Eclipse Government

Posted: **19 Jul 2022, 19:28**

Defendant Name: Tony Solicetto
Defendant Phone: 565-4264
Defendant Address: 3 Forum Dr.
(( Defendant Discord: Dimitri#7980 ))
Requested Attorney: Cyrus Raven

Charging Department: Los Santos Police Department, Los Santos Sheriffs Department

Time & Date of Incident(s): 5:30PM (( UTC )), 19/JULY/2022
Charge(s):

DM02 - Possession of a Controlled Substance While Armed
WF03 -Possession of Illegal Firearms/Weapons
GM14 - Obstruction of Justice

Narrative:

It started from a 9-1-1 call from a felon who was robbed apparently and gave the description of a blacked out Kamacho which at the end of the day, if you see one in the area you will pull it over especially from a robbery call. I want to make it clear for the court that a BLACK KAMACHO, is one of the most common offroading 4 door vehicles anyone has. Now we got pulled out of our vehicle and searched, we were handcuffed and the whole script of what they do. Now as an African American man from the hood, I do expect this often as I was a big time criminal a few months back. I only recently started stepping outside again after the deaths of family Deandre Boreland and Santana Borelands. I haven't committed any crimes that would deem the investigations to go further than they did. We got cleared to leave the traffic stop from the apparent robbery as there was nothing on us that would indict us. As we cleared we were still surrounded by multiple units as the ones that responded were about 6+. So as we leave we are driving up towards Chilliad tunnel leading in direction of Grapeseed to which we were pulled over again by the same exact cop not even 30seconds - 1 minute from the last traffic stop. The driver of that cruiser waited about 15 seconds or so and every single unit was back on us and even the Chief of Police had come down... We were harrassed by the PD officers and ripped out of our car completely disregarding the fact we were cleared from a call earlier from the same guy. Now this new call apparently gave them the reason to search us because the caller was now found shot, which once again how would that be us if we were already out of the area and the first car to leave the scene of a traffic stop.

This is where shit gets out of hand as Detective labradoodle and Chief of Police Lex Roth force their entry into our vehicle and attempt to breach our rights. First things first, they had no hard evidence or even a clue that we were the vehicle involved with the shooting. They kept attempting to force us to do the GSR test which I refused and was threatened with jail because of it. I never once had the charge or the GSR test done on me from Detective labradoodle making it simply a scare tactic to get me to suck up to them and allow them to do as they please. I don't fall for that stuff and I know my rights as a civilian in the county of San Andreas. The lack of knowledge of the whole situation was very well present seeing they kept going away from the scene to whisper to each other in order to find out more things to do. I just feel like we were targeted from PD, as it made no sense to why they were up in SD's JURO investigating 911 calls when they weren't requested to do so.

I do want to make it clear that his appeal is to also callout the corruption that is constantly happening by Detective Labradoodle and Chief of Police Lex Roth.

I, Tony Solicetto, 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: **13 Aug 2022, 09:47**

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

To whom it may concern,

I, Defense Attorney Robert Winejudge, will be representing Defendant Tony Solicetto in this case. I will be reaching out to my client, and making myself aware of the case and its contents. I am ready to proceed at the court's discretion once I have met with my client and the case is activated. I will also reach out to Attorney Cyrus Raven, since he is the requested attorney, to see if he wants to co-counsel on this case.

Respectfully,

Public Defense Attorney
San Andreas Judicial Branch
(909) 372-4223 — [email protected]

Posted: **13 Aug 2022, 15:45**

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

May it please the court,

I, Public Defense Attorney Cyrus Raven, will be co-counselling with Public Defense Attorney Winejudge and representing the defendant Tony Solicetto in this case.

Respectfully,

Public Defense Attorney
San Andreas Judicial Branch
5356160 — [email protected]

Posted: **24 Aug 2022, 02:42**

San Andreas Judicial Branch
Re: #22-CM-0052, State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Parties,

I am Associate Justice Judith Mason and I will be the presiding over this case in my courtroom. At this point in time, I will be assigning this case to docket number #22-CM-0052.

This case is now pending appointment of a prosecuting attorney.

Respectfully,

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Posted: **01 Sep 2022, 10:03**

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

To Whom It May Concern,

I, prosceutor Aleksandar Butanovich, will be representing the State of San Andreas as their counsel. I will get it upon myself to familirize with this case and start collecting evidence for the court.

I would further like to point out to the court that a detective with a last name "Labradoodle" is currently not and never was employed with Los Santos Police Department. The prosecution would like to request that the defendant doesn't give parties invovled random names, as it does not help this case at all.

Respectfully,

General Attorney Aleksandar Pulaski
Prosecuting Division
San Andreas Judicial Branch
(909) 365-8706 — [email protected]

Posted: **01 Sep 2022, 22:38**

San Andreas Judicial Branch
Re: #22-CM-0052, State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Parties,

Now that we have a prosecuting attorney assigned for this case, I will be ordering that discovery be presented within 7 days.

Additionally for Defense Attorneys Winejudge and Raven - please advise your client that derogatory and disrespectful language will not be tolerated by this court.

Respectfully,

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Posted: **01 Sep 2022, 22:39**

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

#22-CM-0052
Presiding Judge: Judith Mason

ORDER FOR DISCOVERY

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Tony Solicetto
#22-CM-0052

A court order was entered in the above case on 1 September, 2022.

The case of the State of San Andreas v. Tony Solicetto, #22-CM-0052 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.

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Posted: **06 Sep 2022, 16:54**

Motion for Continuance

San Andreas Judicial Branch
Motion for Continuance

Honorable Mason,

We the Prosecution in the case below are requesting a Continuance for 5 days for the reason listed below.
State of San Andreas v. Tony Solicetto
Assigned Court Case Number: 22-CM-0052
Detailed explanation:
The arresting department is yet to respond to the Prosecution's request for information.

Sincerely,

Aleksandar Pulaski
General Prosecuting Attorney

Posted: **07 Sep 2022, 18:41**

San Andreas Judicial Branch
Re: #22-CM-0052, State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Parties,

The Motion for Continuance is granted, extending the deadline for discovery to 13/SEP/2022.

Respectfully,

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Posted: **13 Sep 2022, 21:29**

Motion for Discovery

San Andreas Judicial Branch
Motion for Discovery

Honorable Judith Mason,

We the prosecution in the case below are presenting our discovery to the court.
State of San Andreas v. Tony Solicetto
Assigned Court Case Number: 22-CM-0052
Requesting Party: Superior Court
Party Members: State of San Andreas & Tony Solicetto and defense counsel
Exhibit #1: LSPD
Type of Discovery: [Deposition/Physical Evidence/Interview/Interrogation/Document Request] (Ex. Interview)
- Witness Statement
Spoiler
All Information from the Discovery A witness statement from an involved Detective, who reports searching a vehicle Mr. Solicetto was in. During the search of vehicle, Mr. Solicetto's prints were located on one of the pistols located in the vehicle.
- Phillipe Sanchez wrote: ↑04 Sep 2022, 17:55
  Samuel Martin wrote: ↑04 Sep 2022, 17:19
  
  San Andreas Judicial Branch
  Official Witness Statement
  "HERE FOR YOU | SAFE FOR YOU"
  
  Case Information
  
  Case Number: #22-CM-0052
  Incident Date: 19/JULY/2022
  
  Witness Information
  
  Name: Samuel Martin
  Date of Birth: 10/JUNE/1990
  Phone Number: 2576989
  Occupation: Police Detective I, Los Santos Police Department
  
  Witness Statement
  
  I, Samuel Martin, was patrolling in SD's juro when a 911 call came in about regarding a black Kamacho shooting someone. Myself and Lex Roth started to head toward the location of the call. As our unit was on the way we spotted a black Kamacho stopped by an SD unit. Out unit stopped to assist the SD unit on the stop as they were alone. SD saw the vehicle leaving the area of the 911 call. To investigate if these people in the vehicle were the suspects who shot someone I performed a GSR test on the occupants. One of the occupants was compliant and was GSR negative, however when I went to GSR test Tony Solicetto he was not compliant. Tony was warned that he would be charged with Obstruction of Justice if he kept delaying and obstructing the investigation. Tony continued so he was charged.
  
  During a search of the vehicle, two pistol .50's were found. Prints one one of them came back to Tony Solicetto. Both weapons and the fingerprint tape was given to the arresting officer in SD, so they could be stored and logged on the arrest report.
  
  Witness Affirmation
  
  I, Samuel Martin, 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,
  
  Samuel Martin
  Police Detective I
  Los Santos Police Department
  
  Date: 04/SEP/2022
Unfortunately, the arrest report does not exist.

Sincerely,

Hugh R. Allgood
Attorney General

Posted: **13 Sep 2022, 23:32**

Motion to Suppress

San Andreas Judicial Branch
Motion to Suppress

Honorable Judith Mason,

We the Defense in the case below are requesting that certain evidence be inadmissible in court.
State of San Andreas v. Tony Solicetto
Assigned Court Case Number: #22-CM-0052
Requesting Party: Cyrus Raven
Party Members: Cyrus Raven (Attorney), Tony Solicetto (Defendant)
Requested Evidence to Suppress: Exhibit #1
Detailed explanation:

The Defense is requesting the following highlighted portion of Exhibit #1 be suppressed due to hearsay.
Exhibit #1
All Information from the Discovery A witness statement from an involved Detective, who reports searching a vehicle Mr. Solicetto was in. During the search of vehicle, Mr. Solicetto's prints were located on one of the pistols located in the vehicle.
- Phillipe Sanchez wrote: ↑04 Sep 2022, 17:55
  Samuel Martin wrote: ↑04 Sep 2022, 17:19
  
  San Andreas Judicial Branch
  Official Witness Statement
  "HERE FOR YOU | SAFE FOR YOU"
  
  Case Information
  
  Case Number: #22-CM-0052
  Incident Date: 19/JULY/2022
  
  Witness Information
  
  Name: Samuel Martin
  Date of Birth: 10/JUNE/1990
  Phone Number: 2576989
  Occupation: Police Detective I, Los Santos Police Department
  
  Witness Statement
  
  I, Samuel Martin, was patrolling in SD's juro when a 911 call came in about regarding a black Kamacho shooting someone. Myself and Lex Roth started to head toward the location of the call. As our unit was on the way we spotted a black Kamacho stopped by an SD unit. Out unit stopped to assist the SD unit on the stop as they were alone. SD saw the vehicle leaving the area of the 911 call. To investigate if these people in the vehicle were the suspects who shot someone I performed a GSR test on the occupants. One of the occupants was compliant and was GSR negative, however when I went to GSR test Tony Solicetto he was not compliant. Tony was warned that he would be charged with Obstruction of Justice if he kept delaying and obstructing the investigation. Tony continued so he was charged.
  
  During a search of the vehicle, two pistol .50's were found. Prints one one of them came back to Tony Solicetto. Both weapons and the fingerprint tape was given to the arresting officer in SD, so they could be stored and logged on the arrest report.
  
  Witness Affirmation
  
  I, Samuel Martin, 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,
  
  Samuel Martin
  Police Detective I
  Los Santos Police Department
  
  Date: 04/SEP/2022

Sincerely,

Cyrus Raven
Senior Defense Attorney

Posted: **13 Sep 2022, 23:38**

Addendum to discovery

Exhibit 2:

Spoiler

Joe Olson wrote: ↑13 Sep 2022, 23:03

Los Santos County Sheriff's Department
"A TRADITION OF SERVICE"

September 14th, 2022
General Attorney H. Allgood

As requested earlier, you will find in this notice a document attached that shows our evidence locker log book entries for Tony Solicetto on the day of the incident.

** You would see a Logbook copy print**

From

Lieutenant Joe Olson
Assistant Patrol Commander, South Patrol Division
Los Santos County Sheriff's Department

Posted: **13 Sep 2022, 23:40**

Motion to Dismiss

San Andreas Judicial Branch
Motion to Dismiss

Honorable Judith Mason,

We the Defense in the case below are requesting this case be dismissed by the court, please find the reason for it below.
State of San Andreas v. Tony Solicetto
Assigned Court Case Number: #22-CM-0052
Requesting Party: Cyrus Raven
Party Members: Cyrus Raven (Attorney), Tony Solicetto (Defendant)
Motion to Dismiss: Insufficient Evidence
Detailed explanation:

The defense is requesting the charges against the defendant be dismissed due to insufficient evidence provided by the prosecution.

As established in #22-AP-0003, Roxy Teat v. State of San Andreas and 22-CM-0040, State of San Andreas v. Gregory Gregov, the prosecution has to prove, beyond a reasonable doubt, the crimes the defendant was charged with.

In criminal cases, the prosecution's burden of proof must be beyond a reasonable doubt. This means that the evidence must point to the person's guilt in such a way that any reasonable person would find them guilty. (Source: Judicial Branch Handbook)
The prosecution has had a total of 56 days to collect statements from the relevant agencies, Officers and Deputies about the situation that occurred on the 19th of July.

However, the only exhibits given have been a set of evidence locker logs and a single witness statement by Detective Samuel Martin of which no probable cause for a search can be established. The Detective doesn't mention the type of 911 made, nor the location of the 911 call, nor the location of the Kamacho when it was pulled over. Relying on hearsay by claiming ''SD saw the vehicle leaving the area of the 911 call.''

No arrest report has been provided. Arrest reports are a mandatory component of police work and must be submitted with every arrest.

No body-cam/dash-cam from any involved Officer/Deputy was provided. All agencies require their staff members to use body-cams throughout the entirety of their time on-duty

No further witness statements from any other involved officer/deputy has been provided.

As such, there is insufficient evidence to prove beyond a reasonable doubt that the alleged crimes occurred. Any and all evidence allegedly seized from the defendant would have been considered fruit of the poisonous tree and inadmissible.

Thank you for your consideration.

Sincerely,

Cyrus Raven
Senior Defense Attorney

Posted: **13 Sep 2022, 23:49**

San Andreas Judicial Branch
Re: #22-CM-0052, State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Parties,

It is clear a Motions Hearing is required for this case to address the discovery, suppression, and dismissal motions. To account for Attorney Winejudge's soon-expiring leave of absence, please mark your availability between the dates of 15/SEP and 21/SEP using this scheduling tool.

Respectfully,

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Posted: **15 Sep 2022, 23:04**

San Andreas Judicial Branch
Re: #22-CM-0052, State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Parties,

I will be scheduling this Motions Hearing for Friday, September 16th, at 6pm (( UTC )).

Respectfully,

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Posted: **16 Sep 2022, 19:01**

San Andreas Judicial Branch
Re: #22-CM-0052, State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Parties,

Due to unforeseen scheduling concerns, this hearing was canceled pending rescheduling using this scheduling tool.

Respectfully,

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Posted: **13 Oct 2022, 20:33**

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

Honorable Judith Mason,

I, Junior Defense Attorney Sarah Williams, will be co-counseling with Defense Attorney Robert Winejudge and representing the defendant Tony Solicetto in this case. I will be familiarizing myself with the case and will be ready to assist my client.

Respectfully,

Sarah Williams
Junior Defense Attorney
San Andreas Judicial Branch
463-8400 — [email protected]

Posted: **17 Oct 2022, 04:25**

San Andreas Judicial Branch
State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Superior Court of San Andreas,

Let the record reflect that I will prosecute this case on behalf of the State of San Andreas. I will begin the necessary preparations and will be ready to proceed at the discretion of the Superior Court.

Respectfully,

Attorney General
San Andreas Judicial Branch
(909) 235-6076 — [email protected]

Posted: **28 Oct 2022, 17:14**

San Andreas Judicial Branch
Re: #22-CM-0052, State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Honorable Judith Mason,

Is the court able to schedule a hearing for the pending evidence and motions at it's earliest convenience? I believe Attorney General Allgood has assigned himself and we are ready to proceed.

Respectfully,

Chief Public Defender
San Andreas Judicial Branch

Posted: **29 Oct 2022, 00:59**

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

Honorable Judith Mason,

I, Junior Defense Attorney Sarah Williams, will be stepping off this case due to division transfers.

Respectfully,

Sarah Williams
Junior Defense Attorney
San Andreas Judicial Branch
463-8400 — [email protected]

Posted: **29 Oct 2022, 02:15**

San Andreas Judicial Branch
Re: #22-CM-0052, State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Parties,

This case is now pending a Motions Hearing to discuss the following:
- Prosecution's Motion for Discovery of S. Martin Witness Statement
- Defense's Motion to Suppress Portion of S. Martin Witness Statement
- Prosecution's Addendum to Motion for Discovery to include Evidence Locker Logbook entries
- Defense's Motion to Dismiss
Please use this scheduling tool to mark your upcoming availability.

Respectfully,

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Posted: **11 Nov 2022, 00:56**

San Andreas Judicial Branch
Re: #22-CM-0052, State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Parties,

Please use this scheduling tool to mark your upcoming availability for a Motions Hearing.

Respectfully,

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Posted: **23 Nov 2022, 12:32**

Motion for Involuntary Dismissal

San Andreas Judicial Branch
Motion for Involuntary Dismissal

Honorable Judith Mason,

We the Defense in the case below are requesting an involuntary dismissal from the court, please find the reason for it below.
State of San Andreas v. Tony Solicetto
Assigned Court Case Number: #22-CM-0052
Requesting Party: Cyrus Raven
Party Members: Tony Solicetto, Cyrus Raven, Robert Winejudge
Involuntary Dismissal: Unreasonable Delay
Detailed explanation:

This case has been active since the 1st of September following the Order for Discovery, we've had plenty of opportunities to resolve this case and have motions pending, including a motion to dismiss. The length of time taken to get this case over with has placed an extreme unreasonable delay on the Defendant.

We at this time waive any hearing relating to this specific motion and request the court make a determination on the docket. If denied, we would like to request a verbal hearing for the other outstanding motions.

As such we request an involuntary dismissal for this matter.

Thank you for your consideration.

Sincerely,

Cyrus Raven
Chief Public Defender

Posted: **26 Nov 2022, 22:42**

San Andreas Judicial Branch
Re: #22-CM-0052, State of San Andreas v. Tony Solicetto
"HERE FOR YOU | SAFE FOR YOU"

Parties,

At this point in time, I will be denying the defense's recent Motion for Involuntary Dismissal due to the recent changes to the Superior Court, which will allow this case to proceed without an in-person Motions Hearing.

I would ask that any supplementary arguments in support or against the pending motions listed below be presented to the docket in writing and in a timely manner. I will be making a decision on these motions within the next few days and will proceed with scheduling a trial, should it be necessary.
- Prosecution's Motion for Discovery of S. Martin Witness Statement
- Defense's Motion to Suppress Portion of S. Martin Witness Statement
- Prosecution's Addendum to Motion for Discovery to include Evidence Locker Logbook entries
- Defense's Motion to Dismiss
Thank you all for your patience and cooperation.

Respectfully,

Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]

Posted: **27 Nov 2022, 00:04**

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

Honorable Judith Mason,

The Defense has no objections against Exhibit #1 and #2 being admitted into evidence. However, we are seeking to suppress a portion of Exhibit #1 which is, in our view, clearly hearsay, further details in the motion to suppress.
Motion to Suppress
Cyrus Raven wrote: ↑13 Sep 2022, 23:32
Motion to Suppress

San Andreas Judicial Branch
Motion to Suppress

Honorable Judith Mason,

We the Defense in the case below are requesting that certain evidence be inadmissible in court.
State of San Andreas v. Tony Solicetto
Assigned Court Case Number: #22-CM-0052
Requesting Party: Cyrus Raven
Party Members: Cyrus Raven (Attorney), Tony Solicetto (Defendant)
Requested Evidence to Suppress: Exhibit #1
Detailed explanation:

The Defense is requesting the following highlighted portion of Exhibit #1 be suppressed due to hearsay.

Exhibit #1
All Information from the Discovery A witness statement from an involved Detective, who reports searching a vehicle Mr. Solicetto was in. During the search of vehicle, Mr. Solicetto's prints were located on one of the pistols located in the vehicle.

Phillipe Sanchez wrote: ↑04 Sep 2022, 17:55
Samuel Martin wrote: ↑04 Sep 2022, 17:19

San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"

Case Information

Case Number: #22-CM-0052
Incident Date: 19/JULY/2022

Witness Information

Name: Samuel Martin
Date of Birth: 10/JUNE/1990
Phone Number: 2576989
Occupation: Police Detective I, Los Santos Police Department

Witness Statement

I, Samuel Martin, was patrolling in SD's juro when a 911 call came in about regarding a black Kamacho shooting someone. Myself and Lex Roth started to head toward the location of the call. As our unit was on the way we spotted a black Kamacho stopped by an SD unit. Out unit stopped to assist the SD unit on the stop as they were alone. SD saw the vehicle leaving the area of the 911 call. To investigate if these people in the vehicle were the suspects who shot someone I performed a GSR test on the occupants. One of the occupants was compliant and was GSR negative, however when I went to GSR test Tony Solicetto he was not compliant. Tony was warned that he would be charged with Obstruction of Justice if he kept delaying and obstructing the investigation. Tony continued so he was charged.

During a search of the vehicle, two pistol .50's were found. Prints one one of them came back to Tony Solicetto. Both weapons and the fingerprint tape was given to the arresting officer in SD, so they could be stored and logged on the arrest report.

Witness Affirmation

I, Samuel Martin, 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,

Samuel Martin
Police Detective I
Los Santos Police Department

Date: 04/SEP/2022

Sincerely,

Cyrus Raven
Senior Defense Attorney
Furthermore, we have likewise issued a Motion to Dismiss. In this motion we assume the previous motion to suppress has been denied. If the motion to suppress is granted, I suspect this would further warrant the motion to dismiss.

To provide clear arguments for the motion to dismiss:
1. There is a single witness statement posted. While this doesn't in itself prove or disprove a case, it is very concerning given the alleged amount of units on scene.
2. There is no body-cam footage provided, something which all on-duty law enforcement officers are obligated to use.
3. There is no arrest report, something which is mandatory for all law enforcement agencies to record after every arrest.
4. There was no probable cause for a traffic-stop. In the Los Santo's Police Department's own manual 1.2 Evidence and Probable Cause, 1.2.2 Probable Cause it is very clear under the examples section that a vehicle near an illegal area where a crime has been committed does not give officers automatic probable cause to search someone or their vehicle. Instead this can be used to approach the vehicle and try and obtain extra information through questioning. It is clear from the testimony by Detective Martin
  
  To investigate if these people in the vehicle were the suspects who shot someone I performed a GSR test on the occupants.
  That the Defendant and other occupants were subject to a GSR test while no probable cause had been established and after one negative test and a refusal from the Defendant, the Los Santos Police Department proceeded with an unlawful search and seizure.
  
  As established by this court on #22-CM-0048, State of San Andreas v. Nanna Bohanna
  
  Probable cause requires there to be sufficient evidence available to lead a reasonable person to believe that a specific crime had been committed
  It is our argument that the abundant lack of probable cause has led to an unlawful search and seizure and thus all charges being appealed should be dismissed.
Respectfully,

Chief Public Defender
San Andreas Judicial Branch - Command
5356160 — [email protected]