Eclipse Government

Defendant Name: Nanna Bohanna
Defendant Phone: 5585281
Defendant Address: Homeless
(( Defendant Discord: )) Hatter1990#5565
Requested Attorney: Tony McFornell

Charging Department: LSSD

Time & Date of Incident(s): 7/18/2022 around 6PM UTC
Charge(s): Possession of an illegal firearm & Possession of an illegal substance while armed.
Narrative: My boys and I were sitting at the gas station in Sandy talking to some nice young men while we waited for one of my boys to get his vehicle fixed as he crashed down the road. We were assaulted by men who were there to rob us at gunpoint. My hands went into the air and they robbed the men on bikes we were talking to of their guns and told us all to get on our knees. The police showed up and I took advantage of the moment to jump on my bike and get away. I waited until all the gunshots stopped and went back to find the place crawling with police and two of my boys on the ground bleeding from gunshots. Immediately, the police put me in cuffs and said I was detained as I was part of an active shoot out even though I was just being robbed and ran away. They told me that they wanted to search my motorcycle and I said that it was not something I felt comfortable with as I had done nothing wrong. They checked with another officer and came back to tell me that they legally had to check it. They led me to my motorcycle where I told them I did have a firearm that I found that I had kept for protection and some he found 4 joints that some nice young man gave me for my arthritis. They then took me to DOC and put me in the slammer for 2 months.

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I, [Nanna Bohanna], 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. ))

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• To whom it may concern,
  
  I, Public Defense Attorney Peit Vanniekerk, will provide Defense for Nanna Bohanna and am ready to proceed at the court's discretion.
  
  Respectfully,
  
  
  Junior Defense Attorney
  San Andreas Judicial Branch
  (909) 485-1978 — [email protected]

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• To whom it may concern,
  
  The purpose of this notice is to inform you that as of this moment I, Roderick Marchisio, will be representing the State of San Andreas in all the proceedings pertaining to the underlying case.
  
  I will take it upon myself to reach out to the involved parties to collect and review all evidence in relation to the underlying case to ensure a proper and smooth continuation of this process.

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Respectfully,


Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 — [email protected]

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• To whom it may concern,
  
  I will be presiding judge on this case and am activating it under docket #22-CM-0048.
  
  As I see both sides already have representation I will be ordering discovery from the prosecuting following this docket post.
  
  Respectfully,
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 402-9713 — [email protected]

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The case of the State of San Andreas v. Nanna Bohanna, #22-CM-0048 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 the 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]

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• Parties,
  
  While the prosecution collects evidence in the case I would like to clarify Ms. Bohannas representation. Listed on the initial case post by the defendant he requests Senior Defense Attorney Tony McFornell, however Public Defense Attorney Peit Vanniekerk made the court aware that he would be representing the client. Can the defense in the case please make the court aware who will be representing the defendant and who/if there will be co-counsel as well. Thank you.
  
  Respectfully,
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 402-9713 — [email protected]

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• Honorable Judge Daniels
  
  Due to some constrains on time, Defense Attorney McFornell will not be able to be primary counsels and so I will be taking primary in his stead.
  
  Respectfully,
  
  
  Junior Defense Attorney
  San Andreas Judicial Branch
  (909) 485-1978 — [email protected]

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• Honorable Judge Daniels
  
  Due to some constrains on time, Defense Attorney McFornell will not be able to be primary counsels and so I will be taking primary in his stead.
  
  Respectfully,
  
  
  Junior Defense Attorney
  San Andreas Judicial Branch
  (909) 485-1978 — [email protected]

San Andreas Judicial Branch
Motion for Discovery

Honorable Daniels,

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

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  State of San Andreas v. Nanna Bohanna
  Assigned Court Case Number: #22-CM-0048
  Requesting Party: N/A
  Party Members: Roderick Marchisio

  ---

  Exhibit #1: Arrest Report
  Type of Discovery: Physical Evidence
  Spoiler

  All Information from the Discovery [Provide a detail explanation as to the relevance of the discovery request]

  • 
    ARREST REPORT
    

    MUGSHOT

    SUSPECT 1 DETAILS

    • 
      Full Name: Nanna_Bohanna
      Telephone Number: 5585281
      Licenses Revoked: No
      Charges:
      • WF03 - Possession of Illegal Firearms/Weapons
      • DM02 - Possession of a Controlled Substance While Armed
      How did the suspect plea to the above charges?
      Suspect pleaded guilty to all charges.
      Additional Details (Suspect's vehicle, etc.) :

    VEHICLES INVOLVED

    • Vehicle A: Black Colored Manchez Ro Nanna Bohanna

    DEPUTY DETAILS

    • Full Name: Jay alva
      Badge Number: 21927
      Callsign: 11-R-31

    INCIDENT DETAILS

    • Date of Arrest: 2022-07-18
      Deputies Involved: agent Reno Sheriff Kirk
      
      Provide details of the incident leading up to the arrest
      • After receiving a radio call off a suspicious vehicle, we responded to the scene as shots were being fired.
        multiple injured and some fleeing scene, I detained a woman and and searched her person and vehicle.
        on her vehicle was a illegal .50 pistol and marijuana plants, she was placed under arrest and the firearm was taken in as evidence.

    ARRESTING DEPUTY SIGNATURE
    Jay Alva
    

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  Exhibit #2: Illegal items found on the Defendant
  Type of Discovery: Physical Evidence
  Spoiler

  .50 pistol with the serial number 1657247810078 together with the processed Marijuna
  

  Photo of the evidence

  
  Exhibit #3: Witness Statement Field Agent Wiley Reno
  Type of Discovery: Witness Statement
  Spoiler

  All Information from the Discovery [Provide a detail explanation as to the relevance of the discovery request]

  • 
    

    
    San Andreas Judicial Branch
    Official Witness Statement
    "HERE FOR YOU | SAFE FOR YOU"
    Case Information
    • Case Number: #22-CM-0048
      Incident Date: 18/JUL/2022
    Witness Information
    • Name: Wiley Reno
      Date of Birth: 23/MAY/1991
      Phone Number: 519-9706
      Occupation: Field Agent in the Sheriff's Department
    Witness Statement
    • On the date in question I was patrolling with my partner at the time Investigator Bunkie Johnson in Sandy Shores. We were aware of a developing situation at Grave's Gas in Sandy Shores and pulled around to investigate further. As we pulled around, we heard silenced firearm shots around the corner and dismounted, preparing to engage. There we saw multiple individuals discharging their firearms at each other at which time I neutralized a suspect actively discharging his weapon.
      
      We thoroughly investigated the scene and began searching the vehicles on scene as the shootout was quite expansive. Within the scene of the shootout was Ms. Bohanna's vehicle in question, which upon being opened was seen to be containing a Pistol .50 and narcotics. I believe we may have footage of this incident if Investigator Charlie Wilkinson saved the recording he acquired on scene.
      
      I'd be happy to answer further questions.
    Witness Affirmation
    • I, Wiley Reno, 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,
      
      
      Wiley Reno
      Field Agent
      Los Santos County Sheriff's Department
      
      Date: 17/AUG/2022
    
  Exhibit #4: Security footage
  Type of Discovery: Physical Evidence
  Spoiler

  • Security footage of the gas station at which the incident took place. It is clear and obvious that the Defendant was affiliated and friendly with the group that, as seen in the footage, also carried firearms and ended up in the shootout. The prosecution believes that this is more than enough justification to detain and search the suspect as well as their vehicle, as this had clearly been used in the situation.
    
    ((
    
    Please note that for RP purposes, the audio should not be included in the footage. As such, please treat the footage as if without any kind of audible audio.
    RP proof

    
    ))
    Evidence footage

    https://www.twitch.tv/videos/1535613965

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Sincerely,


Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 — [email protected]

San Andreas Judicial Branch
Motion to Amend Charges

Honorable Daniels,

• We the prosecution in the case are requesting an amendment of the charges.

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  State of San Andreas v. Nanna Bohanna
  Assigned Court Case Number: #22-CM-0048
  Requesting Party: Prosecution
  Party Members: Roderick Marchisio

  ---

  Original Charges:
  • WF03 - Possession of Illegal Firearms/Weapons
  • DM04 - Possession of a Controlled Substance while Armed
  Amended Charges:
  • WF03 - Possession of Illegal Firearms/Weapons
  • DM04 - Possession of a Controlled Substance while Armed
  • NM03 - Unlawful Assembly

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  Detailed explanation:
  
  The Prosecution notes that, as shown in Evidence Exhibit 4 as presented previously to the court, the Defendant was involved in the assembly of a group that displayed an act in a manner likely to terrify the general public, which is proven by the fact that all of the vehicles are parked in a manner to disturb the public as well as a public display of firearms. Therefore, the Prosectuion can only conclude that these circumstances should result in the applicability of the charge NM03 - Unlawful Assembly.

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Sincerely,


Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 — [email protected]

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• Counselors,
  
  At this time I move to schedule an evidence hearing to establish what will be admissible in regards to this case. Please use the following scheduling tool to file your availability, once completed I will announce a date and time when this will take place.
  
  Respectfully,
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 402-9713 — [email protected]

San Andreas Judicial Branch
Motion to Suppress

Honorable Judge Colt Daniels,

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

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  State of San Andreas v. Nanna Bohanna
  Assigned Court Case Number: #22-CM-0048
  Requesting Party: Defense
  Party Members: Defense Attorney Peit Vanniekerk in Defense of Nanna Bohanna

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  Requested Evidence to Suppress: Exhibit #2: Illegal items found on the Defendant

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  Detailed explanation: We believe that no reasonable suspicion was provided in discovery that opens Nanna Bohanna up for a search and detainment as they were not present when any firearms were discharged nor there during the active shoot out. Nor did they brandish any weapons of any kind.
  

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Sincerely,


Junior Defense Attorney
San Andreas Judicial Branch
(909) 485-1978 — [email protected][/list]

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• Counselors,
  
  At this time I move to have a motions hearing on this case. Use this scheduling tool to mark your availability, once completed I will be announcing the time and date when this will take place.
  
  Respectfully,
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 402-9713 — [email protected]

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• Counselors,
  
  I am once again attempting the schedule this Motions Hearing. Please use this scheduling tool, once completed I will announce a date and time.
  
  Respectfully,
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 402-9713 — [email protected]

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• Honourable Colt Daniels,
  
  I, Chief Public Defender Cyrus Raven, will be co-counsel on this case and representing the defendant Nanna Bohanna. I have filled my availability in the above scheduling tool.
  
  Respectfully,
  
  
  Chief Public Defender
  San Andreas Judicial Branch
  5356160 — [email protected]

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• Counselors,
  
  From the availability posted on the scheduling tool I will officially be scheduling this Motions Hearing for Thursday, October 6th at 7:00PM UTC. Please be at City Hall no later than 15 minutes prior.
  
  Respectfully,
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 402-9713 — [email protected]

San Andreas Judicial Branch
Motion for Discovery

Honorable Daniels,

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

  ---

  State of San Andreas v. Nanna Bohanna
  Assigned Court Case Number: #22-CM-0048
  Requesting Party: N/A
  Party Members: Roderick Marchisio

  ---

  Exhibit #5: Additional witness statement Wiley Reno
  Type of Discovery: Witness statement
  Spoiler

  All Information from the Discovery This additional witness statement of Senior Agent Reno with the LSSD gives a further insight into the timeline of events that happened at the time of the arrest of the Defendant. The Prosecution notes that this incident was a gang related one. As can be seen in evidence exhibit #4, it leaves no doubt that these different groups of people were coherently aiding each other in committing crimes and are affiliated with each other in a criminal way.
  
  As the LSSD obviously had to ensure safety of everyone on and around the scene, they detained everyone on it, as is standard protocol with incidents like these. The Prosecution further notes that the Defendant has already previously admitted to returning back to the scene. The witness statement of Agent Reno shows the timeline of events: first the Defendant was detained, then the footage was reviewed and only then was the Defendants' vehicle searched.
  
  Based on this witness statement, the Prosecution can only conclude that the Defendant was first detained based on reasonable suspicion, after which the review of the CCTV footage led to the probable cause for their vehicle to be searched. As such, the Prosecution can only conclude that the search and arrest were entirely justified.

  • 
    

    
    San Andreas Judicial Branch
    Official Witness Statement
    "HERE FOR YOU | SAFE FOR YOU"
    Case Information
    • Case Number: #22-CM-0048
      Incident Date: 18/JUL/2022
    Witness Information
    • Name: Wiley Reno
      Date of Birth: 23/May/1991
      Phone Number: 519-9706
      Occupation: Senior Agent in the Sheriff's Department
    Witness Statement
    • Upon arriving on the scene of the shootout, I immediately saw a suspect shooting at armed men who were driving away from the scene. I neutralized the suspect and worked quickly to arrange the detainment of everyone left on the scene. As can be seen from the footage, many of the individuals who were detained by us were armed prior to our arrival. As I detained all the individuals on scene, we began forming a perimeter in the general area of the shooting as we had reason to believe that the hostiles were still in the area.
      
      As the scene became more secure we began searching several containers as a part of our investigation into the shooting. It was clear that 1) This was a gang shooting, 2) There were armed members of either side engaging in the shootout and most importantly for this case, 3) Miss Bohanna was associated with the individuals taking part in the shootout.
      
      In an attempt to find the cause of the shooting, we began reviewing CCTV footage and searching containers. Miss Bohanna later returned to the scene and was detained as we believed she was involved in the shootout. After reviewing the footage, it was clear that Miss Bohanna was involved in the situation to some degree and fled upon our arrival. As Miss Bohanna's associates were armed and discharged their weapons, she was of course detained. After reviewing the footage further, we found that more individuals than we initially realized had been armed during the shootout. In an effort to be rigorous in our investigations into this gang-related shootout, Miss Bohanna's bike was searched due to it's integral nature in the original scene. Being that Miss Bohanna fled from this scene upon our arrival combined with the fact that she was associated with some of the assailants, we did not find this search improper. Sure enough, we found that Miss Bohanna had a firearm stored in the bike.
    Witness Affirmation
    • I, Wiley Reno, 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,
      
      
      Wiley Reno
      Senior Agent
      Los Santos County Sheriff's Department
      
      Date: 08/OCT/2022
    
  
  

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Sincerely,


Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 — [email protected]

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• Counselors,
  
  I have made the decision to grant the Motion to Suppress of Exhibit #2.
  
  This is due to the court's belief that, while law enforcement officers had established reasonable suspicion due to the defendants alleged association with some of the assailants and her proximity to the shootout, the court believes that probable cause to search Nanna Bohanna was not established, and thus the search of the defendant's vehicle was not a lawful search.
  
  Probable cause requires there to be sufficient evidence available to lead a reasonable person to believe that a specific crime had been committed, however, it is the court's decision that Nanna Bohanna's actions only established reasonable suspicion and not probable cause.
  
  Respectfully,
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 402-9713 — [email protected]

San Andreas Judicial Branch
Motion for Summary Judgment

Honorable Colt Daniels,

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

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  State of San Andreas v. Nanna Bohanna
  Assigned Court Case Number: #22-CM-0048
  Requesting Party: Cyrus Raven
  Party Members: Cyrus Raven, Nanna Bohanna

  ---

  Reasoning: Given the suppression of Exhibit #2, the defense believes no other facts are in contention and requests immediate summary judgement.

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  Detailed explanation:
  
  The Defense requests immediate summary judgement in favor of the Defendant. As observed in the latest motion ruling, probable cause was not established to justify the search and seizure of Ms Bohanna or her vehicle, making the items a product of an unlawful search and seizure and therefor inadmissible.
  
  Furthermore, with regards to the Unlawful Assembly amended charge. It seems clear to the Defense that Ms. Bohanna at no point meets the components of the charge.
  

  Two or more people, gathering together to do something illegal or who are disobedient to law enforcement instruction

  Ms. Bohanna was neither doing something illegal or disobedient to law enforcement.
  

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  Thank you for your consideration.

Sincerely,


Cyrus Raven
Chief Public Defender

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• The case of #22-CM-0048, State of San Andreas v. Nanna Bohanna has been resolved.
  
  On October 13th 2022 a Motions Hearing was held on this case. On October 10th the defense filed a Motion for Summary Judgement citing that due to the suppression of Exhbit #2 there was no evidence to prove guilty of the defendants two original charges.
  
  The defense also made the argument that due to no evidence of wrongdoing from the defendant, there was no baring for the amended charge of NM03 - Unlawful Assembly as the charge description states, "Two or more people, gathering together to do something illegal or who are disobedient to law enforcement instruction"
  
  As stated in the Motion for Summary Judgement, Ms. Bohanna was neither doing something illegal or disobedient to law enforcement.
  
  It is with the above considerations that I issue the following verdict:
  • On the count of WF03 - Possession of Illegal Firearms/Weapons, I find the defendant, Nanna Bohanna, not guilty.
  • On the count of DM04 - Possession of a Controlled Substance while Armed, I find the defendant, Nanna Bohanna, not guilty.
  • On the count of NM03 - Unlawful Assembly, I find the defendant, Nanna Bohanna, not guilty.
  
  
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 402-9713 — [email protected]