Eclipse Government

• Docket Number:
  #23-CM-0103
  Date Filed:
  30/OCT/2023
  Violations:
  GF02 - Robbery of a Government Employee
  GF16 - Tampering with Evidence
  GM14 - Obstruction of Justice
  State of San Andreas
  
  v.
  
  Frank Haswell

• THE PROSECUTION CHARGES THAT:
  
  1. Previously employed CCO Frank Haswell was seen on CCTV footage taking items from both his locker and a fellow employees locker. Locker stands for the evidence locker placed behind the front desk at SADOC. CCO Haswell was later seen on CCTV footage filling two bags before heading to the locker room to clock off shift.
  2. An investigation was done into whether or not he had permission to enter his fellow correctional officers locker, and he did not. Opening up the locker of CCO Haswell, Investigator Whitehorse found a hoard of items totaling up to 280,000 in value. While there is no telling whether or not he stole these items, he did fill two bags with items prior to exiting the building.
  3. The Prosecution believes a reasonable person would assume CCO Haswell was attempting to conceal evidence as he knew he was being investigated due to the questioning from Invesitgator Whitehorse. It is for these reasons that the Prosecution in conjunction with the SADOC would like to file the above charges.

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

• Docket Number:
  #23-CM-0103
  Date Filed:
  30/OCT/2023
  Violations:
  GF02 - Robbery of a Government Employee
  GF16 - Tampering with Evidence
  GM14 - Obstruction of Justice
  State of San Andreas
  
  v.
  
  Frank Haswell

• Notice is given that Frank Haswell is ordered to respond using the Plea Form below between the dates of;
  • 30/OCT/2023
    • and
  • 07/NOV/2023
  Or make contract with the presiding judge;
  
  For the purpose of an Arraignment.

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

• Docket Number:
  #23-CM-0103
  Date Filed:
  30/OCT/2023
  Violations:
  GF02 - Robbery of a Government Employee
  GF16 - Tampering with Evidence
  GM14 - Obstruction of Justice
  State of San Andreas
  
  v.
  
  Frank Haswell

• Frank Haswell you are facing misdemeanor and felony charges for alleged conduct that occurred on or about 17/AUG/2023
  
  This form will formally read you the charges filed against you. You may plead in one of three ways for each charge:
  • Guilty
    A plea of guilty indicates to the court that you confirm your guilt of the alleged conduct that was in violation of Penal Code. If you plead guilty, the charge and fines will be placed on your record and you will have to turn yourself into law enforcement.
  • Not Guilty
    A plea of not guilty indicates to the court that you dispute the charges being filed against you. If you plead not guilty, preliminary pretrial proceedings will begin and a criminal trial will be scheduled in the near future.
  • No Contest
    A plea of no contest is similar to that of a guilty plea, but indicates to the court that you accept the conviction, with the exception of avoiding a factual admission of guilt. If you plead no contest, the charge and fines will similarly be placed on your record and you will have to turn yourself into law enforcement.
  Before the court can accept a plea of guilty or no contest, you must be advised of your rights in this situation.
  1. You have the right to plead not guilty to any and all of these charges.
  2. You have the right to be represented by counsel at trial and at every other stage of the proceedings.
  3. You have the right to testify and present any evidence of your own in your defense against these charges.
  4. You also have the right to not testify during any of the proceedings in accordance with your right to remain silent.
  5. Please be advised that anything you say or do during the proceedings can and will be used against you by the prosecution.
  Frank Haswell, please be aware that any plea you give must be made voluntarily and of your own volition, and did not result from force, threats, or promises made by any person, with the exception of a Plea Agreement that can be arranged between yourself and the prosecution.
  
  Count 1 is GF02 - Robbery of a Government Employee, a felony charge punishable by 75 months of incarceration and a fine of $3,000.
  
  Count 2 is GF16 - Tampering with Evidence, a felony charge punishable by 45 months of incarceration and a fine of $3,000.
  
  Count 3 is GM14 - Obstruction of Justice, a misdemeanor charge punishable by 25 months of incarceration and a fine of $1,000.
  
  The prosecuting is seeking a total of 145 months of incarceration and a total fine of $7,000.
  
  With all previous information in mind, please make your formal plea using the following form;

[img]https://i.imgur.com/UM5h3vl.png[/img]
[img]https://i.imgur.com/6h9z9Jh.png[/img]
[divbox=antiquewhite]
[b]Defendant Name:[/b] Firstname Lastname
[b]Defendant Phone:[/b] ###-####
[b]Defendant Address:[/b] Here
[b][color=#0040FF](([/color] Defendant Discord:[/b] Here [color=#0040FF][b]))[/b][/color]
[b]Requested Attorney:[/b] [i]N/A if none[/i]
[/divbox]
[img]https://i.imgur.com/F76nFHB.png[/img]
[divbox=antiquewhite]
[b]On the charge of GF02 - Robbery of a Government Employee, I am entering a plea as follows:[/b]
[list=none]
[ ] Guilty
[ ] Not Guilty
[ ] No Contest
[/list]

[b]On the charge of GF16 - Tampering with Evidence, I am entering a plea as follows:[/b]
[list=none]
[ ] Guilty
[ ] Not Guilty
[ ] No Contest
[/list]

[b]On the charge of GM14 - Obstruction of Justice, I am entering a plea as follows:[/b]
[list=none]
[ ] Guilty
[ ] Not Guilty
[ ] No Contest
[/list]



[hr][/hr]
I, [b]FIRSTNAME LASTNAME[/b], hereby affirm that this pleading is being made voluntarily and of my own volition, and did not result from force, threats, or promises made by any person, with the exception of a Plea Agreement arranged between myself and the prosecution.
[/divbox]

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

• [ ] Guilty
  [X] Not Guilty
  [ ] No Contest

• [ ] Guilty
  [X] Not Guilty
  [ ] No Contest

• [ ] Guilty
  [X] Not Guilty
  [ ] No Contest

• Exhibit #1: SADOC Investigator Julia Whitehorse Witness Statement

  

  

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

  Case Information

  • Case Number: [Case Number]
    Incident Date: 17 of August 2023

  Witness Information

  • Name: [Julia Whitehorse]
    Date of Birth: [17/05/1995]
    Phone Number: [299-8974]
    Occupation: [Captain of Departmental Administration, Investigator at San Andreas Department of Correction]

  Witness Statement

  • [On Arround the 17 of August 2023, at 8 AM, Myself, Captain Julia Whitehorse, and Senior Correctional Officer Remmi Raccoon headed to San Andreas Department of Correction evidence locker in order to store items from 10-15s, once entered the room they discovered the presence of multiple Knives on the ground. An investigation opened on the spot by myself in order to determine the cause of the presence of around 10 knives on the ground of the evidence locker. While collecting all the evidence and categorising them, Correctional Custodian Officer Frank Haswell entered the evidence locker, I asked the CCO Haswell, if he is aware of the present knives on the ground, the CCO responded as follow:

    i actually do, i found a bag on the ground in the front desk hall, so i wanted to clean the area at that moment i took the bag inside and throw it.

    
    
    At that moment, Investigator Whitehorse checked the CCTV and discovered that there was no bag on the ground, the only bag that was on scene was the one Frank having, kept watching the evidence locker room and it was discovered that Frank was looking into a locker and there was a lot of knifes slipping out of a briefcase.
    
    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.
    
    CCO Haswell clocked off, and at that time a check on his locker was performed and here is a list of the findings:
    1. 48x Laundry
    2. 18x Litter
    3. 10x Tin Ore
    4. 4x Gloves
    5. 2x Hats
    6. 1x Shirts
    7. 8x Tops
    8. 4x Shoes
    9. 2x Radio
    10. 6x Neck accessories
    11. 5x Pants
    12. 3x Pickaxe
    13. 3x mask
    14. 1x GPS
    15. 2x Speaker
    16. 1x Glasses
    17. 1x Ball
    18. 1x Charger
    19. 1x Map
    20. 56731x Stamps
    21. 1x Weight Squat Furniture
    22. 4x Bags
    23. 1x Briefcase
    
    
    Investigator Whitehorse, left the area at that time and came back later checking the CCTV to see what Frank was doing in the evidence locker from the moment the investigator left and there it was discovered as follow:
    
    • Once Investigator Whitehorse left the evidence locker room, Frank grabbed two bags from what appears to be his personal locker
    • Frank grabbed some clothing from the same locker.
    • Frank went to the inmates lockers and opened a locker from there grabbing more clothes
    • Frank places all the clothes in the bags he grabbed.
    • all the clothes seemed to be rolled in a way that it hiding something inside
    • Frank stands still and then seen in the locker room clocking off
    
    
    At that time, CCO Haswell was placed on Suspension pending investigation and was invited for interrogation.
    
    On around the 20 of August 2023: Ex SADOC Corporal Jack Goodnight presented himself to DOC in order to collect his personal belongings that he left in his personal locker, It was discovered that all the items in Jack Goodnigt locker are missing and by investigating it, it was discovered that Frank Haswell retrieved all the personal belongings of Jack Goodnight. At that moment of time, CCO Frank was discharged and all the items in his personal locker were seized and confiscated by the San Andreas Department of Correction.
    
    
    Later the same day, Jack Goodnight was invited to interrogation to which he confirmed while mirandized, that he never gave the authority at any point of time from the moment he joined DOC to the moment of the interrogation, the authority to retrieve any of their item. ]

  Witness Affirmation

  • I, [Julia Whitehorse], 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,
    
    
    Julia "Chedhamenou" Whitehorse
    Captain of Departmental Administration
    San Andreas Department of Corrections
    [email protected]
    
    Date: [29/OCT/2023]

  
  
  Exhibit #2: Sergeant Remmi Raccoon Witness Statement

  

  

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

  Case Information

  • Case Number: [Case Number]
    Incident Date: 17/AUG/2023

  Witness Information

  • Name: Remmi Raccoon
    Date of Birth: 09/SEP/1994
    Phone Number: 496-2703
    Occupation: Sergeant at DOC

  Witness Statement

  • On 17/08/2023 I was heading to the evidence locker to put some items away for an inmate. Once I entered the locker area I came across multiple knives on the floor. Confused I asked about it over the radio and Captian Whitehorse came to look at it. Then from there I left the locker room and went on about my shift.

  Witness Affirmation

  • I, Remmi Raccoon, 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,
    
    
    Remmi Raccoon
    Sergeant
    DOC
    
    Date: 31/OCT/1994

  
  
  Exhibit #3: Bodycam Footage of Investigator Whitehorse

  ((RP Proof))

  

  
  
  Exhibit #4: CCTV Footage Part 1

  
  Exhibit #5: CCTV Footage Part 2

  
  Exhibit #7: CCTV Still of Knives on the Ground

  
  Exhibit #8: Showing Number of Knives in Evidence

  
  Exhibit #9: Contents of Frank Haswell's SADOC Locker

  
  Exhibit #10: Questioning of Jack Goodnight

  ((RP Proof))

  

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

• Parties,
  
  With the Order for Discovery now having expired, the defense shall have a period of 72 hours to file any motions in response.
  
  Respectfully,
  
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 257-9183 — [email protected]

• Exhibit #1: SADOC Investigator Julia Whitehorse Witness Statement
  Requested Evidence to Suppress:

  Exhibit #1: SADOC Investigator Julia Whitehorse Witness Statement

  

  

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

  Case Information

  • Case Number: [Case Number]
    Incident Date: 17 of August 2023

  Witness Information

  • Name: [Julia Whitehorse]
    Date of Birth: [17/05/1995]
    Phone Number: [299-8974]
    Occupation: [Captain of Departmental Administration, Investigator at San Andreas Department of Correction]

  Witness Statement

  • [On Arround the 17 of August 2023, at 8 AM, Myself, Captain Julia Whitehorse, and Senior Correctional Officer Remmi Raccoon headed to San Andreas Department of Correction evidence locker in order to store items from 10-15s, once entered the room they discovered the presence of multiple Knives on the ground. An investigation opened on the spot by myself in order to determine the cause of the presence of around 10 knives on the ground of the evidence locker. While collecting all the evidence and categorising them, Correctional Custodian Officer Frank Haswell entered the evidence locker, I asked the CCO Haswell, if he is aware of the present knives on the ground, the CCO responded as follow:

    i actually do, i found a bag on the ground in the front desk hall, so i wanted to clean the area at that moment i took the bag inside and throw it.

    
    
    At that moment, Investigator Whitehorse checked the CCTV and discovered that there was no bag on the ground, the only bag that was on scene was the one Frank having, kept watching the evidence locker room and it was discovered that Frank was looking into a locker and there was a lot of knifes slipping out of a briefcase.
    
    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. - The witness directly quotes the Defendant, making it hearsay, unlike prior quotes, this one is not backed up by CCTV footage or any other additional evidence and should be suppressed. Additionally, the witness goes on to speculate about the intent of the Defendant's alleged actions such as '' it obvious that Frank is hiding something'' and proceeds to analyze the evidence, this is speculation and outside the scope of a witness statement.
    
    CCO Haswell clocked off, and at that time a check on his locker was performed and here is a list of the findings:
    1. 48x Laundry
    2. 18x Litter
    3. 10x Tin Ore
    4. 4x Gloves
    5. 2x Hats
    6. 1x Shirts
    7. 8x Tops
    8. 4x Shoes
    9. 2x Radio
    10. 6x Neck accessories
    11. 5x Pants
    12. 3x Pickaxe
    13. 3x mask
    14. 1x GPS
    15. 2x Speaker
    16. 1x Glasses
    17. 1x Ball
    18. 1x Charger
    19. 1x Map
    20. 56731x Stamps
    21. 1x Weight Squat Furniture
    22. 4x Bags
    23. 1x Briefcase
    
    
    Investigator Whitehorse, left the area at that time and came back later checking the CCTV to see what Frank was doing in the evidence locker from the moment the investigator left and there it was discovered as follow:
    
    • Once Investigator Whitehorse left the evidence locker room, Frank grabbed two bags from what appears to be his personal locker
    • Frank grabbed some clothing from the same locker.
    • Frank went to the inmates lockers and opened a locker from there grabbing more clothes
    • Frank places all the clothes in the bags he grabbed.
    • all the clothes seemed to be rolled in a way that it hiding something inside - The Defense is doubtful that the witness can intuit the nature of how clothes were stored through CCTV without additional evidence confirming these suspicions, making it speculative in nature.
    • Frank stands still and then seen in the locker room clocking off
    
    
    At that time, CCO Haswell was placed on Suspension pending investigation and was invited for interrogation.
    
    On around the 20 of August 2023: Ex SADOC Corporal Jack Goodnight presented himself to DOC in order to collect his personal belongings that he left in his personal locker, It was discovered that all the items in Jack Goodnigt locker are missing and by investigating it, it was discovered that Frank Haswell retrieved all the personal belongings of Jack Goodnight. At that moment of time, - Speculation, assumes facts not in evidence, there is no indication provided during discovery that corroborates this statement. CCO Frank was discharged and all the items in his personal locker were seized and confiscated by the San Andreas Department of Correction.
    
    
    Later the same day, Jack Goodnight was invited to interrogation to which he confirmed while mirandized, that he never gave the authority at any point of time from the moment he joined DOC to the moment of the interrogation, the authority to retrieve any of their item. ]

  Witness Affirmation

  • I, [Julia Whitehorse], 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,
    
    
    Julia "Chedhamenou" Whitehorse
    Captain of Departmental Administration
    San Andreas Department of Corrections
    [email protected]
    
    Date: [29/OCT/2023]

  
  

  • Detailed Reasoning: The highlighted sections above represent what we would like suppressed with a detailed explanation also highlighted.

• Honorable Judge Mason and pertaining parties,
  
  The Prosecution will await notice as for how to proceed and whether or not to recognize the previous motion from the Attorney Raven. As he is now suspended, we await the defendant obtaining council and any Judge direction. Thank you.
  
  Respectfully,
  
  
  Attorney General
  Director of Public Notary
  San Andreas Judicial Branch
  (909) 321-2132 — [email protected]

• Parties,
  
  Now that alternative representation for the defendant has been confirmed, I will allow the defense a period of approximately 72 hours to provide any motions in response to the prosecution's discovery. As for the previously submitted Motion to Suppress filed by former counsel on the 10th of November, I would request that current counsel either confirm the filing of the motion as-is or retract it before it is to be reviewed by the court.
  
  Respectfully,
  
  
  Chief Justice
  San Andreas Judicial Branch
  (909) 257-9183 — [email protected]

Exhibit #10: Questioning of Jack Goodnight

((RP Proof))

it was discovered that Frank Haswell retrieved all the personal belongings of Jack Goodnight.

• Exhibit #11: CCTV Footage Continued

  
  
  

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

• Honorable Judge Daniels and pertaining parties,
  
  We want to start by thanking the courts for allowing myself time for my LOA. I understand this case has gone on longer than normal, but we could consider the length of time it would've taken had I not made an unprecedented requested that it be moved originally to the front due to the nature of the crime, the indictment process, etc.. All things considered, with the above motion we request that the motion to suppress be denied in full.
  
  As stated by the Prosecution on another docket, there are multiple times where the court has agreed to see/hear evidence outside of the normal realm of discovery. Most notably these instances occur for the defense, requesting witnesses be allowed to come forward 24-48 hours before trial. Junior Attorney McNamara was attempting to prove that with the previous precedence set by #23-CM-0094, State of San Andreas v. Linden Thuynsma where the defense introduced a witness after the scheduling tool had been provided, leaving the Prosecution little to no time to prepare for what some consider to be more intensive than reviewing an exhibit.
  
  Let it be noted that the Prosecution was not provided this information with the bulk of the other information, but much later. This is no fault of the charging department or the Prosecution, but the speed at which the court case was moving. Initially neither side wanted to wait, but with the holidays having come and gone both parties have been made to wait. As not only myself, but also the Judge on the case had active LOA's throughout the duration of this trial.
  
  The importance of the evidence provided cannot be understated. There's even previous precedence that allows the prosecution to present evidence after the 7 day window for discovery: #22-CM-0010, State of San Andreas v. Gaven Montasser and #22-CM-0036, State of San Andreas v. Hailee Joyce. The Honorable Judge Daniels is even quoted saying "A Motion for Continuance allows an additional 7 days in which the prosecution can submit further discovery to the court without the court attempting the schedule any proceedings, however it does not limit discovery from being submitted past that point." While this case had no motion for continuance, the fact still remains the same. The time limit on the motion for discovery does not limit the Prosecution from being able to present more discovery.
  
  In consideration of each point made above, we request that each exhibit presented be allowed to remain in it's entirety.
  
  Respectfully,
  
  
  Attorney General
  Director of Public Notary
  San Andreas Judicial Branch
  (909) 321-2132 — [email protected]

• Honorable Judge Mason and included parties,
  
  In response to your motion to deny in full the suppression of evidence filed by the defense, we would like to address some concerns regarding the possibility of evidence tampering due to the significant time elapsed since the indictment was posted on Sunday October 29th, 2023 at 10:17 pm.
  
  While it is true that the Defense appreciates the expeditious handling of certain aspects of the case, the primary concern lies in the potential compromise of evidence integrity over the two-month period. This is not a reflection on the court or the Prosecution, but rather a precautionary measure to ensure a fair and unbiased legal process.
  
  The Defense acknowledges instances where the court has allowed the introduction of evidence outside the normal discovery window, particularly when it comes to the Defense requesting witnesses to come forward shortly before trial. However, the uniqueness of this case lies in the elongated time frame after the initial scene, raising concerns about the preservation of evidence.
  
  The Defense notes the cases cited by the Prosecution, #22-CM-0010, State of San Andreas v. Gaven Montasser, and #22-CM-0036, State of San Andreas v. Hailee Joyce, where the court permitted the presentation of evidence after the 7-day discovery window. However, the Defense contends that the circumstances of this case differ significantly, as there was no formal motion for continuance made upon this case, and the elongated timeframe presents a distinct challenge.
  
  The Defense emphasizes that the potential for evidence tampering, given the time lapse, should not be dismissed lightly. The concern is not merely about the court's ability to accept additional evidence but about the reliability and authenticity of the evidence presented after a considerable delay.
  
  In consideration of the unique circumstances surrounding this case, the Defense respectfully requests that the court thoroughly evaluates the potential impact of the extended time period on the evidence's integrity. The Defense believes that, in the interest of a fair and just legal process, the court should carefully assess the admissibility of evidence given the concerns raised.
  
  Thank you for your attention to this matter.
  
  Respectfully,
  
  Public Defense Attorney
  Notary Clerk
  San Andreas Judicial Branch
  (909) 339-5979 — [email protected]

• Honorable Judge Mason and pertaining parties,
  
  The Prosecution believes this to be the case of extenuating circumstances. Supported by the previous precedence listed above and the commentary below.
  1. The Prosecution as stated previously received this information at the very tail end when we had already sent in our discovery. Initially this information was lost amongst emails as it was not located with the initial evidence. We can show the email to prove chain of evidence and ensure that there was no tampering. The Prosecution also has no problem going to SADOC in order to get the original copy, if need be.
  2. 23-CM-0103, State of San Andreas v. Frank Haswell was pushed through quicker than other cases due to the nature of indictments and the crime.
  3. The Prosecution department has been stretched thin as of late with only 2 Prosecutors able to handle cases on their own. We are asking that some concessions be taken due to the nature of the job and the fact that myself puts in almost 30 hours a week (prior to my LOA).
  4. Outside of our court system the period for discovery goes from the initiation of the case until the trial. While evidence is not typically allowed within a certain amount of time before the trial, the Prosecution is not barred completely from being able to present and keep further evidence. If that was the case, then why would we allow motions to compel evidence? As technically that would be evidence presented after the discovery phase. Our current process is designed to make the timeline for trial shorter, but it should not bar people from doing their jobs.
     ((Prosecutors must also provide the defendant copies of materials and evidence that the prosecution intends to use at trial. This process is called discovery, and continues from the time the case begins to the time of trial. https://www.justice.gov/usao/justice-101/discovery))
  5. Prosecutors have one trial to present all of our evidence to the courts. If we miss evidence and it goes to trial, that is one thing. However, it is another when we attempt to present all our evidence in a reasonable time before trial. Prosecutors do not have the same opportunity that Defense does. We cannot appeal based off of new evidence. We would appreciate that recognition and allowance to be given, as there is no true legal reasoning behind why Prosecutors can't provide their discovery after the given 7 days.
  We hope that you hear us and our given reasons. We ask that you allow the evidence to be accepted for trial and presented at court given the circumstances surrounding the events.
  
  Respectfully,
  
  
  Attorney General
  Director of Public Notary
  San Andreas Judicial Branch
  (909) 321-2132 — [email protected]

• Honorable Judge Mason and included parties,
  
  The defense would like to mention a recent decision made by Honorable Judge Daniels regarding a similar matter on #23-CM-0102, State of San Andreas v. Melody Frey et al.. Denying the prosecutions motion for discovery after the allotted time. While the prosecution division is low the prosecutor could have and should have filed for a motion for continuance which was not filed.
  
  The prosecution did not follow the respective measures for submitting evidence AFTER the 7 day limitation. Which is expressed by honorable Judge Daniels in the above mentioned case.
  
  Thank you for your attention to this matter and the defense believes the Motion for Discovery by the prosecution should be denied in full.
  
  Respectfully,
  
  Public Defense Attorney
  Notary Clerk
  Training and Hiring Staff
  San Andreas Judicial Branch
  (909) 339-5979 — [email protected]

• Honorable Judge Judith Mason,
  
  This is to serve as a Notice of Recusal. As Chief Public Defender Shaun Harper, I will be stepping away from the case. If anything else is needed, I will await further instruction from the Judge.
  
  Respectfully,
  
  
  Chief Public Defender
  Director of Training & Hiring
  Notary Clerk
  San Andreas Judicial Branch
  (909) 308-7889 — [email protected]

• Honorable Judge Mason and included parties,
  
  This is a notice that I will be moving from Co-Counsel to Primary Counsel on this case. Any further information should be directed to myself Public Defense Attorney Mary Burrows.
  
  Respectfully,
  
  Public Defense Attorney
  Notary Clerk
  Training and Hiring Staff
  San Andreas Judicial Branch
  (909) 339-5979 — [email protected]