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#22-CM-0055, State of San Andreas v. Brody King
Posted: Wed Jul 20, 2022 11:16 pm
by Brody King
Re: The State of San Andreas vs. Brody King
Posted: Tue Jul 26, 2022 11:49 pm
by Cyrus Raven
Re: The State of San Andreas vs. Brody King
Posted: Wed Jul 27, 2022 4:15 pm
by Caroline Johnson
Superior Court,
I, Caroline Johnson, am recusing myself from taking on this case, as it would be in breach my ethics and obligations under my oath to proceed. The Attorney General is hereby requested to appoint another individual to this case.
Respectfully,
Caroline Johnson
Prosecuting Attorney
San Andreas Judicial Branch - Office of the Attorney General
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Wed Aug 24, 2022 4:16 am
by Colt Daniels
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Thu Sep 01, 2022 10:10 am
by Aleksandar Pulaski
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Sat Sep 03, 2022 7:50 pm
by Colt Daniels
San Andreas Judicial Branch
"HERE FOR YOU | SAFE FOR YOU"
#22-CM-0055
Presiding Judge: Colt Daniels |
ORDER FOR DISCOVERY
IN THE SUPERIOR COURT OF SAN ANDREAS
State of San Andreas v. Brody King
#22-CM-0055
A court order was entered in the above case on the 3rd of August, 2022.
The case of the State of San Andreas v. Brody King, #22-CM-0055 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]
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Sun Sep 11, 2022 12:26 am
by Cyrus Raven
Motion for Involuntary Dismissal
San Andreas Judicial Branch
Motion for Involuntary Dismissal
Honorable Colt Daniels,
- 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. Brody King
Assigned Court Case Number: #22-CM-0055
Requesting Party: Cyrus Raven
Party Members: Brody King (Defendant), Cyrus Raven (Attorney)
Involuntary Dismissal: Failure to Comply to Court Order, Unreasonable Delay
Detailed explanation:
An order for discovery was issued on the 3rd of September 2022 for the prosecution to provide all evidence collected from the arresting Law Enforcement Agency and submit it to the Court via Motion for Discovery within seven days.
It is now the 11th of September 2022, no Motion for Discovery has been posted or a motion for continuance.
Given the above facts, the defense is requesting the case be dismissed with prejudice.
Thank you for your consideration.
Sincerely,
Cyrus Raven
Senior Defense Attorney
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Sun Sep 11, 2022 12:47 am
by Aleksandar Pulaski
Motion for Discovery
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. Brody King
Assigned Court Case Number: 22-CM-0055
Requesting Party:
Party Members:
Exhibit #1: Los Santos Police Department
Type of Discovery:
- Arrest Report of Brody King
All Information from the Discovery
Samuel Martin wrote: ↑Thu Jul 14, 2022 9:56 pm
Los Santos Police Department
ARREST REPORT
"TO PROTECT AND TO SERVE" |
MUGSHOT
- SUSPECT DETAILS
-
Full Name: Brody King
Phone Number: 5469294
Licenses Suspended: No
Officers Involved:
- Deputy Chief of Police Lex Roth
- Police Detective I Samuel Martin
- Police Officer III+1 Sebastian Papadakis
- Police Officer III Don Mozzarella
- Police Officer III+1 Ryan Moore
- Police Officer III+1 Alex Sorvanis
- Colt Daniels
- Lewis Langley
- Samuel Osborn
Charges:
- WF03 - Possession of Illegal Firearms/Weapons
- DM01 - Controlled Substance Possession
- VF03 - Operating a Chop Shop
- GM12 - Giving False Information to a Police Officer
- Accessory to GF11 - Grand Theft Auto
INCIDENT NARRATIVE
- Explain what happened, no need to provide too much detail, videos could be provided
- The suspect was involved in storing illegal cars in his property that then were destroyed into parts. This is seen on CCTV of his property. The property was searched as it was getting taken by the government and marijuana was found in a lard quantity along with a micro SMG.
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: Vehicle Scrap
Exhibit B:Engine
Exhibit C:Lug Wrench
Exhibit D:Screwdriver
Exhibit E:Door
Exhibit F:Wheel
Exhibit G:Bonnet
Exhibit H:Trunk Lid
Exhibit I:Marijuana Plant
Exhibit J:Micro SMG
Exhibit #2: Los Santos Police Department
Type of Discovery:
- Police Sergeant I R. Moore's Statement
All Information from the Discovery
Ryan Moore wrote: ↑Mon Sep 05, 2022 6:45 pm
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"
Case Information
- Incident Date: [14/JUL/2022]
Witness Information
- Name: [Ryan Moore]
Date of Birth: [24/FEB/1994]
Phone Number: [513-7407]
Occupation: [Police Sergeant]
Witness Statement
- Commander Dunbar,
I remember the events vaguely and I will do my best to point out what occurred that day. I believe we received a 911 call regarding someone potentially being held hostage at the shop itself. We had Metro units available as we were waiting for training to begin, we responded to the 911 call and when we arrived we noticed that there were multiple bikes and vehicles that began to leave which seemed to be affiliated with Shenzhen Dragons at first glance.
Once the immediate area was cleared the first thing on the Metro units mind was to ensure that there was no hostage and or an immediate threat still existing, after a short sweep of the area we believed that it was clear. DB then shown up on the scene which I believe was Chief Roth, Detective Martin and Detective Durry. I believe it was noticed that there was a vehicle which had been reported stolen on the property inside the garage which was open, DB then began an investigation whilst we provided scene security until they were done. I believe they checked CCTV etc. which may have given them the probable cause but I am unsure as to what gave them the PC, I can't fully remember either how the vehicle which was reported stolen was also noticed, but said vehicle led them to check the CCTV to see if it was driven in by the owner as far as I can remember.
Once the Detectives investigated further Commissioners (I believe one was Commissioner Langley and the second was Commissioner Samuel Osborn) were also brought down to the location to discuss closing the shop down as it was believed/proven that there was a chop shop currently being operated on the premises and also Illegal weaponry was found in the safes after further investigation.
I have included the very brief deployment log below which was written by Officer Stanford, it doesn't really provide any additional information as the main priority for my team was scene security.
► Show Spoiler
Peter Stanford wrote: ↑Thu Jul 14, 2022 9:50 pm
Date: 14/Jul/2022
Deployment Hours: 2h 20m
- Type of Deployment: Active
Name of Assigning SWAT Officer: Ryan Moore-Active
- Participating SWAT Officers:
- Sebastian Papadakis
- Andreas Oconner
- Don Mozzarella
- Tyrell Lee
- Deployment Summary: The pager was rang for training but insufficient METRO Officers showed up.
- A hostage situation was called over a 911 call at the Tuna Shop, multiple Shenzhen gang members were around the area and were seen exiting the entering the garage. They all left when Officers showed up Code 3. We ended up seizing the property.
-
- Deployment Outcome: Successful
I hope my statement may help in the investigation but as it was a couple of months ago my recollection of events may not be the best as we had a couple of incidents at that location we had to attend!
If you need anything further just let me know!
Witness Affirmation
- I, Ryan Moore, 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,
Ryan Moore
Police Sergeant I
Los Santos Police Department, Metropolitan Divison
Date: [05/SEP/2022]
Exhibit #3: Los Santos Police Department
Type of Discovery:
- Police Officer III D. Mozzarella's Statement
All Information from the Discovery
Don Mozzarella wrote: ↑Mon Sep 05, 2022 6:47 pm
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"
Case Information
- Incident Date: 14/JUL/2022
Witness Information
- Name: Don Mozzarella
Date of Birth: 06/AUG/2022
Phone Number: 381-1675
Occupation: Police Officer III, Senior SWAT Officer, Los Santos Police Department
Witness Statement
- Hello, and apologies for any 'grey areas' as this was well over 1.5 months ago and my memory is a bit spotty regarding this and there may be inconsistencies throughout;
We had received a 911 call for a 'hostage' situation involving multiple (I believe the caller said 15(?)) heavily armed suspects near "The Tuna Shop". Upon arriving at the scene (myself and another member of SWAT were first responders) we had not seen too many people in the immediate area, but there were multiple vehicles of gang affiliation in the area on the elevated freeways around the property, so we circled around waiting for backup to arrive. Once backup arrived we dismounted and did a brief sweep of the garage area at the property, finding a few individuals walking out of the garage as we approached. This is where my memory gets spotty, but I believe once having the people exit the garage, they were questioned on what happened and they stated that nothing happened and someone had prank called us and there was nothing happening at the location. I can't remember who (extra) was detained aside from Brody King. Upon clearing the garage, there were two vehicles (modified Peyote and a modified Tornado, 'lowriders', as some would call them) inside of the garage - they were both reported stolen. Brody (or someone else) had stated that they were customer's vehicles that had asked for their assistance with repairs or modifications. After that, I believe Det. Samuel Martin began to check the CCTV that was installed on the premises, in which it was reviewed inside. From that point on, I assisted externally only doing scene security while DB performed a search inside with the assistance of another member of SWAT, I believe Sebastian Papadakis. After sitting on scene for a while, we were tasked to retrieve TARVs from METRO HQ, which were loaded with multiple car parts (Hoods, Tires, Doors, etc.) from inside. I recall Brody mentioning that they were ordered for vehicle repairs as that is something they do on the side. I recall a Micro SMG being brought out aswell.
From thereon out, I just assisted with evidence transport and continued scene security.
Witness Affirmation
- I, Don Mozzarella, 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,
Don Mozzarella
Police Officer III
Los Santos Police Department
Date: 05/SEPT/2022
Exhibit #4: Los Santos Police Department
Type of Discovery:
- Police Detective I S. Martin's Statement
All Information from the Discovery
Samuel Martin wrote: ↑Mon Sep 05, 2022 7:00 pm
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"
Case Information
- Incident Date: 07/JUL/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 responded late to a call at the Tuna Shop. As I arrived the area was already secured by police units. There was a situation involving the criminal orginazation Shenzhen Dragons robbing the Tuna Shop. There was also a few stolen vehicles parked inside the Tuna Shop garage. The owner of the shop, Brody King, was on scene. We requested to see the CCTV fottage to see what happened. While wtaching the CCTV I found that Brody was involved in storing the stolen vehicles inside of the garage. Also while watching it was clear that equipment for a Chop Shop was stolen by Shenzhen Dragos from inside the Tuna Chop.
The government was contacted about this issue. Tyrone Cox, Lewis Langley, and Samuel Osborn all came down to the property and agreed that the property would be getting taken by the government. The property was fully searched, this was due to the CCTV footage, car parts around the stolen cars and the property seazure.
Later it was decided to allow the suspect to keep the property and a contract was signed to allow the following.
- The Detective Bureau and the Police Department can conduct full searches of the property at random times and any other property you are being associated with;
- All the gates, safes, and everything that could be locked must be unlocked during the search if ordered by the Detective Bureau of the Police Department;
- If the Detective Bureau discovers that any of the properties that you own or you are associated with are being used for illegal purposes, a proper seizure without the chance of appealing would be conducted with the guidance of the Judicial and the San Andreas Government;
- If during the random search you failed to comply with the Detective's orders, criminal charges such as but not limited to;
- GM10 - Failure to Comply / Identify;
- GM14 - Obstruction of Justice;
A copy of this contract will be sent separately.
((I would recommend that logs get checked for the order of the CCTV as these screenshots are not in order))
CCTV.mp4
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: 05/SEP/2022
Exhibit #5: Los Santos Police Department
Type of Discovery:
- Email chain between D. Chief of Police L. Roth and the Defendant B. King
All Information from the Discovery
Lex Roth wrote: ↑Fri Jul 15, 2022 12:38 am
Los Santos Police Department
Detective Bureau
"TO PROTECT AND SERVE" |
- To:
Brody King,
On the date of 14/JUL/2022, you have been found operating a chop shop at the address Autopia Pkwy. 1 which is a property that the San Andreas Government built for you for the legal purposes of "
Type of Business: Boat/Auto Repair Shop" as stated in your business license.
You have disregarded the legality of your business and you have engaged in illegal activities, thus your property was requested to be seized by the Detective Bureau, the Government of San Andreas, and the Judicial.
Although after careful deliberations we have come to an agreement that you can keep the property if you agree to the following;
- The Detective Bureau and the Police Department can conduct full searches of the property at random times and any other property you are being associated with;
- All the gates, safes, and everything that could be locked must be unlocked during the search if ordered by the Detective Bureau of the Police Department;
- If the Detective Bureau discovers that any of the properties that you own or you are associated with are being used for illegal purposes, a proper seizure without the chance of appealing would be conducted with the guidance of the Judicial and the San Andreas Government;
- If during the random search you failed to comply with the Detective's orders, criminal charges such as but not limited to;
- GM10 - Failure to Comply / Identify;
- GM14 - Obstruction of Justice;
would be placed on your record and the San Andreas Government and the Judicial will be informed of your behavior.
If you agree to all the above, please use the button "Reply All" to respond with an answer which will be your signature of agreement to that document.
Colt Daniels wrote: ↑Thu Jul 14, 2022 10:45 pm
Supreme Court of the State of San Andreas
The Office of Contract Authenticity issues this:
Certificate of Authenticity
22-07-14-CA-008
That certifies the contract associated with the above reference number has been processed and authenticated by an Officer of the Court of the San Andreas Judicial Branch. This Certificate of Authenticity serves as notice that the contract associated with the above reference number is valid and legally enforceable by the San Andreas Judicial Branch within the State of San Andreas.
Effective this 14h of July in the Year 2022
Chief Justice
San Andreas Judicial Branch
(909) 402-9713 —
[email protected]
- Sincerely,
Deputy Chief of Police Lex Roth,
Director, Detective Bureau
Los Santos Police Department.
Brody King wrote: ↑Fri Jul 15, 2022 2:09 pm
Yes I agree to the parameters of this contract, but I would like something that states the duration this would proceed for as well.
Sincerely,
Aleksandar Pulaski
General Prosecuting Attorney
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Sun Sep 11, 2022 12:50 am
by Aleksandar Pulaski
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Thu Sep 15, 2022 12:42 pm
by Cyrus Raven
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Sat Oct 01, 2022 3:51 am
by Colt Daniels
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Thu Oct 13, 2022 6:25 pm
by Cyrus Raven
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 2 days for the reason listed below.
State of San Andreas v. Brody King
Assigned Court Case Number: #22-CM-0055
Detailed explanation:
The Defense requests a brief continuance to post any further motions as the initial discovery still needs to be analysed. Given that this case also needs a prosecutor, we hope the court is amenable to this request. The Defense is also open to a further extension of the continuance if needed by the court.
Sincerely,
Cyrus Raven
Chief Public Defender Cyrus Raven
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Mon Oct 17, 2022 4:25 am
by Hugh Allgood
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Tue Oct 18, 2022 7:59 pm
by Cyrus Raven
Motion to Suppress
San Andreas Judicial Branch
Motion to Suppress
Honorable Colt Daniels,
- We the Defense in the case below are requesting that certain evidence be inadmissible in court.
State of San Andreas v. Brody King
Assigned Court Case Number: #22-CM-0055
Requesting Party: Cyrus Raven
Party Members: Cyrus Raven, Brody King
Requested Evidence to Suppress: Exhibit #2 - Police Sergeant I R. Moore's Statement
Detailed explanation:
The defense is requesting the following areas highlighted in YELLOW be suppressed due to speculation, hearsay and relevance.
Ryan Moore wrote: ↑Mon Sep 05, 2022 6:45 pm
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"
Case Information
- Incident Date: [14/JUL/2022]
Witness Information
- Name: [Ryan Moore]
Date of Birth: [24/FEB/1994]
Phone Number: [513-7407]
Occupation: [Police Sergeant]
Witness Statement
- Commander Dunbar,
I remember the events vaguely and I will do my best to point out what occurred that day. I believe we received a 911 call regarding someone potentially being held hostage at the shop itself. We had Metro units available as we were waiting for training to begin, we responded to the 911 call and when we arrived we noticed that there were multiple bikes and vehicles that began to leave which seemed to be affiliated with Shenzhen Dragons at first glance.
Once the immediate area was cleared the first thing on the Metro units mind was to ensure that there was no hostage and or an immediate threat still existing, after a short sweep of the area we believed that it was clear. DB then shown up on the scene which I believe was Chief Roth, Detective Martin and Detective Durry. I believe it was noticed that there was a vehicle which had been reported stolen on the property inside the garage which was open, DB then began an investigation whilst we provided scene security until they were done. I believe they checked CCTV etc. which may have given them the probable cause but I am unsure as to what gave them the PC, I can't fully remember either how the vehicle which was reported stolen was also noticed, but said vehicle led them to check the CCTV to see if it was driven in by the owner as far as I can remember.
Once the Detectives investigated further Commissioners (I believe one was Commissioner Langley and the second was Commissioner Samuel Osborn) were also brought down to the location to discuss closing the shop down as it was believed/proven that there was a chop shop currently being operated on the premises and also Illegal weaponry was found in the safes after further investigation.
I have included the very brief deployment log below which was written by Officer Stanford, it doesn't really provide any additional information as the main priority for my team was scene security.
► Show Spoiler
Peter Stanford wrote: ↑Thu Jul 14, 2022 9:50 pm
Date: 14/Jul/2022
Deployment Hours: 2h 20m
- Type of Deployment: Active
Name of Assigning SWAT Officer: Ryan Moore-Active
- Participating SWAT Officers:
- Sebastian Papadakis
- Andreas Oconner
- Don Mozzarella
- Tyrell Lee
- Deployment Summary: The pager was rang for training but insufficient METRO Officers showed up.
- A hostage situation was called over a 911 call at the Tuna Shop, multiple Shenzhen gang members were around the area and were seen exiting the entering the garage. They all left when Officers showed up Code 3. We ended up seizing the property.
-
- Deployment Outcome: Successful
I hope my statement may help in the investigation but as it was a couple of months ago my recollection of events may not be the best as we had a couple of incidents at that location we had to attend!
If you need anything further just let me know!
Witness Affirmation
- I, Ryan Moore, 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,
Ryan Moore
Police Sergeant I
Los Santos Police Department, Metropolitan Divison
Date: [05/SEP/2022]
Requested Evidence to Suppress: Exhibit #3 - Police Officer III D. Mozzarella's Statement
Detailed explanation:
The defense is requesting the following areas highlighted in YELLOW be suppressed due to speculation, hearsay and relevance.
Don Mozzarella wrote: ↑Mon Sep 05, 2022 6:47 pm
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"
Case Information
- Incident Date: 14/JUL/2022
Witness Information
- Name: Don Mozzarella
Date of Birth: 06/AUG/2022
Phone Number: 381-1675
Occupation: Police Officer III, Senior SWAT Officer, Los Santos Police Department
Witness Statement
- Hello, and apologies for any 'grey areas' as this was well over 1.5 months ago and my memory is a bit spotty regarding this and there may be inconsistencies throughout;
We had received a 911 call for a 'hostage' situation involving multiple (I believe the caller said 15(?)) heavily armed suspects near "The Tuna Shop". Upon arriving at the scene (myself and another member of SWAT were first responders) we had not seen too many people in the immediate area, but there were multiple vehicles of gang affiliation in the area on the elevated freeways around the property, so we circled around waiting for backup to arrive. Once backup arrived we dismounted and did a brief sweep of the garage area at the property, finding a few individuals walking out of the garage as we approached. This is where my memory gets spotty, but I believe once having the people exit the garage, they were questioned on what happened and they stated that nothing happened and someone had prank called us and there was nothing happening at the location. I can't remember who (extra) was detained aside from Brody King. Upon clearing the garage, there were two vehicles (modified Peyote and a modified Tornado, 'lowriders', as some would call them) inside of the garage - they were both reported stolen. Brody (or someone else) had stated that they were customer's vehicles that had asked for their assistance with repairs or modifications. After that, I believe Det. Samuel Martin began to check the CCTV that was installed on the premises, in which it was reviewed inside. From that point on, I assisted externally only doing scene security while DB performed a search inside with the assistance of another member of SWAT, I believe Sebastian Papadakis. After sitting on scene for a while, we were tasked to retrieve TARVs from METRO HQ, which were loaded with multiple car parts (Hoods, Tires, Doors, etc.) from inside. I recall Brody mentioning that they were ordered for vehicle repairs as that is something they do on the side. I recall a Micro SMG being brought out aswell.
From thereon out, I just assisted with evidence transport and continued scene security.
Witness Affirmation
- I, Don Mozzarella, 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,
Don Mozzarella
Police Officer III
Los Santos Police Department
Date: 05/SEPT/2022
Requested Evidence to Suppress: Exhibit #4 - Police Detective I S. Martin's Statement
Detailed explanation:
The defense is requesting the following areas highlighted in YELLOW be suppressed due to speculation, hearsay and relevance. In the case of the CCTV footage, we are likewise request this be suppressed as no search warrant for the footage was obtained nor consent provided by the Defendant.
Samuel Martin wrote: ↑Mon Sep 05, 2022 7:00 pm
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"
Case Information
- Incident Date: 07/JUL/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 responded late to a call at the Tuna Shop. As I arrived the area was already secured by police units. There was a situation involving the criminal orginazation Shenzhen Dragons robbing the Tuna Shop. There was also a few stolen vehicles parked inside the Tuna Shop garage. The owner of the shop, Brody King, was on scene. We requested to see the CCTV fottage to see what happened. While watching the CCTV I found that Brody was involved in storing the stolen vehicles inside of the garage. Also while watching it was clear that equipment for a Chop Shop was stolen by Shenzhen Dragos from inside the Tuna Chop.
The government was contacted about this issue. Tyrone Cox, Lewis Langley, and Samuel Osborn all came down to the property and agreed that the property would be getting taken by the government. The property was fully searched, this was due to the CCTV footage, car parts around the stolen cars and the property seizure.
Later it was decided to allow the suspect to keep the property and a contract was signed to allow the following.
- The Detective Bureau and the Police Department can conduct full searches of the property at random times and any other property you are being associated with;
- All the gates, safes, and everything that could be locked must be unlocked during the search if ordered by the Detective Bureau of the Police Department;
- If the Detective Bureau discovers that any of the properties that you own or you are associated with are being used for illegal purposes, a proper seizure without the chance of appealing would be conducted with the guidance of the Judicial and the San Andreas Government;
- If during the random search you failed to comply with the Detective's orders, criminal charges such as but not limited to;
- GM10 - Failure to Comply / Identify;
- GM14 - Obstruction of Justice;
A copy of this contract will be sent separately.
((I would recommend that logs get checked for the order of the CCTV as these screenshots are not in order))
CCTV.mp4
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: 05/SEP/2022
Sincerely,
Cyrus Raven
Chief Public Defender Cyrus Raven
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Tue Oct 18, 2022 8:09 pm
by Cyrus Raven
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Wed Oct 19, 2022 12:52 am
by Hugh Allgood
San Andreas Judicial Branch
State of San Andreas v. Brody King
"HERE FOR YOU | SAFE FOR YOU" |
- Superior Court of San Andreas,
I wish to formally go on record as disputing the previous two motions filed by Chief Public Defender Cyrus Raven, the motion to suppress and the motion to amend defense of charges.
Motion to suppress
I am going to first begin with a motion to dismiss the motion to suppress in its entirety due to improper court procedure. The grounds for awarding this motion in favor of the prosecution can be found in this very case, and ironically enough within a motion filed by Chief Defender Cyrus Raven himself. With previous prosecutorial counsel, Chief Public Defender Cyrus Raven filed a motion to dismiss evidence presented by counsel on the grounds the prosecutor was five hours late in meeting with deadlines set by the court. On 30/Sept, the court ruled against this motion but noted "the prosecution is on thin ice" and within this same ruling, the court gave both sides seven days to file any remaining motions, meaning the deadline is 7-8/October/2022, depending on how the court looks at it. Previous prosecutorial counsel resigned from the branch on 8/October, meaning Public Defender Cyrus Raven had ample time to file the motions on the evidence provided by previous counsel. This motion to suppress filed by Chief Public Defender Cyrus Raven was filed on 18/October, nearly 2 1/2 weeks after the deadline imposed by the court. I strongly believe in fairness, and if Chief Defender Public Defender Cyrus Raven wants evidence to be suppressed on account of going over the deadline by five hours, I feel 2 1/2 weeks is more than sufficient cause to rule against this motion that has been available since 10/September/22, over a month.
In the event the court does not rule against the defense motion on the above listed grounds, I will also oppose the motion on grounds of disagreeing with the factors in which Chief Defender Raven seeks to dismiss them on. First, regarding exhibit #2, counsel wishes to suppress portions of this written statement on grounds of "speculation, hearsay and relevance". Regarding speculation, this is not a proper use of this objection. Within our code of ethics, speculation is defined as, "A witness may not testify about any matter of which they have no personal knowledge. Only if the witness has directly observed an event may the witness testify about it. Personal knowledge must be shown before a witness may testify concerning a matter." The Commander has personal knowledge, but at the time of completing the statement, could not vividly recall. This is not speculation, this is just normal human performance and recall. Furthermore, the statement is not subjection to suppression on grounds of hearsay because it is an "official records by public employees", which is a covered exception in our code of ethics, and also covered in precedence in the 22-CM-0050, State of San Andreas v. Harley Pavlovich case. Lastly, returning back to our code, relevance is defined as "Evidence is considered relevant if it has any tendency to make a fact that is important to the case more or less probable than the fact would be without the evidence." I would mention these statements in the evidence are important as it lays the groundwork for explaining the situation which led to the defendant getting the charges they are now appealing.
On a side note regarding the objection on grounds of speculation... Even though the memory is not clear, the contested statements can be found in all three exhibits of evidence. This further suggests the accuracy, validity and reliability of the evidence. The objection for speculation is to prevent inaccurate information being used as evidence. In this instance, the gang affiliation was documented and known by the police department, CCTV was checked demonstrating the defendant has been part of bringing vehicles in and chopping them, and the equipment used in this endeavor were stolen by other individuals prior to the arrival of PD.
Motion to amend charges of contest
Very simply, the defendant filed this case on 20/JUL/22, and defense counsel has been representing this client on 26/JUL. The defendant only listed the charges of Operating a Chopshop in a place of business. Defense counsel has had nearly three months to defend these charges. It is the opinion of the prosecution that the charges omitted from this appeal have been abandoned. It's no different than the time limit this court imposes on citizens to file an appeal. The defendant in this case has abandoned their appeal on the other charges, especially at this rate.
Either way, I am prepared to prosecute this case in whatever flavor it is, but I believe my objections must be made in the interest of justice.
Respectfully,
Attorney General
San Andreas Judicial Branch
(909) 235-6076 — [email protected]
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Wed Oct 19, 2022 11:41 am
by Cyrus Raven
San Andreas Judicial Branch
"HERE FOR YOU | SAFE FOR YOU" |
- Honorable Colt Daniels,
A few points to clarify:
- A hearing's main purpose is to determine the admissibility of evidence. During the hearing the court asks either party if they have any issues/objections with regards to the evidence. While it is good practice to submit a motion to suppress prior to the hearing as was instructed, it is understood that new information can be gained closer to the time of the hearing which alters the Defense strategy.
However, I understand that we went over a deadline, this will fixed in the future by an early continuance request. If it pleases the court and the Attorney General, it can be retracted and one will be submitted verbally during the hearing. However, this motion provides a clear and fair visualization of what we will argue during the hearing, which I think is to the court's advantage.
- The suppression due to speculation is valid. The same way the court disallows statements made without personal knowledge, it equally disallows statements that are uncertain. A Witness Statement as the name implies should only contain what a witness can reliably remember from a situation. (E.g: ''I saw three people'' as opposed to ''I don't remember, but I think I saw three people''). Any specifics that an individual does not remember with certainty should be excluded or answered with ''I do not recall'' (or similar phrasing). Further oral arguments can be given on this point.
- ''official records by public employees'' - This is incorrect. During the 22-CM-0050, State of San Andreas v. Harley Pavlovich, the Arrest Report statement was allowed due to the exception to the hearsay rule, which states:
Official records by public employees are writing made by a public employee as a record of an act or event. The writing must be made within the scope of duty of a public employee.
Arrest reports, duty reports, deployment logs, case files, etc... are examples of records made within the scope of duty of a Police Officer close to the time of the incident, we argue that a witness statement made 53 days from the incident is not ''writing made within the scope of duty of a public employee''. To say this would mean that any and all statements that would usually be struck as Hearsay are allowed 100% of the times so long as a public employee is making it, an unreasonable standard to say the least.
Further oral arguments can be given on this point.
- With regards to the clarification of charges being appealed. The Defendant stated ''I feel the arrest was unjust and has slandered the name of my shop.'', likewise due to a lack of an MDC, he stated his charges as ''Operating a Chopshop in a place of business'' which is not a formal charge description on the penal code.
This to say that although blame can be placed on my end for not clarifying this sooner, the Defendant does not have access to an MDC to clearly check what he was charged with nor are arrest reports made public. If the court wishes to continue only with ''VF03 - Operating a Chop Shop'' we are amenable to this. Preferably, if allowed to amend these charges, we remain open to allowing suitable time for the prosecution to prepare any further evidence in the pursuit of justice and fairness.
Respectfully,
Chief Public Defender
San Andreas Judicial Branch - Command
5356160 — [email protected]
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Tue Oct 25, 2022 2:30 am
by Colt Daniels
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Fri Oct 28, 2022 5:07 pm
by Cyrus Raven
Motion for Involuntary Dismissal
San Andreas Judicial Branch
Motion for Involuntary Dismissal
Honorable Colt Daniels,
- 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. Brody King
Assigned Court Case Number: #22-CM-0055
Requesting Party: Cyrus Raven
Party Members: Cyrus Raven (Attorney), Brody King (Defendant)
Involuntary Dismissal: Failure to Make Contact with council
Detailed explanation:
The Defense has not been able to establish cntact with the Defendant for several weeks now. We sent out correspondence on the 18th of October and have not received a reply.
((Player has stated he will not be returning to the server.))
Thank you for your consideration.
Sincerely,
Cyrus Raven
Chief Public Defender
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Fri Oct 28, 2022 10:44 pm
by Colt Daniels
Re: #22-CM-0055, State of San Andreas v. Brody King
Posted: Mon Nov 21, 2022 11:46 pm
by Colt Daniels
San Andreas Judicial Branch
"HERE FOR YOU | SAFE FOR YOU" |
COURT DECISION - #22-CM-0055
IN THE SUPERIOR COURT OF SAN ANDREAS
State of San Andreas v. Brody King
#22-CM-0055
CHARGES BEING DISPUTED:
VF03 - Operating a Chop Shop
A decision was reached in the above case on the 30th day of October, 2022.
- The case of #22-CM-0055, State of San Andreas v. Brody King has hereby been dismissed by this court.
The defense in this case filed a Motion for Involuntary Dismissal on the basis of not being able to establish contact with the defendant for several weeks. After a hearing was held on this case the prosecution agreed that due to the defendant not making contact with the court within a reasonable time frame to continue with their case they have now abandoned it. Due to the reasoning provided the court granted the motion and the case was dismissed. The defendant will be fined $25,000 in court fees.
Chief Justice
San Andreas Judicial Branch
(909) 402-9713 — [email protected]