#24-CM-0080, State of San Andreas v. Billy Pappalardo

[Billy_Pappalardo]

Defendant Name: Billy Pappalardo
Defendant Phone: 479-1672
(( Defendant Discord: @Demonmit1 ))
(( Defendant Timezone: CST ))
Type of Representation (Pick one): Public Defender

Charging Department: LSPD

Date & Time of Incident(s): 23/OCT/2024 21:00
Charge(s):

• Face Concealment (b)
• Failure to Comply/Identify

Narrative:
I was unlawfully arrested

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I, Billy Pappalardo, 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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NOTICE OF RECEIPT

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Billy Pappalardo

The court has hereby received and acknowledged the above case on the 24th day of October, 2024.

The Superior Court of San Andreas has received your filing and the case is now pending activation. Be advised that the bench trial court system operates off a time-slot scheduling system. Please look out for notifications from either the courts or your attorney in regards to scheduling your bench trial.

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
Branch Administrator
San Andreas Judicial Branch
505-9925 — [email protected]

[Hope Kant]

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

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NOTICE OF ACTIVATION & ORDER FOR DISCOVERY

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Billy Pappalardo

A Notice of Activation & Order for Discovery was entered in the above case on the 24th day of Month, 2024.

The case of State of San Andreas v. Billy Pappalardo is hereby activated and opened by this Court.

Be advised that the bench-trial court system runs on a weekly time-slot system. The prosecution and defense are hereby ordered to provide their evidence to the Court via Motion for Discovery within the next 7-14 days.

If at any point in time the defendant or prosecution wishes to dispute more than just misdemeanor charges or desires a more in-depth examination of the case, they are welcome to file a Motion for a Change in Venue.


Superior Court Judge
Branch Administrator
San Andreas Judicial Branch
505-9925 — [email protected]

[Larin Tai]

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. Billy Pappalardo


A Motion for Discovery was filed in the above case on the 29 of October, 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: Arrest Report Billy Pappalardo 23/OCT/2024

  
  
  

  

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

  
  

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  MUGSHOT

  • SUSPECT DETAILS
    • 
      Full Name: Billy Pappalardo
      Phone Number: 4791672
      Licenses Suspended: No
      Officers Involved:
      • Police Detective I Sebastian Knight
      Charges:
      • GM19 - Face Concealment (b)
      • GM10 - Failure to Comply / Identify
    INCIDENT NARRATIVE
    • Incident Date: 23/OCT/2024
      
      Explain what happened, sufficient detail must be given to justify the placed charges, videos could be provided.
      • Billy was seen by detective Knight outside of Alta Appartments wearing a mask, Detective Knight approached Billy asking him to remove the mask and to identify himself, Billy removed his mask but refused to identify himself. Based on GC04 - Face Concealment : Individuals who defy a lawful request to remove and/or keep their facial concealment off or fail to identify themselves after removing the face covering are liable for GM-10 and a subsequent upgrade of GC-04 to GM-19. Detective Knight arrested the suspect and processed him in MRPD cell block.
    EVIDENCE DETAILS
    • Document the possessions confiscated from the arrested suspect.
      Possessions are to be documented individually, examples of documented illegal possessions are "Pistol .50" or "12 grams of Cocaine". Legal possessions that can be categorized may be grouped, eg. "Clothing" to describe all clothing items. Body camera footage/pictures may be attached as an evidence exhibit.
      
      Where possible, the serial number of each firearm seized as evidence should be noted.
      • Illegal Possessions:
        Exhibit A: Mask
        
        
        Legal Possessions:
        Exhibit A: GPS
        Exhibit B: Radio
        
        
        Photograph of Possessions (MANDATORY)

        

  
  
  

• Exhibit #2: Bodycam Footage

  
  
  
  
  

Larin Tai
Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 244-5389 — [email protected]

[Larin Tai]

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

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MOTION FOR SUMMARY JUDGEMENT

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Billy Pappalardo

A Motion for Summary Judgement was filed in the above case on the Day of Month, 2024.

The State of San Andreas, by and through the undersigned attorney, filed this Motion for Summary Judgement, and the reasoning for request is as follows;

• Reasoning: Billy Pappalardo refused to identify himself after multiple requests from officers after being told to remove his mask.
  • Detailed Explanation: On the 23rd of October, 2024, a masked Billy Pappalardo was seen leaving Alta Apartments by Detective Knight. It is shown in the body cam footage that Detective Knight requested that Mr. Pappalardo remove his mask and identify himself. Mr. Pappalardo then removed the mask but refused to identify himself or provide identification to the Detective. Billy began checking his phone and telling Detective Knight, "I don't have time, fuck off" and still refusing to identify. It is shown that Detective Knight requested identifcation from Mr. Pappalardo two more times, still being refused identifcation. Mr. Pappalardo is guilty of Face Concealment and Failure to Identify as written in the Arrest Report and shown in the body cam footage provided to the court.

Larin Tai
Junior Prosecuting Attorney
San Andreas Judicial Branch
(909) 244-5389 — [email protected]

[Hope Kant]

San Andreas Judicial Branch
Docket Notice
"EQUAL JUSTICE UNDER LAW"

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• Parties,
  
  This case is now pending the assignment of a defense attorney. The court would like to hear the opinion of the attorney be that objecting or agreeing to the above Motion for Summary Judgement. Thank you to all parties for your time and patience.
  
  Respectfully,
  
  
  Superior Court Judge
  Branch Administrator
  San Andreas Judicial Branch
  505-9925 — [email protected]

[Clara Lopez]

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. Billy Pappalardo


A Notification of Counsel was filed in the above case on the 13/NOV/2024

I,Clara Lopez, a Public Defender with the San Andreas Judicial Branch, will be representing the defendant, Billy Pappalardo in the underlying case.

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

The defense would like 48 hours to get into contact with the defendant and review the case before accepting or denying any motions.


Public Defender
San Andreas Judicial Branch
(909) 495-1265 — [email protected]

[Clara Lopez]

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

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• Honorable Judge Kant and prosecution,
  
  The defense has no objection for the Motion for Summary Judgement.
  
  Respectfully,
  
  Public Defender
  San Andreas Judicial Branch
  (909) 495-1265 — [email protected]

[Hope Kant]

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. Billy Pappalardo
#24-CM-0080

A court order was issued in the above case on the 18th day of November, 2024.

The courts will be granting the Motion for Summary Judgement filed by the prosecution on the grounds that defense has no objected.

The court will now allow the prosecution seventy-two hours to present their initial arguments to the court. The defense will then be given the same opportunity to give a response. At that point the prosecution will then be given another seventy-two hours for any counter-arguments to be made. Once both sides have been given their opportunity to make their stance on the case known, the could will then render their decision and issue a verdict.


Superior Court Justice
Branch Administrator
San Andreas Judicial Branch
505-9925 — [email protected]

[Hope Kant]

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

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• Prosecution,
  
  It has been a significant amount of time since the court has ruled to allow the proposed motion for summary judgement. Could you provide a reasonable explanation for the delay in response?
  
  Respectfully,
  
  
  Superior Court Justice
  Branch Administrator
  San Andreas Judicial Branch
  505-9925 — [email protected]

[Terence Williams]

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

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• Your Honor,
  
  The Prosecution has no excuse for the tardiness exhibited with the failure to provide a brief and apologise to the court. Being conscious of judicial economy and resources, the Prosecution is prepared to withdraw the motion and instead move to schedule this case for a bench trial. However, we will also be prepared to post a brief within 24 hours, should we still move ahead with the current motion.
  
  Regards,
  
  Terence Williams
  Attorney General
  San Andreas Judicial Branch
  (909) 234-9321 — [email protected]

[Hope Kant]

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

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• Prosecution and defense counsel,
  
  This is to serve as a notice of receipt for the prosecutions request of recinding their motion in favor of the typical bench trial. Since the defense previously agreed to the motion, I would like to see the response, if any, to the case moving back into bench trial format.
  
  As a general notice, if we are to move forward with the case, the prosecution will have forfeited their opening statement. Meaning the defense, should they want to continue with a motion for Summary Judgement, will be given the opportunity to give their opening statement, followed by the prosecutions first closing statement.
  
  The defense now has 72 hours to respond to the request of the prosecution.
  
  Respectfully,
  
  
  Superior Court Justice
  Branch Administrator
  San Andreas Judicial Branch
  505-9925 — [email protected]

[Larin Tai]

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

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• Honorable Judge Kant and pertaining parties,
  
  The prosecution has presented the court very clear evidence for the events that occurred on October 23, 2024. The defendant, Billy Pappalardo, was observed by Detective Knight leaving Alta Apartments with a mask on. Detective Knight asked Mr. Pappalardo to remove his mask and provide his license. Billy Pappalardo did remove his mask after being requested to do so, however, refused to provide his license. After repeated requests from Detective Knight, Mr. Pappalardo retrieved his phone and told Detective Knight, “I don’t have time, fuck off”, in response to the requests from the Detective. The bodycam footage clearly shows Detective Knight asking twice more from the defendant to identify himself before placing him under arrest.
  
  Billy Pappalardo was captured on video refusing to comply with officers orders after multiple requests. This indisputable evidence that the defendant willingly and knowingly committed the acts charged against him. The San Andreas Penal Code indicates that GC04 - Face Concealment, “Individuals who defy a lawful request to remove and/or keep their facial concealment off or fail to identify themselves after removing the face covering are liable for GM-10 and an upgrade of charges from GC04 to GM-19”. The defendant clearly has violated the penal code set forth by the government of San Andreas and thus should be found guilty of the charges placed upon him by Detective Knight.
  
  
  
  Respectfully,
  
  
  Larin Tai
  Junior Prosecuting Attorney
  San Andreas Judicial Branch
  (909) 244-5389 — [email protected]

[Clara Lopez]

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

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• Honorable Judge Kant and prosecution,
  
  The defense is confused why the prosecution is providing this deliberation to the docket as the defense is still in their 72 hour timeframe to determine the venue of the trial.
  
  There should be no opening statements or any statements for this matter regarding the case and the defense requests this statement to be stricken from the docket.
  
  Respectfully,
  
  Public Defender
  San Andreas Judicial Branch
  (909) 495-1265 — [email protected]

[Hope Kant]

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

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• Prosecution and defense counsel,
  
  The prosecutions opening statement will not be considered on the docket. We do thank the prosecution for at least attempting to provide one for the court, but as was previously stated, it will not be included in final deliberations, only if the motion for summary judgement continues. If the case is to change back to a bench trial, the court will consider an opening statement from the prosecution.
  
  Respectfully,
  
  
  Superior Court Justice
  Branch Administrator
  San Andreas Judicial Branch
  505-9925 — [email protected]

[Clara Lopez]

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

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• Honorable Judge Kant and prosecution,
  
  The defense has concluded their deliberations and thank the courts for the chance to make this decision.
  
  The defense would like to keep the venue on the docket and continue with the previous motion for summary judgment.
  
  The defense will provide an opening statement when the judge is ready.
  
  Respectfully,
  
  Public Defender
  San Andreas Judicial Branch
  (909) 495-1265 — [email protected]

[Hope Kant]

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

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• Prosecution and defense counsel,
  
  Thank you to both parties. This case will now continue with the defense. You now have 72 hours to present your statements.
  
  Respectfully,
  
  
  Superior Court Justice
  Branch Administrator
  San Andreas Judicial Branch
  505-9925 — [email protected]

[Clara Lopez]

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

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OPENING STATEMENT

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Billy Pappalardo

A opening statement was filed in the above case on the 1st of December 2024

Honorable Kant and parties,

Today, we are here to address the charges brought against Billy Pappalardo, who stands accused of face concealment and failure to comply with lawful identification. However, we will show that the charges brought against Mr. Pappalardo are both unwarranted and unjustified.

The evidence will demonstrate that at the time of the incident, Mr. Pappalardo was on private apartment property where he resides. He was not in a public space but in the walkway leading to his apartment building a location where he reasonably believed he could exercise his right to wear a mask for personal comfort, privacy, or safety. This was not a random public act of concealment but an expression of his autonomy within a residential setting.

Furthermore, while Mr. Pappalardo did comply with the officer’s request to remove his mask, he exercised his constitutional right to refrain from identifying himself. Since this was not a lawful request Mr. Pappalardo was not obligated to comply. His actions were not an act of defiance or obstruction but a legitimate expression of his rights as a private citizen.

We ask you to consider whether the charges brought against Mr. Pappalardo appropriately reflect the situation. The prosecution must prove beyond a reasonable doubt that Mr. Pappalardo’s actions constituted a breach of public order or safety, something we argue they cannot do.

At the end of this trial, we are confident you will find that Mr. Pappalardo was acting within his rights and that the charges brought against him do not hold under scrutiny.


Public Defender
San Andreas Judicial Branch
(909) 495-1265 — [email protected]

[Hope Kant]

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

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• Prosecution and defense counsel,
  
  Thank you for your response defense. Prosecution, you now have 72 hours to submit your response to the court. The case will continue once or move forward after that time frame.
  
  Respectfully,
  
  Superior Court Justice
  Branch Administrator
  San Andreas Judicial Branch
  505-9925 — [email protected]

[Bruce Tubby]

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. Billy Pappalardo

A Notification of Counsel was filed in the above case on the 4th of December, 2024.

I, Bruce Tubby, a Junior Public Defense Attorney with the San Andreas Judicial Branch, will be representing the Defendant, Billy Pappalardo in the underlying case.

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



Junior Public Defender
San Andreas Judicial Branch
(909) 494-8268 — [email protected]

[Larin Tai]

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

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CLOSING STATEMENT

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Billy Pappalardo

A closing statement was filed in the above case on the 6th of December 2024

Honorable Judge Kant and pertaining parties,

The defense state that Mr. Pappalardo has a constitutional right to refrain from identifying himself; that what he did was not an obstruction of justice or defiance, but an assertion of his rights as a private citizen. The defense states, “he exercised his constitutional right to refrain from identifying himself”, this is an reprehensible interpretation of the Constitution of San Andreas and its rights guaranteed therein. According to GC04 of the San Andreas Penal Code, “an individual may not be present on foot and wear facial concealment in public or on the property of San Andreas”, which Mr. Pappalardo intentionally defied by leaving his place of residence while wearing a mask. Subsection 2 of GC04 continues to state, “individuals who defy a lawful request to remove and/or keep their facial concealment off or fail to identify themselves after removing the face covering are liable for GM10 and subsequent upgrade of GC04 to GM19. Mr. Pappalardo did remove his mask when Detective Knight requested, however, after many requests Mr. Pappalardo refused to identify himself or provide government identification. Thus, violating the San Andreas Penal code with full intent of refusal to abide by lawful requests.

The defense has claimed that Mr. Pappalardo was on private property and exercising his freedom of expression to wear a mask. Alta Apartments is owned, operated, and maintained by the San Andreas Government Property and Housing Bureau. The sidewalk and roadway in front of the building are owned and maintained by the San Andreas Government, none of which is considered to be private property. Private property is defined as “land that belongs to an individual or non-government entity who has the freedom to use, sell, mortgage, or trade it.” Hence the entrance, hallways, parking garages, and common areas are not deemed to be part of a person's private property whether they are leasing or have purchased an apartment from the government or other entity. Their private property begins at the entrance to their personal accommodations within the building and contains all goods within. The premise that Mr. Pappalardo was exercising his rights on private property is a deceitful attempt by the defense to justify his actions taken that day.

The prosecution asks the court to see through the defense's erroneous and illogical claims. That the court sees the truth in the evidence presented by Detective Knight in the form of the arrest report and accompanying bodycam proof provided. We ask that the defendant, Billy Pappalardo, be held accountable and liable for the charges of GM19 - Face Concealment(b) and GM10 - Failure to Comply/Identify.


Respectfully,


Larin Tai
Junior Prosecuting Attorney
San Andreas Judicial Branch
244-5389 — [email protected]

[Clara Lopez]

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

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• Honorable Judge Kant and prosecution,
  
  The defense is again confused why the prosecution is providing this closing statement to the docket instead of their response/case in chief. Will the prosecution not be going into detail about the evidence they provided? If so the defense would like to provide their response to the evidence provided.
  
  The defense requests this closing statement to be stricken from the docket.
  
  Respectfully,
  
  Public Defender
  San Andreas Judicial Branch
  (909) 495-1265 — [email protected]

[Terence Williams]

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

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• Honorable Judge Kant and pertaining parties,
  
  Just as the Prosecution lost the prerogative to present its evidence outside of a Motion for Discovery by filing a Motion for Summary Judgment, so has the Defense forfeited the possibility to respond to the evidence by agreeing to said motion.
  
  Besides following simple procedure, the Prosecution has adhered to the instructions given by Judge Kant in a previous notice on the docket:

  Meaning the defense, should they want to continue with a motion for Summary Judgement, will be given the opportunity to give their opening statement, followed by the prosecutions first closing statement.

  The Prosecution will pre-emptively administer an objection to any attempt by the Defense to comment on the provided evidence, has they have agreed to its submission in full without restriction when agreeing to the Motion for Summary Judgment.
  
  
  Regards,
  
  Terence Williams
  Attorney General
  San Andreas Judicial Branch
  (909) 234-9321 — [email protected]

[Hope Kant]

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

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• Prosecution and defense counsel,
  
  Thank you to both parties for their responses, and apologies for the delay. The defense has provided their opening statements to the courts; the prosecution has responded with their first closing statement. The defense will now be given 3 days to respond with their final closing statement.
  
  The court would like to note that this is a summary judgement and not a docket trial, meaning the review of evidence should occur simultaneously during the presentation of arguments by either side. I apologize if this was not made clear earlier.
  
  Defense you may proceed.
  
  Respectfully,
  
  Superior Court Justice
  Branch Administrator
  San Andreas Judicial Branch
  505-9925 — [email protected]

[Bruce Tubby]

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

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NOTIFICATION OF CHANGE IN COUNSEL

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IN THE SUPERIOR COURT OF SAN ANDREAS

State of San Andreas v. Billy Pappalardo

A Notification of Change in Counsel was filed in the above case on 16th of December, 2024.

Please be advised that effective immediately, Bruce Tubby will assume the role of Primary Counsel in the above-referenced matter. All future correspondence, filings, and communications should be directed to their attention.

Should you have any questions or require clarification, please do not hesitate to reach out.


Junior Public Defender
San Andreas Judicial Branch
(909) 494-8268 — [email protected]