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#22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Wed Jul 27, 2022 9:18 pm
by Greedw15318
Re: State of San Andreas v. Edward Greeg
Posted: Thu Aug 11, 2022 5:34 am
by Caroline Johnson
San Andreas Judicial Branch
Re: State of San Andreas v. Edward Greeg
"HERE FOR YOU | SAFE FOR YOU" |
- Superior Court,
My name is Caroline Johnson, and I will be the prosecuting attorney for this case representing the State of San Andreas. @Kendall Frances may be my co-counsel as she assisted me in informing the department of the charges, but until she announces her entrance, the state will be solo at this time.
Best Wishes,
Caroline Johnson
Attorney-At-Law
San Andreas Judicial Branch
(909) 590-4566 — [email protected]
Re: State of San Andreas v. Edward Greeg
Posted: Thu Aug 11, 2022 7:55 pm
by Kendall Groyce
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Sat Oct 01, 2022 4:05 am
by Judith Mason
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Sun Oct 02, 2022 9:20 pm
by Roderick Marchisio
San Andreas Judicial Branch
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
"HERE FOR YOU | SAFE FOR YOU" |
- To whom it may concern,
The purpose of this notice is to inform you that as of this moment I, Roderick Marchisio, will be representing the State of San Andreas in all the proceedings pertaining to the underlying case.
I will take it upon myself to reach out to the involved parties to collect and review all evidence in relation to the underlying case to ensure a proper and smooth continuation of this process.
Respectfully,
Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 —
[email protected]
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Mon Oct 03, 2022 11:37 am
by Cyrus Raven
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Mon Oct 03, 2022 6:35 pm
by Sarah Williams
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Thu Oct 06, 2022 3:07 am
by Judith Mason
San Andreas Judicial Branch
"HERE FOR YOU | SAFE FOR YOU"
#22-CM-0060
Presiding Judge: Judith Mason |
ORDER FOR DISCOVERY
IN THE SUPERIOR COURT OF SAN ANDREAS
State of San Andreas v. Edward Greeg
#22-CM-0060
A court order was entered in the above case on 6 October, 2022.
The case of the State of San Andreas v. Edward Greeg, #22-CM-0060 is hereby opened and acknowledged by the Court.
The prosecution is hereby ordered to provide all evidence collected from the arresting Law Enforcement Agency and submit it to the Court via Motion for Discovery within seven days. If additional time is needed, the prosecution can file a Motion for Continuance.
Once evidence has been submitted to the official docket the defense can begin filing motions.
Associate Justice
San Andreas Judicial Branch
(909) 257-9183 — [email protected]
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Tue Oct 11, 2022 9:26 pm
by Roderick Marchisio
Motion for Continuance
San Andreas Judicial Branch
Motion for Continuance
Honorable Mason,
- We the Prosecution in the case below are requesting a Continuance for [14] days for the reason listed below.
State of San Andreas v. Edward Greeg
Assigned Court Case Number: #22-CM-0060
Detailed explanation:
As the court and all parties are aware, I have recently taken over this case from the previously assigned Prosecuting Attorney. Upon taking over this case, I reviewed the information already available to me and have come to the conclusion I will need more time to request and organize the information in relation to this case in a presentable way.
Sincerely,
Senior Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 —
[email protected]
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Tue Oct 11, 2022 10:03 pm
by Judith Mason
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Mon Oct 17, 2022 5:34 pm
by Roderick Marchisio
Motion for Discovery
San Andreas Judicial Branch
Motion for Discovery
Honorable Mason,
- We the Prosecution in the case below are presenting our discovery to the court.
State of San Andreas v. Edward Greeg
Assigned Court Case Number: #22-CM-0060
Requesting Party: N/A
Party Members: Roderick Marchisio
Exhibit #1: Arrest Report Edward Greeg
Type of Discovery:
All Information from the Discovery The arrest report written by Deputy Hoffman provides insight into the situation that led to the arrest of the Defendant.
-
ARREST REPORT
MUGSHOT
SUSPECT 1 DETAILS
-
Full Name: Edward Greeg
Telephone Number: 389-7223
Licenses Revoked: No
Charges:
- NM03 - Unlawful Assembly
- GF03 - Armed Robbery
- SF02 - Accessory to Attempted Murder
How did the suspect plea to the above charges?
Suspect pleaded not guilty to all charges.
Additional Details (Suspect's vehicle, etc.) :
Vehicle Model: BF-400 Vehicle Color: Black License Plate: JVKUMH0W Vehicle Owner: Edward Greeg Miscelleanous Details: Bike is moderately dirty
VEHICLES INVOLVED
- Vehicle A: Vehicle Model: BF-400 Vehicle Color: Black License Plate: JVKUMH0W Vehicle Owner: Edward Greeg Miscelleanous Details: Bike is moderately dirty
DEPUTY DETAILS
- Full Name: Louise Hoffman
Badge Number: 20109
Callsign: 12-R-21
INCIDENT DETAILS
- Date of Arrest: 2022-07-27
Deputies Involved: Deputy Hoffman, Deputy Valor, Investigator Murdock, Trainee Johnson, Investigator Wilkinson, Deputy L. Spencer
Provide details of the incident leading up to the arrest
- The Robbery, initial situation.
My partner and I were in a police scout, travelling through Grapeseed from the intersection on Senora Freeway, on a regular patrol of the county. We first noticed a black Issi pulled up at Grapeseed store, two times occupied. We were able to identify two individuals, dressed all in black.
Pulling around the corner, I notice immediately three bikes facing the road, outside Grapeseed clothing store. On approach I notice two more bikes parked in the alleyway on the left side of the store. I pull up in the middle of the road and notice individuals inside. I tell my partner that there is a store robbery, and stepped out of the vehicle, immediately pulling my shotgun.
It is important to note that as soon as I pulled up, I heard dispatch informing us that a robbery was in progress in Grapeseed, corresponding to the location. Four individuals came running out of the store. Three went right out of the store and one went left. I pointed my gun towards the three individuals, at which point I noticed a man aiming an AK at me. I hear the shots before I discharge my gun.
I am able to get to cover on the other side of my scout, the side furthest from the store. At this time, I hear a silenced .50 shooting and more bullets whizzing past my head, alongside the sounds of the AK being discharged.
Our own 10-15 went immediately to the bike, and left the scene whilst the individual with the AK made no attempt to run, but aim his gun. This lead me to believe that it was a premeditive act in order to let the man escape.
I could say without doubt that I had at least two individuals shooting at me, so I made an attempt to escape. Successful, I managed to get into position behind the building directly opposite the clothing store. Here I make the Code 1 radio call. I attempt to see if the individuals had left the scene, since my unit was the only unit on scene. However, they had not and the individual with the gun was running towards me. I make it to high ground, in which I see that they are attempting to surround me. Shots are still firing in my direction. This is a irrefutable case of the individuals actively attempting to find me and murder me.
I ran around the building, attempting to lose them. I go to one side, find another individual on the left side of the store, further down the street who got off his Hakuchou, and was withdrawing a firearm. I went back around the back, and heard more shots being fired.
I make a final attempt at this point to flee to cover in the forest area, attempting to get higher ground in case they were to continue in my search. At this point, no more shots were heard so I informed the units who were inbound that I believed they had left.
I got treated for three GSW wounds to my person, whilst my partner, stuck in the vehicle, had been taken to MD to get treated for his wounds.
After the scene, I reviewed my bodycam footage of events (exhibit B- Bodycam footage) and having my MDC open during the arrival on scene, we were able to grab three license plates and get clear views of the suspects.
The arrest.
Following the situation, I reviewed the footage thoroughly to make BOLO's for the suspects (Exhibit C). As I was calling over radio the RO of the black Issi sport that we saw outside of Grapeseed store, Deputy L. Spencer radioed to say that he had the RO of the vehicle in front of MD. My unit arrived on scene, but there was not enough evidence to detain the individual longer and Ms. Harley Pavlovich was let go off. The vehicle was not an Issi but a Kamacho. As I got back into my scout, I saw a black BF400 and a man riding it slowly go past, and identified him from his clothing and tattoos on his right arm as one of the individuals who had run out of the store. I radioed for him to be pulled over, and with enough evidence we called it a 10-66.
We pulled the BF400 over on Great Ocean Highway, proceeded to conduct our 10-66 stop, and quickly and efficiently we were able to arrest the individual.
Reasons why we made the arrest:
- Wearing the exact same clothing as one of the individuals from the store, specifically recognizable from the white mask and white head wrap. Same shoes and shorts.
- Tattoo is easily recognizable from the footage on his right arm.
- Found in close proximity to the RO after the fact of the Issi found on scene.
- BF400 was identical to the one found on scene.
EVIDENCE DETAILS
- Refer to later evidence exhibits
ARRESTING DEPUTY SIGNATURE
Exhibit #2: Clothing of the Defendant
Type of Discovery:
All Information from the Discovery This piece of evidence contains the clothes that the Defendant was wearing at the time of his arrest. As can be clearly seen, these clothes are an exact match to the outfit as seen in evidence exhibit #3.
Exhibit #3: Bodycam Footage
Type of Discovery:
Exhibit #4: Mugshots of the Defendant
Type of Discovery:
All Information from the Discovery The mugshots of the Defendant show him at the time of his arrest. Additionally, the Prosecution would like to note that as can be seen on the bodycam footage of the Deputy as presented in evidence exhibit #3, the tattoos of the Defendant correspond exactly.
Exhibit #5: Impound Report
Type of Discovery:
All Information from the Discovery The impound report shows the vehicle which the Defendant was driving at the time of his arrest, which is the exact same vehicle as seen on evidence exhibit #3.
Exhibit #6: Statement Investigator Murdock
Type of Discovery:
All Information from the Discovery The statement of Investigator Murdock with the Los Santos County Sheriff's Department gives additional insight into the situation and confirms the story of events as described in the arrest report.
Los Santos County Sheriff's Department
RE: Statement Request - Edward Greeg - 27/JUL/2022
"A TRADITION OF SERVICE" |
- On the 27th of July 2022 I responded to a traffic stop initiated by Deputy Lance Spencer. The RO of the vehicle matched that of a BOLO recently posted by Deputy Louise Hoffman after a store robbery at Grapeseed. After reviewing her body cam, she was able to create BOLOs after being shot at by the store robbers.
The vehicle pulled over was a Kamacho, and we were across the road from the station at Paleto MD. I went to get a Komacho and told at the time Trainee Quentin Johnson to get in with me.
The traffic stop didn't lead to anything, however, as it was wrapping up a BF400 drove by. At this point, Deputy Hoffman radioed to us, saying he was one of the BOLOs from the store robbery. My unit was the first to pull him over, and we initiated and completed a 10-66 after additional units arrived.
The suspect (Edward Greeg) matched the BOLO exactly; vehicle, clothing, shoes and tattoos. Everything matched the BOLO exactly.
Deputy Hoffman was confident he was involved, but we wanted a second opinion from JB. We met with Prosecuting Attorney Caroline Johnson and Prosecuting Attorney Kendall Frances, who advised with the charges eventually placed on Edward Greeg.
- From
Investigator I Lucas Murdock,
Gangs and Narcotics Division
Los Santos County Sheriff's Department
Sincerely,
Senior Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 —
[email protected]
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Mon Oct 17, 2022 5:51 pm
by Roderick Marchisio
Motion to Amend Charges
San Andreas Judicial Branch
Motion to Amend Charges
Honorable Mason,
- We the Prosecution in the case are requesting an amendment of the charges.
State of San Andreas v. Edward Greeg
Assigned Court Case Number: #22-CM-0060
Requesting Party: Prosecution
Party Members: Roderick Marchisio
Original Charges:
- NM03 - Unlawful Assembly
- GF03 - Armed Robbery
- SF02 - Accessory to Attempted Murder of a Government Employee
Amended Charges:
- NM03 - Unlawful Assembly
- GF03 - Armed Robbery
- SF02 - Accessory to Attempted Murder of a Government Employee
- VF01 - Evading an Officer
- GM19 - Face Concealment (b)
Detailed explanation:
With reference to the evidence exhibits as previously presented to the court, the Prosecution deems it absolutely clear that the Defendant also willingly evaded from the Deputies and can be seen communicating on his radio while running towards his bike. Additionally, the Defendant can be seen wearing a mask while committing these crimes.
Sincerely,
Senior Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 —
[email protected]
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Thu Oct 20, 2022 2:57 am
by Judith Mason
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Thu Oct 20, 2022 6:48 pm
by Shaun Harper
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Thu Oct 20, 2022 11:25 pm
by Sarah Williams
Motion for Continuance
San Andreas Judicial Branch
Motion for Continuance
Honorable Judith Mason,
- We the Defense in the case below are requesting a Continuance for [7] days for the reason listed below.
State of San Andreas v. Edward Greeg
Assigned Court Case Number: #22-CM-0060
Detailed explanation:
The defense still need to meet with our client. He has responded to texts, however we have not managed to find a mutually available time. We plan to file a motion to suppress certain pieces of evidence, but it is in everyone's best interest that we have the time to meet with our client before doing so.
Respectfully,
Sarah Williams
Junior Defense Attorney
San Andreas Judicial Branch
463-8400 —
[email protected]
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Wed Oct 26, 2022 10:55 pm
by Judith Mason
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Fri Oct 28, 2022 11:09 pm
by Sarah Williams
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Sat Oct 29, 2022 5:31 pm
by Shaun Harper
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Fri Nov 11, 2022 12:58 am
by Judith Mason
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Fri Nov 11, 2022 12:41 pm
by Shaun Harper
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Fri Nov 11, 2022 12:42 pm
by Shaun Harper
Motion to Suppress
San Andreas Judicial Branch
Motion to Suppress
Honorable Judith Mason,
- We the Defense in the case below are requesting that certain evidence be inadmissible in court.
State of San Andreas v. Edward Greeg
Assigned Court Case Number: #22-CM-0060
Requesting Party: Defense
Party Members: Cyrus Raven, Shaun Harper
Requested Evidence to Suppress: See Below
Detailed explanation:
Exhibit 1:
The following should be suppresed for: Relevance and Speculation
All Information from the Discovery The arrest report written by Deputy Hoffman provides insight into the situation that led to the arrest of the Defendant.
-
ARREST REPORT
MUGSHOT
SUSPECT 1 DETAILS
-
Full Name: Edward Greeg
Telephone Number: 389-7223
Licenses Revoked: No
Charges:
- NM03 - Unlawful Assembly
- GF03 - Armed Robbery
- SF02 - Accessory to Attempted Murder
How did the suspect plea to the above charges?
Suspect pleaded not guilty to all charges.
Additional Details (Suspect's vehicle, etc.) :
Vehicle Model: BF-400 Vehicle Color: Black License Plate: JVKUMH0W Vehicle Owner: Edward Greeg Miscelleanous Details: Bike is moderately dirty
VEHICLES INVOLVED
- Vehicle A: Vehicle Model: BF-400 Vehicle Color: Black License Plate: JVKUMH0W Vehicle Owner: Edward Greeg Miscelleanous Details: Bike is moderately dirty
DEPUTY DETAILS
- Full Name: Louise Hoffman
Badge Number: 20109
Callsign: 12-R-21
INCIDENT DETAILS
- Date of Arrest: 2022-07-27
Deputies Involved: Deputy Hoffman, Deputy Valor, Investigator Murdock, Trainee Johnson, Investigator Wilkinson, Deputy L. Spencer
Provide details of the incident leading up to the arrest
- The Robbery, initial situation.
My partner and I were in a police scout, travelling through Grapeseed from the intersection on Senora Freeway, on a regular patrol of the county. We first noticed a black Issi pulled up at Grapeseed store, two times occupied. We were able to identify two individuals, dressed all in black.
Pulling around the corner, I notice immediately three bikes facing the road, outside Grapeseed clothing store. On approach I notice two more bikes parked in the alleyway on the left side of the store. I pull up in the middle of the road and notice individuals inside. I tell my partner that there is a store robbery, and stepped out of the vehicle, immediately pulling my shotgun.
It is important to note that as soon as I pulled up, I heard dispatch informing us that a robbery was in progress in Grapeseed, corresponding to the location. Four individuals came running out of the store. Three went right out of the store and one went left. I pointed my gun towards the three individuals, at which point I noticed a man aiming an AK at me. I hear the shots before I discharge my gun.
I am able to get to cover on the other side of my scout, the side furthest from the store. At this time, I hear a silenced .50 shooting and more bullets whizzing past my head, alongside the sounds of the AK being discharged.
Our own 10-15 went immediately to the bike, and left the scene whilst the individual with the AK made no attempt to run, but aim his gun. This lead me to believe that it was a premeditive act in order to let the man escape.
I could say without doubt that I had at least two individuals shooting at me, so I made an attempt to escape. Successful, I managed to get into position behind the building directly opposite the clothing store. Here I make the Code 1 radio call. I attempt to see if the individuals had left the scene, since my unit was the only unit on scene. However, they had not and the individual with the gun was running towards me. I make it to high ground, in which I see that they are attempting to surround me. Shots are still firing in my direction. This is a irrefutable case of the individuals actively attempting to find me and murder me.
I ran around the building, attempting to lose them. I go to one side, find another individual on the left side of the store, further down the street who got off his Hakuchou, and was withdrawing a firearm. I went back around the back, and heard more shots being fired.
I make a final attempt at this point to flee to cover in the forest area, attempting to get higher ground in case they were to continue in my search. At this point, no more shots were heard so I informed the units who were inbound that I believed they had left.
I got treated for three GSW wounds to my person, whilst my partner, stuck in the vehicle, had been taken to MD to get treated for his wounds.
After the scene, I reviewed my bodycam footage of events (exhibit B- Bodycam footage) and having my MDC open during the arrival on scene, we were able to grab three license plates and get clear views of the suspects.
The arrest.
Following the situation, I reviewed the footage thoroughly to make BOLO's for the suspects (Exhibit C). As I was calling over radio the RO of the black Issi sport that we saw outside of Grapeseed store, Deputy L. Spencer radioed to say that he had the RO of the vehicle in front of MD. My unit arrived on scene, but there was not enough evidence to detain the individual longer and Ms. Harley Pavlovich was let go off. The vehicle was not an Issi but a Kamacho. As I got back into my scout, I saw a black BF400 and a man riding it slowly go past, and identified him from his clothing and tattoos on his right arm as one of the individuals who had run out of the store. I radioed for him to be pulled over, and with enough evidence we called it a 10-66.
We pulled the BF400 over on Great Ocean Highway, proceeded to conduct our 10-66 stop, and quickly and efficiently we were able to arrest the individual.
Reasons why we made the arrest:
- Wearing the exact same clothing as one of the individuals from the store, specifically recognizable from the white mask and white head wrap. Same shoes and shorts.
- Tattoo is easily recognizable from the footage on his right arm.
- Found in close proximity to the RO after the fact of the Issi found on scene.
- BF400 was identical to the one found on scene.
EVIDENCE DETAILS
- Refer to later evidence exhibits
ARRESTING DEPUTY SIGNATURE
Specifically, there is no matching photos from the arrest, only a mugshot and clothes found on his person. The shirt visible in the mugshot does not match any of the photos provided.
For reason 2, there are no tattoos visible in the mugshots, and does not lay down the foundation to say it matches.
Reason 3 is irrelevant. Cars are allowed to be in close proximity to each other. They were not told to separate, and nothing illegal is in this point.
Reason 4 falls under speculation, as no plate was giving from the BOLOs, and black BF400's are a very common vehicle in Los Santos.
Exhibit 2:
The following should be suppresed for: Speculation
All Information from the Discovery This piece of evidence contains the clothes that the Defendant was wearing at the time of his arrest.
As can be clearly seen, these clothes are an exact match to the outfit as seen in evidence exhibit #3.
There's is no way to clearly see clothes in an evidence locker are a match to what a suspect was wearing.
Exhibit 3:
The following should be suppresed for: Speculation
All Information from the Discovery The bodycam footage as provided by the Los Santos County Sheriff's Department clearly shows the Defendant wearing the clothes as presented in evidence exhibit #2, stepping on the exact same bike as presented in evidence exhibit #5.
- **video**
(( Unfortunately, only photos were able to be taken from the footage. However, this should in no way impact the roleplay.
))
As repeated earlier, there is no proof that this is the same BF400, nor the same clothes. This provides images that do not match the given mugshot.
Exhibit #4:
The following should be suppresed for: Hearsay
All Information from the Discovery The mugshots of the Defendant show him at the time of his arrest.
Additionally, the Prosecution would like to note that as can be seen on the bodycam footage of the Deputy as presented in evidence exhibit #3, the tattoos of the Defendant correspond exactly.
The defense would like to note that there are no tattoos visible in this mugshot.
Exhibit #6:
The following should be suppresed for: Relevance and Speculation
All Information from the Discovery The statement of Investigator Murdock with the Los Santos County Sheriff's Department gives additional insight into the situation and confirms the story of events as described in the arrest report.
Los Santos County Sheriff's Department
RE: Statement Request - Edward Greeg - 27/JUL/2022
"A TRADITION OF SERVICE" |
- On the 27th of July 2022 I responded to a traffic stop initiated by Deputy Lance Spencer. The RO of the vehicle matched that of a BOLO recently posted by Deputy Louise Hoffman after a store robbery at Grapeseed. After reviewing her body cam, she was able to create BOLOs after being shot at by the store robbers.
The vehicle pulled over was a Kamacho, and we were across the road from the station at Paleto MD. I went to get a Komacho and told at the time Trainee Quentin Johnson to get in with me.
The traffic stop didn't lead to anything, however, as it was wrapping up a BF400 drove by. At this point, Deputy Hoffman radioed to us, saying he was one of the BOLOs from the store robbery. My unit was the first to pull him over, and we initiated and completed a 10-66 after additional units arrived.
The suspect (Edward Greeg) matched the BOLO exactly; vehicle, clothing, shoes and tattoos. Everything matched the BOLO exactly.
Deputy Hoffman was confident he was involved, but we wanted a second opinion from JB. We met with Prosecuting Attorney Caroline Johnson and Prosecuting Attorney Kendall Frances, who advised with the charges eventually placed on Edward Greeg.
- From
Investigator I Lucas Murdock,
Gangs and Narcotics Division
Los Santos County Sheriff's Department
There is no proof that the vehicle, clothing, shoes and tattoos match, only speculation.
Furthermore, the consulting with prosecuting attorneys has no relevance to the case, and is only a frail attempt to provide justification for charges.
Junior Defense Attorney
San Andreas Judicial Branch
(909) 308-7889 —
[email protected]
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Sun Nov 13, 2022 3:25 pm
by Shaun Harper
Motion to Compel Discovery
San Andreas Judicial Branch
Motion to Compel Discovery
Honorable Judith Mason,
- We the Defense in the case below are requesting the disclosure of the following material by opposing counsel, please find a detailed reason as to our request below.
State of San Andreas v. Edward Greeg
Assigned Court Case Number: #22-CM-0060
Requesting Party: Defense
Party Members: Cyrus Raven, Shaun Harper
Discovery from: LSSD
Type of Discovery: Physical Evidence
- The defense is requesting the weapon used in the crime.
Detailed reasoning:
- Considering the charge GF03 - Armed Robbery states ''Taking the property of another person off of them without uncoerced consent through use of a firearm or deadly weapon. We the defense would like to find out of the defendant was caught with a weapon.
Type of Discovery: Physical Evidence
- The defense is requesting information surrounding a GSR test.
Detailed reasoning:
- The defendant informed the defense that officers did a GSR test the moment they arrested him. We the defense would like to know the results to this test. Considering the client is on trial for SF02 - Accessory to Attempted Murder having this information could be crucial to see if the defendant fired a weapon.
Respectfully,
Junior Defense Attorney
San Andreas Judicial Branch
(909) 308-7889 —
[email protected]
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Sat Nov 26, 2022 11:52 am
by Roderick Marchisio
Motion for Discovery
San Andreas Judicial Branch
Motion for Discovery
Honorable Mason,
- We the Prosecution in the case below are presenting our discovery to the court.
State of San Andreas v. Edward Greeg
Assigned Court Case Number: #22-CM-0060
Requesting Party: N/A
Party Members: Roderick Marchisio
Exhibit #3: Renewed file Bodycam Footage
Type of Discovery:
Sincerely,
Senior Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 —
[email protected]
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Sat Nov 26, 2022 12:04 pm
by Roderick Marchisio
San Andreas Judicial Branch
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
"HERE FOR YOU | SAFE FOR YOU" |
- Honorable Mason,
In relation to the Motion to Suppress as filed by the Defense, the Prosecution notes the following:
- 1. As case law per #22-CM-0050, State of San Andreas v. Harley Pavlovich, official records by public employees are writing made by a public employee as a record of an act or event. The Prosecution further notes that this writing had been conducted within the scope of duty of a public employee. It was decided that the arrest report is a record of an event and as they are a requirement it was made within the scope of the arresting officers duty. The Prosecution deems it obvious an arrest report needs to include the reasoning for the arrest itself;
- 2. The Prosecution notes that the clothing as presented in the evidence is more than clear and leads to no doubts. (( This is a picture that was taken from the inventory items. Realistically, this would show you the clothing itself rather than the "items. As such, this argument does not make any sense whatsoever from a roleplay perspective. ))
- 3. The Prosecution points out that the clothing is indeed matching to the clothes found in possession of the Defendant at the time of his arrest. Additionally, as per the evidence exhibits as previously provided to the court, there is no doubt whatsoever this particular BF400 is the exact same as the one the Defendant was driving at the time of his arrest. We reference to the bodycam footage as provided to the court. As such, the Prosecution doubts the argument of the Defense in this respect.
- 4. The Prosecution points out that, again, this becomes abundantly clear on the bodycam footage as provided. The tattoos on the bodycam footage as presented in the initial situation are an exact match to the Defendant at the time of his arrest. The Prosecution wonders how, with the presented evidence in mind, this argument is hearsay.
- 6. The Prosecution again refers to the evidence exhibits as previously presented to the court in which becomes abundantly clear the Defendant did in fact match the BOLO as described. The Prosecution has no issues with the consultation part highlighted in red to be struck from the record.
Following this, the Prosecution can only conclude that this motion to suppress, bar the specific section in exhibit #6, should be denied. Further, in accordance with the recent changes to the docket, we waiver our rights for a motions hearing in any kind, unless the Defense would like to of course.
Respectfully,
Deputy Attorney General
San Andreas Judicial Branch
(909) 372-7719 — [email protected]
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
Posted: Sat Nov 26, 2022 12:23 pm
by Roderick Marchisio
San Andreas Judicial Branch
Re: #22-CM-0060, State of San Andreas v. Edward Greeg
"HERE FOR YOU | SAFE FOR YOU" |
- Honorable Mason,
With reference to the Motion to Compel Discovery, the Prosecution would like to response as follows.
In relation to the first point, the Prosecution points out that the charge GF03 - Armed Robbery as described in the penal code can be committed by a group of people, for which not all individuals involved have to be carrying a firearm. The phrase "use of a firearm" does not specifically refer to one individual but refers to the act in which the robbery is committed. As can be clearly seen through the bodycam footage as provided previously to the court, there definitely were illegal firearms at play. Further, the Prosecution notes that if a firearm had indeed been visible on the Defendant, the Motion to Amend Charges would have included at the very least the charges WM01 - Unlawful Brandishing of a Firearm or Weapon as well as WM02 - Possession of an Unlicensed Firearm.
In relation to the second point, the Prosecution notes that, it is clear beyond any reasonable doubt that the Defendant and the other individual that was being pursued in the original situation are affiliated with each other in a criminal way. It is not in contention that the situation to which the Deputies responded was a store robbery. Per the ruling in the case of State of San Andreas v. Nanna Bohanna, it is case law that the charge NM03 - Unlawful Assembly should be explained that it is only applicable in cases where a Defendant is gathering together with another individual or other individuals to do something illegal. The Prosecution notes that this something illegal in this case is the obvious collaboration in the attempt to commit a store robbery, but also to have illegal firearms present to potentially use if law enforcement officers interrupted the execution of their plan. As such, this degree of premeditated acting cannot and should not been seen separately from each other. Further, the Prosecution notes that if the Defendant was utilizing a firearm himself, he would not have been appealing an Accessory to Attempt charge but an Attempted charge.
Respectfully,
Deputy Attorney General
San Andreas Judicial Branch
(909) 372-7719 —
[email protected]