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21-09-09-AP-011 | Shawn Meekins - LSSD
Posted: 07 Aug 2021, 22:19
by Shawn Meekins


San Andreas Judicial Branch
[SAJB] Appeals Court
"HERE FOR YOU | SAFE FOR YOU" |
Personal Information:
DEFENDANTS NAME: Shawn Meekins
DEFENDANTS PHONE: 450-9643
DEFENDANTS ADDRESS: None at this time
ATTORNEY NAME: Judith Mason
ATTORNEY PHONE: 257-9183
General Information:
OFFICERS NAME: Former Deputy Sheriff II Elysia Smith and Staff Sergeant Tyrone Balakay
RANK: Former Deputy Sheriff II and Staff Sergeant
BADGE NUMBER:
ATTORNEY NAME:
ATTORNEY PHONE:
Incident Information:
DATE AND TIME OF INCIDENT(s): 09/JUL/2021 around 04:30
CHARGES BEING APPEALED:
- WF03 - Possession of Illegal Firearms/Weapons
- GF11 - Attempted Grand Theft Auto of a Government Employee
- VF01 - Felony Evading
DEFENDANTS STORY/OPENING STATEMENTS: (any evidence attached must pertain to or somehow involve the situation)
On 09/JUL/2021 around 04:30, I was driving in the parking lot of Paleto Bank when what appeared to be two Sheriff's Deputies pulled up with a Deputy's cruiser with lights and sirens on. After a brief conversation, they informed me that they would be arresting me for Reckless Driving. I complied with their orders and got into the back of cruiser.
From the bank, we were driving towards Paleto Station when another Sheriff's Deputy's cruiser pulled up behind the one I was in and attempted to pull us over. It was at this time I realized the two men in the seats in front of me were not Deputies, but instead were impersonating them.
A pursuit then took place and I had no opportunity to leave the cruiser once I realized what had happened. After a vehicle crash that flipped the cruiser I was in, I immediately exited the vehicle and put my hands up, waiting for the real Deputies to take control of the scene. I was then arrested for Attempted Grand Theft Auto of a Government Employee and Felony Evading, despite the fact that I was a victim in this situation.
On the way to DOC, I was informed that Sheriff's Deputies had searched my vehicle that was legally parked at the bank without my consent. Due to the fact that my vehicle was not involved in the alleged crimes I was charged with, I believe this was an illegal search. Deputies allegedly recovered a firearm from my vehicle and I was additionally charged with Possession of Illegal Firearms/Weapons.
Signed, Shawn Meekins
Shawn Meekins

Re: charge appeal
Posted: 16 Aug 2021, 15:30
by Darby Adler
Re: charge appeal
Posted: 17 Aug 2021, 19:46
by Judith Mason


San Andreas Judicial Branch
Re: Shawn Meekins | Charges Appeal
"HERE FOR YOU | SAFE FOR YOU" |
- Your Honor,
In regards to the illegality of the vehicle search, the Los Santos Police Department Official Press Release entitled "Knowing Your Rights & Due Process" states that:
Officers are allowed to search and seize any and all illegal or potentially dangerous items from the person of interest, and any and all property involved at the time of the crime, and at the time of an arrest.
The conduct that resulted in my client's arrest did not involve his vehicle. Additionally, Mr. Meekins' subsequent arrest was nowhere near his vehicle and the timestamp of his charges show that it took approximately 6.5 minutes for the firearms charge to be added to his record.
In regards to the other charges of Attempted Grand Theft Auto of a Government Employee and Felony Evading, the individuals that were impersonating Deputies of the Sheriff's Department had an implied authority over my client and, not wanting to be charged with Failure to Comply, my client complied with their demands and ended up in the back seat of the cruiser.
My client did not attempt to take another person's vehicle without consent, as the individuals in the front seats of the cruiser arrived at my client's location already in possession of the vehicle and my client's actions do not constitute Felony Evading because he did not have an opportunity to safely exit the vehicle at an earlier time.
I would like to request body-camera footage and any arrest report that was made by the involved law enforcement, which will show that my client complied to the fullest extent when actual law enforcement arrived on scene and will also potentially show the line of thinking that was involved with the search of my client's vehicle.
Thank you, Your Honor.
Respectfully,

Judith Mason
State Attorney
San Andreas Judicial Branch

Re: charge appeal
Posted: 24 Aug 2021, 15:20
by Darby Adler
Re: Shawn Meekins | Charges Appeal
Posted: 27 Aug 2021, 04:42
by Judith Mason
Re: charge appeal
Posted: 01 Sep 2021, 15:24
by Colt Daniels
Re: charge appeal
Posted: 02 Sep 2021, 16:06
by Darby Adler
Re: Shawn Meekins | Charges Appeal
Posted: 02 Sep 2021, 22:58
by Judith Mason


San Andreas Judicial Branch
Re: Shawn Meekins | Charges Appeal
"HERE FOR YOU | SAFE FOR YOU" |
- Your Honor,
If the Sheriff's Department wanted to charge my client with VC04 - Illegal Parking, they should have done so. However, even if they did, that would not warrant a search of his vehicle. Referring back to the Los Santos Police Department's "Knowing Your Rights & Due Process" Public Release, the section on Search and Seizure states the following:
A citation alone does not authorize law enforcement officers the right to conduct a search and seizure, but does authorize them to lawfully identify the person(s) involved.
Since VC04 - Illegal Parking is a simple Vehicular Citation and his vehicle was not used in the commission of any crime, a search of his vehicle without proper cause is a violation of his rights.
My client is under no obligation to provide proof of payment for a parking ticket that he may or may not have purchased almost two months ago. Again, if the Sheriff's Department wanted to claim that my client parked illegally and wanted to charge him with Illegal Parking, they should have done so, but that still does not give them the right to search the vehicle.
Respectfully,

Judith Mason
State Attorney
Court Clerk
San Andreas Judicial Branch

Re: charge appeal
Posted: 03 Sep 2021, 02:10
by Colt Daniels


San Andreas Judicial Branch
Shawn Meekins | Charges Appeal
"HERE FOR YOU | SAFE FOR YOU" |
- Your Honor,
I would like to request a motion for summary judgment. With the evidence as follows I believe the appellant falsified multiple points within his appeal and believe the appellant has no real prospect of success and there is no other good reason to allow the litigation to continue.
Lieutenant Balakay went through the appeal and pointed out everything that was falsified.
Tyrone Balakay wrote:03 Sep 2021, 00:15
My responses to the statement can be found in
red.
On 09/JUL/2021 around 04:30, I was driving in the parking lot of Paleto Bank when what appeared to be two Sheriff's Deputies
(They were all wearing gang clothing.) pulled up with a Deputy's cruiser with lights and sirens on. After a brief conversation, they informed me that they would be arresting me for Reckless Driving. I complied with their orders and got into the back of cruiser.
It is obvious that they were not Sheriff's Deputies for two reasons. First, they are wearing gang clothing. Second, they are in a Los Santos Police Department Cruiser.
From the bank, we were driving towards Paleto Station when another Sheriff's Deputy's cruiser pulled up behind the one I was in and attempted to pull us over. It was at this time I realized the two men in the seats in front of me were not Deputies, but instead were impersonating them.
There were not two men in the seats in front of him. There was one man driving, and one female sitting next to him in the back seats. They were not impersonating, as they were not wearing any type of clothes that resembled law enforcement.
A pursuit then took place and I had no opportunity to leave the cruiser once I realized what had happened. After a vehicle crash that flipped the cruiser I was in, I immediately exited the vehicle and put my hands up, waiting for the real Deputies to take control of the scene. I was then arrested for Attempted Grand Theft Auto of a Government Employee and Felony Evading, despite the fact that I was a victim in this situation.
Meekins ran about 200ft, before dropping to his knees. Yes his hands were up, but still ran along with the female suspect.
On the way to DOC, I was informed that Sheriff's Deputies had searched my vehicle that was legally parked at the bank without my consent. Due to the fact that my vehicle was not involved in the alleged crimes I was charged with, I believe this was an illegal search. Deputies allegedly recovered a firearm from my vehicle and I was additionally charged with Possession of Illegal Firearms/Weapons.
This is covered in my statement above.
In regards to the vehicle the appealent felt was illegaly searched Lieutenant Balakay wrote,
I returned back to the bank shortly after the scene, to check the vehicles. Note, the driver of the pursuit and Meekins' vehicles were parked right next to each other, with no parking pay. As we had probable cause due to the owners of those vehicles a) not having parking pays and b) having felonies currently on their warrant list, we searched and impounded the vehicles. Meekins' car had an illegal firearm inside of it, and was thus charged with that due to it being in his possession as the car was not reported stolen. Both vehicles were impounded, and the gun was stored in the evidence room. Also, Ms. Mason is referring to the Police Department's public statement about their probable cause, but that is an entirely different Department and has a different handbook than the Los Santos County Sheriff's Department.
In regards to the bodycam footage you can find it here
From

Colt Daniels, State Attorney
San Andreas Judicial Branch
(909) 402-9713 — [email protected]

Re: charge appeal
Posted: 03 Sep 2021, 20:31
by Darby Adler
Re: charge appeal
Posted: 25 Oct 2021, 12:26
by Bret Hyland
Re: 21-09-09-AP - Shawn Meekins - LSSD
Posted: 26 Oct 2021, 23:45
by Hugh Allgood
Re: 21-09-09-AP-011 | Shawn Meekins - LSSD
Posted: 02 Nov 2021, 11:46
by Bret Hyland
Re: 21-09-09-AP-011 | Shawn Meekins - LSSD
Posted: 03 Nov 2021, 03:38
by Colt Daniels
Re: 21-09-09-AP-011 | Shawn Meekins - LSSD
Posted: 18 Nov 2021, 17:15
by Bret Hyland