Eclipse Government

Defendant Name: Kevin Reyes
Defendant Phone: 4068375
Defendant Address: N/A
(( Defendant Discord:kj.1 ))
Requested Attorney: Jacob Schmidt

Charging Department: LSPD

Date & Time of Incident(s): 17/11/2023 ##:##
Charge(s):

• Reckless operation

Narrative:
Officer cowell thought I was being a "dick" to him, because i pulled over prior to him trying to pull me over,. knowing he's gonna come try to do something as he always does, dressed in blue gang appearing clothing, then with my 100% compliance he states I violated a lane, and decided to arrest me for no reason, and failed to provide bodycam to his supervisors.

The initial traffic stop was made apparently for "Violating lane, which is totally false, and I was placed under arrest for that reason" and later the claim reckless was made after searching the car

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I, Kevin Reyes, 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. ))

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

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

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



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

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I, David Coast, a Junior Public Defense Attorney with the San Andreas Judicial Branch, will be representing The Defendant, Kevin Reyes in the underlying case.

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



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

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

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


Frank Raven
Junior Defense Attorney
San Andreas Judicial Branch
5356160 — [email protected]

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The case of the State of San Andreas v. Kevin Reyes is hereby activated by this Court under #24-CM-0012.

Both the State and Defendant in this case are still awaiting adequate representation. At this time the court will delay the Order for Discovery until adequate representation has been assigned for the Defendant and a State Prosecutor has been assigned to the case and both parties inform the court they are ready to proceed.

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.



Court Clerk
San Andreas Judicial Branch
(909) 553-8869 — [email protected]

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

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



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

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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) 505-9925 — [email protected]

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The case of #24-CM-0012, State of San Andreas v. Kevin Reyes is hereby opened and acknowledged by the Court.

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

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




Court Clerk
San Andreas Judicial Branch
(909) 553-8869 — [email protected]

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I, Witt Mcmulligan, a Junior Public Defense Attorney with the San Andreas Judicial Branch, will be representing The Defendant, Kevin Reyes in the underlying case.

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



Junior Defense Attorney
San Andreas Judicial Branch
(909) 568-7062 - [email protected]

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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: Attempting to Contact Expert Witnesses
  • Detailed Explanation: The Prosecution reached out a few weeks ago to gain an expert witness statement on the case. We are requesting an additional 7 days to gather the necessary information (or less if we get the information before that time). Apologies for the delay, but the courts have received a large amount of submissions in the past month or so.

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

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The Motion for Continuance filed by the prosecution on the 11th of March is hereby granted. The deadline for the Discovery phase shall be set for the 18th of March, thus giving the prosecution a full 7 days since the filing of the Continuance.



Court Clerk
San Andreas Judicial Branch

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

• Exhibit #1: Arrest Report - Kevin Reyes (17/NOV/2023)

  

  

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

  
  

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  MUGSHOT

  • SUSPECT DETAILS
    • 
      Full Name: Kevin Reyes
      Phone Number: 4068375
      Licenses Suspended: Yes
      Officers Involved:
      • Police Sergeant II Rija Luigi
      • Police Detective I Mikael Cowell
      • Police Officer I Ben Masseria
      • Police Cadet Kayden Man
      Charges:
      • VM03 - Reckless Operation of a Road or Marine Vehicle
    INCIDENT NARRATIVE
    • Incident Date: 17/NOV/2023
      
      Explain what happened, sufficient detail must be given to justify the placed charges, videos could be provided.
      • During the evening of the 17/NOV, Kevin Reyes was identified as the driver of a black Issi Sport, belonging to an individual with a suspended drivers license. The traffic stop was originally conducted on the basis of a suspected traffic violation, but upon approaching the vehicle and noticing a third passanger in the twice (2) seated vehicle, it escalated the traffic stop to an arrest.
        
        As stated, a third passanger was laying down in the back of the Issi Sport. The driver was placed under arrest for reckless operation as the trunk of the vehicle is not designated to carry a person and thus intentionally disregarding life and/or property through the operation of a road or marine vehicle.
        
        The driver claimed on scene that the passanger got in there willingly.
        
        He was taken to Mission Row, his mask is located there.
        
        Spoiler

        
        
    EVIDENCE DETAILS
    • Document the possessions confiscated from the arrested suspect.
      Possessions are to be documented individually, examples of documented illegal possessions are "Pistol .50" or "12 grams of Cocaine". Legal possessions that can be categorized may be grouped, eg. "Clothing" to describe all clothing items. Body camera footage/pictures may be attached as an evidence exhibit.
      
      Where possible, the serial number of each firearm seized as evidence should be noted.
      • Illegal Possessions:
        
        
        Legal Possessions:
        Exhibit A: 1x Mask
        
        
        Photograph of Possessions (MANDATORY)

        

  
  Exhibit #2: Witness Statement - Detective I Mikael Cowell

  

  

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

  Case Information

  • Incident Date: 17/NOV/2023

  Witness Information

  • Name: Mikael Cowell
    Date of Birth: 23/AUG/1995
    Phone Number: Redacted
    Occupation: LSPD Gang Detective

  Witness Statement

  • On the evening of the 17/NOV, I was driving near Eclipse Towers when I witnessed a black Issi Sport driving towards myself. I activated the MDC and scanned the license plate of the vehicle. This resulted in me discovering that the drivers license of the registered owner was suspended, which resulted in me conducting a traffic stop on the vehicle.
    
    Upon approaching the vehicle and identifying the owner, I had a look inside of the vehicle. This lead me to discovering a male laying down in the trunk of the Issi. I first asked the driver who the male was, but got no response. I then requested the driver to step out, and he was placed under arrest as he is operating the vehicle with three people inside, whereof one is not seated in a designated spot for travel, thus showing disregard for life and/or property through the operation of a road vehicle.
    
    Picture of male inside Issi

    
    
    The only quote I have from Kevin pertaining to the same situation, is the following;
    
    When Kevin called for a supervisor, Martin responded. During their talk, Kevin verbally told us that he only IA reports us to annoy us. I believe this is a grave misuse of the system, as it is intended to investigate and prevent officer misconduct, and not act as a retaliatory tool when civilians want to "annoy" officers, which he is clearly using it as.
    
    Spoiler

    (())
    Bodycam attached

  Witness Affirmation

  • I, Mikael Cowell, 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,
    
    
    Police Detective I Mikael Cowell
    Gang and Narcotics Division
    Los Santos Police Department
    Date: [27/NOV/2023]

  
  Exhibit #3: Witness Statement - Sergeant II Rija Luigi

  

  

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

  Case Information

  • Incident Date: [17/NOV/2023]

  Witness Information

  • Name: [Rija Luigi]
    Date of Birth: [27/OCT/1995]
    Phone Number: [redacted]
    Occupation: [Sergeant II Rija Luigi]

  Witness Statement

  • [I was a bystander at the scene where Kevin Reyes got arrested. To my understanding, after speaking to the detective, the car was initially pulled over because the owner of the car had a suspended license. When it was discovered that Kevin Reyes was driving instead of the owner, an individual was found in the trunk. The driver in this situation, Kevin Reyes, willingly had someone in their trunk and drove with him. The individual in the trunk, named "Marcus Curtis," stated he was willingly in the car on the scene itself making the driver even more liable.]

  Witness Affirmation

  • I, [Rija Luigi], 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,
    
    
    [Rija Luigi]
    [Sergeant II]
    [Los Santos Police Department]
    
    Date: [27/NOV/2023]

  
  Exhibit #4: Witness Statement - Police Officer I Ben Masseria

  

  

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

  Case Information

  • Incident Date: [17/NOV/2023]

  Witness Information

  • Name: [Ben Masseria]
    Date of Birth: [11/FEB/1998]
    Phone Number: [4491028]
    Occupation: [Officer at the LSPD]

  Witness Statement

  • [For the Incident that occurred on the 17th of November 2023 Regarding Officer Cowell and Mr Kevin Reyes, I was the 2nd Unit to respond and I witnessed the entire event unfold. Primarily Mr Reyes was visibly unhappy about the arrest and the entire stop as a whole and this was clear throughout the entire interaction with not only Officer Cowell but also myself, Officer Man and Sergeant Luigi, He was shouting at the officers on scene and we all attempted to calm him down, he asked for a supervisor and Sergeant Rija Luigi got out of her vehicle and took Detective Cowell off to the side whilst me and Cadet Man Watched the two individuals that occupied the vehicle (At this time the vehicle had not been searched and we were unaware of the man in the boot of the vehicle). After the detective had been taken to the side, the reason of which and what was discussed I am unsure, He proceeded with Mr Reyes By cuffing him, reading him his rights and placing him in the back of his cruiser (where Mr Reyes continued to shout to the point that he was audible through the shut windows) The charges were added by Detective Cowell and We searched the vehicle, this is where we found someone in the boot of the vehicle with no form of safety harness or protection, making it very unsafe. In conclusion, I think that Detective Cowell Was correct in his actions, and although I didnt see the reason for the initial stop Detective Cowell remained professional at all time despite being shouted at, he even gave the RO of the vehicle the opportunity to drive off with the passenger in a seat, to which he didn't respond and the vehicle was impounded. I do not have any bodycam of the incident as I buy a new SD card on a weekly basis.]

  Witness Affirmation

  • I, [Ben Masseria], 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,
    
    
    [Ben Masseria]
    [Police Officer 1]
    [Los Santos Police Department]
    
    Date: [27/NOV/2023]

  
  Exhibit #5: Interim Assistant Head of AMU and Master EMT Viktor Markov Expert Witness Statement

  

  

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

  Case Information

  • Incident Date: 17/NOV/2023

  Witness Information

  • Name: Viktor Markov
    Date of Birth: 02/MAY/2001
    Phone Number: 595-3649
    Occupation: Master EMT / Interim Assistant Head of AMU within LSEMS

  Witness Statement

  • Statement written by the Interim Assistant Head of the Advance Medicine Unit of Los Santos
    
    NOTE: I'd firstly like to have it know that I was not present at the time of the incident. This expert witness statement is solely based on scientific research, professional experience, as well as details provided from Police statements and the arrest report.
    
    While we from LSEMS would still highly advise against civilians transporting injured people in the trunk of their cars, it is acceptable for extreme situations. Although note that most injuries that an individual may suffer, allow them to be transported in a seated manner. Meaning, the wounded individual can be sat in a designated seat of a vehicle with a seatbelt. Transportation done by civilians in such a manner is considered safe and may be carried out for lighter incidents that do not require speeds above the legal limit. This is ultimately the safest way to transport an individual, whereas a normal trunk compartment is not equipped with the necessary safety belts, head rests etc.
    
    (( Players are welcome to RP having injured "seated" inside of a vehicle, as the set command script will not allow for an injured to be in the actual seat of a vehicle. It makes more sense from a realistic point of view and it encourages quality RP. Although placing injured inside a vehicle, besides the trunk slot cannot be scriptly bypassed as far as I'm aware. ))
    
    However, transport of patients who have received a life-threatening condition, must be done by EMT's, in an Ambulance. So, as it appears, logically 911 should be attempted as a first hand solution to try and see if Medics are available to respond. In a worst case scenario, it may be an even greater risk for an untrained driver to transport someone injured in a vehicle not equipped with lights and sirens.
    
    The exact same risks are met by a perfectly healthy person which only needs to be in the trunk to get from point A to B. Therefore we strongly discourage such behavior, as the reason for it can not justify having a human life exposed to such great dangers, should a MVA (Motor Vehicle Accident) take place.
    
    Furthermore, the specific case with the Issi Sport which had an individual laying down in the trunk was no different. The Issi is a rather compact vehicle which even comes with a roll-cage and performance bucket seats, with limited interior and trunk space (As seen in the pictures of the arrest report). All of these factors further contribute to the risks of transporting a person in the trunk to become even more severe. The roll cage itself is a solid metal that can cause significant head trauma, should a person hit their head in a sharp turn, hard braking or accelerating. An experienced driver may attempt to operate a vehicle in a way so that there is no rapid turns, braking or accelerating - While in reality, no one is assured of never being involved in an accident that requires emergency braking or swerving to avoid it. This is why drivers and passengers of vehicles fitted with a roll cage have to be wearing helmets.
    
    Other dangers and health risks for individuals traveling in the trunk of a vehicle, away from any seats or safety belts:
    • Should the trunk lock mechanism fail at any given time, a body inside the trunk of a moving vehicle can be ejected out of the vehicle. The consequences of such an occasion are expected to involve great bodily harm or death.
    • During a rear end collision, the trunk end of a vehicle chassis is designed to "Crumble". Undeniably an essential process which is meant to absorb the vast majority of impact energy during an accident. If a human body is located in this rapidly shrinking area (instead of a seat designated for travel), they stand close to no odds of surviving.
    • Overall, a passenger inside a trunk with no access to standard safety measures for vehicle travel is more prone to injury. Because nothing is securing them in place, their body will tumble around, while their neck and spine will endure severe whiplash. Being tossed around in a moving vehicle could lead to fractures in limbs, torso, spine or head.

  Witness Affirmation

  • I, Viktor Markov, 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,
    
    
    Viktor Markov
    Master EMT | Interim Assistant Head of AMU
    Los Santos Emergency Medical Services | Advanced Medicine
    
    Date: 12/MAR/2024

  

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• Parties,
  
  With the Motion for Discovery having been presented by the Prosecution, and after having confirmed that they do not wish to make use of the remaining time granted in their Motion for Cotinuance, the defense shall have a period of 72 hours to file any motions in response.
  
  Best regards,
  
  
  Director of the San Andreas Bar Association
  Clerk - State Judiciary
  San Andreas Judicial Branch
  (909) 553-8869 — [email protected]

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• Honorable Judge McFornell and pertaining parties,
  
  Thank you all for being here today. The Prosecution would like to take the time to educate the defense on the subject of evidence. There are two different types of evidence as noted in the Judicial Branch handbook: Direct Evidence and Circumstantial Evidence.
  
  Exhibit #3: Witness Statement - Sergeant II Rija Luigi is circumstantial evidence that is being used to prove the fact that the officer was suspicious of a crime being violated by the driver, which was the initial reason for the traffic stop.
  
  The Prosecution is not opposed to the partial suppression of Exhibit #2: Witness Statement - Detective I Mikael Cowell. While the abuse of the IA system is concerning and should cease, it is not relevant to the case at hand.
  
  Respectfully,
  
  
  Attorney General
  Director of Public Notary
  San Andreas Judicial Branch
  (909) 505-9925 — [email protected]

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• Parties,
  
  With the recent recusal presented by Attorney David Coast, the defendant is now in need of a defense attorney. With that in mind, Wood Law is being required to present an attorney for the proceeding at hand. Given that the recusal was presented after the period for presenting motions for the defense was over, the presiding judge will submit their decision throughout the coming days.
  
  Furthermore, the necessary arrangements will be made to hold the trial once a defender has been appointed.
  
  
  Best regards,
  
  
  Director of the San Andreas Bar Association
  Clerk - State Judiciary
  San Andreas Judicial Branch
  (909) 553-8869 — [email protected]

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I, Rowin Lawson, Prosecuting Attorney 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 Co-Counsel and will await further instruction from the Presiding Judge.

Rowin Lawson
Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 327-8882 — [email protected]

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• In the case of #24-CM-0012, State of San Andreas v. Kevin Reyes, the Court has carefully reviewed the Motions to Suppress filed by the defense and the prosecution’s response. The defense has raised several objections to the admissibility of certain exhibits, citing issues such as lack of relevance and hearsay. The prosecution, in turn, has provided counterarguments supporting the admissibility of some of the contested exhibits and also recognized the valid arguments behind some objections to the admissibility of specific exhibits.
  
  In relation to Exhibit #2, the Defense advocates that the witness statement provided by Detective I Mikael Cowell, along with the body camera footage attached, be suppressed due to lack of relevance without providing specific reasonings behind said request. Particularly, the portion of the statement that the defense seeks removed states the following:
  • "When Kevin called for a supervisor, Martin responded. During their talk, Kevin verbally told us that he only IA reports us to annoy us. I believe this is a grave misuse of the system, as it is intended to investigate and prevent officer misconduct, and not act as a retaliatory tool when civilians want to "annoy" officers, which he is clearly using it as.”
  
  
  In response, the prosecution agreed with the request formulated by the defense in regards to Exhibit #2 and did not address the request related to the body camera footage. In this particular case, it would be insensitive to consider the text that has been challenged for suppression independently of the body camera footage, which essentially contains the video and audio recording of what would be eventually suppressed. With that in mind, this Court considers that the body camera footage must be treated equally as the statement that stems from it. As such, and having in mind that the Prosecution did not object to the requested portion of text to be suppressed, this Court will be granting the Motion and will suppress the body camera footage and the quoted portion of the Witness Statement provided by Detective I Mikael Cowell.
  
  In relation to Exhibit #3, the Defense argues that the entire statement should be suppressed under the pretense that it is completely Hearsay, arguing that “[Sergeant II Rija Luigi stated] that she only gained (…) knowledge from speaking to the detective”.
  The Prosecution disagreed with the motion under the basis that the statement provided by Sergeant II Rija Luigi constitutes circumstantial evidence that was used to prove the fact that an officer was suspicious of a crime being [committed] by the driver, which was the initial reason for the traffic stop.
  
  In deciding this matter, the Court finds that the statement regarding the initial reason for the vehicle stop, as relayed by the witness after speaking to the detective, shall be suppressed for its hearsay nature. While the witness account provides insight into the events surrounding the arrest, the Court must adhere to rules of evidence, and therefore, this particular hearsay statement cannot be considered as direct evidence in the proceedings. However, this Court will adopt the argument presented by the prosecution and admits the remainder of the statement due to its valid nature.
  
  With that in mind, the Witness Statement provided by Sergeant II Rija Luigi allowed within Exhibit #3 will be as follows (Striked text added for ease in reading, it must be omitted):
  • I was a bystander at the scene where Kevin Reyes got arrested. To my understanding, after speaking to the detective, the car was initially pulled over because the owner of the car had a suspended license. When it was discovered that Kevin Reyes was driving instead of the owner, an individual was found in the trunk. The driver in this situation, Kevin Reyes, willingly had someone in their trunk and drove with him. The individual in the trunk, named "Marcus Curtis," stated he was willingly in the car on the scene itself making the driver even more liable.
  
  
  So ordered,
  
  Superior Court Judge
  Director of the San Andreas Bar Association
  San Andreas Judicial Branch
  (909) 553-8869 — [email protected]

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I, Michael Blaise, a Prosecuting Attorney with the San Andreas Judicial Branch, will be representing the State of San Andreas in the underlying case.

I will be taking the responsibility of Primary Counsel with Hope Kant as co-counsel and will await further instruction from the Presiding Judge.



Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 552-8150 — [email protected]