#23-CM-0049, State of San Andreas v. Harley Pavlovich

[Harley Pavlovich]

Defendant Name: Harley Pavlovich
Defendant Phone: 4714790
Defendant Address: N/A
(( Defendant Discord: Harley#0600 ))
Requested Attorney: Cyrus Raven

Charging Department: LSPD

Date & Time of Incident(s): 21/FEB/2023 22:30
Charge(s):

• Possession of an Illegal Firearm

Narrative:
I believe I was unlawfully arrested and wish to appeal my charges.

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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. ))

[Roderick Marchisio]

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

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• 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.

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Respectfully,


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

[Robert Winejudge]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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NOTICE OF RECEIPT

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich

The court has hereby received and acknowledged the above case on the 22nd of February, 2023.

The Superior Court of San Andreas has received your filing and the case is now pending activation. Be advised that the court system runs on a first-come, first-served basis and will only activate cases out of order for special circumstances.

During this time, the defendant is encouraged to reach out to a licensed defense attorney in order to prepare a proper defense, otherwise, a court-appointed attorney will be assigned to the case upon its activation.

The defendant is further encouraged to speak with an authorized individual at Rockford Hills City Hall, Mission Row Police Station, or Paleto Bay Sheriff's Office for official clarification on the specific charges received and their respective date and times, as once the case has been activated, any omitted charges will be considered abandoned and unable to be disputed within this case.



Court Clerk
San Andreas Judicial Branch
(909) 372-4223 — [email protected]

[Ruwin Korbel]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich

A Notification of Counsel was filed in the above case on the 23rd of March 2023

I, Ruwin Korbel, a Public Defense Attorney with the San Andreas Judicial Branch, will be representing Harley Pavlovich in the underlying case.

I will be taking the responsibility of Primary Counsel and will await further instruction from the Presiding Judge.



Defence Attourney
San Andreas Judicial Branch
(909) 556-2848 — [email protected]

[Hope Kant]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich

A Notification of Counsel was filed in the above case on 13/APR/2023.

I, Hope Kant, a Junior Prosecuting Attorney with the San Andreas Judicial Branch, will be representing the State of San Andreas in the underlying case.

I will be taking the responsibility of Co-Counsel and will await further instruction from the Presiding Judge.



Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 321-2132 — [email protected][/list]

[Lisa Winter]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich

A Notification of Counsel was filed in the above case on 18th/April/2023

I, Lisa Winter, a Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant, Harley Pavlovich in the underlying case.

I will be taking the responsibility of Co-Counsel and will await further instruction from the Presiding Judge.



Junior Defense Attorney
San Andreas Judicial Branch
(909) 233-5420 — [email protected]

[Jane Cook]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Defendant

A Notification of Counsel was filed in the above case on the 19th of April.

I, Jane Cook, a Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant(s), Harley Pavlovich in the underlying case.

I will be taking the responsibility of the Co-Counsel and will await further instruction from the Presiding Judge.



Junior Defense Attorney
San Andreas Judicial Branch
(909) 235-7365 — [email protected]

[Judith Mason]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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NOTICE OF ACTIVATION

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#23-CM-0049

A Notice of Activation was entered in the above case on the 20th day of April, 2023.

The case of the State of San Andreas v. Harley Pavlovich is hereby activated by this Court under #23-CM-0049.

Both the State and Defendant have adequate representation in the case, as such, immediately following this notice, the Presiding Judge will be filing the Order for Discovery.



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

[Judith Mason]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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ORDER FOR DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#23-CM-0049

A court order was entered in the above case on the 20th day of April, 2023.

The case of #23-CM-0049, State of San Andreas v. Harley Pavlovich 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]

[Hope Kant]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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MOTION FOR CONTINUANCE

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#23-CM-0049

A Motion for Continuance was filed in the above case on the 26 of April, 2023.

The State of San Andreas by and through the undersigned attorney, filed this Motion for Continuance, and the reasoning for request is as follows;

• Reasoning: Exploring New Evidence Surrounding the Arrest
  • Detailed Explanation: The prosecution is requesting more time in order to properly investigate new evidence that has appeared surrounding the events on the 21st of February, 2023. The prosecution would appreciate the courts patience as we request 7 days in order to fully explore the evidence and gather all information to form the best possible path forward. The evidence must be reviewed for classified information and possibly redacted due to security purposes. Thank you.

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Notary Public
Prosecuting Attorney
San Andreas Judicial Branch
(909) 321-2132 — [email protected]

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

[Ruwin Korbel]

San Andreas Judicial Branch
State of San Andreas Vs Harley Pavlovich
"EQUAL JUSTICE UNDER LAW"

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• Your Honour,
  
  With regards to the prosecutions motion for continuance the defence would like to note the following:
  
  -This case was acknowledged and represented by the prosecution on the 21st of February, over 2 months ago. as such the theory that new evidence could come to light is highly improbable.
  -Discovery phase has been open for 6 days. during this time the prosecution has not submitted any evidence for the defence to examine.
  -Despite the impressive legal vernacular on the motion, the Prosecution hasn't actually provided a specific compelling argument for continuance.
  
  With these facts in mind, the Defence believes that the grounds for a continuance have not been fulfilled. as a minimum, we would request the prosecution provides further details into the evidence they are hoping to uncover to both validate the motion and so that the defence can prepare accordingly. failure to do so would be a clear violation of the defendants right to a fair and speedy trial.
  
  Respectfully,
  
  
  
  Ruwin "Quiet" Korbel
  Public Defence Attourney
  San Andreas Judicial Branch
  (909) 556-2848 — [email protected]

[Judith Mason]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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• Parties,
  
  Would the prosecution like to submit any further arguments or context as to why the Motion for Continuance should be granted?
  
  Respectfully,
  
  
  Associate Justice
  San Andreas Judicial Branch
  (909) 257-9183 — [email protected]

[Hope Kant]

San Andreas Judicial Branch
State of San Andreas Vs Harley Pavlovich
"EQUAL JUSTICE UNDER LAW"

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• Dear All,
  
  While the prosecution appreciates the defenses stance on the matter, they are very aware that even as of early this morning we are still receiving witness statements surrounding the event. They have been made aware of this same evidence. Each and every piece of information that crosses the prosecutions desk is meticulously review and combed for evidence as well as reviewed for importance.
  
  This includes sensitive information from both PD and SD that require not only the cooperation of the prosecution, but other departments with many people needing to sign off on the information prior to it being shown to the public. The safety and security of LEO protocol and information must be kept, as possible redactions are being looked into. It is not the goal of the prosecution to circumvent police protocol for the means of furthering a case.
  
  We once again ask the courts for their understanding in the matter.
  
  Respectfully,
  
  
  Prosecuting Attorney
  Notary Public
  San Andreas Judicial Branch
  (909) 321-2132 — [email protected]

[Ruwin Korbel]

San Andreas Judicial Branch
State of San Andreas Vs Harley Pavlovich
"EQUAL JUSTICE UNDER LAW"

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• Your Honour,
  
  In the prosecutions response, the defence would contest that:
  
  since our previous response to the motion (not earlier) the prosecution has disclosed a single witness statement, pertaining to this case. in this statement, all facts and evidence for the case are made clear. in the defences view is there is no additional evidence provided that would result in a continuance being necessary. therefore we maintain that the initial discovery period was valid and ample for the case and thus, the prosecution should submit all evidence for the case within the legal pre-agreed timelines. The defendants right to a fair and speedy trial without abuse of continuance to further draw out proceedings outside of the constitutional limits of the court is a cornerstone of the judicial branches legal remit.
  
  Respectfully,
  
  
  
  Ruwin "Quiet" Korbel
  Public Defence Attourney
  San Andreas Judicial Branch
  (909) 556-2848 — [email protected]

[Hope Kant]

San Andreas Judicial Branch
State of San Andreas Vs Harley Pavlovich
"EQUAL JUSTICE UNDER LAW"

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• Your Honour,
  
  The prosecution would like to remind the courts of the previous rulings and allowances given. Citing #22-CM-0069, State of San Andreas v. Zeak Cruz and #23-CM-0011, State of San Andreas v. Jimbo Kimbo where the State has been given extra time to get in contact with the respective departments due to a lack of response. The prosecution is awaiting responses to investigative questions/receiving witness statements that require time to thoroughly explore. The prosecution does not want to waste the defenses or the courts time with presenting more exhibits than needed, if we do not have the appropriate evidence to back up it's relevance.
  
  It is important for both order and presentation to the court for the prosecution to have all it's exhibits accounted for prior to presenting them on the docket. To that end, the prosecution has not presented the evidence it currently has, as we are still awaiting answers to questions posed.
  
  Respectfully,
  
  
  Prosecuting Attorney
  Notary Public
  San Andreas Judicial Branch
  (909) 321-2132 — [email protected]

[Judith Mason]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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COURT DECISION

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#23-CM-0049

A decision was reached in the above case on the 27th day of April, 2023.

The court is granting the Motion for Continuance, allowing an extension on the Order for Discovery until approximately 7am on the 4th of May. With that being said, while this continuance does allow for submissions in relation to discovery to be made within the next week, the court would ask that the prosecution present evidence which does not contain classified material or require further exploration, such as the arrest report and accompanying witness statement presumably, so that all parties including the court may immediately begin reviewing the preliminary information contained therein.



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

[Ruwin Korbel]

San Andreas Judicial Branch
State of San Andreas Vs Harley Pavlovich
"EQUAL JUSTICE UNDER LAW"

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• To whom it may concern,
  
  The defence awaits the submission of all non time sensitive discovery submissions by the initial allotted time period as decided by the court on this date and time, 27th of April 2023 at 7:53AM
  
  Respectfully,
  
  
  
  Ruwin "Quiet" Korbel
  Public Defence Attourney
  San Andreas Judicial Branch
  (909) 556-2848 — [email protected]

((time compensated to match server time.))

[Hope Kant]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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MOTION FOR DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#23-CM-0049

A Motion for Discovery was filed in the above case on the 27th of April, 2023.

The State of San Andreas by and through the undersigned attorney, filed this Motion for Discovery, and presents the following as evidence; The prosecution would like to note that we have managed to make it within the initial window for discovery, meaning we no longer need the previously approved Motion for Continuance.

• Exhibit #1: Harley Pavlovich Arrest Report - 21/FEB/23

  

  Los Santos Police Department ARREST REPORT "TO PROTECT AND TO SERVE"

  
  

  ---

  MUGSHOT

  • SUSPECT DETAILS
    • 
      Full Name: Harley Pavlovich
      Phone Number: 4714790
      Licenses Suspended: No
      Officers Involved:
      • Police Officer III Tyrell Lee
      • Police Lieutenant II Gareth Longford
      Charges:
      • WF03 - Possession of Illegal Firearms/Weapons
    INCIDENT NARRATIVE
    • Explain what happened, sufficient detail must be given to justify the placed charges, videos could be provided.
      • Ms. Pavlovich's XA-21 w/ LP: NOTCRIM was seen in a police pursuit, interfering by ramming police cruisers multiple times with a couple of attempts to pick up 10-15s that were being arrested. The XA-21 had a BOLO for it and I spotted it at Legion Parking where Ms. Pavlochich parked it prior to me coming up to her and detaining her. I looked through the parking lot and found her car, where I unlocked it with her keys and spotted an illegal firearm in the trunk.

  
  Exhibit #2: Firearm and Ammo

  
  Exhibit #3: Gareth Longford - Bodycam Footage

  BODYCAM FOOTAGE
  ((EVIDENCE OF RP))
  Exhibit #4: Still of Gareth Longford Bodycam Footage

  • ((
    
    
    
    
    
    ))
  Exhibit #5: Police Lieutenant Gareth Longford's Statement

  

  

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

  Case Information

  • Incident Date: 21/02/2023

  Witness Information

  • Name: Gareth Longford
    Date of Birth: 09/10/1995
    Phone Number: 4784979
    Occupation: Police Lieutenant II

  Witness Statement

  • AIR-1 called out vehicles speeding up and down the Los Santos storm drain. I went to the area to investigate and found three vehicles driving at extremely high speeds. I returned to mission row and deployed a high-speed and then went back to the storm drain. I found the vehicles speeding again and pulled one of them over. They stopped but eventually took off and began evading from us. Ms. Pavlovich's XA21 was interfering in the pursuit, attempting to push the highspeed out of the way to assist the original suspect in evading. A Police Scout successfully PITed the XA21 out of the pursuit line and we did not see it again from then on. The pursuit came to an end. A few minutes later, Officer Tyrell Lee called out that he witnessed the XA21 being parked in the City Parking lot and detained the individual who was inside it which turned out to be Ms. Pavlovich. Given the fact that the vehicle was used in a crime, we had it taken back out of the parking lot and searched it to investigate the interference in the pursuit. Upon the search, a Pistol .50 was found and Ms. Pavlovich was subsequently charged for the possession of it. The vehicle was then impounded.

  Witness Affirmation

  • I, Gareth Longford, 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,
    
    Gareth Longford
    Police Lieutenant II
    Los Santos Police Department
    
    Date: 25/02/2023
  Exhibit #6: Police Officer Tyrell Lee's Statement

  

  

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

  Case Information

  • Incident Date: 21/FEB/2023

  Witness Information

  • Name: Tyrell Lee
    Date of Birth: 11/SEP/1991
    Phone Number: 320-7369
    Occupation: Police Officer

  Witness Statement

  • The gang Los Santos Drift (LSD) were driving around the city with multiple high-end vehicle, including an XA-21 with the LP: NOTCRIM that was registered to Harley Pavlovich. There was a BOLO made on this vehicle for its participation in racing and evading officers. The car was found at Legion Square parking before it was placed in the parking lot, which is when I detained Ms. Pavlovich and after searching her vehicle, there was an illegal Pistol .50 w/ 40x bullets in the trunk of the car. I placed an illegal firearm charge on her since she owned the vehicle and was driving it before putting it away.

  Witness Affirmation

  • I, Tyrell Lee, 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,
    
    
    Tyrell Lee
    Police Officer III
    Los Santos Police Department
    
    Date: 23/FEB/2023

  
  Exhibit #7: Impound report - 21/FEB/23

  
  Exhibit #8: 9/11 call logs - 21/FEB/23

  (())
  Exhibit #9: Verdict #22-CM-0065, State of San Andreas v. Harley Pavlovich

  

  

  
  
  San Andreas Judicial Branch
  Superior Court of San Andreas
  "EQUAL JUSTICE UNDER LAW"

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  ISSUANCE OF VERDICT

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  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 22nd day of January, 2023.

  
  
  A verdict was reached following a trial that look place on the above listed day. The court believes that Ms. Pavlovich used her vehicle on the day in question in an attempt to assist the evading suspect from escaping the police. This is supported by the defendant waiting until the fleeing suspect passed to fully accelerate blocking off the police officers giving chase as shown in the prosecutions Exhibit #2.
  
  The court also believes that due to Ms. Pavlovich blocking off the officers giving chase she threated bodily harm as they were driving at extremely high rates of speed throughout the course of the chase. Due to this the charge of Assault with a Deadly Weapon of a Gov. Employee applied correctly in this case.
  
  Lastly, the defendant put in her statement when filing the case that she didn't know the fleeing suspect and has no connection to him. However this was discovered to be incorrect by the evidence submitted under seal. This evidence showed that Ms. Pavlovich was intentionally trying the deceive the court by knowingly providing these false statement.
  
  It is with the above considerations that I issue the following verdict:

  • On the count of VF01 - Accessory to Evading an Officer, I find the defendant, Harley Pavlovich, guilty.
  • On the count of WF01 - Assault with a Deadly Weapon of a Gov. Employee, I find the defendant, Harley Pavlovich, guilty.
  • On the count of GF24 - Perjury, I find the defendant, Harley Pavlovich, guilty.

  
  
  
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 402-9713 — [email protected]

  

  Exhibit #10: Darryl Morningstar Arrest Report September 10th, 2022

  
  Exhibit #11: Darryl Morningstar MDC Printout September 10th, 2022

  
  ((RP Proof
  
  ))
  Exhibit #12: Harley Pavlovich Arrest Report September 10th, 2022

  
  Exhibit #13: Harley Pavlovich MDC Printout September 10th, 2022

  
  ((RP Proof
  ))
  Exhibit #14: Detective Sayaka Yukimura Witness Statement

  

  

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

  Case Information

  • Case Number: #23-CM-0049
    Incident Date: 21/FEB/2023

  Witness Information

  • Name: Sayaka Yukimura
    Date of Birth: 22/DEC/1990
    Phone Number: On File
    Occupation: Detective I, Gangs and Narcotics Division, Los Santos Police Department

  Witness Statement

  • Harley Pavlovich has been a known affiliate of the criminal organization known as "Rooks" since 2019. Darryl Morningstar has been a known affiliate of the criminal organization known as "Rooks" since 2021. Neither person has had any other known affiliations, and still maintain their relationships with the "Rooks" organization to this day. These statements can be backed up with years of paperwork filed by the Gangs and Narcotics Division of the Los Santos Police Department.

  Witness Affirmation

  • I, Sayaka Yukimura, 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,
    
    
    Sayaka Yukimura,
    Detective I, Gangs and Narcotics Division
    Los Santos Police Department
    
    Date: 27/APR/2023

  
  

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Notary Public
Prosecuting Attorney
San Andreas Judicial Branch
(909) 321-2132 — [email protected]

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

[Hope Kant]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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MOTION TO AMEND

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#23-CM-0049

A Motion to Amend was filed in the above case on the 27/APR/2023.

The State of San Andreas by and through the undersigned attorney, filed this Motion to Amend, the original charges with the underlined amended charges.

• Original Charges
  • WF03 - Possession of Illegal Firearms/Weapons

• Amended Charges
  • WF03 - Possession of Illegal Firearms/Weapons
  • Primarily VF04 - Felony Public Endangerment, Subsidiarily Accessory to VF04 - Felony Public Endangerment
  • Primarily WF01 - Assault with a Deadly Weapon, Subsidiarily Accessory to WF01 - Assault with a Deadly Weapon
  • Accessory to VF01 - Felony Evading

• Detailed Explanation:
  
  To explain fully why the prosecution wishes to place each charge we will go in order, one by one.
  
  Primarily VF04 - Felony Public Endangerment, Subsidiarily Accessory to VF04 - Felony Public Endangerment and
  • The defendant at many times in the bodycam footage provided can be seen moving in and out of lanes, running over sidewalks and into lampposts, entering into the incorrect lane of travel for lengthy periods at a time, amongst other infractions, leaving the prosecution no other option than to pursue VF04.
  
  Primarily WF01 - Assault with a Deadly Weapon, Subsidiarily Accessory to WF01 - Assault with a Deadly Weapon
  • The prosecution believes, based on the evidence provided, that the defendant did knowingly use her vehicle to to ram and/or otherwise impede Law Enforcement officers from conducting their duties in a manor that was harmful to the public as well as the officers in pursuit qualifying for WF01. There was clear intent in her actions to harm officers, hoping to removed them from the pursuit line in order to free her associate.
  
  Accessory to VF01 - Felony Evading
  • Although the defendant was not the one evading on the 21st of February, she did knowingly engage in aiding Darryl Morningstar in VF-01. As he drove his vehicle, attempting to evade police, the XA-21 was see bumping, ramming, and braking in front of Law Enforcement Officers with the goal of hindering their pursuit. In these actions, the prosecution believes the defendant has committed Accessory to VF-01

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Notary Public
Prosecuting Attorney
San Andreas Judicial Branch
(909) 321-2132 — [email protected]

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

[Judith Mason]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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COURT DECISION

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#23-CM-0049

A decision was reached in the above case on the 27th day of April, 2023.

With the full Motion for Discovery now having been posted by the prosecution in addition to their written withdrawal of the Motion for Continuance, the court shall be vacating the previous decision granting the Motion for Continuance and this case shall move forward with the original timeline. With that said, given the number of exhibits and additional charges, the court is open to a Motion for Continuance by the defense in order to examine the evidence beyond the traditional 72 hour window to file motions in response, should it be deemed necessary.

The court now awaits any motions to be filed by the defense in response to the presented Motion for Discovery and Motion to Amend.



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

[Ruwin Korbel]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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MOTION FOR CONTINUANCE

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavolvich
#00-CM-0000

A Motion for Continuance was filed in the above case on the 28th April, 2023

The Defendant, Harley Pavolvich by and through the undersigned attorney, Ruwin Korbel, filed this Motion for Continuance, and the reasoning for request is as follows;

• Reasoning: expansion on the evidence submitted by the prosecution
  • Detailed Explanation: given the extensive submissions allotted to the defence by the prosecution on the 11th hour the defence requests a minimum of 7 days (168 hrs) from the date of this request to properly disseminate the evidence submitted by the prosecution to appeal any suppressions and prepare for trial.
    
    
    
    
    
    Ruwin "Quiet" Korbel
    Public Defence Attourney
    San Andreas Judicial Branch
    (909) 556-2848 — [email protected]

[Hope Kant]

San Andreas Judicial Branch
Personal Email
"EQUAL JUSTICE UNDER LAW"

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• Your Honour,
  
  While the prosecution appreciates the defenses stance on the matter, a minimum 7 day extension request is a bit much.
  
  As stated by Defense Attorney Korbel, when the prosecution made their initial motion for continuance, "the initial discovery period was valid and ample for the case and thus, the prosecution should submit all evidence for the case within the legal pre-agreed timelines. The defendants right to a fair and speedy trial without abuse of continuance to further draw out proceedings outside of the constitutional limits of the court is a cornerstone of the judicial branches legal remit."
  
  The prosecution was awaiting a response from the arresting department, once obtained the discovery was posted immediately. It was never the intention of the prosecution to drag proceedings on longer than was necessary. While our 7 day continuance was granted, but ultimately unnecessary, the court placed certain stipulations around the discovery.
  
  To note: The prosecution has complied with the requests of both the courts and the defense and presented their discovery on-time.
  
  Despite the fact that we understand the discovery has not been made available to the defense until now, the prosecution would hope that they were conducting their own investigation into the charges and talking to their client to get a sense for what their strategy would be. That being said, the prosecution would not argue with a continuance of another 168 (double the initial given time of the courts) hours from the posting of the Court Decision by Justice Judith Mason. However, we would caution the court against any further allowances as for the precedence it would set.
  
  Respectfully,
  
  
  Prosecuting Attorney
  Notary Public
  San Andreas Judicial Branch
  (909) 321-2132 — [email protected]

[Ruwin Korbel]

San Andreas Judicial Branch
Personal Email
"EQUAL JUSTICE UNDER LAW"

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• Your Honour,
  
  Under normal circumstances, i would tend to agree with the prosecution however i would note two things:
  
  - 1. whilst the prosecution did technically submit all evidence within agreed timeframes this was only after much discussion on the docket and the prosecution took full advantage of their 7 day window. we are only asking for that same understanding.
  
  -2. as the prosecution has submitted 14 exhibits to the defence in the final hours of discovery period with no prior disclosure and an additional 5 charges onto a one charge case, the core dynamics of this appeal have changed durastically. you could almost say 1 case has suddenly multiplied into 6.
  
  Neither of these changes of circumstance were within the defences control. The defence requires this time to marshall its resources, disseminate evidence and decide on case strategy.
  
  Respectfully,
  
  
  
  Ruwin "Quiet" Korbel
  Public Defence Attourney
  San Andreas Judicial Branch
  (909) 556-2848 — [email protected]

[Hope Kant]

San Andreas Judicial Branch
Personal Email
"EQUAL JUSTICE UNDER LAW"

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• Your honour,
  
  The prosecution would like to correct several inconsistencies in the defenses statements.
  
  1. The prosecution is looking to amend three charges, not five.
  2. The prosecution filed a motion for continuance. To suggest that the prosecution is at fault for arguing towards their own proposed motion would be an attempt to circumvent the fairness of the judicial system. The prosecution has every right to defend its position as much or as little as needed.
  3. The prosecution is not required, nor is it written anywhere, to submit their discovery as it becomes available. Instead the prosecution opted to release all the discovery at once, allowing for better order should the case go to trial.
  While the changes are out of the defenses control, the purpose of Attorney-Client confidentiality and it's existence is to prepare the defense for when the prosecution releases it's discovery and trial. That being said, the extent of the defendants crimes on the day in question should not come as a shock. As previously stated, the prosecution would hope during the discovery phase and period after the appeal was submitted, that the defense is conducting their own investigation into the charges and talking to their client to get a sense for what their strategy would be.
  
  To reiterate: the prosecution would not argue with a continuance for a total of 168 (double the initial given time of the courts, as was granted with stipulations to the prosecution, but ultimately not needed) hours from the posting of the Court Decision by Justice Judith Mason.
  
  Respectfully,
  
  
  Prosecuting Attorney
  Notary Public
  San Andreas Judicial Branch
  (909) 321-2132 — [email protected]

[Judith Mason]

San Andreas Judicial Branch
Superior Court of San Andreas
"EQUAL JUSTICE UNDER LAW"

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COURT DECISION

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Harley Pavlovich
#23-CM-0049

A decision was reached in the above case on the 29th day of April, 2023.

The court finds it reasonable to reinstate the previous timeline in the Motion for Continuance as defined by the first Court Decision on the 27th of April. As such, the Motion for Continuance filed by the defense is granted and the deadline for motions in response to the presented discovery shall be 6:53am on the 4th of May.



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