#23-CM-0111, State of San Andreas v. Kevin Reyes

[Jacob Schmidtt]

Defendant Name: Kevin Reyes
Defendant Phone: 4068375
Defendant Address: u/k
(( Defendant Discord: HERE ))
Requested Attorney: Jacob Schmidtt

Charging Department: Los Santos Police Department

Date & Time of Incident(s): 22/AUG/2023 9:12 pm
Charge(s):

• SF07 - Bank Robbery
  WM02 - Possession of a Class 1 Firearm

Narrative:
As a government appointed attourney by the State of San Andreas, I, Jacob Schmidtt, am filing this on behalf on my client Kevin Reyes who states he had his constitutional rights violated during this arrest.

---

I, Jacob Schmidtt, 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"

---

NOTICE OF RECEIPT

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes

The court has hereby received and acknowledged the above case on the 26th day of August, 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]

[Jacob Schmidtt]

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

---

NOTIFICATION OF COUNSEL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes

A Notification of Counsel was filed in the above case on the 27 of August, 2023.

I, Jacob Schmidtt, Public Defender with the San Andreas Judicial Branch, will be representing the Defendant, Kevin Reyes 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]

[Hope Kant]

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

---

NOTIFICATION OF COUNSEL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes

A Notification of Counsel was filed in the above case on 26/SEP/2023.

I, Hope Kant, Deputy Attorney General of 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.



Deputy Attorney General
Director of Public Notary
San Andreas Judicial Branch
(909) 321-2132 — [email protected]

[Robert Winejudge]

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

---

NOTICE OF ACTIVATION

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes
#23-CM-0111

A Notice of Activation was entered in the above case on 17th of December, 2023.

The case of the State of San Andreas v. Kevin Reyes is hereby activated by this Court under #23-CM-0111.

At this time the State has adequate representation, however, the prosecutor on the case is on a Leave Of Absence The Defendant is still seeking representation as well. 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 and the prosecution's LOA has ended.

In accordance with guidelines set forth by the Supreme Court of San Andreas, this case shall require an in-person trial. Once all pretrial matters have been resolved, a Notice of Scheduling will be issued to arrange an appropriate time for trial.


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

[Shaun Harper]

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

---

NOTIFICATION OF COUNSEL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes

A Notification of Counsel was filed in the above case on the 29th of December, 2023.

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

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


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

[David Vespucci]

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

---

NOTIFICATION OF COUNSEL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes

A Notification of Counsel was filed in the above case on the 29th December, 2023.

I, David Coast, a Junior Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant, Kevin Reyes 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) 593-1338— [email protected]

[Kendall Groyce]

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

---

NOTIFICATION OF COUNSEL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes

A Notification of Counsel was filed in the above case on the 2nd of January, 2023.

I, Kendall Groyce, a Prosecuting Attorney with the San Andreas Judicial Branch, will be taking over for Prosecution on behalf of Attorney General Hope Kant, and representing the State of San Andreas in the underlying case.

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



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

[Robert Winejudge]

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

---

ORDER FOR DISCOVERY

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes
#23-CM-0111

A court order was entered in the above case on 4th of January, 2024.

The case of #23-CM-0111, State of San Andreas v. Kevin Reyes 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 Judge
San Andreas Judicial Branch
(909) 372-4223 — [email protected]

[Michael Paul]

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

---

NOTIFICATION OF COUNSEL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Defendant

A Notification of Counsel was filed in the above case on 07th January, 2024.

I, Michael Paul, 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 alongside the Primary, Kendall Groyce and will await further instruction from the Presiding Judge.



Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 304-6031 — [email protected]

[Kendall Groyce]

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

---

MOTION FOR DISCOVERY

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes
#23-CM-0111

A Motion for Discovery was filed in the above case on the 8th of January, 2024.

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

• Exhibit #1: Kevin Reyes Arrest Report - 22/AUG/2023

  

  

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

  
  

  ---

  MUGSHOT

  • SUSPECT DETAILS
    • 
      Full Name: Kevin Reyes
      Phone Number: 4068375
      Licenses Suspended: No
      Officers Involved:
      • Police Detective I Coral Lafleur
      • Police Detective II Samuel Martin
      • Police Officer III Mark Snow
      Charges:
      • SF07 - Bank Robbery
      • WM02 - Possession of a Class 1 Firearm
    INCIDENT NARRATIVE
    • Incident Date: 22/AUG/2023
      
      Explain what happened, sufficient detail must be given to justify the placed charges, videos could be provided.
      • On 21st August 2023 at 10:23pm, the Pink Cage bank alarm rang and sent an SOS to dispatch. Officers arrived on scene, including Lieutenant Bill Breacher. Within this, Bill Breacher was able to save his duty bodycam and roll back the footage to show all the individuals inside, alongside their plates. With this, an individual was seen leaving the bank wearing blue trousers, white daps, black gloves, watch on left wrist, white/silver chain around their neck, shirtless, white full facemask - Image shown below.
        
        
        
        With this, a BF400 was left at the scene by an individual who seemed to have issues gaining access to the bike. With this, the individual left the bike behind, and the RO was found, being Kevin Reyes. Kevin was later found ringing the impound bell and upon arrival Lieutenant Bill Breacher identified the individual with matching clothing - to which was clearly seen in the footage; the only difference between the two was that he now had a shirt on his person. Kevin Reyes was detained under probable cause of being involved in this bank robbery and taken to Mission Row for legal questioning.
        
        Upon being at Mission Row, a JB defence attorney came to represent Mr Reyes, and met officers with hostility claiming the evidence we had was nothing but a mere thought that had no proof, however after using LSPD's internal policies Kevin was told to take his shirt off due to the defining factor of evidence being the tattoos he had. Upon his shirt being removed, Kevin Reyes had the exact tattoos matching the ones seen within the footage from the Bank Robbery; pictures of tattoos found below. The decision to gain evidence of tattoos were made under the justification and belief that once in the knowledge of knowing that the tattoos are valuable evidence - The individual is liable to remove/alter their tattoos to change the outcome of said investigation.
        
        
        
        
        After this was found out, Kevin was placed under arrest due to the mask he had (a white T-shirt mask), his chain around his neck matching the video, the tattoos matching to the individuals seen, the trousers being same style and colour, shoes being the same style and colour. With all of this evidence, Kevin Reyes was taken to DOC, escorted by the defence attorney from JB (believes that Kevin Reyes was not safe in police custody) and was sent to serve his time.
        
        To add for reference to the class 1 firearm charge, the individual in the footage had a pistol to which they were actively brandishing.
    EVIDENCE DETAILS
    • Document the possessions confiscated from the arrested suspect.
      Possessions are to be documented individually, examples of documented illegal possessions are "Pistol .50" or "12 grams of Cocaine". Legal possessions that can be categorized may be grouped, eg. "Clothing" to describe all clothing items. 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 Possessions:
        Exhibit A: White T-shirt mask
        
        
        Legal Possessions:
        Exhibit A: Knife
        Exhibit B: Clothing
        Exhibit C: Lockpick
        Exhibit D: Radio
        Exhibit E: GPS
        Exhibit F: Painkiller
        
        
        Photograph of Possessions (MANDATORY)

        

  
  Exhibit #2: Detective Coral Lafleur's Witness Statement

  

  

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

  Case Information

  • Incident Date: [21/AUG/2023]

  Witness Information

  • Name: [Coral Lafleur]
    Date of Birth: [12/AUG/2000]
    Phone Number: [N/A]
    Occupation: [Los Santos Police Officer - Detective]

  Witness Statement

  • Thank you for the enquiry, please find below my statement to the situation, alongside the facts we had, the affiliation we had, and the final conclusion.
    
    First and foremost, the situation began at Pink Cage bank, to which the group formerly known as "Crime Scene Boys" we're actively inside stealing money from the vault. As units arrived, METRO gave demands to the individuals who came out, but each person jumped onto a bike and ran. During this, an individual wearing a brown checked shirt, black mask and black shorts jumped onto a black BF400, before an individual shirtless, blue pants, white shoes and white mask jumped on the back. No one on scene was able to be identified at this time. The only piece of evidence that was left from this was a BF400 to which was registered to "Kevin Reyes" to which the impound report will be found below.
    
    The plates from said bank were handed to a Gang and Narcotics Detective to run through and determine who may be a suspect. As this was happening, Kevin Reyes was found by the Impound lot, to which Lieutenant Bill Breacher had found him and brought him in for questioning, ie detaining for further investigations. Kevin Reyes was brought into questioning to where he requested a lawyer and was given said lawyer.
    
    As the questioning began, there go the lack of questioning that was allowed, PD units were not allowed to speak to Kevin Reyes, and Kevin was told to remain silent and not give any defending statements. During this, Jacob Schmidtt continued to state that all evidence that Detectives had were circumstantial without seeing the evidence to which the Detectives had gained, and refused to allow us to prove Kevin Reyes guilty or not, instead inhibited the entire questioning and made this situation more heated than it needed to be.
    
    During this questioning, Kevin Reyes stated that he had been at front desk of Mission Row at the time of Pink Cage bank being hit, he also stated that he had been there to mark his bike as stolen, however CCTV cameras showed Kevin Reyes arriving long after the alarm had been triggered. Kevin Reyes then began to state that he had to walk to Mission Row from Vespucci beach, but when Detectives asked the location to get the alibi for Kevin Reyes, once again Jacob Schmidtt refused any response to prove Kevin Reyes innocent.
    
    Due to the obstruction of the investigation that was shown by Jacob Schmidtt, Detectives used their totality of circumstances, with the evidence shown within the arrest report, bodycam and known knowledge about Kevin Reyes to determine there was more than enough probable cause to see Kevin Reyes tattoos to either gain the final piece of evidence, or to prove Kevin innocent. Kevin Reyes and Jacob Schmidtt were told the plan of which to remove Kevin Reyes from the area to a more private location so he can remove his shirt to see if said tattoos matches the individual in the bodycam footage saved, to which Kevin stated he did not want to leave that corridor we were within which was his own want of the situation.
    
    As law enforcement detectives attempted to remove Kevin Reyes shirt as a lawful order due to probable cause given, Jacob Schmidtt began to interfere, refusing to remove out of the way of law enforcement, raising his voice and completely obstructing the justice of which officers were acting from their own internal policies to perform this act. It was mentioned multiple times that the 4th amendment was being broken, however as stated "but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized." There was reasonable probably cause against Kevin Reyes to have his shirt removed and tattoos to be seen, Kevin Reyes removes his pants at his own free will, and when asked to put them back on, he refused.
    
    Once the tattoos were seen, it was decided amongst the officers from the Los Santos Police Department that there was enough evidence surrounding this case for Kevin Reyes to be charged. To sum up the evidence provided the following clothes matched: White T-shirt mask, Blue jeans, white dap trainers, silver chain around the neck and the watch on the left wrist. As well as the clothes, both the individual in the video's tattoos and Kevin Reyes' tattoos matched, to which there were multiple which were identical. Lastly, the bike of Kevin Reyes being located at Pink Cage Bank.
    
    The other license plates and bikes seen on scene (the ones which can be retrieved from footage ((it's really small and hard to see)).) : Vehicle: BF400, Plate:OPF17O4Y, Owner: Modie_Richards. Vehicle: BF400, Plate:LR7DYDJZ, Owner: Stewie_Saxton. Vehicle: Draugur, Plate: RAKEV, Owner: Kevin_Knox.

  Witness Affirmation

  • I, [Coral Lafleur], 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,
    
    
    [Coral Lafleur]
    [Los Santos Police Department]
    
    Date: [8/SEP/2023]

  
  Exhibit #3: Detective Mark Snow's Witness Statement

  

  

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

  Case Information

  • Incident Date: [21/AUG/2023]

  Witness Information

  • Name: [Mark Snow]
    Date of Birth: [07/APR/2023]
    Phone Number: [291-3567]
    Occupation: [Officer of the Law]

  Witness Statement

  • [I did not have much of an influence on this investigation but I was definitely a part of it. Detectives brought Kevin Reyes from the Impound to MRPD for questioning. We read him his rights and he wanted a lawyer which with his legal right he is allowed, so we called for one.
    
    At this point Jacob Schmidt came down to Mission Row and spoke with his client. He then came out and said that we are not allowed to speak to Kevin and that he will be speaking for Kevin. We labelled out our evidence and what we were going to be doing. He then said that Kevin is innocent and that all of our evidence was circumstantial. We then explained that it absolutely was not.
    
    The PD units present went to the side and had a small "sidebar" if you will, which Kevin and the JB representative attempted to interfere with out discussion and attempted to eavesdrop. We told them to back off for a minute and continued to talk. We then decided with out evidence that we are going to search Kevin and remove his shirt to gain evidence of his tattoos as an exhibit of evidence was the description of the Bank Robber's tattoos.
    
    Jacob Schmidt said that we were not going to do that and that we were breaking Kevin's 4th amendment right. I spoke and explained that everything we were doing was inline with the 4th amendment right.
    • Under the 4th amendment it states: The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.
    I would like to say that the search was very much lawful and reasonable due to the evidence we had gained to move forward. I would like to say that we had probably cause for out evidence provided, we explained the area that we wanted to search and that nothing was going to be seized at that moment. But with all this in mind the JB Defence lawyer still refused to acknowledge our evidence. With this we acted on our evidence and proceeded with out search where we found the exact tattoos on Kevin that the Bank Robber had. He was charged and processed in DOC.]

  Witness Affirmation

  • I, [Mark Snow], 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,
    
    
    [Mark Snow]
    [Police Detective]
    [Los Santos Police Department]
    
    Date: [08/SEP/2023]

  
  Exhibit #4: Lieutenant Bill Breacher's Witness Statement

  

  

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

  Case Information

  • Incident Date: [22/AUG/2023]

  Witness Information

  • Name: Bill Breacher
    Date of Birth: 07/JUL/1983
    Phone Number: 380-3680
    Occupation: Police Lieutenant, Los Santos Police Department

  Witness Statement

  • On August 22nd, 2023, LSPD responded to a bank robbery at the Fleeca Bank on Occupation avenue just across from the Pink Cage Motel. I was one of the first units to arrive. I pulled up on scene and saw multiple motorcycles out front of the bank with the robbers still inside, coming out of the front door just as I had pulled up and got into position behind my car for cover in case they shot at me. I was able to collect license plates from most of the suspect vehicles with my cruiser's MDC, one of which was a motorcycle registered to Kevin Reyes. Myself and other officers tried to apprehend the criminals involved, but most of them escaped right away. If I recall, there was one BF400 that was left behind registered to Kevin Reyes, which I had taken to impound by another unit. Shortly later on that day, Kevin Reyes rung the bell at the impound lot to retrieve that bike. We had a BOLO out for Kevin and some of the other individuals with vehicles registered to them following the robbery from the license plate information I was able to capture. I responded to the impound lot, and upon arrival saw Kevin there, where he gave me his license per standard procedure to retrieve a vehicle from impound. I called it in over radio to some detectives that Kevin was verified at the impound lot and asked if they wanted to question him for potential involvement with the bank robbery. I reviewed my body camera evidence from earlier in the day and found that one individual that had run out of the bank had the same skin tone, same shoes, and same pants as what Kevin was wearing at the impound lot, in addition to his bike being present at the scene. I detained Kevin and told him he would have to come down to Mission Row PD for questioning as I suspected he was involved with the bank robbery. I placed him in handcuffs and read him his Miranda Rights and placed him in the back of my police vehicle and brought him to Mission Row where he was questioned by Detectives and later arrested on the charge of Bank Robbery.

  Witness Affirmation

  • I, Bill Breacher, 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,
    
    
    Bill Breacher
    Police Lieutenant I
    Los Santos Police Department
    
    Date: 09/SEP/2023

  
  Exhibit #5: Lieutenant Breacher Bodycam Footage

  
  

  ((Proof of RP))

  
  Exhibit #6: Impound Report - 20/AUG/2023

  

  

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

  ---

  • VEHICLE DETAILS
    • Vehicle Owner: Kevin Reyes
      Phone Number: 4068375
      License Plate: PNFMG6DD
      Vehicle Model: BF400
      Vehicle Color: Silver.
      Miscelleanous Details: N/A.
    
    IMPOUND DETAILS
    • Date and Time: 20/AUG/2023 22:00
      Location: Hawick Avenue.
      Brief Statement of Impounding Reason: The vehicle was found at the scene of an active bank robbery at pink cage hotel, however, all suspects had managed to escape and we could not get positive identification of any of the suspects that fled. As we could not determine whether or not the vehicle was stolen or actually used by the registered owner, we secure impounded it.
      Officers Involved: Police Officer I Hukaz Zidane, Police Cadet Brian Stone
      Documented Evidence:

  
  

  ---

  
  Exhibit #7: LS Impound Lot CCTV

  
  

---

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

Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 304-6031 —[email protected]

[David Vespucci]

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

---

MOTION TO SUPPRESS

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes
#23-CM-0111

A Motion to Suppress was filed in the above case on the 9th of January, 2024.

The Defendant, Kevin Reyes, by and through the undersigned attorney, filed this Motion to Suppress, and requests to following be suppressed from evidence;

• Exhibit #: 1,2,3
  Requested Evidence to Suppress:

  All evidence resulting from the search of the defendant Kevin Reyes.

  • Detailed Reasoning: This motion is based on the grounds of an unlawful search conducted during the investigation, which violates the defendant's Fourth Amendment rights under the Constitution of San Andreas.
    
    Exhibit 1

    "Upon his shirt being removed, Kevin Reyes had the exact tattoos matching the ones seen within the footage from the Bank Robbery"

    
    Exhibit 2

    "both the individual in the video's tattoos and Kevin Reyes' tattoos matched, to which there were multiple which were identical"

    
    Exhibit 3

    "where we found the exact tattoos on Kevin that the Bank Robber had"

    
    
    The search conducted by law enforcement officials involved the removal of clothing from Mr. Reyes, specifically his shirt, in an attempt to identify tattoos linking him to the alleged bank robbery. The circumstances surrounding this search raise serious concerns regarding its lawfulness, constitutionality, and adherence to proper procedures.
    
    The Fourth Amendment safeguards individuals from unreasonable searches and seizures and mandates that warrants be issued based on probable cause supported by oath or affirmation. The search in question lacked the necessary authorization or probable cause to justify its intrusive nature. Law enforcement officials failed to demonstrate sufficient legal grounds or evidence to merit the removal of clothing for tattoo identification.
    
    Furthermore, the search was conducted without appropriate consent from Mr. Reyes and lacked the requisite procedural steps to ensure compliance with constitutional protections against unwarranted searches.
    
    The reasoning behind the search is that the defendant, Kevin Reyes, matched the same shoes and trousers as the alleged bank robber. These reasoning does not uphold probable cause to search the individual and remove his clothing.
    
    A quote from Exhibit 3 shows that the police officer search with out evidence to gain evidence, which is a clear violation of the 4th amendment rights
    Exhibit 3

    "We then decided with out evidence that we are going to search Kevin and remove his shirt to gain evidence"

    
    The defense contends that the evidence obtained from this unlawful search, specifically the identification of tattoos, is inadmissible in court due to its violation of Mr. Reyes' Fourth Amendment rights. The search was conducted in contravention of established legal principles and without the necessary legal basis, rendering the evidence obtained thereby unlawfully obtained and unreliable.
    
    In light of the aforementioned constitutional violation, we respectfully request that the court grants the Motion to Suppress Evidence, thereby excluding any information, identification, or evidence acquired from the unconstitutional search from being presented or considered during the proceedings of this case.

• Exhibit #: 1,2,3
  Requested Evidence to Suppress:

  All evidence which is regarding Attorney Jacob Schmidtt

  • Detailed Reasoning: Relevancy.
    
    Exhbit 1

    "Upon being at Mission Row, a JB defence attorney came to represent Mr Reyes, and met officers with hostility claiming the evidence we had was nothing but a mere thought that had no proof"

    
    Exhbit 2

    "As law enforcement detectives attempted to remove Kevin Reyes shirt as a lawful order due to probable cause given, Jacob Schmidtt began to interfere, refusing to remove out of the way of law enforcement, raising his voice and completely obstructing the justice of which officers were acting from their own internal policies to perform this act."

    
    Exhbit 3

    "As law enforcement detectives attempted to remove Kevin Reyes shirt as a lawful order due to probable cause given, Jacob Schmidtt began to interfere, refusing to remove out of the way of law enforcement, raising his voice and completely obstructing the justice of which officers were acting from their own internal policies to perform this act."

    
    
    
    Junior Defense Attorney
    San Andreas Judicial Branch
    (909) 593-1338— [email protected]

[Kendall Groyce]

San Andreas Judicial Branch Docket Notice "HERE FOR YOU | SAFE FOR YOU"

---

• Honorable Judge Winejudge and pertaining parties,
  
  The Prosecution believe the arresting department to be well within their rights to check to make sure the defendant still retains the same tattoos as was shown in an earlier bodycam still photo. Our city allows for hot-pursuit protocol to be in place whenever a piece of evidence is more than likely to be tampered with if not recovered immediately. As it is possible for any person to go into a tattoo shop and change their tattoos at will, almost instantly, without having to cover up the previous tattoo ((AKA Game limitations)), the Prosecution agrees with the actions of the arresting department and feel it to be a lawful request.
  
  Respectfully,
  
  
  Senior Prosecuting Attorney
  San Andreas Judicial Branch
  (909) 489-9881 — [email protected]

[David Vespucci]

San Andreas Judicial Branch Docket Notice "HERE FOR YOU | SAFE FOR YOU"

---

• Honorable Judge Winejudge and pertaining parties,
  
  The Defense would like to mention the concept of hot-pursuit protocol is grounded in the need to prevent the destruction or tampering of evidence, It still must be balanced with the individual's rights, particularly regarding privacy and protection against unwarranted searches.
  
  The arresting department's actions appear to lack the necessary specificity and immediacy required for a valid hot-pursuit scenario. The search, based on a vague clothing match without corroborating evidence or a clear indication of ongoing criminal activity, seems more aligned with a general investigatory approach rather than an urgent pursuit of a suspect.
  
  Respectfully,
  
  Junior Defense Attorney
  San Andreas Judicial Branch
  (909) 593-1338— [email protected]

[Hope Kant]

San Andreas Judicial Branch Docket Notice "HERE FOR YOU | SAFE FOR YOU"

---

• Honorable Judge Winejudge and pertaining parties,
  
  This is a notice to the courts that the Primary Prosecutor on the case has an approved LOA from the 15th of January to the 23rd of January. When she returns from her LOA and the previous motions ruled upon, the Prosecution is fine moving forward. We thank the courts for their patience during this time.
  
  Respectfully,
  
  
  Attorney General
  Director of Public Notary
  San Andreas Judicial Branch
  (909) 321-2132 — [email protected]

[Robert Winejudge]

San Andreas Judicial Branch "EQUAL JUSTICE UNDER LAW"

---

• To whom it may concern,
  
  The Primary Prosecutor on this case has an approved LOA until the 2nd of February, therefore we will resume on February 3rd. Thank you for your patience, I will need a couple of days to deliver a decision on the Motion to Suppress. I believe the prosecution has nothing more to add to that matter.
  
  Respectfully,
  
  
  Superior Court Judge
  San Andreas Judicial Branch
  (909) 372-4223 — [email protected]

[Mary Burrows]

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

---

NOTIFICATION OF COUNSEL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes

A Notification of Counsel was filed in the above case on the 28th of January, 2024

I, Mary Burrows, 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 Primary Counsel and will await further instruction from the Presiding Judge.

We will also not need a pause on this case, we can resume and we will allow 2 days for a verdict on the motion to suppress as the prosecution has nothing further to add.


Prosecuting Attorney
Notary Clerk
Training and Hiring Staff
San Andreas Judicial Branch
(909) 339-5979 — [email protected]

[Bret Hyland]

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. Defendant
#22-CM-0111

A decision was reached in the above case on the 29th day of January, 2024.

Good afternoon firstly I would like to inform both sides that I will now be handling this file.

Pertaining the notice for suppression.

I will be granting the notice for suppression at this time based on information provided.


Superior Judge
San Andreas Judicial Branch
(909) 225-3056
[email protected]

[Mary Burrows]

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

---

MOTION TO STAY PENDING APPEAL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes
#23-CM-0111

A Motion to Stay Pending Appeal was filed in the above case on the 30th of January, 2024.

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

• Reasoning: The Prosecution in this case has initiated an appeal within the San Andreas Court of Appeals following the latest Court Decision.

Prosecuting Attorney
Notary Clerk
Training and Hiring Staff
San Andreas Judicial Branch
(909) 339-5979 — [email protected]

[Bret Hyland]

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. Defendant
#22-CM-0111

A decision was reached in the above case on the 30th day of January, 2024.

I recognize your appeal of my decision I have made and will await its verdict to continue.

Both sides are hereby notified that this file will remain pending until a verdict is reached on the appeal submitted by the prosecution.




Superior Judge
San Andreas Judicial Branch
(909) 225-3056
[email protected]

[Jay Wellberg]

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

---

NOTIFICATION OF COUNSEL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes

A Notification of Counsel was filed in the above case on the 28 of February, 2024 .

I, Jay Wellberg, a Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant, Kevin Reyes in the underlying case.

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



Public Defense Attorney
San Andreas Judicial Branch
(909) 2956979 — [email protected]

[Kylar Carter]

Your honor,

I will be going private with Wood Law.

[David Vespucci]

Notification Of Counsel
State of San Andreas v. Kevin Reyes

To whom it may concern,

I, David Coast, an Associate with Wood Law, will be representing the Defendant, Kevin Reyes in the underlying case.

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

Respectfully,


David Coast
Associate
Bar Certified Attorney
☏ 593-1338

[Bret Hyland]

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. Kevin Reyes
#23-CM-0111

This case is currently pending an active appeal by the state prosecution team. Please be patient whilst we await the conclusion of that appeal.


Superior Judge Bret Hyland
San Andreas Judicial Branch

[Al Triton]

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

---

NOTIFICATION OF COUNSEL

---

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Kevin Reyes
A Notification of Counsel was filed in the above case on 13/MAR/2024.

I, Al Triton, 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 Primary Counsel and will await further instruction from the Presiding Judge and the conclusion of the appeal currently pending with this case.


Al Triton
Prosecuting Attorney
San Andreas Judicial Branch
(909) 318-8168 — [email protected]