#24-CM-0020, State of San Andreas v. Cyrus Raven

[Cyrus Raven]

Defendant Name: Cyrus Raven
Defendant Phone: 535-6160
Defendant Address: N/A
(( Defendant Discord: MrWhiteRaven ))
Requested Attorney: Shaun Harper

Charging Department: Los Santos Police Department

Date & Time of Incident(s): 10/NOV/2023 23:00
Charge(s):

• GF07 - Felony Fraud
• GF09 - Embezzlement
• GF18 - Racketeering
• Any other charges issued on the 10th of November, 2023

Narrative:
N/A

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I, Cyrus Raven, hereby affirm that all information provided above is true and correct to the best of my knowledge, and understand that knowingly providing false information could result in additional charges and/or fines. (( I affirm that all information submitted has been obtained via In-Character means. ))

[Hope Kant]

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

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven

A Notification of Counsel was filed in the above case on 10/NOV/2023.

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 the responsibility of Primary 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]

[Robert Winejudge]

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

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NOTICE OF RECEIPT

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven

The court has hereby received and acknowledged the above case on the 11th of November, 2023.

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

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

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



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

[Shaun Harper]

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

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven

A Notification of Counsel was filed in the above case on the 11th of November, 2023.

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

[Lisa Winter]

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

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NOTIFICATION OF COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven

A Notification of Counsel was filed in the above case on the 11th of November 2023.

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

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



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

[Robert Winejudge]

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

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NOTICE OF ACTIVATION

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
#24-CM-0020

A Notice of Activation was entered in the above case on 4th of April, 2024.

The case of the State of San Andreas v. Cyrus Raven is hereby activated by this Court under #24-CM-0020.

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

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



Chief Justice
San Andreas Judicial Branch
(909) 372-4223 — [email protected]

[Robert Winejudge]

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

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ORDER FOR DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
#24-CM-0020

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

The case of #24-CM-0020, State of San Andreas v. Cyrus Raven is hereby opened and acknowledged by the Court.

The prosecution is hereby ordered to provide all evidence collected from the arresting Law Enforcement Agency and submit it to the Court via Motion for Discovery within seven days. If additional time is needed, the prosecution can file a Motion for Continuance.

Once evidence has been submitted to the official docket the defense can begin filing motions.


Chief Justice
San Andreas Judicial Branch
(909) 372-4223 — [email protected]

[Hugh Allgood]

Allgood Law Entry of appearance "Right Firm. Right Now"

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• To all concerned,
  
  I, Hugh R. Allgood, of Allgood Law have been retained as counsel for Cyrus Raven and hereby notify the Court and all parties of my appearance, and will join Chief Defender Harper and Senior Defense Attorney Winter in this matter.

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Respectfully,

Owner/Attorney
Allgood Law
(909) 235-6076 — [email protected]

[Hope Kant]

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

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MOTION FOR CONTINUANCE

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
24-CM-0020

A Motion for Continuance was filed in the above case on the 8th 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
  • Detailed Explanation: The Prosecution has received new information that needs review. We feel that 7 days from the posting of this motion to be sufficient time (April 15th). We appreciate the patience of the courts. ((On top of IC reasons, I also have a short family vacation that I'm going to be going on and I'd like to not have to worry about this case while I'm on it!))

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

[Hugh Allgood]

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

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DEFENSE RESPONSE AND OBJECTION TO THE STATE'S MOTION FOR CONTINUANCE

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
24-CM-0020

Defense response objecting to the State's motion for continuance filed on the 8th of April, 2024 was filed in the above case on the 9th of April, 2024.

Cyrus Raven, by and through the undersigned attorney and Chief Public Defender Shaun Harper and Senior Defense Attorney Lisa Winter, filed this Reponse objecting to the State's Motion for Continuance, and the reasoning for request is as follows;

• Reasoning: Undue Delay; violation of the defendant's 6th Amendment
  • Detailed Explanation:
    
    Mr. Raven was charged 5 months ago, on 10/November/2023 and waited until 11/April/2024 for the case to be activated, despite this Court skipping over Mr. Raven for other cases that were filed over his, which took several weeks to rectify. The Defense objects to this motion and believes granting this motion will add further delay to this matter, and will further deprive Mr. Raven of his Constitutional right to a fair and speedy trial and his right to confront his accusers and the evidence being used against him. To date, Mr. Raven nor his defense team has been allowed to view and confront the evidence supposedly being used against him or to confront the State of San Andreas in its accusation against Mr. Raven. The Defense believes the State has had an ample amount of time to investigate and collected alleged evidence against Mr. Raven as evidenced by the charges not being brought against Mr. Raven for several months after the investigation allegedly began (with Mr. Raven's administrative suspension and eventual termination occurring in August of 2023).
    
    Although opposed in its current format, the Defense would be amenable to a compromise. If the Prosecution complies with the Order for Discovery and provides all evidence the Prosecution currently has, the Defense will not object to a further Motion for Discovery with whatever alleged "new information" the State wishes to file, as long as that Motion is filed by the 15/Apr/2024 deadline currently requested by the State. The defense believes this compromise is mutually beneficial to all parties -- Mr. Raven and his legal team gets the evidence currently held by the State, the State gets more time to review and analyze the "new information", and this case can continue to move without any significant delay.
    
    ((We also believe this would be a fair compromise OOCLy and respects Hopes out of game committments.))

Attorney
Owner
Allgood Law
909) 235-6076 — [email protected]

[Hugh Allgood]

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

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MOTION FOR INVOLUNTARY DISMISSAL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
#24-CM-0020

A Motion for Involuntary Dismissal was filed in the above case on the 12th day of April, 2024

Cyrus Raven, by and through the undersigned attorney and Chief Public Defender Shaun Harper and Senior Defense Attorney Lisa Winter, filed this Motion for Involuntary Dismissal, and the reasoning for request is as follows;

• Reasoning: Undue Delay; violation of the defendant's 4th and 6th Amendments; failure to comply with court order
  • Detailed Explanation: The Superior Court of San Andreas issued an ORDER to the State of San Andreas on April 4th, 2024 that specifically states,
    

    The prosecution is hereby ordered to provide all evidence collected from the arresting Law Enforcement Agency and submit it to the Court via Motion for Discovery within seven days. If additional time is needed, the prosecution can file a Motion for Continuance.

    
    
    4 days later, the State requests a continuance to review "new information", to which the Defense filed an objection to the continuance, but also offered up a compromise. The Court did not rule on the motion for continuance, the State did not take up the Defense's offer for a compromise, and the State did not comply with the Order of the court. Therefore, the Defense believes an undue delay has been provided to our client, and our clients 6th Amendment right to "enjoy the right to a speedy and public trial" and "to be confronted with the witnesses against them". As detailed in the previous defense motion, our client has been waiting to have the chance to confront the evidence and witnesses against him since August, 2023 and has been subjected to several delays up to this point, as detailed in our previous motion. It is asinine to think that just because the State has received "new information", the Defendant should just continue to 'hurry up and wait'. The State and its agent, the Los Santos Police Department, was comfortable arresting Mr. Raven back in November of 2023, and therefore, the Defense believes it a more than reasonable ask in our suggested compromise for the State to comply with the ORDER of the court to afford Mr. Raven, through his defense team, his right to confront the witnesses and against him by disclosing "all evidence collected from the arresting Law Enforcement Agency" within a 7-day time period. Any 'new' information is not information that existed back in November 2023 when Mr. Raven was arrested, therefore, the existence of this information should not have any bearing on the evidence used to ARREST Mr. Raven and seize him.
    
    In further support of this motion, the Defense submits the following cases as precedence:
    
    23-CM-0089, State of San Andreas v. Summer Haze: In this case, the Defense prevailed on a motion to suppress evidence provided beyond the 7-day window as ordered by the court. This is directly what is happening here.
    

    The Courts Order for Discovery, issued on the 9th of September, 2023, unequivocally mandated the prosecution to provide all evidence within seven days. Exhibit #4, comprising an additional witness statement and body camera footage from Mike Luigi, was submitted by the prosecution on the 29th of September, well beyond the deadline stipulated in the order. This much is undisputed.
    
    It is well-established that compliance with court orders and procedures is fundamental to the fair administration of justice. The purpose of discovery is to ensure that both parties in a legal proceeding have equal access to the evidence, thereby promoting fairness and transparency in the trial process.
    
    Upon reviewing the facts and circumstances of the case, the Court finds that the prosecutions submission of Exhibit #4 outside the prescribed time frame was a violation of the Courts explicit Order for Discovery. The prosecution had ample opportunity to include this evidence within the initial Motion for Discovery and, by failing to do so, they have placed the defense at a disadvantage by depriving them of adequate time to examine and prepare for its inclusion in the trial.

    
    
    23-CM-0103, State of San Andreas v. Frank Haswell: In this case, the Court ruled against the Defense motion, citing several reason to include: approved leaves of Absence, "the time of year", and other considerations. No such evidence has been provided by the State or Court in this case. And the delay of evidence is in-fact prejudicial towards the Defendant who has been waiting this entire time for a chance to confront the evidence against him; the Defense has not 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."
    

    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.

Attorney
Owner
Allgood Law
909) 235-6076 — [email protected]

[Robert Winejudge]

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

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COURT DECISION

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
#24-CM-0020

A decision was reached in the above case on the 13th day of April 2024.

I'm going to be responding to the 3 motions filed since April 8th 2024. The Prosecution's motion for continuance is granted, it would have been granted sooner, I apologise for not responding within a timely manner. Therefore, the Prosecution has until April 15th, 11:59 PM to provide their discovery.

The Motion for Involuntary Dismissal submitted by the Defense is denied, as the prosecution has requested a Continuance which has now been responded to, once again I apologise for the delay, they have until the 15th of April to provide Discovery.

After the deadline given by the court has expired, we will move forward with this case. No further continuance will be granted for Discovery.


Chief Justice
San Andreas Judicial Branch
(909) 372-4223 — [email protected]

[Hope Kant]

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

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MOTION FOR DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
# 24-CM-0020

A Motion for Discovery was filed in the above case on the 15th 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 #1: Cyrus Raven Chronology of Events

  Link
  Exhibit #2: Cyrus Raven LRC Application

  SEALED
  Exhibit #3: Proof of Cartel Donations to LRC Campaign

  SEALED
  Exhibit #4: Cyrus Raven Community Letter Box Inquiry

  SEALED
  Exhibit #5: Summary of the Director Bob Kidnapping

  SEALED
  Exhibit #6: Cyrus Raven Introduces a Bill into the LRC

  SEALED
  Exhibit #7: Ava Raven Interrogation

  SEALED
  Exhibit #8: LSSD Commanding Officer Oscar Black Expert Witness Statement

  

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

  Case Information

  • Case Number: Not applicable.
    Incident Date: Unsure.

  Witness Information

  • Name: Oscar Black
    Date of Birth: 21st of June, 1998
    Phone Number: [REDACTED]
    Occupation: Captain, Los Santos County Sheriff's Department

  Credentials

  • I first entered service within the Sheriff's Department on the 8th of August, 2021. Nearly three (3) years ago. Since then, I've always had a deep interest in the Gangs and Narcotics Division, and I've been a part of the Sheriff's Investigations Bureau for two (2) years. In September of last year, I was appointed the official Commanding Officer of the Gangs & Narcotics Division, which I had already been leading without the official title and appointment.

  Expert Witness Statement

  • All individuals involved in this incident are confirmed to be members of "The Cartel". We know this since the incident that took place sometime last year, I had compromised a frequency from a gang that has since disbanded, "The Russians". They were speaking about receiving messages from Vince Williams, who they mentioned was the leader of "The Cartel". The message was about picking up a Supercar from an undisclosed location for a prize which could've been in money, or weapons. Fortunately for us, "The Russians" managed to find the vehicle that "The Cartel" was looking for, they ended up delivering the vehicle behind a warehouse on Popular St, where I had set up several units from METRO and SED to breach in once the deal was made. The deal was made, and units managed to push in, we secured all evidence, and located on Charlie Mchoe was a duffel bag, which had two (2) AK-47s with 200 rounds of ammunition each.
    
    Vince Williams was also recently arrested for operating a military-esque vehicle on the 18th of March, 2024. He was driving an armoured vehicle which had built-in machine guns. With this, he was subsequently charged by the Los Santos Police Department for WF05 - Possession of a Class 4 Firearm. Arrest Report: Vince Williams.

  Witness Affirmation

  • I, Oscar Black, 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,
    
    Captain Oscar Black
    Commanding Officer, Gangs & Narcotics Division
    
    Date: 2nd of April, 2024

  
  
  Exhibit #9: Proof of Business Associations

  Hi, I would like to update the MotorsnacksCH registration information, as there have been some internal changes. Dario Greenwood has stepped down from Owner, and Luke Raven will take over as Owner, furthermore Cyrus Raven will be added as store Manager.
  

  UPDATED BUSINESS INFORMATION

  OWNER INFORMATION

  • First and Lastname: Luke Raven
    Phone Number: 3522900
    Email: [email protected]
    Home Address: N/A

  
  
  BUSINESS INFORMATION

  • Name of Business: Raven24/7
    Business Address: 15 Inseno Road.
    Type of Business: General Store
    
    Mark an X in the appropriate checkbox.
    [ ] Stand-Alone ($15,000)
    [X] Subsidiary ($35,000)
    [ ] Parent ($50,000)
    
    Parent Company name: Eriksen-West Holdings
    
    Photo of the Business Exterior Entrance:
    Spoiler

    
    
    
    (( Make sure that the address of the property / business door is visible on the image above. ))

  
  
  EMPLOYEE INFORMATION

  • List of Current Employees & their position(s):
    • Luke Raven - Owner
    • James Eriksen - Advisor
    • Cyrus Raven - Manager

  
  
  
  AGREEMENT

  • By submitting this request you hereby agree that all information provided is truthful. If your registration is approved, you agree on a continuous effort to adhere to laws and regulations laid out by the San Andreas State Government. You also agree to submit any future changes to your business to the Business Licensing Bureau. You also agree to a full legal background check of your person and that you're the rightful owner of the property in question.
    
    Previous Owner's Signature:
    
    Date: 06/APR/2023
    
    New Owner's Signature:
    Luke Raven
    Date: 06/APR/2023

  
  Sincerely,
  
  Luke Raven
  Luke Raven
  
  
  Dario Greenwood
  
  
  James Eriksen
  

  .

  Exhibit #10 Vince Williams Phone Records and Search Warrant

  Link

  ► Show Spoiler

  

  

  San Andreas Judicial Branch Re: Search Warrant - Vince Williams "HERE FOR YOU | SAFE FOR YOU"

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  • To:
    The Office of the Attorney General operating within the State of San Andreas and their respective investigative and tactical divisions;
    
    You are hereby directed to conduct a search of Bank Logs within the Bank of San Andreas for the following designated records:
    • Telephone Company Phone Records for Vince Williams between 29/JUL/2023 and 31/JUL/2023
    [X] Any evidence of crimes in violation of the San Andreas Penal Law Article GM to SF included but not limited to:
    • GF14 - False Impersonation of a Gov. Employee
    You are directed to execute this warrant between the hours of:
    • [ ] 06:00 - 21:00
    • [X] 08:00 - 22:00 (Hours of Operation for the San Andreas Phone Company)
    • [ ] Any time day or night.
    You are being directed to send a copy of this warrant to Vince Williams once executed, and return a copy with all property seized pursuant there to your respective department without unnecessary delay. The court requires a copy be submitted to the warrant application for internal archive.
    
    

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    This warrant is issued on 04/OCT/2023 and is effective for 7 days. Should an extension be required please submit a notice no less then 12 hours prior to this warrants closing.
    
    
    Chief Justice
    San Andreas Judicial Branch
    (909) 257-9183 — [email protected]

  
  Exhibit #11: Cyrus Raven Phone Records

  SEALED
  Exhibit #12: Cyrus Raven Interrogation

  • Jaxon Nash (JN): For the record, this is Captain Jaxon Nash with the Los Santos Police Department the time is now 8:42 PM (( UTC )) on the 31st of August 2023
    JN: Can you please state your name for the record?
    Cyrus Raven (CR): Cyrus Raven
    JN: Thank you for coming in today Mr. Raven. I called you in today to ask you a few questions today so this shouldn't take to long. For the record you are waving your right to have a lawyer present correct?
    CR: Yea
    JN: Alright wonderful, lets get to it. The first question I have for you is regarding the two large donations you received from a Mr. Vince Williams, and a Mr. James Eriksen in the sum of $1,000,000. Could you please explain to me what that money was used for upon receiving it?
    CR: Um, it was a mixer of things, I believe about $200,000 of it, I not going to be able to give you an exact as its been awhile. But around $200,000 went to Weazel News advertisements for my LRC campaign, and then the rest was just kept in reserves depending on whether it was needed for anything.
    JN: Ok, so $200,000 went to Weazel for advertising, do you happen to have any of the receipts to confirm this?
    CR: Uh, you would have to check with Weazel. If I bought the ads then I signed the invoice which should exist on their end. I don't keep receipts.
    JN: Ok, do you remember the person you bought the ads from?
    CR: Um (Pause) no, I don't recall.
    JN: Ok, fair enough. You stated that you spent roughly $200,000 at Weazel for ads regarding your LRC campaign. So do you happen to know what happen to the roughly $800,000 that was left over from the donations?
    CR: The rest of the amount was kept in my own personal bank account, I don't know if I allocated a specific amount for personal endeavors. It just became part of my total wealth if you want to put it that way.
    JN: Is there a way that you kept that money separate from any other income?
    CR: Its hard to say. I had that money in my bank account. I obviously have my money outside of that campaign donation. Besides those Weazel ads I bought um, the rest was just kept in my accounts. I'm assuming it was spent just like I spend my own personal money, whether its on cars or houses etc.
    JN: Ok, so in the time that you received that donation up until this point have you made any large purchases?
    CR: Any large purchases? Oh gosh yeah.
    JN: I would consider anything over the $500,000 mark a large purchase, just for the record.
    CR: Probably yes, I bought a Comet S2. I believe I bought that after my LRC campaign, Comet S2's cost anywhere between $800,000 to $900,000. Bought a couple of houses as well. One thing that should be noted. The reason, and I'm sure that now you have access to my bank logs to check this. I also play a lot of poker and I make a decent chunk of change doing that. So it could be the case that I bought like three or four houses, two or three houses' ever since I received that initial donation. But I am not going to be able to tell you that specific amount of money went to a specific house or car. It just sort of got blended with the rest of my money.
    JN: Ok, now do you currently own any of those properties or vehicles at this current point in time?
    CR: The houses are all flipped. The only house I currently own is my Weazel plaza one. I still do own the car yeah.
    JN: Ok Mr. Raven, that is going to conclude everything I have at this time. Should we require more in the future I will reach out via telephone. Do you have any questions for me?
    CR: No, no. I mean you already know my thoughts on the subject I have written about it extensively so I don't think I need to rehash that.
    CR: I do hope you take in to consideration my cooperation. I could have very well asked for a lawyer and remain quiet. I have nothing to hide.

    ---

    30/AUG/2023
    
    Police Captain II Jaxon Nash
    Los Santos Police Department

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

[Hugh Allgood]

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

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MOTION TO UNSEAL EVIDENCE

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
24-CM-0020

The following motion for unseal evidence was filed in the above case on the 18th of April, 2024.

Cyrus Raven, by and through the undersigned attorney and Chief Public Defender Shaun Harper and Senior Defense Attorney Lisa Winter, filed this Motion requesting the unsealing of evidence, and the reasoning for request is as follows;

• Reasoning: Preserve Defendant's right to a public trial.
  • Detailed Explanation:
    
    Related to the evidence under seal, the Defense believes the following exhibits should be unsealed;
    
    • 2: "Cyrus Raven LRC Application"
    • 3: "Proof of Cartel Donations to LRC Campaign"
    • 4: "Cyrus Raven Community Letter Box Inquiry"
    • 6: "Cyrus Raven Introduces a Bill into the LRC"
    
    "because they are Government documents that are not publicly available" --These exhibits are derived from information that were once publicly accessible. There is no sensitive information in any of these documents, and therefore, the Defense requests them to be unsealed, citing the Defendant's right to a public trial. Mr. Raven's LRC application was public information, Mr. Raven's receipt of donations were public, the community letter box inquiry was public, and so was the introduction of the bill within the LRC.
    
    The Defense does not object to sealing Exhibit 10 if the State feels it to be important.

Attorney
Owner
Allgood Law
909) 235-6076 — [email protected]

[Hugh Allgood]

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

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MOTION TO SUPPRESS

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
#24-CM-0020

A Motion to Suppress was filed in the above case on the 17th Day of April, 2024.

Cyrus Raven, by and through the undersigned attorney and Chief Public Defender Shaun Harper and Senior Defense Attorney Lisa Winter, filed this Motion to Suppress, and requests to following be suppressed from evidence;

• Exhibit #1: Cyrus Raven Chronology of Events
  Requested Evidence to Suppress:

  Line 4, specifically the text, "Cartel Donations"
  Line 21, specifically the text, "Vince Williams initiates the case with his 'Cartel' affiliates."
  Line 22, specifically, "connecting Charlie McHoe to the 'Cartel' members in the case"
  Lines 27-29 in full
  

  • Detailed Reasoning: Lack of foundation as it pertains to the requested suppressions of line 4, 21, and 22. The State by using the word "Cartel" throughout this timeline is not supported by any foundation for this claim. Relevance as it pertains to lines 27-29. This information has nothing to do with this matter or any of the charges Mr. Raven is appealing, nor has any foundational evidence been provided purporting this 'leak' was done by Mr. Raven.

• Exhibit #5: Summary of the Director Bob Kidnapping
  Requested Evidence to Suppress:

  **SEALED**

  • Detailed Reasoning: **SEALED**

• Exhibit #7: Ava Raven Interrogation
  Requested Evidence to Suppress:

  **SEALED**

  • Detailed Reasoning:**SEALED**

• Exhibit #8: LSSD Commanding Officer Oscar Black Expert Witness Statement
  Requested Evidence to Suppress:

  All individuals involved in this incident are confirmed to be members of "The Cartel". We know this since the incident that took place sometime last year, I had compromised a frequency from a gang that has since disbanded, "The Russians". They were speaking about receiving messages from Vince Williams, who they mentioned was the leader of "The Cartel". The message was about picking up a Supercar from an undisclosed location for a prize which could've been in money, or weapons. Fortunately for us, "The Russians" managed to find the vehicle that "The Cartel" was looking for, they ended up delivering the vehicle behind a warehouse on Popular St, where I had set up several units from METRO and SED to breach in once the deal was made. The deal was made, and units managed to push in, we secured all evidence, and located on Charlie Mchoe was a duffel bag, which had two (2) AK-47s with 200 rounds of ammunition each.
  
  Vince Williams was also recently arrested for operating a military-esque vehicle on the 18th of March, 2024. He was driving an armoured vehicle which had built-in machine guns. With this, he was subsequently charged by the Los Santos Police Department for WF05 - Possession of a Class 4 Firearm. Arrest Report: Vince Williams.

  • Detailed Reasoning: The statement that "All individuals involved in this incident are confirmed to be members of "The Cartel" is a combination of hearsay, lacks foundation, and lacks relevance. Saying "all individuals" lacks any level of specificity - who exactly is all individuals? Additionally, even if these "individuals" are named, there has been no evidence to confirm the individual(s) are members of The Cartel, nor how these individuals are connected with Cyrus Raven. Furthermore, the case related to this statement, #23-CM-0052, State of San Andreas v. Vince Williams, James Eriksen, Leah Lennox, Rocky Bologna, Captain Black issues a written statement about that situation and in this statement, Captain Black does not make any direct mention of Vince Williams therein, and the Defense finds it surprising that all of sudden Vince Williams is being included now in this exhibit, which is a statement about the same events. Exhibit 4 in that case also confirms Captain Black (and Gangs and Narcotics Division) did not even know they were dealing with "The Cartel".
    
    The statement, "We know this since the incident that took place sometime last year", lacks foundation. What "incident" are we referring to? This is further complicated by the remainder of the statement as Captain Black goes back and forth between discussing several incidents. There's "the incident" (non-specific), an incident involving "The Russians" intercepting a car "The Cartel" was looking for, and then we have the "military-esque" situation from 18/March/2024. The State has not laid any foundation for these statements, or the relevance of these statements in this matter. The entire section discussing Vince Williams arrest from 18/March/2024 should be suppressed wholly due to lack of relevance. Mr. Raven was arrested and charged back in 2023 -- another individuals arrest from 2024 is irrelevant.
    
    The entire section about the delivery of the supercar, is not relevant to this matter. This would be great evidence for a criminal case against perhaps Vince Williams, or Charlie McHoe, but not Cyrus Raven. In addition to relevance, the State has not laid any foundation for any connection to the charges currently faced by Cyrus Raven.

• Exhibit #10: Vince Williams Phone Records and Search Warrant
  Requested Evidence to Suppress:

  The entire exhibit

  • Detailed Reasoning: Lack of relevance - Vince Williams calls logs do not contain ANY evidence of communication or association between Vince Williams and Cyrus Raven.
    
    Mr. Raven has clearly stated his associations with Mr. Williams were strictly in the context of communications with a constituent when Mr. Raven was an elected member of the legislature and at one point an appointed attorney for Mr. Williams. If mere association with someone is grounds for lumping a person into whatever crimes that person has been associated with, then the State needs to charge a whole lot more individuals based on this exhibit alone. To further demonstrate the ridiculousness of this exhibit, I would begin with calling for charges against Sheriff Bobby Kirk, Undersheriff Harry Payne, and Governor Jason Castillo.

• Exhibit #11: Cyrus Raven Phone Records
  Requested Evidence to Suppress:

  **SEALED**
  
  

  • Detailed Reasoning: **SEALED**

Attorney
Owner
Allgood Law
(909) 235-6076 — [email protected]

[Hugh Allgood]

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

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MOTION TO UNSEAL EVIDENCE

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Cyrus Raven
24-CM-0020

The following motion for unseal evidence was filed in the above case on the 18th of April, 2024.

Cyrus Raven, by and through the undersigned attorney and Chief Public Defender Shaun Harper and Senior Defense Attorney Lisa Winter, filed this Motion requesting the unsealing of evidence, and the reasoning for request is as follows;

• Reasoning: Preserve Defendant's right to a public trial + request of Cyrus Raven
  • Detailed Explanation:
    
    Related to the evidence under seal, the Defense believes the following exhibits should be unsealed;
    
    • 11: “Cyrus Raven Phone Records”
    
    
    Mr. Raven requests his phone and text logs to be unsealed in the full interest of transparency, and wants this information (his information) to be fully available to the public.

Attorney
Owner
Allgood Law
909) 235-6076 — [email protected]