#22-CM-0055, State of San Andreas v. Brody King

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Brody King
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#22-CM-0055, State of San Andreas v. Brody King

Post by Brody King »

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Defendant Name: Brody King
Defendant Phone: 546 9294
Defendant Address: 13 El Rancho Blvd.
(( Defendant Discord: The Sweaty Barber#9110 ))
Requested Attorney: Tony McFornell
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Charging Department:
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Time & Date of Incident(s): 7/14/22 at 21:25
Charge(s): Operating a Chopshop in a place of business
Narrative:

My mechanic shop called The Tuna Shop was recently subjected to a break in. The cops instead of going for the individuals that had just robbed me decided it was a better idea to go through my shop. They went inside and found parts sitting on our parts shelves and instantly accused me of running a chop shop. The parts on the shelf was ones we would normally sell to people. They went into our garage and found another crate of parts, which was a shipment we had just received but not put onto our shelves. I feel the arrest was unjust and has slandered the name of my shop.

I, [Brody King], 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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Re: The State of San Andreas vs. Brody King

Post by Cyrus Raven »

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San Andreas Judicial Branch

Re: State of San Andreas v. Brody King
"HERE FOR YOU | SAFE FOR YOU"

  • To whom it may concern,

    I, Public Defense Attorney Cyrus Raven and Senior Defense Attorney Tony Mcfornell, will be representing the defendant, Brody King, in this case. I have made myself aware of the contents of this case and have made contact with the defendant. I am ready to proceed at the court's discretion.

    Respectfully,


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

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Re: The State of San Andreas vs. Brody King

Post 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
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Colt Daniels »

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San Andreas Judicial Branch

Re: #22-CM-0055, State of San Andreas v. Brody King
"HERE FOR YOU | SAFE FOR YOU"

  • Counselors,

    I will be opening this case under docket number #22-CM-0055. At this time I ask the Attorney General to appoint a prosecutor for this case. Once known to the court I will order discovery.

    Respectfully,

    Chief Justice
    San Andreas Judicial Branch
    (909) 402-9713 — [email protected]
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Aleksandar Pulaski »

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  • Honorable Daniels,

    I, prosecuting attorney Aleksander Pulaski, will be representing the State of San Andreas as their counsel. I will be familirizing myself with this case and it's evidence. Ready to proceed upon court's discretion.

    Respectfully,
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    General Attorney Aleksandar Pulaski
    Prosecuting Division
    San Andreas Judicial Branch
    (909) 365-8706 — [email protected]
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Colt Daniels »

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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]

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Re: #22-CM-0055, State of San Andreas v. Brody King

Post 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,

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Cyrus Raven
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post 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
    Spoiler
    All Information from the Discovery
    • Samuel Martin wrote: Thu Jul 14, 2022 9:56 pm Image
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      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

            Photograph of possessions in evidence locker (if applicable)
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    Exhibit #2: Los Santos Police Department
    Type of Discovery:
    • Police Sergeant I R. Moore's Statement
    Spoiler
    All Information from the Discovery
    • Ryan Moore wrote: Mon Sep 05, 2022 6:45 pm Image

      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
        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]
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    Exhibit #3: Los Santos Police Department
    Type of Discovery:
    • Police Officer III D. Mozzarella's Statement
    Spoiler
    All Information from the Discovery
    • Don Mozzarella wrote: Mon Sep 05, 2022 6:47 pm Image

      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,
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        Don Mozzarella
        Police Officer III
        Los Santos Police Department

        Date: 05/SEPT/2022
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    Exhibit #4: Los Santos Police Department
    Type of Discovery:
    • Police Detective I S. Martin's Statement
    Spoiler
    All Information from the Discovery
    • Samuel Martin wrote: Mon Sep 05, 2022 7:00 pm Image

      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.
        CCTV Footage
        ((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,

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        Samuel Martin
        Police Detective I
        Los Santos Police department

        Date: 05/SEP/2022
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    Exhibit #5: Los Santos Police Department
    Type of Discovery:
    • Email chain between D. Chief of Police L. Roth and the Defendant B. King
    Spoiler
    All Information from the Discovery
    • Lex Roth wrote: Fri Jul 15, 2022 12:38 am Image
      dblogo

      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.
        Certificate of Authenticity
        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.
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      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.
      Lex Roth wrote: Fri Jul 15, 2022 2:14 pm Image
      dblogo

      Los Santos Police Department

      Detective Bureau
      "TO PROTECT AND SERVE"

      • To:

        Brody King
        ,

        Thank you for the confirmation of the e-mail and your written agreement to this document.

        We have discussed this matter with the Commissioners and we have agreed that a period of six (6) months should be efficient.

        This means that this document would be effective from 15/JUL/2022 until 15/JAN/2023.

      • Sincerely,


        Deputy Chief of Police Lex Roth,
        Director, Detective Bureau
        Los Santos Police Department.
      Image


Sincerely,

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Aleksandar Pulaski
General Prosecuting Attorney
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General Attorney Aleksandar Pulaski
Prosecution Division
San Andreas Judicial Branch
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Aleksandar Pulaski »

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San Andreas Judicial Branch

Personal Email
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Daniels,

    The prosecution would like to contest the motion for dismissal of this case. I believe that considering the amount of statements and evidence that had to be collected it is understandable that we took more time than we hoped for. We do apologise for the delay and we presented all the evidence to the court now. I believe that the dismissal is not necessary at this point and that the court should consider proceeding with the case and issue a verdict once ready that might be more suitable, after the trial.

    Respectfully,
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    General Attorney Aleksandar Pulaski
    Prosecuting Division
    San Andreas Judicial Branch
    (909) 365-8706 — [email protected]
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Cyrus Raven »

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San Andreas Judicial Branch

Docket Reply
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  • Honorable Colt Daniels,

    To avoid analyzing and setting up a defense based on evidence which might not be admissible, the defense requests a hearing on the Motion for Involuntary Dismissal before proceeding with any other hearings on the other motions presented.

    Respectfully,

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    Senior Public Defense Attorney
    San Andreas Judicial Branch
    5356160 — [email protected]
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Colt Daniels »

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San Andreas Judicial Branch

Re: #22-CM-0055, State of San Andreas v. Brody King
"HERE FOR YOU | SAFE FOR YOU"

  • Counselors,

    I will be denying the Motion for Involuntary Dismissal on the case due to the Motion for Discovery being presented less than 5 hours after the 7 day window was expired. However please note the prosecution is on thin ice. Any further unnecessary delay or technical mishaps on this case will result in a dismissal by the court. I should not need to remind the prosecution that we have a Motion for Continuance that should be used should an extension be needed.

    At this time I will be giving both parties 7 days to file any motions they see fit before proceeding.

    Respectfully,

    Chief Justice
    San Andreas Judicial Branch
    (909) 402-9713 — [email protected]
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post 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,

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Cyrus Raven
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Hugh Allgood »

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San Andreas Judicial Branch

State of San Andreas v. Brody King
"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,

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    Attorney General
    San Andreas Judicial Branch
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post 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.
    Exhibit #2
    Ryan Moore wrote: Mon Sep 05, 2022 6:45 pm Image

    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
      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]
    Image

    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.
    Exhibit #3
    Don Mozzarella wrote: Mon Sep 05, 2022 6:47 pm Image

    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,
      Image
      Don Mozzarella
      Police Officer III
      Los Santos Police Department

      Date: 05/SEPT/2022
    Image

    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.
    Exhibit#4
    Samuel Martin wrote: Mon Sep 05, 2022 7:00 pm Image

    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.

      CCTV Footage
      ((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,

      Image
      Samuel Martin
      Police Detective I
      Los Santos Police department

      Date: 05/SEP/2022
    Image


Sincerely,

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Cyrus Raven
Chief Public Defender Cyrus Raven
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Cyrus Raven »

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San Andreas Judicial Branch

Court Notice
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Colt Daniels,

    The Defense is issuing this notice to clarify that the Defendant is appealing all charges from the day in question as confirmed in the arrest report.
    • GF11 - Accessory to Grand Theft Auto
    • GM12 - Giving False Information to a Police Officer
    • VF03 - Operating a Chop Shop
    • DM01 - Controlled Substance Possession
    • WF03 - Possession of Illegal Firearms/Weapons
    Respectfully,

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    San Andreas Judicial Branch - Command
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Hugh Allgood »

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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,

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    San Andreas Judicial Branch
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Cyrus Raven »

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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,

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    Chief Public Defender
    San Andreas Judicial Branch - Command
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Colt Daniels »

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San Andreas Judicial Branch

Re: #22-CM-0055, State of San Andreas v. Brody King
"HERE FOR YOU | SAFE FOR YOU"

  • Counselors,

    I understand that each party has there own beliefs in regards to the two motions filed by the defense in the case. However in regards to the Motion to Amend Charges, I will have to rule in favor of the prosecution on this issue, I understand that the defendant does not have access to the MDC however Mr. King had the opportunity to go to Mission Row, Paleto Station, or even the Courthouse/City Hall for clarification on what he was charged with on the day in question. With this motion coming nearly three months after the initial case was filed I cannot allow any other charge to be heard except for "VF03 - Operating a Chop Shop" as the prosecution stated "It is the opinion of the prosecution that the charges omitted from this appeal have been abandoned."

    In regards to the Motion to Suppress, I would like both sides to save their arguments for my courtroom. At this time please navigate to the scheduling tool and file your availability. Once completed I will announce a time for the Motions Hearing to take place.

    Respectfully,

    Chief Justice
    San Andreas Judicial Branch
    (909) 402-9713 — [email protected]
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post 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,

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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Colt Daniels »

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San Andreas Judicial Branch

Re: #22-CM-0055, State of San Andreas v. Brody King
"HERE FOR YOU | SAFE FOR YOU"

  • Counselors,

    With the availability filed on the scheduling tool I will be holding this Motions Hearing for Sunday October 30th, at 9:30PM. Please note I will be hearing the new motion filed by the defense. Please be present at the hearing no later than 15 minutes prior.

    Respectfully,

    Chief Justice
    San Andreas Judicial Branch
    (909) 402-9713 — [email protected]
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Re: #22-CM-0055, State of San Andreas v. Brody King

Post by Colt Daniels »

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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]
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