Eclipse Government

• Detailed Reasoning:
  
  Regarding line labeled as (1): The defense moves to strike this portion of the arrest narrative as irrelevant and unduly prejudicial.
  
  The individuals identified in this line (off-duty agents, Department Secretary Ren Sanchez, and unnamed civilian employees) are not alleged victims, not witnesses to the charged conduct, and not participants in the act forming the basis of the arrest. Their presence has no bearing on whether the elements of GM01 – Assault of a Government Employee were met.
  
  Furthermore, inclusion of this list serves no legitimate evidentiary purpose and instead invites the fact-finder in this case to infer that multiple government officials were involved in, affected by, or endorsed the arrest decision. This risks improperly bolstering the prosecution’s case by suggesting institutional gravity or governmental consensus where none is legally relevant.
  
  The probative value of identifying these individuals is minimal to nonexistent, while the risk of unfair prejudice (implying heightened governmental involvement or authority) is substantial. Accordingly, this portion of the narrative should be struck pursuant to principles of relevance and fairness, as it does not assist the trier of fact in determining any disputed issue and instead risks misleading or inflaming consideration of the charge.
  
  Regarding the line labeled as (2): The defense moves to strike or require rewording of this segment as it contains speculative intent, subjective characterization, and non-expert opinion, rather than a neutral statement regarding observable facts. The phrase “took the opportunity” constitutes an assumption regarding Mr. Langley’s mental state and motive, which the reporting officer is not qualified to assert. Determinations of intent are reserved for the judge in this case and may not be inferred through narrative phrasing in an arrest report. The narrative must be limited to what was observed, not why the officer believes it occurred or what intent is implied. Accordingly, the defense respectfully requests that this portion either be struck or reworded to reflect a neutral, fact-based description of events, removing speculative language and assumptions regarding intent.
  
  Regarding the line labeled as (3): The defense moves to strike this portion of the narrative as irrelevant and unduly prejudicial. This statement describes conduct occurring after the alleged contact had already ceased and does not bear on any element of GM01 – Assault of a Government Employee, including intent or harm. The alleged offense, as described by the arresting agent, was complete at the moment of contact and immediate withdrawal of the cigarette. The inclusion of post-incident behavior that is not alleged to have caused further harm serves no probative purpose and instead risks improper character inference, inviting the judge to interpret the defendant’s demeanor or attitude as evidence of guilt.
  
  Regarding the line labeled as (4): The defense moves to strike this portion of the arrest report as irrelevant and unduly prejudicial. The referenced conversation with Department Secretary Ren Sanchez occurred after the alleged conduct had already taken place and does not pertain to any factual element of GM01 – Assault of a Government Employee. Whether a third party was consulted, or what opinions were exchanged during that discussion, has no bearing on whether the defendant committed the charged offense or possessed any malicious intent at the time of the alleged contact. Moreover, inclusion of this conversation improperly suggests that the arrest decision was validated or endorsed by supervisory authority, thereby inviting the fact finder to infer of correctness or legitimacy based on hierarchical approval rather than evidentiary facts. Such language constitutes improper bolstering and risks shifting the judge’s focus away from the underlying conduct and toward internal administrative agreement.
  
  Regarding the lines labeled as (5): The defense moves to strike this section in its entirety as irrelevant and unduly prejudicial. This section describes post-arrest administrative logistics and internal decision-making, including requests for assistance, transport between facilities, detention location preferences, and conversations with supervisory and executive officials. None of these facts bear on any element of GM01 – Assault of a Government Employee, nor do they assist the judge in determining whether the alleged offense occurred or whether any malicious intent existed at the time of the alleged conduct. The charged offense, if any, was complete prior to arrest. Actions taken afterward (such as which officers assisted, where the defendant was transported, or how detention was administratively handled) are procedural in nature and have no probative value as to guilt. Moreover, the repeated references to supervisory approval and executive involvement (including conversations with the Department Secretary and the Governor) constitute improper bolstering by suggesting that the arrest and charges were validated by higher authority. Such language, once again, invites the fact finder to infer that the correctness of the charges has been endorsed by governmental leadership, a determination reserved solely for the court.

• Detailed Reasoning: The defense moves to strike the phrase “beginning to smoke it as usual” as irrelevant and unduly prejudicial. This language describes post-contact behavior occurring after the alleged conduct had ceased and does not relate to any element of GM01 – Assault of a Government Employee. The alleged offense, as described by the witness, was complete at the moment the cigarette was removed. Whether the defendant continued to smoke afterward has no probative value as to intent or harm. Instead, this phrasing operates as demeanor evidence, inviting the trier of fact to infer guilt based on conduct unrelated to the charged act. Such inferences are improper, particularly where the behavior did not result in further contact or harm.
  Any marginal relevance of this detail is substantially outweighed by the risk of unfair prejudice.
  
  Furthermore, the defense moves to strike the remainder of the highlighted section as irrelevant and unduly prejudicial. This portion describes post-detention administrative handling, including transport logistics, detention location decisions, supervisory approval, and sentence execution. These events occurred after the alleged conduct and after the witness’s detention decision, and they do not bear on any factual element of GM01 – Assault of a Government Employee. Additionally, as with the arrest report, inclusion of references to supervisory and executive approval (specifically the involvement of Department Secretary Ren Sanchez and Governor Whitehorse) constitutes improper bolstering and risks creating an impermissible inference that the validity of the charge has been endorsed by higher authority. Such determinations are reserved for the court and are not evidentiary facts.

• GM01 - Assault (Gov. Emp.)

• GM02 - Battery (Gov. Emp.)

• First, no individual listed in that line is identified elsewhere in the any of the evidence as a witness to the alleged conduct, nor has the State given any testimony or evidence suggesting that these individuals observed the alleged act. Speculation that unnamed persons might become witnesses does not create relevance. Evidence must be relevant at the time it is offered, not hypothetically relevant at some future stage.
• Second, the Attorney General's claim that striking this line would render the report “less factual” misunderstands the purpose of an arrest narrative. An arrest report is not a lifeinvader post of who is hanging about; it is a factual record supporting probable cause. Naming high-ranking government officials who play no role in the alleged offense serves no evidentiary function.
• Third, naming multiple government officials who are not alleged witnesses or victims adds little factual value and risks giving the appearance that the arrest carries added authority or validation. This does not assist the Court in determining whether the charged conduct occurred.

• Caused no further harm
• Involved no further contact
• Was not accompanied by statements or conduct indicating intent

(1)off-duty agent's Tanner Brooks, Conrad Fredrico, Department Secretary Ren Sanchez, a number of both civilian SASG employees and civilian non-SASG employees, and

(3)and continued to smoke it.

(4)At this time, I consulted Department Secretary Ren Sanchez on the matter, asking her thoughts on the situation. After our brief discussion,

(2)took the opportunity

(5)I then requested that off-duty agents Conrad Fredrico and Tanner Brooks clock on to assist with the arrest being carried out, as I assisted the arrestee Lewis Langley into the back of my slick top Crown Victoria cruiser before radioing to the LSPD to inform them we were en route to their facility and request an officer be present to assist with processing.
I then drove to MRPD with Department Secretary and Arrestee Lewis Langley in my cruiser with the 2 other agent's Tanner and Conrad, following behind in a separate vehicle, where we were greeted by 2 officers from the LSPD.

Once in the processing area of MRPD, Arrestee Lewis Langley began to beg to be held at city hall until he was able to speak to Governor Whitehorse. I left this decision with my supervisor, Department Secretary Ren Sanchez, who approved the request.
I then escorted Arrestee Lewis Langley back to my cruiser, and all SASG employees then drove back to City Hall, where I assisted him into the holding cells located in the GSB offices under City Hall.

At this time, Department Secretary Ren Sanchez then issued a pager for Governor Emily Whitehorse and emailed her explaining the situation, requesting she fly in and clock on to assist with the situation.
After a short period of time, Governor Whitehorse responded to the pager and discussed the charges at length with myself and Department Secretary Sanchez.
After this, she had a short discussion with the arrestee Lewis Langley and decided to continue with the charges placed where he served his time and was released.

and beginning to smoke it as usual.

Mr Langley was transported to MRPD to be processed. He then requested to be held in the city hall holding cells so he could speak to Governor Whitehorse. This request was granted by Department Secretary Ren Sanchez.
He was then transported to the city hall holding cells, where he carried out the rest of his sentence.

However, based on the situation, with several people on site cracking jokes and generally seeming jovial, one would not have imagined Lester to be in distress.

I assumed they were friends, so I didn't immediately respond to the behaviour, as some people have unorthodox platonic love languages.

I do not think he acted with malice or the intent to harm, but rather in a very misguided attempt to render aid based on a warped understanding of wound cauterization principles.

I don't know whether that distinction is important, but considering Mr Langley's unique position, he is left in a precarious situation if revoked of his firearms license and body armour privileges.

Leaving him defenseless does seem a little like death by exposure in ancient Rome.