#23-CM-0086, State of San Andreas v. Bongo Haze

[Summer Haze]

Defendant Name: Bongo Haze
Defendant Phone: 587-8283
Defendant Address: N/A
(( Defendant Discord: N/A))
Requested Attorney: N/A if none

Charging Department: LSPD

Date & Time of Incident(s): 22/JUN/2023 02:04
Charge(s):

• GM10 - Failure to Comply / Identify
• VF01 - Evading an Officer
• VM03 - Reckless Operation of a Road or Marine Vehicle

Narrative:
As a Government Appointed attorney by the State of San Andreas, I, Summer Haze, am filing this on behalf on my client Bongo Haze who was wrongfully charged.

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I, Summer Haze, 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. ))

[Judith Mason]

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. Bongo Haze

The court has hereby received and acknowledged the above case on the 1st day of July, 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.



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

[Shaun Harper]

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. Bongo Haze

A Notification of Counsel was filed in the above case on the 6 of July, 2023.

I, Shaun Harper, Deputy Chief Public Defender with the San Andreas Judicial Branch, will be representing the Defendant, Bongo Haze in the underlying case.

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


Deputy Chief Public Defender
San Andreas Judicial Branch
(909) 308-7889 — [email protected]

[Jacob Schmidtt]

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. Bongo Haze

A Notification of Counsel was filed in the above case on the 6 of July, 2023.

I, Jacob Schmidtt, Public Defender with the San Andreas Judicial Branch, will be representing the Defendant, Bongo Haze 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) 309-8976 — [email protected]

[Hugh Allgood]

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. Bongo Haze
#23-CM-0086

A Notice of Activation was entered in the above case on the 3rd of August, 2023.

The case of the State of San Andreas v. Bongo Haze is hereby activated by this Court under #23-CM-0086.

At this time the Defendant has adequate representation, however, a State Prosecutor has not been assigned to this case. At this time the court will delay the Order for Discovery until adequate representation has been assigned and they inform the court they are ready to proceed.


Superior Court Justice
San Andreas Judicial Branch
(909) 235-6076 — [email protected]

[Cyrus Raven]

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. Bongo Haze

A Notification of Counsel was filed in the above case on the 3rd of August, 2023.

I, Cyrus Raven, the Attorney General 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 Primary Counsel and will await further instruction from the Presiding Judge.


Cyrus Raven
Attorney General
San Andreas Judicial Branch
5356160 — [email protected]

[Shaun Harper]

San Andreas Judicial Branch Docket Update "EQUAL JUSTICE UNDER LAW"

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• Honorable Judge Hugh Allgood,
  
  I feel it's best to recuse myself from the case due to an overwhelming caseload and pressing professional commitments, in the interest of ensuring the client receives the best representation possible. This will allow the defendant to have a lawyer who can dedicate the necessary time and attention to their case.
  
  Attorney Jacob Schmidtt will become the primary attorney for this case as he has been the primary contact point for Mr. Haze
  
  Respectfully,
  
  
  Chief Public Defender
  Director of Training & Hiring
  San Andreas Judicial Branch
  (909) 308-7889 — [email protected]

[Jacob Schmidtt]

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. Bongo Haze

A Notification of Counsel was filed in the above case on the 6 of July, 2023.

I, Jacob Schmidtt, Public Defender with the San Andreas Judicial Branch, will be representing the Defendant, Bongo Haze in the underlying case.

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


Defense Attorney
San Andreas Judicial Branch
(909) 309-8976 — [email protected]

[Haylee Star]

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. Bongo Haze

A Notification of Counsel was filed in the above case on the 4 of August, 2023.

I, Haylee Star, a Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant, Bongo Haze in the underlying case.

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


Haylee Star
Junior Defense Attorney San Andreas Judicial Branch
(909) 390-1560— [email protected]

[Hugh Allgood]

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. Bongo Haze
#23-CM-0086

A court order was entered in the above case on 8th of July, 2023.

The case of #23-CM-0086, State of San Andreas v. Bongo Haze 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.


Superior Court Justice
San Andreas Judicial Branch
(909) 235-6076 — [email protected]

[Hugh Allgood]

San Andreas Judicial Branch #23-CM-0086, State of San Andreas v. Bongo Haze "HERE FOR YOU | SAFE FOR YOU"

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• Counselors
  
  In accordance with recently-enacted Superior Court procedures, this matter will be conducted via a docket trial and once the Notice of Trial has been issued, all arguments and evidence examination shall take place on the public docket. I recognize that I made an error in the process by not announcing such when this case was activated, and for that I do apologize as this is a new procedure for me.

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Respectfully,


Superior Court Justice
San Andreas Judicial Branch
(909) 235-6076 — [email protected]

[Kendall Groyce]

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. Bongo Haze

A Notification of Counsel was filed in the above case on the 9th of August, 2023.

I, Kendall Groyce, a 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) 489-9881 — [email protected]

[Kendall Groyce]

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. Bongo Haze
#23-CM-0086

A Motion for Discovery was filed in the above case on the 12th of August, 2023.

The State of San Andreas by and through the undersigned attorney, filed this Motion for Discovery, and presents the following as evidence;

• Exhibit #1: Arrest Report of Bongo Haze, Los Santos Police Department
  Spoiler

  

  

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

  
  

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  • SUSPECT DETAILS
    • Full Name: Bongo Haze
      Phone Number: 5878283
      Officers Involved:
      • Police Officer III+1 Luca Andollini
      Charges:
      • VM03 - Reckless Operation of a Road or Marine Vehicle
      • GM10 - Failure to Comply / Identify
      • VF01 - Evading an Officer
    INCIDENT NARRATIVE
    • Explain what happened, sufficient detail must be given to validate the justify the placed charges, videos could be provided.
      • The individual was pulled over on Boulevard Del Perro after being clocked speeding at 218 km/h.
        They were identified and asked to step out of the vehicle which they ignored, turned the engine off and drove off. The pursuit was called in but the suspect was lost.
      Method of Identification
      • LICENSE
    EVIDENCE DETAILS
    • Document the possessions confiscated from the arrested suspect.
      Illegal evidence must be documented individually, examples of documented illegal evidence are "Pistol .50" or "12 grams of Cocaine". Body camera footage/pictures may be attached as an evidence exhibit.
      
      Where possible the serial number of each firearm seized as evidence should be noted.
      • Illegal Evidence:
        
        
        Photograph of possessions in evidence locker (if applicable)

  

• Exhibit #2: Witness State of Luca Andollini, Los Santos Police Department
  Police Officer III+1 Luca Andollini Witness Statement

  

  

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

  Case Information

  • Incident Date: 22/JUN/2023

  Witness Information

  • Name: Luca Andollini
    Date of Birth: 06/JUN/1995
    Phone Number: 530 8359
    Occupation: Police Officer III+1, Los Santos Police Department

  Witness Statement

  • As I was patrolling the city, I was driving on South Boulevard Del Perro and was about to merge on Boulevard Del Perro from the west side of the Lifeinvader building. As per usual, my mini MDC with speed camera was up and running and suddenly, a purple jugular sped past me at said speed written in the warrant report. I immediately turned on my sirens and went after them when they stopped after the intersection with Dorset Drive.
    I called for additional unit for a misdemeanor arrest due to high speeds.
    I approached the driver and asked them to remove their mask and show me the license, which they did. I asked them to step out of the vehicle at least two times after which they turned on the engine of the vehicle and evaded.

  Witness Affirmation

  • I, Luca Andollini, 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,
    
    
    Luca Andollini
    Police Officer III+1
    Los Santos Police Department
    
    Date: 13/JUL/2023

  

Attorney General
San Andreas Judicial Branch
(909) 535-6160 — [email protected]

Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 489-9881 — [email protected]

[Hugh Allgood]

San Andreas Judicial Branch #23-CM-0086, State of San Andreas v. Bongo Haze "HERE FOR YOU | SAFE FOR YOU"

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• Counselors
  
  The defense will now be given 72 hours to respond to the discovery as presented by the prosecution, unless the court is advised otherwise. A response is due before the 15th of August at 9:00PM ((UTC)).

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Respectfully,


Superior Court Justice
San Andreas Judicial Branch
(909) 235-6076 — [email protected]

[Jacob Schmidtt]

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

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MOTION TO COMPEL DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Bongo Haze
#23-CM-0086

A Motion to Compel Discovery was filed in the above case on the 15 of August, 2023.

The State of San Andreas/Defendant, name, by and through the undersigned attorney, filed this Motion to Compel Discovery, and requests as follows;

• Requested Discovery: Bodycam footage, LSPD
  • Detailed Reasoning: We, the defense, are requesting any available bodycam footage from the aforementioned events.

• Requested Discovery: Arrest report, LSPD
  • Detailed Reasoning: We are requesting the arrest report from when the defendant was arrested and charged. Exhibit #1 appears to be a warrant report and not an arrest report.

• Requested Discovery: CCTV, LSPD
  • Detailed Reasoning: We are requesting any CCTV footage that would have captured the events in question.

Defense Attorney
San Andreas Judicial Branch
(909) 309-8976 — [email protected]

[Kendall Groyce]

San Andreas Judicial Branch
Docket Notice
"EQUAL JUSTICE UNDER LAW"

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• Honorable Judge Allgood and pertaining parties,
  
  The prosecution will be unable to comply with the motion to compel discovery, unless ordered to do so by Judge Allgood, for the following reason.
  
  Requested Discovery:Arrest report, LSPD
  

  Detailed Reasoning: The provided Warrant Report, is the commencing report documented in this case by the Los Santos Police Department, which led to the defendants arrest. This report contains all such charges that the defendant is contesting, with narrative of the incident, and as such this report serves as sufficient in this case.
  At this time, all gathered evidence has been provided to the court.
  
  
  Respectfully,
  
  
  Junior Prosecuting Attorney
  San Andreas Judicial Branch
  (909) 489-9881 — [email protected]

[Jacob Schmidtt]

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

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Bongo Haze
#23-CM-0086


Honorable Judge Allgood and all other pertaining parties,

I would like to clarify the prosecution's statement. The prosecution's position is that there is no arrest report, Bodycamera footage or CCTV footage for this case?

We compelled the Arrest Report as evidence was presented as an arrest report when it was, in fact, a warrant report.









Defense Attorney
San Andreas Judicial Branch
(909) 309-8976 — [email protected]

[Hugh Allgood]

San Andreas Judicial Branch 23-CM-0086 "HERE FOR YOU | SAFE FOR YOU"

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• Counselors,
  
  Clarification from the State on whether body camera or CCTV exists?? The response from the State only mentioned the lack of an arrest report as the warrant report is what gave rise to the defendant's arrest. The Court is not inclined to order the prosecution to turn over evidence they either don't have, or evidence which may no longer be retained.

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Respectfully,


Superior Court Justice
San Andreas Judicial Branch
(909) 235-6076 — [email protected]

[Kendall Groyce]

San Andreas Judicial Branch
23-CM-0086
"EQUAL JUSTICE UNDER LAW"

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• Honorable Judge Allgood and pertaining parties,
  
  Body camera footage has not been retained from this incidence and there is no CCTV footage that captured this encounter.
  The warrant report entails all of the details of the defendants arrest, which should suffice the requirements of the court in place of the arrest report.
  
  Respectfully,
  
  
  Junior Prosecuting Attorney
  San Andreas Judicial Branch
  (909) 489-9881 — [email protected]

[Jacob Schmidtt]

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. Bongo Hazd
#023CM-0086

A Motion for Continuance was filed in the above case on the 17 of Aug, 2023.

The Defendant, Bongo Haze by and through the undersigned attorney, filed this Motion for Continuance, and the reasoning for request is as follows;

• Reasoning: Gathering statements
  • Detailed Explanation: We are requesting a short continuance of two days in order to gather and compile statements.

Defense Attorney
San Andreas Judicial Branch
(909) 309-8976 — [email protected]

[Hugh Allgood]

San Andreas Judicial Branch #23-CM-0086, State of San Andreas v. Bongo Haze "HERE FOR YOU | SAFE FOR YOU"

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• Counselors
  
  In light of the lack of evidence as requested from the defense, the Court cannot in good faith order the production of such evidence that does not exist. As a result, the Court also believes the defense request for continuance to be in good faith and will grant the request. The defense will be given up to 72-hours to respond with any further motions (due by 20/AUG/2023 at 03:00AM) before the docket trial commences.

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Respectfully,


Superior Court Justice
San Andreas Judicial Branch
(909) 235-6076 — [email protected]

[Jacob Schmidtt]

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

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MOTION TO COMPEL DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Bongo Haze
#23-CM-0086

A Motion to Compel Discovery was filed in the above case on the 18 of August, 2023.

The State of San Andreas/Defendant, name, by and through the undersigned attorney, filed this Motion to Compel Discovery, and requests as follows;

• Requested Discovery: Personnel File, Luca Andolini, LSPD
  • Detailed Reasoning: The core of the prosecution's case relies solely on the testimony of Officer Andolini, and it is imperative that we have the opportunity to examine any relevant information that could impact the credibility of this crucial witness.
    
    In a case where the only evidence presented is the officer's word; the officer's background, training, and conduct become essential factors in evaluating the reliability and trustworthiness of their testimony. The personnel file could potentially shed light on any prior disciplinary actions, complaints, or patterns of behavior that may be relevant to the officer's testimony or their overall credibility.
    
    We firmly believe that access to Officer Andolini's personnel file is not only relevant but also necessary to ensure a balanced and just legal proceeding.
    
    Furthermore, this request aligns with the principles of due process and the defendant's right to a fair trial. Denying access to information that could impact the reliability of the prosecution's key witness would be a disservice to justice. Our goal is to ensure that all relevant evidence is considered, and that the defendant's right to a robust defense is upheld.

• Requested Discovery: Names of officers who responded to the backup call, LSPD
  • Detailed Reasoning: As presented in Mr Andolini's testimony, he requested backup from other officers. We the defense are requesting the names of the officers who responded to that call, so that we may question them on the events of that day.
    
    
    
    
    Defense Attorney
    San Andreas Judicial Branch
    (909) 309-8976 — [email protected]

[Cyrus Raven]

San Andreas Judicial Branch Re: #23-CM-0086, State of San Andreas v. Bongo Haze "HERE FOR YOU | SAFE FOR YOU"

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• Honorable Hugh Allgood,
  
  
  Former Officer Andollini's file is not relevant to the criminal charges the Defendant was arrested for. Equally, the Defense has failed to provide a reasonable justification for suspecting Officer Andollini's credibility to warrant the disclosure of his personnel file. We would be open to this request if there was any foundation for it. For lack of better terms, this is a fishing expedition.
  
  Regarding the name of the officer who responded to the backup call, Luca Andollini is no longer employed by the Los Santos Police Department as such concluding this request would prove a difficult task potentially requiring several continuances.
  
  Lastly, the Courts have consistently held that Officer Statements alone are sufficient evidence to uphold an arrest. An example is Superior Court Case #22-CM-0034 State of San Andreas v. Mike Bartowski where a motion to dismiss was submitted arguing a lack of evidence, specifically that the only discovery provided was one witness statement and one arrest report by the same Deputy. This motion was later denied in a in-person hearing given the detail in both the arrest report and statement. Officer Andollini's statement is clear and direct with no ambiguous language in it, going into detail about the circumstances that led to the Defendant's arrest and focusing on the facts that directly justify the Defendant's charges.
  
  It is with the above considerations that we request the court deny the motion for discovery.
  
  
  Respectfully,
  
  Cyrus Raven
  Attorney General
  San Andreas Judicial Branch
  5356160 — [email protected]

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  DISCLAIMER: This message, including attachments, is confidential and may contain information protected by the attorney-client privilege or work product doctrine. If you are not the addressee, any disclosure, copying, distribution, or use of the contents of this message is prohibited.

[Jacob Schmidtt]

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

Honorable Hugh Allgood and all other parties,

Your Honor,

Respectfully addressing the prosecution's response, accessing Officer Andollini's personnel file is a crucial step in upholding the principles of fairness and justice within this court case.

The prosecution asserts that the personnel file is not relevant to the current criminal charges. However, the defendant's right to a fair trial encompasses the exploration of all aspects that could potentially impact the credibility and reliability of the prosecution's key, and only, witness.

It is not a matter of a "fishing expedition." Rather, it is about ensuring that the trial is conducted with a comprehensive understanding of the witness's background, which directly influences the weight placed upon his testimony. The file's content will unveil pertinent information that might otherwise remain obscured, and thus, its relevance is undeniable.

Furthermore, the prosecution contends that there is no reasonable justification for suspecting Officer Andollini's credibility. However, it is not a matter of suspicion, but rather the obligation of the defense to comprehensively scrutinize and assess the prosecution's evidence. In a case where the defendant's fate hinges solely on the officer's account, it is a responsibility to exercise due diligence in exploring all avenues that could contribute to the defendant's defense.

As for Officer Andollini's departure from the Los Santos Police Department, the prosecution suggests that providing the names of the backup officers would be a difficult request. Yet, the necessity of obtaining this information far outweighs any procedural complexities. The pursuit of justice and the defendant's right to a fair trial should not be impeded by administrative challenges.

Lastly, the reference to a previous case's outcome has no bearing upon our request. The Defense is not seeking to dismiss the case based on a lack of evidence, we are seeking more evidence.

Respectfully,



Defense Attorney
San Andreas Judicial Branch
(909) 309-8976 — [email protected]

[Hugh Allgood]

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. Bongo Haze
#23-CM-0086

A decision was reached in the above case on the 28th day of August, 2023.

The motion to compel the discovery of former Officer Andollini's personnel file is denied. The reason for the denial are as follows;

1- The defense has failed to provide a compelling and substantial reason why Officer Andollini's file needs to be reviewed. While the Court does appreciate and agree with the defendant's right to a fair trial, this right does not come at the expense of another person's rights; in this instance, Officer Andollini. Officer Andollini does not deserve to have their personnel record submitted into the public domain without a more substantial reason as to why the contents of such record are relevant towards a defendant's defense.

2- Allowing this request would set a bad precedence wherein the personnel files of law enforcement officers would be de facto discoverable, and every defendant and their defense would be entitled to a review of this file.

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The Court believes there are other more appropriate ways to discover any potential evidence about a Officer's background that does not require a personnel file to be submitted into evidence in a criminal case. The Court also points to the fact the defendant's "fate" does not depend solely on the officer's account -- this is just one piece of the puzzle, but the Court will welcome any arguments or counter-evidence from both sides to reach a conclusion this Court feels just. The defendant's "fate" depends on the ability of the prosecution to prove the allegations against the defendant beyond a reasonable doubt.

The Court will however request the prosecution to contact the Los Santos Police Department and make a good faith effort to inquire if there are further records about the names of the backup officers who responded to Officer Andollini's request, and if so, provide this information to the defense. However, consistent with this Presiding Judge's previous ruling, the Court will not order the prosecution to produce evidence from a law enforcement entity that does not exist.



Superior Court Justice
San Andreas Judicial Branch
(909) 235-6076 — [email protected]