#23-CM-0103, State of San Andreas v. Frank Haswell

Post by **Al Triton** » Wed Jan 31, 2024 6:33 pm

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

Honorable Judge Mason and pertaining parties,

The prosecution wishes to retain the prior motions and notices by former Attorney General Hope Kant. The Prosecution has nothing else to add to the previous notices regarding the additional Motions for Discovery that were submitted and awaits the ruling on the suppressions and inclusions. Once a decision has been reached, the Prosecution will move forward accordingly.

Respectfully,

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

Post by **David Vespucci** » Fri Feb 02, 2024 6:08 pm

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

Honorable Judge Mason and pertaining parties,

The defense reaffirms our intention to proceed with the motions set forth by the prior defense. We maintain our stance regarding the motion to suppress evidence, and we respectfully request the court's consideration and evaluation of these motions in due course.

Furthermore, we reiterate our opposition to the prosecution's motion for discovery beyond the 7-day deadline. Our position remains unchanged, emphasizing the importance of adherence to established procedural safeguards and the principles of fairness and transparency in the legal process.

Thank you for your attention to these matters, and we trust in the court's wisdom in addressing these issues impartially and justly.

Respectfully,

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

Post by **Hope Kant** » Mon Feb 05, 2024 5:02 pm

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. Frank Haswell

A Notification of Counsel was filed in the above case on 05/FEB/2024.

I, Hope Kant, Attorney General of the San Andreas Judicial Branch, will be representing the State of San Andreas in the underlying case.

I will be taking over the responsibility of Primary Counsel alongside Prosecuting Attorney Al Triton as co-counsel, and will await further instruction from the Presiding Judge.

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

Post by **Judith Mason** » Sun Feb 11, 2024 11:25 am

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. Frank Haswell
#23-CM-0103

A decision was reached in the above case on the 11th day of February, 2024.

The court would like to apologize for the length of time for this decision since the filing of the previous pretrial motions and thank those involved for their patience while various matters had previously remained unresolved.

The court has reviewed the pretrial motions filed in this case as well as the arguments that have been submitted in favor and against the proposed outcomes and a decision has been reached.

Regarding the defense's Motion to Suppress as filed on the 10th day of November, 2023, the court will be granting, in part, the motion as follows:

Julia Whitehorse wrote:"At that time, Investigator Whitehorse went back to Frank and asked him where did the bag go after he picked it up and he says :" I incarcerated it as at that point have nothing to do with it". this statement make it obvious that Frank is hiding something as the knives were found inside the locker room that means the bag went by there, if what he said is true ( which is by the CCTV is not), it contradict with his previous statement and in the CCTV that is not what happened."

Motion to Suppress is granted, in part - the court has found that while the specific statement quoted by Investigator Whitehorse of "I incarcerated it as at that point have nothing to do with it." does constitute an out-of-court statement, it is not being used to prove that the defendant [incinerated] it, but rather, is apparently used as a means to impeach the testimony of the defendant via inconsistent statements.

With that said, the witness goes on to extrapolate on the statement, stating, "this statement makes it obvious that Frank is hiding something [...] if what he said is true, [...] it contradict with his previous statement and in the CCTV that is not what happened." Given that this is an interpretation of the evidence provided rather than an objective fact that the witness is testifying to, this portion of the statement has been deemed inadmissible by this court for the speculative and opinion-based nature of the statement.

Thus, the Motion to Suppress is granted for the following portion of the statement: "this statement make it obvious that Frank is hiding something as the knives were found inside the locker room that means the bag went by there, if what he said is true ( which is by the CCTV is not), it contradict with his previous statement and in the CCTV that is not what happened."

Julia Whitehorse wrote: "all the clothes seemed to be rolled in a way that it hiding something inside"

Motion to Suppress is granted, in part - the latter half of the statement made relies upon the speculations of the declarant, asserting that evidence may be contained within the rolls of clothing. The court will retain the statement that "all the clothes seemed to be rolled" however will strike "in a way that it hiding something inside."

Julia Whitehorse wrote: "and by investigating it, it was discovered that Frank Haswell retrieved all the personal belongings of Jack Goodnight. At that moment of time,"

Motion to Suppress is denied - as will be discussed within the next Motion to Suppress, the above statement made is corroborated in the prosecution's Exhibit #11 filed on the 3rd day of January, 2024.

Regarding the defense's Motion to Suppress as filed on the 29th day of November, 2023, the court will be denying the Motion to Suppress Exhibit #10 and the referenced portion of Exhibit #1. With the inclusion of Exhibit #11 filed on the 3rd day of January, 2024, the foundation for these exhibits has been provided and the Motion to Suppress is thus denied.

Regarding the prosecution's Motion for Discovery of Exhibit #11 as filed on the 3rd day of January, 2024, the court will be granting the Motion for Discovery, thus deeming Exhibit #11 admissible at trial. The court recognizes the fact that this exhibit was filed outside of the window prescribed in the Order for Discovery filed on the 3rd day of November, 2023, however, the court has determined that the cause of this delay in submission to be reasonable given compounding factors including but not limited to approved Leaves of Absence and the time of year, among other considerations.

More importantly, the court has determined that the delayed inclusion of this exhibit has neither violated the established Rules of Evidence nor presented prejudicial circumstances against the defendant as the defense has now had adequate time to account for it's inclusion by way of identifying alternative trial strategy or lodging any further formal objections or Motions to Suppress against specific portions of the exhibit.

While the court sympathizes with the defense's concern of evidence tampering, the mere fact that it has been several months since the beginning of the case does not even rise to the level of reasonable suspicion, let alone probable cause, to believe that this particular piece of evidence has been tampered with.

With all pretrial matters now having been resolved, the court will soon move to schedule a time for trial via a Notice of Scheduling to be submitted within the coming days.

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

Post by **Ariel Anderson** » Sun Feb 11, 2024 7:49 pm

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. Frank Haswell

A Notification of Counsel was filed in the above case on 11th of february, 2024.

I, Ariel Anderson, a Junior Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant Frank Haswell 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) 439-5821 — [email protected]

Post by **Shaun Harper** » Mon Feb 26, 2024 8:08 am

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. Frank Haswell

A Notification of Counsel was filed in the above case on the 26th of February, 2024.

I, Shaun Harper, Chief Public Defender with the San Andreas Judicial Branch, will be representing the Defendant, Frank Haswell 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]

Post by **Shaun Harper** » Mon Feb 26, 2024 8:10 am

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

Included Parties,

I will be taking over as primary counsel on this case and will await the courts decision on motions put forward by the previous counsel.

Respectfully,

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

Post by **Judith Mason** » Wed Feb 28, 2024 10:14 pm

((

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

To whom it may concern,

In accordance with a ruling from Legal Faction Management, the RP submitted in Exhibit #11 from 03/JAN and any subsequent suppression discussions relating to that exhibit have been voided. All other exhibits and the remainder of the 11/FEB Court Decision will not be affected. This case will now be pending the submission of clarifying RP, at which point the case shall continue as normal.

Respectfully,

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

))

Post by **Hope Kant** » Wed Feb 28, 2024 11:44 pm

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. Frank Haswell
#24-CM-0103

A Motion for Discovery was filed in the above case on the 28th of February, 2024.

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

Exhibit #11: CCTV Clarification

((RP Proof))

Exhibit #12: Shelf/Picture Clarification

((RP Proof))

Attorney General
Director of Public Notary
San Andreas Judicial Branch
(909) 505-9925 — [email protected]

Post by **Frank Haswell** » Thu Mar 07, 2024 1:33 pm

Going Forward, I shall request that Mary Burrows of Wood Law is the primary counsel for my defense.

An individual with a lighter workload in my opinion will be more effective counsel than a team stretched thin across 12 different cases, I hope that the Men and Women of the Defense Division can understand.

Post by **Mary Burrows** » Thu Mar 07, 2024 2:02 pm

Notification Of Counsel
#23-CM-0103 State of San Andreas v. Frank Haswell

To whom it may concern,

I, Mary Burrows, an Associate with Wood Law, will be representing the Defendant, Frank Haswell in the underlying case.

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

Respectfully,

Mary Burrows
Associate
Bar Certified Attorney
☏ 339-5979

Post by **Mary Burrows** » Fri Mar 08, 2024 5:44 am

Motion to Supress
#23-CM-0103 State of San Andreas v. Frank Haswell

IN THE SUPERIOR COURT OF SAN ANDREAS

A Motion to Suppress was filed in the above case on the 8th of March, 2024.

Since the filing of my last motion to supress new evidence has came into play, thus I will make a new motion for the new evidence and how it effects old evidence.

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

Exhibit #7: CCTV Still of Knives on the Ground

Exhibit #8: Showing Number of Knives in Evidence

There is no association with knifes and the charges stacked against the defendant. The defense asks this to be suppressed due to relevancy to the case and the charges as knives are not illegal in the State of San Andreas which is why the two above exhibits should be suppressed in their respective entirety.

Exhibit #10: Questioning of Jack Goodnight

((RP Proof))

There is still no evidence showing that the defendant took anything from ex-corporal Jack Goodnight's items which makes this hearsay. Therefore having no need for this exhibit in its entirety.

Exhibit #12: Shelf/Picture Clarification

((RP Proof))

This exhibit has no relevancy. This is the new set-up of the San Andreas Department of Corrections locker system. The lockers in question for this case are not above provided ones (the old set-up of evidence lockers can be found in exhibit 7) which means that this exhibit has no relevancy to the case.

Respectfully,

Mary Burrows
Associate
Bar Certified Attorney
☏ 339-5979

Post by **Hope Kant** » Fri Mar 08, 2024 2:15 pm

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

Honorable Justice Mason and pertaining parties,

The Prosecution appreciates the time of the defense and their motion to suppress, but I believe there's been a bit of a confusion. Relevance is only an applicable objection when "The evidence being solicited does not relate to merits of the case or another admissible purpose such as foundation or permissible character evidence." The defendant is being charged with GF02 - Robbery of a Government Employee, GF16 - Tampering with Evidence, and GM14 - Obstruction of Justice.

The knives, their placement, where they were taken from, and how they ended up in the possession of the defendant are absolutely relevant as the evidence points to the possibility of the defendant lying to investigators in order to make himself appear less guilty. To exclude that from the case would be to state that part of the charges are also not relevant to the case, which would make little to no sense as that is the reason why we are here today.

In reference to the suppression of both exhibit 10 and 12, the shelves, although they have been moved, still house the same information. IE: A-F, G-M, N-S, etc. ((It has been ruled that deductive reasoning skills would allow someone with a clarifying picture/RP to determine who's locker was accessed. This can be confirmed by the Associate Justice on the case as there are logs to prove it and multiple admins whom have commented.)) We see the defendant taking from a specific locker/box, while we cannot determine from the footage exactly who the items belonged to, the picture would show the placement of the box and the name on the label: Jack Goodnight.

Making the statements both relevant to the case and no longer considered hearsay as Mr. Goodnight was both an SADOC officer at the time and a possible victim.

Respectfully,

Attorney General
Director of Public Notary
San Andreas Judicial Branch
(909) 505-9925 — [email protected]

Post by **Mary Burrows** » Tue Mar 12, 2024 2:13 am

Motion for Discovery and Dismissal
#23-CM-0103 State of San Andreas v. Frank Haswell

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Frank Haswell
#24-CM-0103

A Motion for Discovery was filed in the above case on the 11th of March, 2024.

The defendant Frank Haswell by and through the undersigned attorney, filed this Motion for Discovery, and presents the following as evidence;

Exhibit #13: Witness Statement from Jack Goodnight
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"

Case Information
- Case Number: #23-CM-0103
  Incident Date: 17 of August 2023
Witness Information
- Name: Jack Goodnight
  Date of Birth: 18/JAN/1995
  Phone Number: REDACTED
  Occupation: N/A
Witness Statement
- [I Jack Goodnight, of my own volition, gave Frank Haswell permission to go into my Department of Corrections and grab my things for me. At the time, I had just resigned from the department. I did not really want to speak to many people, but Frank was a good guy, always willing to help out. Mr. Haswell did get my things out of my locker and give them back to me. For some reason, I was interrogated by Julia Whitehorse, formerly of the Department of Corrections. At that time, I thought that I was being questioned about a separate incident, as things had been missing from my locker before, but it was always taken care of through internal affairs. However, at the time of this supposed incident, none of my things were stolen from me, nor did anyone go into my locker without my permission. Now I do have to add that if anyone did go into my locker without permission, they surely would not be alive to get arrested for it.
  
  Kind regards,
  
  Jack Goodnight]
  
  I, Jack Goodnight, 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.))
Respectfully,
This witness statement should prove more than sufficient evidence that Frank Haswell did indeed have permission to take Jack Goodnights belongings from his personally locker. This brings me to my next motion.

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Frank Haswell
#24-CM-0103

A Motion for Involuntary Dismissal was filed in the above case on the 11th of March, 2024.
- Reason: No Crime Committed
  Detailed Explanation: The victim of the crime has confirmed that there was no crime committed and that the defendant had permission to grab his belonging from his personal locker and returned them to the owner.
Warm Regards!

Mary Burrows
Associate
Bar Certified Attorney
☏ 339-5979

Post by **Hope Kant** » Tue Mar 12, 2024 2:30 pm

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. Frank Haswell
#23-CM-0103

A Motion to Suppress was filed in the above case on the 12th of March, 2024.

The State of San Andreas/Defendant, name, by and through the undersigned attorney, filed this Motion to Suppress, and requests to following be suppressed from evidence;

Exhibit #: Exhibit #13: Witness Statement from Jack Goodnight
Requested Evidence to Suppress: The entire exhibit
- Detailed Reasoning:
  As what Attorney Burrows has done is unheard of in our courts. I am not entirely sure if how I'm responding is within terms as well, however given the nature of the situation I feel it is necessary. The defense has released a statement from a now disgruntled ex-SADOC worker proposing it as fact. The defense has either not reviewed the evidence or not properly informed the witness of the consequences of lying under oath.
  
  Let us review a timeline of events:
  1. Aug 08, 2023 - Honorable Discharge: #891 Jack Goodnight
  2. Sep 23, 2023 - SADOC Reinstatement - Jack Goodnight DENIED
  3. Oct 15, 2023 - [LSSD Application] Jack Goodnight ((NA)) DENIED due to "Poor recommendation from previous employer."
  4. Oct 28, 2023 - [SADOC REINSTATEMENT DENIED] - Jack Goodnight
  5. Jan 03, 2024 - [DENIED] [SADOC Reinstatement - Jack Goodnight]
  6. Jan 11, 2024 - Jack Goodnight Arrest Report: trespassing on SADOC grounds was held by DOC guards in the front lobby until the LSPD came to pick him up.
  7. Jan 13, 2024 - Jack Goodnight Arrest Report: attempting to take a hostage outside of SADOC
  8. Jan 14, 2024 - Jack Goodnight Arrest Report: DOC contacted SD regarding an individual they had in custody that brandished a knife at a DOC guard and trespassed
  9. Jan 17, 2024 - Notice of Trespass - Jack Goodnight, San Andreas Department of Corrections
  10. Jan 21, 2024 - Jack Goodnight Arrest Report: the deputy was at DOC where he saw DOC officers attempting to arrest Mr. Goodnight for lingering on their property.
  11. Jan 26, 2024 - Jack Goodnight Arrest Report: informed via the department radio that Mr. Goodnight and his friend pulled a knife on DOC guard and were refusing to leave yet again
  12. Feb 22, 2024 - Jack Goodnight Arrest Report: Jack Goodnight was released from DOC and immediately tackled a DOC guard in front of Officer Conrad. Mr. Goodnight was placed in handcuffs, an read his rights. Mr.Goodnight then attempted to kick a DOC guard.
  13. Feb 24, 2024 - Jack Goodnight Arrest Report: Mr. Goodnight was witnessed on DOC Bodycam attacking them with deadly weapons while wearing a facemask
  Mr. Goodnight resigned from SADOC, tried to return multiple times, but was rejected. He tried to join LSSD, but was rejected due to a bad review from his previous employer. Mr. Goodnight then proceeded to terrorize SADOC to the point where he was served a Notice of Trespass. The Prosecution would like to make it clear that the witness statement by Mr. Goodnight as shown in exhibit #13 is nothing short of perjury and we plan to charge him accordingly.
  
  Let's review the evidence from the Prosecution, Exhibit #10:
  - On Sunday August 20th, 2023 Correctional Officer Goodnight was read his Miranda Rights and questioned. He answered questions about the timeline ("when I was still working here everything was still accounted for") and items inside the locker ("pickaxes, a radio, gps, empty water bottles", SADOC stamps, etc.). He then converses with the investigator about who could've possible "taken" items from his locker.
    
    Investigator Whitehorse even asked "Am I correct if I say you did not ask anyone of those or anyone from DOC to hand you your stuff back?" to which Mr. Goodnight replied "No, no, I only learned of my stuff when I asked Robert for it yesterday and he told me it was missing". The investigator then repeats the question in a different way to which Mr. Goodnight responds that yet again he did not ask anyone or access the locker himself.
    
    The investigator asks a third time, "Am I correct as well if I say you gave 0 authority to anyone in DOC in order to hand the stuff back to you?" To which Mr. Goodnight replied, "Other than Robert yesterday, you are correct". She then asks him to repeat what he said to which he again states "Other than uh... asking Robert for it yesterday I have given nobody authority to take anything out of that locker."
    
    The investigator runs through the entire conversation/timeline/story once more prior to concluding the meeting. She even specifically asks him to confirm that he did not give anyone else authority or access the locker himself for the last time. All of which he affirms to be true. At the end he states "Thank you for looking into it. I mean as long as the person is caught I'm happy with that."
  That is 5 recorded times that Mr. Goodnight affirmed the fact that no one was allowed access into his SADOC locker. A striking comparison to the singular witness statement from the defense where he claims "at the time of this supposed incident, none of my things were stolen from me, nor did anyone go into my locker without my permission." He even ends his witness statement with a veiled threat "Now I do have to add that if anyone did go into my locker without permission, they surely would not be alive to get arrested for it."
  
  All of these facts lend towards the assumption that Mr. Goodnight can no longer be considered a trusted witness. His statement shown in Exhibit #10 was made during a time where he still had a good reputation and standing within the community. Mr. Goodnight has since lost that standing and has made it his mission to target SADOC, we ask that the statement submitted by the defense on the 12th of March be suppressed in full.
  
  Edit: The Prosecution would also like to add a witness statement (not relevant to the case, but relevant to the suppression).
  Assistant Warden Issei Schneider Witness Statement
  San Andreas Judicial Branch
  Official Witness Statement
  "HERE FOR YOU | SAFE FOR YOU"
  
  Case Information
  Case Number: [Case Number]
  Incident Date: [01/JAN/2000]
  Witness Information
  Name: [Issei Schneider]
  Date of Birth: [22/AUG/2002]
  Phone Number: [207-8799]
  Occupation: Department of Corrections - Assistant Warden and CERT Commanding Officer
  Witness Statement
  Hello,
  
  I would like to start with the Mr Jack Goodnight is a current threat to the SADOC and is cleared by High Command and CERT Commanding officer that if Jack Goodnight is to remain at the front of DOC he will be arrested for Trespassing. This decision is based off the actions that they are silly enough to do such as Active shooting / Drive by of Prison Officers. Mr Goodnight followed with Mr Corbin Wilder is known for trying SADOC such as harrasing DOC guards, Kidnapping them, Shooting at Active criminal transports putting our Guards, Convicts and Civilians in danger and also with that Shoot at guards when transporting Injured Inmates and Guards to LSEMS at Pillbox for Advanced treatment with MD's AMU division.
  
  This is a team based situation and they do not like how we have responded to there hostile activities, We have resorted to Trespassed on sight when asked to leave and Keep in a cell for the entire stay if they do anything silly such as fighting, Threatening and so on. I have also cleared my CERT Operatives and Guards to partner up as Mr Goodnight is known to come to DOC a lot for hostile issues that we at DOC are tired of.
  
  Based off this though Mr Goodnight does not like that we have made this a thing and also they have been informed VIA email and they responded violently over email and in person. From this they MAY ONLY be allowed at DOC when they are released to collect there possessions but after THEY MUST LEAVE, They will only be given 1 warning then refusing to leave will result in a ARREST with no questions asked.
  
  Here is the SAJB - Notices of Trespass for Jack Goodnight
  
  This has been an occurring thing for Months now.
  
  FILE REDACTED FOR SECURITY PURPOSES
  
  CERT Reports Involving Jack Goodnight
  
  21 Jan 2024, 20:51
  
  CERT Situation Report
  
  Date:
  
  Officers name: Riley Ryker
  
  Other CERT staff: Gina Willow
  
  Non CERT staff(Officers, other inmates, visitors): Lewis Gensen
  
  Rank within CERT: Divisional Trainee
  
  Weapon(s) deployed: Pump Shotgun
  
  Conclusion: Ended up doing a full cellblock lockdown until the rest of the unfinished business was finished.
  
  Situation
  
  Multiple MSI's and HVT's were brought to DOC such as Jack Goodnight, Corbin Wilder and Scott Banks, they were threatening a riot, there was alot of fighting and endless treatments were done in medbay, we decided to do a full lockdown since there were alot of hostile inmates threatening to kill guards, it ended up with us fully locking the cellblock down and finishing our business.
  
  15 Jan 2024, 01:18
  
  CERT Situation Report
  
  Date: 14/01/2023
  
  Officers name: Chris Whittle
  
  Other CERT staff: Alex Pedolski, Galileo Czapiewski, Rock Paz, Bogdan Fernandez
  
  Non CERT staff(Officers, other inmates, visitors): Bradley Coot, the entirety of PD/SD.
  
  Rank within CERT: Operative.
  
  Weapon(s) deployed: Pump Shotgun Mk II, Carbine Mk II, unsure of others.
  
  Conclusion: All the 10-15s were brought in and processed. Jack Goodnight was arrested, Corbin and 'Juan' got bored and left us alone for 5 minutes.
  
  Situation
  
  The whole situation initially started when assistance was called out on department radio about a HVT transport containing an unconfirmed number of 10-15s. We CERTed up and Alex pressed the CERT pager. We headed down to the city to assist with it. Once we reached Mission Row we assembled and began to load the 15s into the TARVs. We then noticed a Kamacho which looked extremely familiar. Funnily enough it contained DOC's favourite duo, Jack Goodnight and Corbin Wilder. Rock disabled their Kamacho with the brickade which was not to their liking. After a protracted interaction we formed back up with the transport and proceeded to take the 15's to DOC where they were processed without issue. Jack goodnight was brought into custody by PD and was processed too due to something he'd done at the transport scene. We maintained in CERT gear due to the present threat of the orange nightmare, Corbin, still remaining free. As luck would have it he decided to make his presence known, again, and he decided to just cause us a headache for a bit. We attempted to get someone from PD & SD to come down and charge them with trespassing however this fell on deaf ears. In the end they left of their own free will once myself and Bradley had 10-15s to process.
  
  13 Jan 2024, 17:49
  
  CERT Situation Report
  
  Date:13/JAN/2024
  
  Officers name:Randy Lee
  
  Other CERT staff:
  22-DELTA - Senior Operative In-Training Remmi Raccoon
  25-JULIET - Operative Vito Saint
  1-ZULU - Probationary Operator Jerry Brooks
  
  Non CERT staff(Officers, other inmates, visitors):
  #1030 - [CO-86] - Correctional Officer II Alex Nieves
  #521 - [WARDEN-01] - Warden Kourtney LaFleur
  SD Hugo
  
  Rank within CERT: Senior Operative
  
  Weapon(s) deployed:
  Pistol MK2
  Shotgun MK2
  Carbine MK2
  
  Conclusion: Kamacho Stolen, HVT transported from SADOC-Pillbox-SADOC
  
  Situation
  
  After already stressful day filled with threats on SADOC officers life (viewtopic.php?p=746057#p746057) SD Special Enforcment Division did what other department refused to do and come to SADOC too stop a active kidnapping attempt by Jack Goodnight and Corbin.
  
  The pair fled when SED showed up and after a chase the two were brought back to SADOC and During the processing Corbin was injured and required a trip to pillbox.
  
  While at pillbox, Jerry Brooks left his car running when he unlocked it to get the injured Corbin out and in that SPILT SECOND the Kamacho was stolen.
  
  22-DELTA - Senior Operative In-Training Remmi Raccoon then left SADOC to race to the city to see if she could find it while everyone else loaded Corbin back in and got him back to SADOC.
  
  From there he was placed and solitary
  
  11 Jan 2024, 02:29
  
  CERT Situation Report
  
  Date: 10/01/2023
  
  Officers name: Jerry Brooks
  
  Other CERT staff: Randy Lee, Remmi Raccoon, Vito Saint, Chris Whittle, Galileo Czapiewski
  
  Non CERT staff(Officers, other inmates, visitors): Officer Zinnia Rose, Chad Rapkov of Weazel News
  
  Rank within CERT: Probationary Op.
  
  Weapon(s) deployed: Remington 870, Sniper Rifle, Carbine Rifle, SMG
  
  Conclusion: 3 suspects detained, 1 guard injured, 1 guard accidentally injured.
  
  Situation
  
  A detailed description of the situation
  Corbin Wilder, an extreme and consistent threat to DOC security was released from his most recent sentence. I notified over radio that he left in a black Kamacho with a man named Jackson. Not shortly after, a recently released inmate by the name of Billy P. notified law enforcement that Wilder and co. were planning hostile action against the DOC. Per this notification, CERT was activated especially due to only one PD unit being on duty at the time.
  
  Chris Whittle and Vito Saint responded to the CERT pager, assisting us in setting up. In co-ordination with law enforcement, we cited approximately 3 individuals in at least two vehicles that were considered to be a part of the hostile action. At the very least Corbin Wilder and Jack Goodnight were ID'd as a part of the planned hostile action. CERT placed themselves into optimal angles in an effort to assess and respond as necessary. Lt. Lee deployed a sniper rifle as a part of his response.
  
  George Hill of METRO informed us that they were planning to shoot and were scouting our operatives out. Operatives re-positioned themselves or placed themselves in positions to countersnipe. A black Kamacho and reddish-orange motorbike continuously circled DOC, despite being given countless trespass warnings.
  
  This back and forth of positioning ourselves to counter their advances resulted in a bit of a stalemate for approximately 30 minutes-an hour. I and Lt. Lee came to the conclusion that one side would have to escalate eventually and we'd prefer it to be us. Coming back from MD after Lt. Lee suffered an Oopsie-Daisy with falling from a tower, we co-ordinated with the units at DOC and law enforcement to hit the now foot mobilized 10-15s from the front and back at the same time, pincering them. This plan worked extremely well, resulting in an instant detain out of 2/3 suspects and one vehicle extremely damaged, retreating and being caught by law enforcement. The suspects were identified as: Johnathan Steinberg, Jack Goodnight and Corbin Wilder.
  
  During their processing, Johnathan got into a fistfight with myself and took me down. Otherwise, no guards were intentionally injured. Overall I am extremely happy with the deployment and find my fellow operatives efforts admirable.
  
  As you can see based of the CERT Reports, this is a Occurring situation that will keep happening, These reports are only for when CERT is called. This is not adding when General staff / NON CERT are also dealing with. Which is mostly a every night situation.
  
  I will attempt to find as much body-cam as I can to help with this request.
  
  Regarding proof that Mr Jack Goodnight has been informed and he is fully aware acknowledging this is below.
  Trespass Email to and from Jack Goodnight
  
  Oliver Dutch wrote: ↑Thu Feb 01, 2024 8:52 pm
  Oliver Dutch wrote:Wed Jan 17, 2024 4:21 pm
  
  S.A.D.O.C. Command
  Notice of Tresspass
  January 17th, 2024
  
  Dear Mr. Goodnight,
  
  It's with this email that I am officially notifying you are no longer permitted on San Andreas Department of Corrections property except if brought in by law enforcement for the purpose of serving a sentence. Any other times that you enter the property or stay on the property for any longer than absolutely necessary after your sentence expires you will be charged immediately with NM06 - Trespassing.
  
  Please find attached the official Notice of Trespass:
  
  ► Show Spoiler
  
  Document 1 | Filed 17/JAN/2024 | Page 1 of 1
  
  TRESPASS WARNING
  IN THE STATE OF SAN ANDREAS
  
  ISSUED TO
  
  Name: Jack Goodnight
  Phone Number: 4856296
  
  NOTICE OF TRESPASS
  
  This notice is to inform you that you are NOT authorized, permitted, or invited to enter or remain on the property located at:
  
  70 Route 68 -- Bolingbroke Penitentiary San Andreas Department of Corrections
  
  You are further advised that if you trespass on said property, law enforcement officers are authorized to pursue criminal charges of NM06 - Trespassing and any other relevant charge. Any previous authorizations to enter or remain on the property are hereby revoked.
  
  Oliver Dutch
  Property Owner/Licensed Manager
  
  Kind regards,
  
  Oliver Dutch
  Captain of Administration
  San Andreas Department of Corrections
  [email protected]
  
  -------- Original Message --------
  Subject: Re: Notice of Trespass
  Date: Wed Jan 17, 2024 12:42 pm
  From: Jack Goodnight
  To: Corbin Wilder, Oliver Dutch
  
  Jack Goodnight wrote: To whom it may concern,
  
  With all due respect a notice of trespass does not scare me. A few months at MRPD is nothing and will not deter me from SADOC. In fact all this notice of trespass has done is made me more upset and more willing to do something. You all at the department of corrections just cannot leave things alone. Are you all still really that upset about the radio? One last thing, and again with all due respect but I think you know where to shove that notice. Also, ammonia nitrate is a wonderful thing and has many uses besides just fertilizing.
  
  Kind regards,
  
  Jack Goodnight
  Witness Affirmation
  I, Issei Schneider, 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,
  
  Issei Schneider
  Assistant Warden - CERT Commander
  Department of Corrections
  
  Date: [01/FEB/2024]

Attorney General
Director of Public Notary
San Andreas Judicial Branch
(909) 505-9925 — [email protected]

Post by **Mary Burrows** » Tue Mar 12, 2024 3:59 pm

Response
State of San Andreas v. Frank Haswell

To whom it may concern,

While I do understand the prosecutions invasion of privacy on Jack Goodnights employment history and his attempts to live a normal life, the whole reason that the defendant was indicted was because of ex-corporal Jack Goodnights items being stolen from his locker.

How can we not trust the person who completely is responsible for the defendants charges.

And yes what the prosecution is doing is unheard of and borderline goes against the code of ethics. The prosecution has deliberately exposed Mr. Goodnights Arrest Records which should be kept private to Law Enforcement Personnel and members of the prosecution ONLY. The courts should not be looking at outside evidence regarding ANYTHING about the court case unless it has been accepted in an order for discovery. The witness statement from Assistant Warden Schneider should not be taken into consideration unless placed and accepted by the courts in a motion for discovery.

Again I would like to reiterate that the sole purpose the defendant Frank Haswell is being charged is because of robbery of a government employee at the time. If we cannot trust the person who was supposedly “robbed” (which can be seen that Mr. Haswell was given permission) why are we even arguing about this case? If the victim of the crime is not able to be a sole witness then that should prove that the situation is not how we thought it was.

Respectfully,

Mary Burrows
Associate
Bar Certified Attorney
☏ 339-5979

Post by **Hope Kant** » Tue Mar 12, 2024 4:21 pm

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

Honorable Justice Mason and pertaining parties,

If the prosecution is required to present each piece of information as an exhibit, we will. However what we have done is presented each piece of information as it relates to the motion to suppress, not as it relates to the case at hand. To reiterate our point, we have "5 recorded times that Mr. Goodnight affirmed the fact that no one was allowed access into his SADOC locker" after he was read his Miranda Rights.

The Prosecution said it best when they stated, that each fact presented in the motion to suppress "lends towards the assumption that Mr. Goodnight can no longer be considered a trusted witness. His statement shown in Exhibit #10 was made during a time where he still had a good reputation and standing within the community. Mr. Goodnight has since lost that standing and has made it his mission to target SADOC". We ask for the Justice on the case to see through the lies to what a reasonable person would believe, Mr. Goodnight gave his initial statement truthfully and has since changed his statement to reflect his current negative standing with the SADOC.

Thank you for your time and review. This will be the last notice we will post until the Justice on the case responds.

Respectfully,

Attorney General
Director of Public Notary
San Andreas Judicial Branch
(909) 505-9925 — [email protected]

Post by **Judith Mason** » Tue Apr 09, 2024 1:17 am

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. Frank Haswell
#23-CM-0103

A decision was reached in the above case on the 9th day of April, 2024.

The court thanks the parties involved for their patience while these recent motions have been reviewed. With careful consideration, the court has made a determination on the pending pretrial exhibits and thus shall issue this following decision.

The prosecution's 28/FEB Motion for Discovery of Exhibit #11 and Exhibit #12 is hereby granted.

The defense's 08/MAR Motion to Suppress is hereby denied.

The court has determined that the CCTV footage in Exhibit #7 and the close-up images of the knives in evidence are deemed relevant to the case and charges in question and are, thus, considered admissible. While the knives themselves might not necessarily be considered illegal as presumed by the defense, the prosecution has asserted that the knives had been unlawfully taken by the defendant, constituting a violation of GF02 - Robbery of a Government Employee. With the knives being part of the basis for this charge, the court has determined that these exhibits are relevant and admissible.

The court has further determined that the questioning of Jack Goodnight in Exhibit #10 is admissible as well. The declarant in this exhibit, Jack Goodnight, is offering testimony about their own actions, observations, and is not attempting to relay any information from a third party as a method to prove the truth, but rather giving direct testimony of his own first-hand experiences. This testimony, by definition, is not considered hearsay.

When it comes to the images included in Exhibit #12, the court will similarly be denying suppression as the exhibits have been determined to be relevant. As asserted by the prosecution, the labels shown in the images were used during the investigation to ascertain what the defendant may have been doing in the evidence locker, which led to further investigation by law enforcement officers. While the physical location of the shelves may have changed since the original incident, the prosecution is focusing on another aspect of the images (i.e. the labels). The court has determined that this exhibit serves to illustrate the process of law enforcement officers during their investigation of the incident, and therefore, is relevant and admissible.

The defense's 12/MAR Motion for Discovery is granted and the prosecution's subsequent Motion to Suppress is denied, however, the defense's Motion for Involuntary Dismissal is denied.

To start, the court will not be granting a Motion for Involuntary Dismissal simply based off of a single additional statement that appears to contradict the witness's previous assertions - this portion of the motion is denied.

The new statement from Jack Goodnight will be considered admissible and relevant to the case as Mr. Goodnight's original testimony has been used as basis for some of the defendant's charges. For the court to determine that either Mr. Goodnight's previous statements or his new statements are inadmissible would effectively prejudice the case in favor of one party or another, as the court would be making a preliminary determination that either statement holds more weight outside the bounds of the criminal trial.

The court will allow both statements to remain admissible and would instruct parties to make their arguments for and against each statement during examination and cross-examination at trial. The veracity and reliability of the statements can certainly be called into question and examined at trial, but the court will not be suppressing either statement at this time.

To address some of the other concerns recently raised by the parties involved, the prosecution is well within their rights to be suspicious of the statement provided by Mr. Goodnight, and the arguments and timeline posed by the prosecution to discredit the recent statement is valid, however as stated above, these arguments are best saved for trial, when the witness's credibility may be called into question during direct or cross-examination. It is accepted practice that parties may attempt to impeach a witness by attacking their reliability as a witness, which may include references to relevant criminal convictions.

As for the witness statement from Assistant Warden Issei Schneider, this court will not require that the prosecution present this piece of evidence through a Motion for Discovery unless they intend to use the statement at trial. Pretrial matters as it relates to admissibility of evidence is not held to the same standard of beyond a reasonable doubt nor are the requirements the same when it comes to matters of admissibility and suppression. The defense is more than welcome to question the statement, as they have so done, but unless the prosecution wishes to present the testimony as evidence at trial, it will not be viewed as, nor held to, the same standard as an admissible witness statement intended to be used as evidence at trial.

Unless any other pretrial matters arise within the coming days, a Notice of Scheduling will be issued later this week and this case will be pending trial.

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

Post by **Hope Kant** » Tue Apr 09, 2024 3:21 am

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

MOTION FOR CONTINUANCE

IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Frank Haswell
23-CM-0103

A Motion for Continuance was filed in the above case on the 9th of April, 2024.

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: New Evidence to be submitted
- Detailed Explanation: Given the recent ruling by Associate Justice Judith Mason, the prosecution is now forced to create and submit another motion for discovery as evidence to impeach the witness. The judge on the case has ruled that any impeachment must be done at trial despite the overwhelming evidence to reasonably suggest the defendant is lying. We feel this would be understandable, if the witness were giving an in person statement and the prosecution was directly allowed to ask questions.
  
  The judge ruled the prosecutions argument as valid, therefore it had/has legal merit. The prosecution feels they have more than proven beyond a reasonable doubt that Jack Goodnight has lost his once retained credibility. However we will now require time from the courts to collect and submit facts into evidence that will allow us to properly cross-examine and impeach the written witness statement of Mr. Goodnight.
  
  As the prosecution will be submitting impeachment evidence that does not include exculpatory or inculpatory evidence. The evidence should not slow the case down more than the time required for the prosecution to formulate and submit the evidence to the courts and the defense to review and prepare. We are requesting a maximum of 7 days or the point of submission, whichever comes first.

Attorney General
Director of Public Notary
San Andreas Judicial Branch
(909) 505-9925 — [email protected]

Post by **Jack Goodnight** » Tue Apr 09, 2024 5:36 am

I, Jack Goodnight would like to go on record in saying that I do not appreciate Attorney General Hope Kant defaming my character. I paid my debt to society by serving my time at Bolingbroke Penitentiary. Attorney General Kant is merely speculating that I would be lying. Speculation is not evidence, so once again I would appreciate if Attorney Kant would stop calling me a liar and to stop accusing me of perjury as I have done no such thing. I also would like to bring up that Attorney General Kant defaming my character is costing me financial, and emotional distress. I am a changed person!

Signed of my own volition,

Jack Goodnight

Post by **Judith Mason** » Tue Apr 09, 2024 6:24 am

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

Mr. Goodnight,

While I can understand your concerns, you are not permitted to comment directly on the public docket without a prompt from myself as the presiding judge. Your role in this case is to provide your own testimony, through the proper channels, of the events that resulted in the charges against the defendant, Frank Haswell, and not to provide any commentary on the arguments made by the parties involved. Should you be formally charged with any crime at some point in the future, you will have the opportunity to defend yourself just like any other defendant, however, this is neither the time nor venue. Please refrain from any additional commentary on these proceedings.

Respectfully,

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

Post by **Mary Burrows** » Tue Apr 09, 2024 2:42 pm

Response
State of San Andreas v. Frank Haswell

To whom it may concern,

The Defense vehemently opposes the State's Motion for Continuance filed on the 9th of April, 2024. We contend that granting such a motion would unduly prolong the legal proceedings and infringe upon the defendant's fifth amendment right to a speedy trial as this case has been going on for 6 months.

Firstly, we assert that the State's reasoning for requesting a continuance is unsubstantiated and lacks merit. The purported need for additional time to collect and submit evidence for impeachment purposes appears to be a strategic maneuver rather than a genuine necessity. The previous ruling by Associate Justice Judith Mason explicitly acknowledged the validity of the prosecution's arguments regarding the witness's credibility. The court rightly concluded that any challenges to the witness's reliability should be addressed during trial proceedings, where both parties will have the opportunity to present their arguments and examine the witness thoroughly.

Moreover, the Defense emphasizes that the State has already been granted ample opportunities for discovery, as evidenced by the court's previous rulings granting the prosecution's motions for discovery of exhibits. The defense has diligently complied with all pretrial requirements and has not hindered the prosecution's efforts to gather evidence or prepare their case.

Granting the State's Motion for Continuance would not only delay the resolution of this case but would also impose unnecessary burdens on the court and the defendant. The Defense asserts that the prosecution's request for an additional seven days to submit evidence is unwarranted, especially considering the lack of new developments or unforeseen circumstances that would justify such an extension.

Furthermore, it is essential to uphold the principles of fairness and expediency in the administration of justice. Allowing the State to delay proceedings without sufficient cause would undermine these principles and undermine the defendant's constitutional right to a speedy trial.

In conclusion, the Defense urges the court to deny the State's Motion for Continuance and proceed with the trial as scheduled. Any concerns regarding witness credibility or evidentiary matters can be addressed during trial proceedings, where both parties will have the opportunity to present their arguments and evidence fully. Granting the continuance would serve no purpose other than to unnecessarily prolong the legal process and infringe upon the defendant's rights.

On a separate note my client Jack Goodnight does have a valid point. Hope Kant has been trying to defame a person who has had a rough past. There have been MANY and I mean MANY people who hold high positions in government agencies who have criminal background, but they were given a chance to prove they can change. This is all that Mr. Jack Goodnight is asking for. A chance to prove that he has changed from his horrid ways.

Respectfully,

Mary Burrows
Associate
Bar Certified Attorney
☏ 339-5979

Post by **Hope Kant** » Thu Apr 11, 2024 8:06 pm

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

Honorable Judge Mason and pertaining parties,

The prosecution would like to being by reviewing the civil case discussed inside of our criminal case. To start, being accused of a crime does not equal defamation. People are accused of crimes everyday by law enforcement officers or prosecutors, and they either accept their guilt or see their day in court. That is the purpose of our penal code and the Constitution. It is not defamation for the prosecution to accuse you of perjury.

As has been established, SAJB does not have civil court at the moment. However, lets review what is needed to prove defamation. A plaintiff must show four things:
- 1) a false statement purporting to be fact;
  2) publication or communication of that statement to a third person;
  3) fault amounting to at least negligence; and
  4) damages, or some harm caused to the reputation of the person or entity who is the subject of the statement.
The prosecution is accusing Mr. Goodnight and attempting to impeach him via proof and evidence. This is neither defamation nor is it untrue as these are uncontested arrest reports and therefore not false or defamatory statements.

Let us now move back and address the case at hand. The defense reports that there has been no new evidence that would require the prosecution to present counter evidence or need more time. They state, "especially considering the lack of new developments or unforeseen circumstances that would justify such an extension." The prosecution would like to point directly to the evidence submitted by the defense council. This is both a new development and an unforeseen circumstance that would justify such an extension, as it was enough evidence for the defense to feel they could motion for involuntary dismissal.

We will be preparing our discovery in the coming days and moving forward with the case. Thank you to both the defense and the Judge on the case for their patience.

Respectfully,

Attorney General
Director of Public Notary
San Andreas Judicial Branch
(909) 505-9925 — [email protected]

Post by **Mary Burrows** » Fri Apr 12, 2024 5:11 pm

Response
State of San Andreas v. Frank Haswell

To whom it may concern,

Firstly, we maintain that the prosecution's characterization of our presentation of new evidence as both a "new development" and an "unforeseen circumstance" is inaccurate. The evidence submitted was not only disclosed within the stipulated time frame but also well within the bounds of discovery protocol. The prosecution has had a full month to review this evidence, which we believe is an ample amount of time to construct a compelling argument in response.

Furthermore, it is essential to clarify that the burden of preparation lies squarely with the prosecution. They are obligated to diligently review all evidence, regardless of when it is presented, to ensure a thorough and fair trial. It is not the fault of the defense if the prosecution has failed to allocate sufficient time and resources to adequately address the evidence we have presented.

Therefore, we respectfully request that any delays or perceived shortcomings in the prosecution's rebuttal not be attributed to the actions or responsibilities of the defense. We are prepared to proceed with the case as scheduled and await further instruction from the court regarding the motion for scheduling so that we can go to trial for this case.

Thank you for your attention to this matter.

Respectfully,

Mary Burrows
Associate
Bar Certified Attorney
☏ 339-5979

Post by **Hope Kant** » Fri Apr 12, 2024 10:16 pm

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. Frank Haswell
#23-CM-0103

A Motion for Discovery was filed in the above case on the 12th of April, 2024.

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

Exhibit #14: Jack Goodnight Chronology of Events
1. SADOC Honorable Discharge
  - Date: Aug 08, 2023
  - Location: Government Website
  - Incident Discription: Honorable Discharge: #891 Jack Goodnight
2. SADOC Reinstatement Application
  - Date: Sep 23, 2023
  - Location: Government Website
  - Incident: SADOC Reinstatement - Jack Goodnight denied due to an HR decision.
3. LSSD Application
  - Date: Oct 15, 2023
  - Location: Government Website
  - Incident: LSSD Application - Jack Goodnight ((NA)) denied due to "Poor recommendation from previous employer."
4. SADOC Reinstatement
  - Date: Oct 28, 2023
  - Location: Government Website
  - Incident: [SADOC Reinstatement - Jack Goodnight denied for the second time.
5. SADOC Reinstatement
  - Date: Jan 03, 2024
  - Location: Government Website
  - SADOC Reinstatement - Jack Goodnight denied for the third time.
6. SADOC Related Arrest
  - Date: Jan 11, 2024
  - Location: SADOC
  - Charge(s): NM06 - Trespassing
  - Incident: Jack Goodnight was arrested for trespassing on SADOC grounds.
7. SADOC Related Arrest
  - Date: Jan 13, 2024
  - Location: SADOC
  - Charge(s): VF01 - Evading an Officer, GM04 - Resisting Arrest
  - Incident: Jack Goodnight was arrested when Law Enforcement Officers were called to SADOC due to Mr. Goodnights attempt to take a hostage. They fled in a vehicle upon Law Enforcement response.
8. SADOC Related Arrest
  - Date: Jan 14, 2024
  - Location: SADOC
  - Charge(s): NM06 - Trespassing, WM01 - Unlawful Brandishing of a Firearm or Weapon
  - Incident: Jack Goodnight was arrested when DOC contacted SD regarding an individual they had in custody that brandished a knife at a DOC guard and trespassed
9. SADOC Notice of Trespass
  - Date: Jan 17, 2024
  - Location: Government Website
  - Incident: Notice of Trespass - Jack Goodnight, San Andreas Department of Corrections
10. SADOC Related Arrest
  - Date: Jan 21, 2024
  - Location: SADOC
  - Charge(s): VF01 - Evading an Officer, NM06 - Trespassing
  - Incident: Jack Goodnight was arrested when a deputy arrived at DOC where he saw DOC officers attempting to arrest Mr. Goodnight for lingering on their property.
11. SADOC Related Arrest
  - Date: Jan 26, 2024
  - Location: SADOC
  - Charge(s): GM10 - Failure to Comply / Identify, GM04 - Resisting Arrest
  - Incident: Jack Goodnight was arrested when LSSD was informed via the department radio that Mr. Goodnight and his friend pulled a knife on DOC guard and were refusing to leave yet again
12. SADOC Related Arrest
  - Date: Feb 22, 2024
  - Location: SADOC
  - Charge(s): GM02 - Battery of a Gov. Employee
  - Incident: Jack Goodnight was arrested after being released from DOC. He immediately tackled a DOC guard in front of Officer Conrad. Mr. Goodnight was placed in handcuffs, an read his rights. Mr.Goodnight then attempted to kick a DOC guard.
13. SADOC Related Arrest
  - Feb 24, 2024
  - Location: SADOC
  - Charge(s): GM19 - Face Concealment (b), WF01 - Assault with a Deadly Weapon of a Gov. Employee
  - Incident: Jack Goodnight was arrested when Mr. Goodnight was witnessed on DOC Bodycam attacking correctional officers with deadly weapons, while wearing a facemask.
Exhibit #15: Assistant Warden Issei Schneider Witness Statement
San Andreas Judicial Branch
Official Witness Statement
"HERE FOR YOU | SAFE FOR YOU"

Case Information
- Case Number: [Case Number]
  Incident Date: [01/JAN/2000]
Witness Information
- Name: [Issei Schneider]
  Date of Birth: [22/AUG/2002]
  Phone Number: [207-8799]
  Occupation: Department of Corrections - Assistant Warden and CERT Commanding Officer
Witness Statement
- Hello,
  
  I would like to start with the Mr Jack Goodnight is a current threat to the SADOC and is cleared by High Command and CERT Commanding officer that if Jack Goodnight is to remain at the front of DOC he will be arrested for Trespassing. This decision is based off the actions that they are silly enough to do such as Active shooting / Drive by of Prison Officers. Mr Goodnight followed with Mr Corbin Wilder is known for trying SADOC such as harrasing DOC guards, Kidnapping them, Shooting at Active criminal transports putting our Guards, Convicts and Civilians in danger and also with that Shoot at guards when transporting Injured Inmates and Guards to LSEMS at Pillbox for Advanced treatment with MD's AMU division.
  
  This is a team based situation and they do not like how we have responded to there hostile activities, We have resorted to Trespassed on sight when asked to leave and Keep in a cell for the entire stay if they do anything silly such as fighting, Threatening and so on. I have also cleared my CERT Operatives and Guards to partner up as Mr Goodnight is known to come to DOC a lot for hostile issues that we at DOC are tired of.
  
  Based off this though Mr Goodnight does not like that we have made this a thing and also they have been informed VIA email and they responded violently over email and in person. From this they MAY ONLY be allowed at DOC when they are released to collect there possessions but after THEY MUST LEAVE, They will only be given 1 warning then refusing to leave will result in a ARREST with no questions asked.
  
  Here is the SAJB - Notices of Trespass for Jack Goodnight
  
  This has been an occurring thing for Months now.
  
  FILE REDACTED FOR SECURITY PURPOSES
  
  CERT Reports Involving Jack Goodnight
  
  21 Jan 2024, 20:51
  
  CERT Situation Report
  
  Date:
  
  Officers name: Riley Ryker
  
  Other CERT staff: Gina Willow
  
  Non CERT staff(Officers, other inmates, visitors): Lewis Gensen
  
  Rank within CERT: Divisional Trainee
  
  Weapon(s) deployed: Pump Shotgun
  
  Conclusion: Ended up doing a full cellblock lockdown until the rest of the unfinished business was finished.
  
  Situation
  
  Multiple MSI's and HVT's were brought to DOC such as Jack Goodnight, Corbin Wilder and Scott Banks, they were threatening a riot, there was alot of fighting and endless treatments were done in medbay, we decided to do a full lockdown since there were alot of hostile inmates threatening to kill guards, it ended up with us fully locking the cellblock down and finishing our business.
  
  15 Jan 2024, 01:18
  
  CERT Situation Report
  
  Date: 14/01/2023
  
  Officers name: Chris Whittle
  
  Other CERT staff: Alex Pedolski, Galileo Czapiewski, Rock Paz, Bogdan Fernandez
  
  Non CERT staff(Officers, other inmates, visitors): Bradley Coot, the entirety of PD/SD.
  
  Rank within CERT: Operative.
  
  Weapon(s) deployed: Pump Shotgun Mk II, Carbine Mk II, unsure of others.
  
  Conclusion: All the 10-15s were brought in and processed. Jack Goodnight was arrested, Corbin and 'Juan' got bored and left us alone for 5 minutes.
  
  Situation
  
  The whole situation initially started when assistance was called out on department radio about a HVT transport containing an unconfirmed number of 10-15s. We CERTed up and Alex pressed the CERT pager. We headed down to the city to assist with it. Once we reached Mission Row we assembled and began to load the 15s into the TARVs. We then noticed a Kamacho which looked extremely familiar. Funnily enough it contained DOC's favourite duo, Jack Goodnight and Corbin Wilder. Rock disabled their Kamacho with the brickade which was not to their liking. After a protracted interaction we formed back up with the transport and proceeded to take the 15's to DOC where they were processed without issue. Jack goodnight was brought into custody by PD and was processed too due to something he'd done at the transport scene. We maintained in CERT gear due to the present threat of the orange nightmare, Corbin, still remaining free. As luck would have it he decided to make his presence known, again, and he decided to just cause us a headache for a bit. We attempted to get someone from PD & SD to come down and charge them with trespassing however this fell on deaf ears. In the end they left of their own free will once myself and Bradley had 10-15s to process.
  
  13 Jan 2024, 17:49
  
  CERT Situation Report
  
  Date:13/JAN/2024
  
  Officers name:Randy Lee
  
  Other CERT staff:
  22-DELTA - Senior Operative In-Training Remmi Raccoon
  25-JULIET - Operative Vito Saint
  1-ZULU - Probationary Operator Jerry Brooks
  
  Non CERT staff(Officers, other inmates, visitors):
  #1030 - [CO-86] - Correctional Officer II Alex Nieves
  #521 - [WARDEN-01] - Warden Kourtney LaFleur
  SD Hugo
  
  Rank within CERT: Senior Operative
  
  Weapon(s) deployed:
  Pistol MK2
  Shotgun MK2
  Carbine MK2
  
  Conclusion: Kamacho Stolen, HVT transported from SADOC-Pillbox-SADOC
  
  Situation
  
  After already stressful day filled with threats on SADOC officers life (viewtopic.php?p=746057#p746057) SD Special Enforcment Division did what other department refused to do and come to SADOC too stop a active kidnapping attempt by Jack Goodnight and Corbin.
  
  The pair fled when SED showed up and after a chase the two were brought back to SADOC and During the processing Corbin was injured and required a trip to pillbox.
  
  While at pillbox, Jerry Brooks left his car running when he unlocked it to get the injured Corbin out and in that SPILT SECOND the Kamacho was stolen.
  
  22-DELTA - Senior Operative In-Training Remmi Raccoon then left SADOC to race to the city to see if she could find it while everyone else loaded Corbin back in and got him back to SADOC.
  
  From there he was placed and solitary
  
  11 Jan 2024, 02:29
  
  CERT Situation Report
  
  Date: 10/01/2023
  
  Officers name: Jerry Brooks
  
  Other CERT staff: Randy Lee, Remmi Raccoon, Vito Saint, Chris Whittle, Galileo Czapiewski
  
  Non CERT staff(Officers, other inmates, visitors): Officer Zinnia Rose, Chad Rapkov of Weazel News
  
  Rank within CERT: Probationary Op.
  
  Weapon(s) deployed: Remington 870, Sniper Rifle, Carbine Rifle, SMG
  
  Conclusion: 3 suspects detained, 1 guard injured, 1 guard accidentally injured.
  
  Situation
  
  A detailed description of the situation
  Corbin Wilder, an extreme and consistent threat to DOC security was released from his most recent sentence. I notified over radio that he left in a black Kamacho with a man named Jackson. Not shortly after, a recently released inmate by the name of Billy P. notified law enforcement that Wilder and co. were planning hostile action against the DOC. Per this notification, CERT was activated especially due to only one PD unit being on duty at the time.
  
  Chris Whittle and Vito Saint responded to the CERT pager, assisting us in setting up. In co-ordination with law enforcement, we cited approximately 3 individuals in at least two vehicles that were considered to be a part of the hostile action. At the very least Corbin Wilder and Jack Goodnight were ID'd as a part of the planned hostile action. CERT placed themselves into optimal angles in an effort to assess and respond as necessary. Lt. Lee deployed a sniper rifle as a part of his response.
  
  George Hill of METRO informed us that they were planning to shoot and were scouting our operatives out. Operatives re-positioned themselves or placed themselves in positions to countersnipe. A black Kamacho and reddish-orange motorbike continuously circled DOC, despite being given countless trespass warnings.
  
  This back and forth of positioning ourselves to counter their advances resulted in a bit of a stalemate for approximately 30 minutes-an hour. I and Lt. Lee came to the conclusion that one side would have to escalate eventually and we'd prefer it to be us. Coming back from MD after Lt. Lee suffered an Oopsie-Daisy with falling from a tower, we co-ordinated with the units at DOC and law enforcement to hit the now foot mobilized 10-15s from the front and back at the same time, pincering them. This plan worked extremely well, resulting in an instant detain out of 2/3 suspects and one vehicle extremely damaged, retreating and being caught by law enforcement. The suspects were identified as: Johnathan Steinberg, Jack Goodnight and Corbin Wilder.
  
  During their processing, Johnathan got into a fistfight with myself and took me down. Otherwise, no guards were intentionally injured. Overall I am extremely happy with the deployment and find my fellow operatives efforts admirable.
  
  As you can see based of the CERT Reports, this is a Occurring situation that will keep happening, These reports are only for when CERT is called. This is not adding when General staff / NON CERT are also dealing with. Which is mostly a every night situation.
  
  I will attempt to find as much body-cam as I can to help with this request.
  
  Regarding proof that Mr Jack Goodnight has been informed and he is fully aware acknowledging this is below.
  Trespass Email to and from Jack Goodnight
  
  Oliver Dutch wrote: ↑Thu Feb 01, 2024 8:52 pm
  Oliver Dutch wrote:Wed Jan 17, 2024 4:21 pm
  
  S.A.D.O.C. Command
  Notice of Tresspass
  January 17th, 2024
  
  Dear Mr. Goodnight,
  
  It's with this email that I am officially notifying you are no longer permitted on San Andreas Department of Corrections property except if brought in by law enforcement for the purpose of serving a sentence. Any other times that you enter the property or stay on the property for any longer than absolutely necessary after your sentence expires you will be charged immediately with NM06 - Trespassing.
  
  Please find attached the official Notice of Trespass:
  
  ► Show Spoiler
  
  Document 1 | Filed 17/JAN/2024 | Page 1 of 1
  
  TRESPASS WARNING
  IN THE STATE OF SAN ANDREAS
  
  ISSUED TO
  
  Name: Jack Goodnight
  Phone Number: 4856296
  
  NOTICE OF TRESPASS
  
  This notice is to inform you that you are NOT authorized, permitted, or invited to enter or remain on the property located at:
  
  70 Route 68 -- Bolingbroke Penitentiary San Andreas Department of Corrections
  
  You are further advised that if you trespass on said property, law enforcement officers are authorized to pursue criminal charges of NM06 - Trespassing and any other relevant charge. Any previous authorizations to enter or remain on the property are hereby revoked.
  
  Oliver Dutch
  Property Owner/Licensed Manager
  
  Kind regards,
  
  Oliver Dutch
  Captain of Administration
  San Andreas Department of Corrections
  [email protected]
  
  -------- Original Message --------
  Subject: Re: Notice of Trespass
  Date: Wed Jan 17, 2024 12:42 pm
  From: Jack Goodnight
  To: Corbin Wilder, Oliver Dutch
  
  Jack Goodnight wrote: To whom it may concern,
  
  With all due respect a notice of trespass does not scare me. A few months at MRPD is nothing and will not deter me from SADOC. In fact all this notice of trespass has done is made me more upset and more willing to do something. You all at the department of corrections just cannot leave things alone. Are you all still really that upset about the radio? One last thing, and again with all due respect but I think you know where to shove that notice. Also, ammonia nitrate is a wonderful thing and has many uses besides just fertilizing.
  
  Kind regards,
  
  Jack Goodnight
Witness Affirmation
- I, Issei Schneider, 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,
  
  Issei Schneider
  Assistant Warden - CERT Commander
  Department of Corrections
  
  Date: [01/FEB/2024]

Attorney General
Director of Public Notary
San Andreas Judicial Branch
(909) 505-9925 — [email protected]

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