#22-CM-0065, State of San Andreas v. Harley Pavlovich

Harley Pavlovich
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#22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Harley Pavlovich »

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Defendant Name: Harley Pavlovich
Defendant Phone: 4714790
Defendant Address: N/A
(( Defendant Discord: )) Harley#0600
Requested Attorney: N/A if none N/A
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Charging Department: Sheriffs Department
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Time & Date of Incident(s): 21:10 - 02/AUG/2022
Charge(s): Accessory to Evading an Officer & Impeding Emergency Response
Narrative:

I was driving down to DOC as I had a call from my good friend Ryan that he wanted a ride from Bolingbroke. I then drove out of DOC, and lost control of my vehicle, stalling the Buffalo STX I was driving on the bridge leading up to Purple Dinosaur. As I turned my engine on, I started to correct my position of my vehicle by turning back into the correct lane of travel, I was then hit by an Issi Sport, and two cruisers. I immediately pulled over to check if everyone was okay. The Sheriffs then told me to turn my engine off, then all of a sudden performed a hard stop on my vehicle, aiming heavy weaponry at myself and my passenger. (We were both unarmed).

We both got out of the vehicle and surrendered immediately, we were both detained. My passenger was soon let go, and I was arrested for impeding emergency response and accessory to Felony Evading.
I had absolutely no connection to the evading Issi Sport, nor did I intentionally collide with the police, I simply stalled my vehicle and was attempting to correct myself when the pursuit met me.

SD Claimed the reason for the arrest was they had bodycam footage of me intentionally ramming police with my vehicle, however this is just untrue, I was not questioned nor spoked to at all about the suspicion on me until 14219 was placing charges, where he refused to listen to me, and instead screamed charges in my ear, saying nothing else but "It's the courts problem not ours" and his badge number.

This behaviour from, according to deputies, a supervisor is just ridiculous. He showed absolutely zero professionalism or respect towards me or my passenger, and showed not a single sign of investigatory work. The investigation was not present, he decided to just place charges without investigating the entire situation, a big mistake for a supervisor to be making.

I, Harley Pavlovich, 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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Caroline Johnson
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Re: State of San Andreas v. Harley Pavlovich

Post by Caroline Johnson »

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San Andreas Judicial Branch

Re: State of San Andreas v. Harley Pavlovich
"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. In addition, we ask the court to affirm its prior rulings and superior court policy that the defendant may not petition the court for judicial review of citations in the case of VC06 - Following or Impeding Emergency Response.

    Best Wishes,

    Caroline Johnson
    Attorney-At-Law
    San Andreas Judicial Branch
    (909) 590-4566 — [email protected]
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Pavel Perrault
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Re: State of San Andreas v. Harley Pavlovich

Post by Pavel Perrault »

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Rockford Law

State of San Andreas v. Harley Pavlovich

  • To whom it may concern,

    I, Pavel Perrault, will be taking on the role of defending Harley Pavlovich in this case. I have made myself familiar with the facts of the case and have communicated with the client. I am ready to continue at the court's discretion.

    Respectfully,
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    Attorney
    Rockford Law
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Colt Daniels
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Colt Daniels »

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San Andreas Judicial Branch

Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich
"HERE FOR YOU | SAFE FOR YOU"

  • Counselors,

    I am Chief Justice Colt Daniels and I will be presiding over this case in my courtroom.

    At this time I am activating this case under #22-CM-0065. I see that currently the defendant has private representation from Rockford Law, however since this case was posted the prosecuting attorney that was assigned to the case has resigned. At this time I will be holding off on ordering discovery until the Attorney General finds adequate representation for the state.

    Respectfully,

    Chief Justice
    San Andreas Judicial Branch
    (909) 402-9713 — [email protected]
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Roderick Marchisio
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Roderick Marchisio »

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San Andreas Judicial Branch

Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich
"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. As I am only taking this case now while it is already on the active docket, I hope all parties involved will understand my need for collecting information first.

Respectfully,


Senior Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 — [email protected]
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Colt Daniels »

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San Andreas Judicial Branch

"HERE FOR YOU | SAFE FOR YOU"


#22-CM-0065
Presiding Judge: Colt Daniels

ORDER FOR DISCOVERY


IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#22-CM-0065

A court order was entered in the above case on 17 October, 2022.


The case of the State of San Andreas v. Harley Pavlovich, #22-CM-0065 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.




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San Andreas Judicial Branch
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Roderick Marchisio »

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. Harley Pavlovich
    Assigned Court Case Number: #22-CM-0065
    Requesting Party: N/A
    Party Members: Roderick Marchisio
    Exhibit #1: Arrest Report Harley Pavlovich
    Type of Discovery:
    • Physical Evidence
    Spoiler
    All Information from the Discovery The arrest report gives insight into the situation that led to the arrest of the Defendant.
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      ARREST REPORT
      MUGSHOT
      SUSPECT 1 DETAILS
      • Full Name: Harley Pavlovich
        Telephone Number: 4714790
        Licenses Revoked: No
        Charges:
        • VF01 - Accessory to Evading an Officer
        How did the suspect plea to the above charges?
        Suspect pleaded not guilty to all charges.
        Additional Details (Suspect's vehicle, etc.) :
      VEHICLES INVOLVED
      • Vehicle A: Dark Brown, Buffalo STX, LP DJ9P1U3K, RO Harley Pavlovich
      DEPUTY DETAILS
      • Full Name: Charlie Wilkinson
        Badge Number: 17792
        Callsign: 3-W-11
      INCIDENT DETAILS
      • Date of Arrest: 2022-08-02
        Deputies Involved: Assistant Sheriff McCornish, Lt. McJohnson, Sgt. Derringer, MD West

        Provide details of the incident leading up to the arrest
        • On the 2nd of August, 2022 at around 8:40 PM units engaged in a pursuit of a black Issi Sport found around the area of shots being fired at the Chiliad State Mountain Wilderness Camp in Paleto Forest. After a few minutes of going in circles around Senora Freeway, all whilst the driver of the Issi Sport could be clearly seen communicating actively on his radio as his rear window was shattered and broken, we turned off on the DOC offramp on Senora Freeway, intersecting with Senora Way, towards the area commonly referred to as "Pink Dino". As I was the lead unit, I could already see the dark brown Buffalo STX sitting on the incorrect lane of travel, angled in a way that clearly already hinted at their future intentions. As we approached closer, I could already see the vehicle starting to move to the correct lane, waiting and timing their movements in a way so they could cut me, as the driver of the High Speed Interception Unit, off from the pursuit line, showing no regard for my life or personal safety.

          The driver was later identified to be Harley Pavlovich. Ms. Pavlovich is known to the Sheriff's Investigation Bureau's Gangs and Narcotics Division to be an active affiliate of a criminal organization called "The Rooks". The same is very much true for the original driver of the black Issi Sport, Marvin Berkowitz.
          The two individuals are both known affiliates and were likely on the exact same radio frequency, working together and coordinating this brutal attack on my personal safety.
      EVIDENCE DETAILS
      • Please refer to evidence exhibit #2
      ARRESTING DEPUTY SIGNATURE
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    Exhibit #2: Bodycam footage
    Type of Discovery:
    • Physical evidence
    Spoiler
    All Information from the Discovery The bodycam footage provided by the Los Santos County Sheriff's Department shows the exact situation that led to the arrest to the Defendant.
    Exhibit #3: Witness Statement Sergeant Cliff Derringer
    Type of Discovery:
    • Witness Statement
    Spoiler
    All Information from the Discovery The witness statement as provided by Sergeant Cliff Derringer with the Los Santos County Sheriff's Department provides further insight into the situation that led to the arrest of the Defendant.
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      San Andreas Judicial Branch
      Official Witness Statement
      "HERE FOR YOU | SAFE FOR YOU"
      Case Information
      • Case Number: [#22-CM-0065]
        Incident Date: [02/AUG/2022]
      Witness Information
      • Name: [Cliff Aaron Derringer]
        Phone Number: [476-1433]
        Occupation: [Seargent - Los Santos County Sheriff's Department]
      Witness Statement
      • [On the provided date in the arrest report, the above witnessed attempt at interfering with police protocol and response by the arrested party was verified by camera footage and checked through the arresting protocols and probable cause. Based upon the viewed evidence, the charges to be placed were confirmed by Charlie Wilkinson, and the arrest wade made.

        As a side note, it is known amongst the department that Harley Pavlovich is a known repeat offender and 'Rooks' affiliate, and who attempts to 'weaponize' the reporting system of officers in both IA and Judicial to attempt to sway or intimidate officers into either dropping charges or ignoring her as means of intimidation.]
      Witness Affirmation
      • I, [Cliff Aaron Derringer], 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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        [Cliff Derringer]
        [Sergeant | Specialist Operator]
        [Los Santos County Sheriff's Department | Special Enforcement Detail]

        Date: [20/OCT/2022]
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    Exhibit #4: Evidence as submitted under seal
    Type of Discovery:
    • Evidence as submitted under seal
    Spoiler
    All Information from the Discovery Evidence as submitted under seal
    • Evidence as submitted under seal


Sincerely,

Senior Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 — [email protected]
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Roderick Marchisio »

Motion to Amend Charges
San Andreas Judicial Branch
Motion to Amend Charges

Honorable Daniels,

  • We the prosecution in the case are requesting an amendment of the charges.
    State of San Andreas v. Harley Pavlovich
    Assigned Court Case Number: #22-CM-0065
    Requesting Party: Prosecution
    Party Members: Roderick Marchisio
    Original Charges:
    • VF01 - Accessory to Evading an Officer
    • VC06 - Following or Impeding Emergency Response
    Amended Charges:
    • VF01 - Accessory to Evading an Officer
    • VC06 - Following or Impeding Emergency Response
    • VM04 - Disruptive Impeding or Blocking Travel
    • GM19 - Face Concealment (b)
    • WF01 - Assault with a Deadly Weapon of a Government Employee
    • VM03 - Reckless Operation of a Road or Marine Vehicle
    • GM08 - Vandalism of Government Property
    • NM03 - Unlawful Assembly
    • GF24 - Perjury

    Detailed explanation:

    The Prosecution notes that, with reference made to evidence exhibit #1, evidence exhibit #2 and evidence exhibit #3 as previously presented to the court, it is abundantly clear that the vehicle of the Defendant was able to move both forwards and backwards. Additionally, the Prosecution notes that it is very clear no damage is visible on the vehicle itself nor the bridge nor on the road as can be seen on the slo-mo. As such, the Prosecution can only conclude that the action of standing still in the incorrect lane of travel was intentional and should only result in the application of the charge VM04 - Disruptive Impeding or Blocking Travel. The Prosecution also notes the Defendant was wearing a mask while conducting said conduct, resulting in the charge GM19 - Face Concealment (b) being applicable.

    Further, the Prosecution notes that, with reference made to evidence exhibit #1, evidence exhibit #2 and evidence exhibit #3 as previously presented to the court, it is abundantly clear that the Defendant willingly drove her vehicle into an upcoming police cruiser, that was nearing at a clocked speed of 152 km/h at the time of impact between the vehicles, in an attempt to hit the police cruiser into the bridge. With this action, the Defendant knowingly put the Deputy at risk. The Prosecution notes that any reasonable thinking person understands the probable risk of such an action. The fact that the movement of the Deputy made him avoid being hit into a bridge does not take anything away from this premeditated action nor from the fact that the execution of this offense had been completed, only fortunately unsuccesfully. Additionally, the Prosecution notes that with this action, the Defendant clearly had intentional disregard for the life of the Deputy through the operation of her road vehicle.
    Per the ruling in the case of State of San Andreas v. Harley Pavlovich, it is case law that the charge GM08 - Vandalism should be explained that it is only applicable in cases where a Defendant maliciously performs an act of colliding with another vehicle in order to damage it. With reference to the aforementioned, the Prosecution deems this clear as well as taking into account this malicious act caused damage to the bridge itself. As such, the Prosecution can only conclude that the act of the Defendant by intentionally hitting the police cruiser of the Deputy should only result in the application of the charges WF01 - Assault with a Deadly Weapon of a Government Employee, VM03 - Reckless Operation of a Road or Marine Vehicle and GM08 - Vandalism of Government Property.

    Continuing, the Prosecution notes that, it is clear beyond any reasonable doubt that the Defendant and the individual that was being pursued are affiliated with each other in a criminal way. 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 to do something illegal. The Prosecution notes that this something illegal in this case is the obvious collaboration in the attempt to evade an officer. As such, the Prosecution can only conclude that the action of this intentional collaboration should only result in the application of the charge NM03 - Unlawful Assembly.

    Also, the Prosecution notes that the Defendant has attempted to appeal the Vehicular Citation 06 - Following or Impeding Emergency Response. The Prosecution notes that per the Superior Court guidelines appeals may not be used for citations.

    Lastly, the Prosecution notes that the Criminal Case Submission Form is an official statement, which has to be signed with the affirmation that, and we quote:
    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
    With reference to the aforementioned, the Prosecution notes that as per the Defendants' narrative under oath as submitted to the court, the Defendant has knowingly and willingly made numerous clearly untrue statements in this official statement to mislead the court in this trial. In this respect, the Prosecution notes to the following sentences:
    • "I then drove out of DOC, and lost control of my vehicle, stalling the Buffalo STX I was driving on the bridge leading up to Purple Dinosaur." - please refer to Paragraph 1 of this Motion.
    • "As I turned my engine on, I started to correct my position of my vehicle by turning back into the correct lane of travel, I was then hit by an Issi Sport, and two cruisers." - please refer to Paragraphs 1 and 2 of this Motion.
    • "I had absolutely no connection to the evading Issi Sport, nor did I intentionally collide with the police, I simply stalled my vehicle and was attempting to correct myself when the pursuit met me." - please refer to Paragraphs 3, 1 and 2 of this Motion.
    • "SD Claimed the reason for the arrest was they had bodycam footage of me intentionally ramming police with my vehicle, however this is just untrue ..." - please refer to Paragraphs 1 and 2 of this Motion.
    • "This behaviour from, according to deputies, a supervisor is just ridiculous. He showed absolutely zero professionalism or respect towards me or my passenger, and showed not a single sign of investigatory work. The investigation was not present, he decided to just place charges without investigating the entire situation, a big mistake for a supervisor to be making." - please refer to Paragraphs 1 and 2 of this Motion.
    The Prosecution notes that in case the Prosecution had not been able to present the abundantly clear evidence as kindly provided by the Los Santos County Sheriff's Department as previously presented to the Court, these false statements by the Defendant, which are in a direct relation to this trial, would at the very least have had the potential to affect the outcome of the trial. As such, the Prosecution can only conclude that the action of knowingly and willingly providing these false statements to the court should only result in the application of the charge GF24 - Perjury.


Sincerely,


Senior Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 — [email protected]
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Pavel Perrault
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Pavel Perrault »

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. Harley Pavlovich
    Assigned Court Case Number: #22-CM-0065
    Requesting Party: The Defense
    Party Members: Pavel Perrault (Attorney), Harley Pavlovich (Defendant)
    Requested Evidence to Suppress: Exhibit #1: Arrest Report
    Detailed explanation:
    The Defense is Requesting that the highlighted sections of the arrest report be stricken due to their speculative nature.
    Spoiler
    • Image
      ARREST REPORT
      MUGSHOT
      SUSPECT 1 DETAILS
      • Full Name: Harley Pavlovich
        Telephone Number: 4714790
        Licenses Revoked: No
        Charges:
        • VF01 - Accessory to Evading an Officer
        How did the suspect plea to the above charges?
        Suspect pleaded not guilty to all charges.
        Additional Details (Suspect's vehicle, etc.) :
      VEHICLES INVOLVED
      • Vehicle A: Dark Brown, Buffalo STX, LP DJ9P1U3K, RO Harley Pavlovich
      DEPUTY DETAILS
      • Full Name: Charlie Wilkinson
        Badge Number: 17792
        Callsign: 3-W-11
      INCIDENT DETAILS
      • Date of Arrest: 2022-08-02
        Deputies Involved: Assistant Sheriff McCornish, Lt. McJohnson, Sgt. Derringer, MD West

        Provide details of the incident leading up to the arrest
        • On the 2nd of August, 2022 at around 8:40 PM units engaged in a pursuit of a black Issi Sport found around the area of shots being fired at the Chiliad State Mountain Wilderness Camp in Paleto Forest. After a few minutes of going in circles around Senora Freeway, all whilst the driver of the Issi Sport could be clearly seen communicating actively on his radio as his rear window was shattered and broken, we turned off on the DOC offramp on Senora Freeway, intersecting with Senora Way, towards the area commonly referred to as "Pink Dino". As I was the lead unit, I could already see the dark brown Buffalo STX sitting on the incorrect lane of travel, angled in a way that clearly already hinted at their future intentions. As we approached closer, I could already see the vehicle starting to move to the correct lane, waiting and timing their movements in a way so they could cut me, as the driver of the High Speed Interception Unit, off from the pursuit line, showing no regard for my life or personal safety.

          The driver was later identified to be Harley Pavlovich. Ms. Pavlovich is known to the Sheriff's Investigation Bureau's Gangs and Narcotics Division to be an active affiliate of a criminal organization called "The Rooks". The same is very much true for the original driver of the black Issi Sport, Marvin Berkowitz.
          The two individuals are both known affiliates and were likely on the exact same radio frequency, working together and coordinating this brutal attack on my personal safety.
      EVIDENCE DETAILS
      • Please refer to evidence exhibit #2
      ARRESTING DEPUTY SIGNATURE
      Image

      Image

    Requested Evidence to Suppress: Exhibit #3: Witness Statement from Sergeant Cliff Derringer
    Detailed explanation:
    The Defense is requesting that the highlighted portion of this witness statement be stricken due to both it's lack of relevance to the case and it's speculative nature about the intentions of the defendent.
    Spoiler
    All Information from the Discovery The witness statement as provided by Sergeant Cliff Derringer with the Los Santos County Sheriff's Department provides further insight into the situation that led to the arrest of the Defendant.
    • Image

      San Andreas Judicial Branch
      Official Witness Statement
      "HERE FOR YOU | SAFE FOR YOU"
      Case Information
      • Case Number: [#22-CM-0065]
        Incident Date: [02/AUG/2022]
      Witness Information
      • Name: [Cliff Aaron Derringer]
        Phone Number: [476-1433]
        Occupation: [Seargent - Los Santos County Sheriff's Department]
      Witness Statement
      • [On the provided date in the arrest report, the above witnessed attempt at interfering with police protocol and response by the arrested party was verified by camera footage and checked through the arresting protocols and probable cause. Based upon the viewed evidence, the charges to be placed were confirmed by Charlie Wilkinson, and the arrest wade made.

        As a side note, it is known amongst the department that Harley Pavlovich is a known repeat offender and 'Rooks' affiliate, and who attempts to 'weaponize' the reporting system of officers in both IA and Judicial to attempt to sway or intimidate officers into either dropping charges or ignoring her as means of intimidation.]
      Witness Affirmation
      • I, [Cliff Aaron Derringer], 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
        [Cliff Derringer]
        [Sergeant | Specialist Operator]
        [Los Santos County Sheriff's Department | Special Enforcement Detail]

        Date: [20/OCT/2022]
      Image


    Sincerely,
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    Pavel Perrault
    Attorney, Rockford Law
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Roderick Marchisio »

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San Andreas Judicial Branch

Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich
"HERE FOR YOU | SAFE FOR YOU"

  • To whom it may concern,

    In relation to the above Motion to Suppress as filed by the Defense, the Prosecution notes the following.

    With regards to evidence exhibit #1, the Defense would like to suppress evidence from the arrest report as provided by the LSSD. However, with reference to State of San Andreas v. Harley Pavlovich, the Prosecution notes that 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. 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.

    With regards to evidence exhibit #3, the Defense would like to suppress evidence from the witness statement as provided by Sgt. Cliff Derringer of the LSSD. In this statement, he firstly notes that the Defendant is a repeat offender. A simple background check proves this statement to be factually true. If the court and/or Defense wishes, the Prosecution could provide this record to the public docket. Secondly, he notes that the Defendant frequently utilizes both the Internal Affairs procedures as well as the Judicial ones to have a second look at the charges. In this respect, the Prosecution refers once again to State of San Andreas v. Harley Pavlovich as well as the underlying case. Again, this statement is factually true. If the court and/or Defense wishes, the Prosecution could provide these records to the public docket.

    Taking account the aforementioned, the Prosecution can only come to the conclusion that the above Motion to Suppress as filed by the Defense should be denied.

Respectfully,

Senior Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 — [email protected]
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Pavel Perrault »

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Rockford Law

#22-CM-0065 State of San Andreas v. Harley Pavlovich

  • To whom it may concern,

    With regards to the State's response to our Motion to Suppress portions of exhibit #1, the defense feels as though the precedent mentioned by the State does not apply to our motion. This is because in #22-CM-0050, the Defense is objecting to statements made on the grounds of hearsay. In this case, we The Defense are objecting to the statement because they go beyond the scope of reporting the facts of an event or arrest and make speculative statements about what the officer thinks may have happened not what they directly observed.

    With regards to the State's response to our Motion to Suppress portions of exhibit #2, The Defense feels as though the response from the State does not address the objection we are making. Even if it is assumed as fact that one uses the judicial system frequently, there is no proof of the defendant's intentions when doing so. We The Defense are objecting to the manner of which the statement made by Sergeant Derringer speculates the intentions of the defendant when utilizing the judicial system, not whether or not the defendant has utilized it before. Therefore, the State's claim that Ms. Pavlovich is a repeat user of various reporting systems is a fact does not address our objection.

    Respectfully,
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    Attorney
    Rockford Law
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Colt Daniels »

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San Andreas Judicial Branch

Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich
"HERE FOR YOU | SAFE FOR YOU"

  • Counselors,

    I understand that both parties have different viewpoints on the motion filed by the defense. With respect to you both I request that no further arguments be made on the public docket. At this time I move to hear this motion in my courtroom. Use the following scheduling tool to mark your availability. Once completed I will select a time.

    Respectfully,

    Chief Justice
    San Andreas Judicial Branch
    (909) 402-9713 — [email protected]
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Colt Daniels »

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San Andreas Judicial Branch

Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich
"HERE FOR YOU | SAFE FOR YOU"

  • Counselors,

    Additionally, I want to make it know as per the regulations set forth by the Superior Court of San Andreas I will not be hearing arguments related to the "VC06 - Following or Impeding Emergency Response" citation as the courts do not review citations, only misdemeanor and felony charges.

    Respectfully,

    Chief Justice
    San Andreas Judicial Branch
    (909) 402-9713 — [email protected]
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Roderick Marchisio »

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San Andreas Judicial Branch

Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich
"HERE FOR YOU | SAFE FOR YOU"

  • To whom it may concern,

    I will be on an approved Leave of Absence from the October 25, 2022 until November 12, 2022. As such, I am not able to make any of the above listed timeslots for the hearing. Following this, I would like to kindly ask to postpone this hearing until my return.

Respectfully,

Senior Prosecuting Attorney
San Andreas Judicial Branch
(909) 372-7719 — [email protected]
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Sarah Williams »

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San Andreas Judicial Branch

Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Chief Justice Daniels,

    I, Junior Prosecuting Attorney, Sarah Williams will be acting as co-counsel for the State of San Andreas, alongside Rodrick Marchisio. I have familiarized myself with the case and will be ready to assist him when he returns from his Leave of Absence.

Respectfully,
Sarah Williams
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Roderick Marchisio »

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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich
"HERE FOR YOU | SAFE FOR YOU"

  • Your Honor,

    I have returned from my Leave of Absence and would like to wish to schedule the Motions hearing for the underlying case.

Respectfully,

Senior Prosecuting Attorney
San Andreas Judicial Branch
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Roderick Marchisio »

Motion for Involuntary Dismissal
San Andreas Judicial Branch
Motion for Involuntary Dismissal

Honorable Daniels,

  • We the Prosecution in the case below are requesting an involuntary dismissal from the court, please find the reason for it below.
    State of San Andreas v. Harley Pavlovich
    Assigned Court Case Number: #22-CM-0065
    Requesting Party: Prosecution
    Party Members: Roderick Marchisio
    Involuntary Dismissal: Unreasonable Delay, Failure to Make Contact with the Court
    Detailed explanation:
    The Prosecution notes that the Defense has not reacted on anything submitted by the Prosecution as per the 25th of October. As such, it has now been 37 days since the Defense has let the court or Prosecution know anything. We argue this has placed undue burden on the State and delayed this case to an unreasonable degree.

    As such, we would like to ask the court to dismiss the case on involuntary grounds and with this, include the Motion to Amend Charges in the final verdict. The Prosecution notes that as the Motion to Amend Charges had been filed before the announced changes to the docket, the principles of legal certainty and due process dictate this Motion should not be changed retroactively and would like to kindly request you to confirm this in your decision on the Motions as previously filed by the Defense.

    Thank you for your consideration.

Sincerely,


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San Andreas Judicial Branch
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Dmitri Leroy »

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Rockford Law

#22-CM-0065 State of San Andreas v. Harley Pavlovich

  • To whom it may concern,

    Rockford Law responded on this public docket on Oct 24th in regards to our motion to suppress and the court attempted to schedule a meeting the same day. On October 25th the Prosecution, in the public docket, stated that due to a vacation they would fail to staff any of the requested meeting slots. Since then Rockford Law has waited patiently for the courts next attempt at scheduling a meeting.

    Respectfully,
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Colt Daniels »

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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

"EQUAL JUSTICE UNDER LAW"

  • Counselors,

    The court will be denying the Motion for Involuntary Dismissal as correspondence has been made by the Law Firm representing the defendant. At this time I ask that Rockford Law or the defendant to make the court aware of who will be representing the defendant in this case before we move forward.

    Respectfully,

    Chief Justice
    San Andreas Judicial Branch
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Re: State of San Andreas v. Harley Pavlovich

Post by Johnnie_Everdeen »

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Rockford Law

State of San Andreas v. Harley Pavlovich

  • To whom it may concern,

    I, Johnnie Everdeen, am the lead on this case, however, the case has our entire firm at its discretion. We will be awaiting the next step in the process, thank you for your patience.

    Respectfully,
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Colt Daniels »

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San Andreas Judicial Branch

Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

COURT DECISION


IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#22-CM-0065

A decision was reached in the above case on the 14th day of December, 2022.


I thank you all for your patience in this case.

First, as laid out in your court information we do not hear citations in the Superior Court, as such I will not be allowing discussion regarding the citation of VC06 - Following or Impeding Emergency Response in this case. Furthermore in regards to the Motion to Amend Charges filed by the Prosecution on October 23rd 2022, I will only be allowing the addition of two out of the seven being brought fourth, those being WF01 - Assault with a Deadly Weapon of a Gov. Employee, and GF24 - Perjury. At this point and moving forward no additional charges can be brought forth or disputed in regards to this case unless it is directly related to actions taken during the course of the case, i.e Tampering with Evidence, Contempt of Court, etc.

Secondly, in regarding to the Motion to Suppress filed by the Defense on October 24th, 2022. In terms of the arrest report, I will not be suppressing the first highlighted portion as I do not believe it is speculative in nature but simply detailing how the vehicle was driving and how the movements it was making impacted the pursuit. However, I will be suppressing the second highlighted portion of the arrest report as it is clear speculation of what actions were taken by the defendant.

In addition, in regards to the requested suppression of the entire second paragraph of Sergeant Cliff Derringers witness statement, I will also be granting that suppression. The entire second paragraph brings into note the past criminal history of the defendant which has no baring to this case and additionally speculates on what the intent of the defendant is when they choose to use their right to have their case heard by the court.

At this time I will allow until end of day Firday, December 16th, 2022 for additional motions and or discovery to be submitted. If at that time nothing has been posted to the docket, or both parties let it be known they are ready to move forward at an earlier time, I will be attempting to schedule a trial for this case.


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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Dmitri Leroy »

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Rockford Law

#22-CM-0065 State of San Andreas v. Harley Pavlovich

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. Harley Pavlovich
      Assigned Court Case Number: #22-CM-0065
      Requesting Party: The Defense
      Party Members: Harley Pavlovich (Defendant), Rockford Law (Firm),
      Requested Evidence to Suppress: Exhibit #2: Bodycam footage
      Detailed explanation:
      The evidence submitted on behalf of the Los Santos County Sheriff's Department has been edited away from its original form making events appear slower. The Defense believes it's important to present untampered with evidence to the court for the most fair interpretation to the intentions of our client in this split second situation. ((Note: We are not referencing the OOC text blur))

    Sincerely,
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Dmitri Leroy »

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Rockford Law

#22-CM-0065 State of San Andreas v. Harley Pavlovich

Motion to Compel Discovery
San Andreas Judicial Branch
  • Motion to Compel Discovery

    Honorable colt Daniels,
    • We the Defense in the case below are requesting the disclosure of the following materials by opposing counsel, please find detailed reasons as to our request below.


      • State of San Andreas v. Harley Pavlovich
        Assigned Court Case Number: #22-CM-0065
        Requesting Party: The Defense
        Party Members: Harley Pavlovich (Defendant), Rockford Law (Firm),
        Discovery from: Los Santos County Sheriff's Department

        Type of Discovery: Document Request
        • All professional documentation or investigative reports detailing damage to vehicles and/or the roadways involved in the scenario.
        Detailed reasoning:
        • The prosecution has challenged the defendants statements regarding the conditions of the road and her vehicle at the time of the incident.

          The prosecutions motion to amend charges states they wish to pursue additional charges of 'GF24 - Perjury' targeting the defendants statements of "I then drove out of DOC, and lost control of my vehicle, stalling the Buffalo STX I was driving on the bridge leading up to Purple Dinosaur." as well as the defendants statement of
          "This behavior from, according to deputies, a supervisor is just ridiculous. He showed absolutely zero professionalism or respect towards me or my passenger, and showed not a single sign of investigatory work. The investigation was not present, he decided to just place charges without investigating the entire situation, a big mistake for a supervisor to be making.".

          It's evident that the presence or absence of documentation/investigation records regarding the condition of the road and vehicles involved would shed light on the accuracy of the defendants statements being challenge for perjury.

      • State of San Andreas v. Harley Pavlovich
        Assigned Court Case Number: #22-CM-0065
        Requesting Party: The Defense
        Party Members: Harley Pavlovich (Defendant), Rockford Law (Firm),
        Discovery from: Los Santos County Sheriff's Department

        Type of Discovery: Document Request
        • Any professional health analyzes done to all related parties caused by this event.
        Detailed reasoning:
        • The defense believes that the presence, or absence, of health documentation regarding this scenario will convey the seriousness of the Sheriffs departments investigation into the matter as well as the seriousness of any assault claims. The defendant has made statements in their original incident report regarding a lack of investigation and the prosecution is pursuing these statements for perjury. If there is any health investigation regarding this case it would be relevant to this accusation.
        Sincerely,
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Colt Daniels »

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San Andreas Judicial Branch
Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

"EQUAL JUSTICE UNDER LAW"

  • Counselors,

    I apologize for the lapse in time this case had over the course of the holidays.

    At this time I will give the prosecution 72 hours to respond with agreements related to the two motions filed by Rockford Law before proceeding and ruling on the motions. Once completed this case will once again move forward.

    Respectfully,

    Chief Justice
    San Andreas Judicial Branch
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Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich

Post by Roderick Marchisio »

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San Andreas Judicial Branch

Re: #22-CM-0065, State of San Andreas v. Harley Pavlovich
"HERE FOR YOU | SAFE FOR YOU"

  • Honorable Daniels,

    With respect to the Motion to Suppress as filed by the Defense, the Prosecution notes that the statements as made by Private Attorney Law are factually untrue:
    Tidus Law wrote: Fri Dec 16, 2022 4:55 am
    The evidence submitted on behalf of the Los Santos County Sheriff's Department has been edited away from its original form making events appear slower. The Defense believes it's important to present untampered with evidence to the court for the most fair interpretation to the intentions of our client in this split second situation.
    Looking at the footage, it becomes abundantly clear to any reasonable thinking person that the footage up until 00:14 is unedited. (( Again, apart from the OOC blur that is due to staff chat being involved. )) The part after 00:14 contains a slow-motion of events to allow all parties to analyze the situation with ease. In this respect, the Prosecution points out that we are free in our manners of presenting evidence as long as this is conducted in a reasonable manner. Taking into account the fact that the whole incident is first included at full speed and only then is a slow-motion included. As such, the Motion to Suppress has no legal foundation whatsoever.

    Further, the Prosecution would like to point out to the Court that the Defense is claiming on the docket that we have tampered with evidence as per GF16 - Tampering with Evidence, which is an outrageous and baseless accusation with the sole intention of putting the Prosecution in a bad light and would like to ask the court to formally take note of this.

Respectfully,

Deputy Attorney General
Director of Public Notary
San Andreas Judicial Branch
(909) 372-7719 — [email protected]
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