241-7634 — [email protected]

Public Defence Attorney
San Andreas Judicial Branch
(909) 354-7387 — [email protected]

Posted: **21 Apr 2022, 21:58**

Motion for Continuance

San Andreas Judicial Branch
Motion for Continuance

Honorable Colt Daniels,

We the Defense in the case below are requesting a Continuance for 1 day for the reason listed below.
State of San Andreas v. Harley Pavlovich
Assigned Court Case Number: #22-CM-0008
Detailed explanation:
As we the defense just put in a Motion to Compel Discovery, we would like to have an ample amount of time to try to inquire and gather the evidence requested.

Sincerely,

Darcy Lafleur
Public Defense Attorney
San Andreas Judicial Branch
(909) 241-7634 — [email protected]

Public Defence Attorney
San Andreas Judicial Branch
(909) 354-7387 — [email protected]

Posted: **22 Apr 2022, 00:28**

San Andreas Judicial Branch

"HERE FOR YOU | SAFE FOR YOU"

Superior Court,

I would like to formally contest the motion to compel discovery that the defense has submitted above. I think it is irrelevant to both the case at hand and the charges that are in dispute in this particular predicament as there is no need to provide any further bodycam footage or any "extended" variants of the submitted bodycam footage as we can clearly see, without a reasonable doubt, that the defendant, Miss Harley Pavlovich has concealed her firearm in an on-going investigation by the Los Santos Police Department, said investigation being the traffic stop. We would like to also like to re-iterate to the court that the reason for this particular traffic stop is that the individual was WANTED for GM16 - failure to pay a fine.

Respectfully,

Sai Modi
Senior Prosecuting Attorney
San Andreas Judicial Branch
364-9436

Posted: **22 Apr 2022, 00:38**

Motion for Summary Judgment

San Andreas Judicial Branch
Motion for Summary Judgment

Honorable Colt Daniels,

We the Prosecution in the case below are requesting a summary judgment.
State of San Andreas v. Harley Pavlovich
Assigned Court Case Number: #22-CM-0008
Requesting Party: Prosecution
Party Members: Sai Modi on behalf of the state of San Andreas
Reasoning: We believe the charges that were placed are valid, beyond a reasonable doubt.
Detailed explanation:
As explained in my formal contest of the defense's Motion to Compel discovery, we have clearly provided that based on the evidence, and beyond a reasonable doubt, the individual concealed their firearm in their vehicle's storage compartment in attempts to elude and to interfere with an investigation that is conducted by an on-duty peace officer at that time.

Thank you for your consideration.

Sincerely,

Sai Modi
Senior Prosecuting Attorney

Posted: **22 Apr 2022, 19:52**

San Andreas Judicial Branch

"HERE FOR YOU | SAFE FOR YOU"

Your Honor,

The Defense is more than happy to hold a meeting in chambers or a motions hearing to discuss the matters at hand.

Sincerely,

Darcy Lafleur
Public Defense Attorney
San Andreas Judicial Branch
(909) 241-7634 — [email protected]

Public Defence Attorney
San Andreas Judicial Branch
(909) 354-7387 — [email protected]

Posted: **23 Apr 2022, 03:29**

Form 3.0.5 - Issuance of Verdict

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

ISSUANCE OF VERDICT - 22-CM-0008

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
22-CM-0008

CHARGES BEING DISPUTED:
GF16 - Tampering with Evidence

A verdict was entered in the above case on the 22th day of April, 2022.

The case of 22-CM-0008 - State of San Andreas v. Harley Pavlovich has hereby been resolved.

During a motions hearing a Motion for Summary Judgement filed by the prosecution was granted. Due to bodycam footage in this case a Motion for Summary Judgement asks the court for a judgment on the merits of the case before the trial. It is properly made where there is no dispute about the facts and only a question of law needs to be decided.

This verdict rules that the prosecution was not able to prove beyond a reasonable doubt that Harley Pavlovich's intent for placing the illegal firearm into the storage compartment of her vehicle was to conceal it from law enforcement during the course of the investigation.

Harley Pavlovich will have the charge of GF16 removed from her record. This case is now closed.
- CHARGES BEING DISPUTED:
  GF16 - Tampering with Evidence [NOT GUILTY]

Chief Justice
San Andreas Judicial Branch
(909) 402-9713 — [email protected]