Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009

Osama Bakir
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Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009

Post by Osama Bakir »

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San Andreas Judicial Branch

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Personal Information:
DEFENDANTS NAME: Osama Bakir
DEFENDANTS PHONE: 5138937
DEFENDANTS ADDRESS: Eclipse Towers, Apt. 409
ATTORNEY NAME:Unknown
ATTORNEY PHONE: Unknown
General Information:
OFFICERS NAME: N/A (N/A If Unknown)
RANK: OMEGA-1 (N/A If Unknown)
BADGE NUMBER: 524
ATTORNEY NAME: n/a
ATTORNEY PHONE:n/a
Incident Information:
(s):

CHARGES BEING APPEALED: Reckless Operation, which lead to me failing parole, and receiving all my charges from prior actions

DEFENDANTS STORY/OPENING STATEMENTS: I was driving down Senora Freeway, southbound. After having been pulled over by OMEGA-1, I give him my license and explain the situation. Omega 1 then goes and back to his cruiser and deliberates what punishment to give me. After his long and hard deliberations, he steps out of his cruiser and informs me that I am going to be arrested on the baises of reckless operation. I comply with everything I am told but ask for Omega-1's badge number. I then ask what speed he clocked me going, and he replies with 175. I am contesting these charges as 1, going 30kph above the speed limit does not entail a 3rd-degree speeding ticket, LET ALONE a reckless operation charge, and secondly, these charges have unfortunately caused me to fail my parole, which has put me in jail for a long time, (any evidence attached must pertain to or somehow involve the situation)

Signed,
Osama Bakir

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Zachary LaBlaze
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Re: Osama Bakir | Charges Appeal | 9/25/2021

Post by Zachary LaBlaze »

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San Andreas Judicial Branch

Re: Osama Bakir | Charges Appeal 25-09-21
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  • Your Honor,

    My name is Zachary LaBlaze and I will be acting as counsel for the Los Santos Sherriff's Department in this case. I will be reaching out to my client and familiarizing myself with the case in the coming days and will be ready to proceed at the court's discretion.

    From

    Attorney Zachary LaBlaze
    State Attorney
    San Andreas Judicial Branch

    (209) 538 - 4399 / [email protected]
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Re: Osama Bakir | Charges Appeal | 9/25/2021

Post by Bret Hyland »

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Re: William Taylor | Charges Appeal | 09/25/2021
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  • Mr. Bakir,
    Your case will be reviewed by a court clerk shortly, please state weather you wish to self represent or are planning to hire an attorney.

  • From


    Associate Justice Bret Hyland
    San Andreas Judicial Branch
    San Andreas Government
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Osama Bakir
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Re: Osama Bakir | Charges Appeal | 9/25/2021

Post by Osama Bakir »

I will be self-representing myself!
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Hank Holt
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[21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Hank Holt »

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San Andreas Judicial Branch

[21-10-12-AP-009] Osama Bakir | Charges Appeal
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  • Mr. Bakir, Counselor Lablaze,

    Good afternoon. As per the directions of Judge Hyland, I have been assigned to this case. Mr. Bakir, you should be advised that you can be assigned an attorney free of charge on behalf of the state should you wish it. If not, I will proceed with this case on the assumption that you waive your right to counsel willingly, which is not a course of action that I recommend you take lightly. In either case, please confirm with this court whenever you wish to continue to self-represent yourself or have an Attorney assigned on your behalf.

    I will set a tentative hearing date of Sunday the 17th at 8 PM ((UTC)). I expect both the Appellant and the Respondent to have any and all submissions they wish to have considered ready by that date. Should either the Appellant or Respondent need any information from the adverse party, you may file motions for discovery on this docket. Any and all submissions that will be presented at the hearing will need to be submitted on this docket before-hand.

    Should the hearing date need to be re-scheduled, please let me know.

  • Respectfully,


    Hank Holt
    Court Clerk
    San Andreas Judicial Branch
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Zachary LaBlaze »

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San Andreas Judicial Branch

Osama Bakir v Los Santos Sheriff's Department
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  • Your Honor,

    The prosecution would like to submit into evidence the following:
    • Statement from LSSD Sheriff [REDACTED] regarding Osama Bakir's September 25th arrest
      Spoiler
      REDACTED wrote: Image
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      Los Santos County Sheriff's Department

      Re: Osama Bakir v Los Santos Sheriffs Department | Representatio
      "A TRADITION OF SERVICE"

      • October 16th, 2021
        District Attorney LaBlaze,

        On September 25th I was posted on the side of Senora Freeway, opposite to the scrap yard, when a pink Rebla GTS, registered to Osama Bakir, sped past me at speeds exceeding 170km/h. I immediately started to follow Mr. Bakir and was reaching speeds of 205km/h while trailing Mr. Bakir before he eventually reduced his speed significantly and came to a stop next to Paul's Farm where I conducted the 10-55. Upon checking the MDC I learned that Mr. Bakir was currently on active parole. I quickly read his parole form and found that, amongst other things, Mr. Bakir was at the time on parole for reckless operation and felony evading. After I radioed my situation to dispatch, Assistant Sheriff [REDACTED] informed me that he too clocked Mr. Bakir on the opposite lane in speeds in excess of 190km/h. I informed Mr. Bakir that I clocked him in excess of 170km/h initially but he fails to mention that he was also informed of my second reading when trailing him and he also fails to mention Assistant Sherriff [REDACTED]'s prior reading.

        I proceeded to talk to Mr. Bakir where he swiftly informed me that the reason he was speeding is that the speed limit is "too slow" and he confirmed that he in fact always speeds and sees no point in following the road law as he thinks it is "stupid".

        After I went back to my cruiser, and after having read the parole form once more, I made the decision to charge Mr. Bakir with both, Speeding 3rd degree for the excessive speed he was confirmed doing from multiple peers, and with Reckless Operation for the manner in which he was driving and his open disregard for the safety of others around him. Mr. Bakir was on parole for these very same offenses and still did not learn from his past mistakes, continuing to drive in a manner which endagers others. It is to my understanding that the charges were applied correctly to a repeat offender in compliance with the penal code descriptions with no room for leniency while on active parole.

        Attached you will find my bodycam recording of the conversation I have had with Mr. Bakir during the 10-55.

        https://www.youtube.com/watch?v=_T-Z4aRz-w0


        • From

          Sheriff [REDACTED]
          Los Santos County Sheriff's Department
      [REDACTED]
    • Footage from LSSD Sheriff[REDACTED]'s body camera detailing the interaction between the Sheriff and Mr. Bakir
      Spoiler
    Relevance:
    Sheriff [REDACTED]'s statement will provide an account of Mr. Bakir's dangerous and reckless operation of a motor vehicle leading to his September 25th arrest. The accompanying body camera footage will show that the appellant admits that he was speeding, and provides no excuse for his actions.

    From


    District Attorney Zachary LaBlaze
    District Attorney's Office
    San Andreas Judicial Branch
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Hank Holt »

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San Andreas Judicial Branch

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  • Following the conclusion of the first preliminary hearing (in which unfortunately, despite this courts best efforts the Appellant has failed to show), the counselor for the State has petitioned this court for this case proceed to trial. This court will schedule the upcoming court date for Sunday 31st at 8 PM ((UTC)).

    This court has found that there is a possibility for the Appellant to succeed in their claims, based on the evidence presented thus far to this court. However, the Appellant needs to take an active role in the proceedings from here on out. Should the Appellant continue to remain Incommunicado, the State reserves the right to ask this court to dismiss the appeal at trial.

    Respectfully,


    Hank Holt
    Court Clerk
    San Andreas Judicial Branch
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Osama Bakir »

Dear Hank Holt, after many a thought, i have decided to appoint you as my attorney
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Hank Holt »

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San Andreas Judicial Branch

Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal
"HERE FOR YOU | SAFE FOR YOU"

  • Mr. Bakir,
     
    As the court clerk assigned to preside over your case, I cannot also act as your attorney. Should you wish to get in touch with one of our attorneys, you may do so using the contact information here.
     

  •  
    Respectfully,
     

    Hank Holt
    Court Clerk
    San Andreas Judicial Branch
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Colt Daniels »

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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal
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  • Your Honor,

    I will be acting as council for the appellant Mr. Bakir. My client was unable to show up for the preliminary hearing as he was still in prison at Bolingbrook Penitentiary. He posted his appeal after a Department of Corrections guard allowed him to use the computer to file it. He is still jailed there due to the Sheriff decision to arrest my client on false charges causing him to fail his parole and re-serve his sentence plus extra. Please allow time for me to familiarize myself with the entirety of the case and meet with my client to gather evidence.

    From
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    San Andreas Judicial Branch
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Colt Daniels »

Motion to Compel Discovery
San Andreas Judicial Branch
Motion to Compel Discovery

Honorable : Hank Holt
  • We the defense in the case below are requesting the disclosure of the following material by opposing counsel, please find a detailed reason as to our request below.
    Osama Bakir vs. the LSSD
    Assigned Court Case Number: [21-10-12-AP-009]
    Requesting Party: Defense
    Party Members: Colt Daniels, Osama Bakir
    Discovery from: LSSD

    Type of Discovery: Document Request
    • The parole contract for Osama Bakir
    Detailed reasoning:
    • I believe the conditions of his parole will be outlined in his parole contract, sense my client was charged causing him to fail his parole we would like a copy of the contract.

    Thank you for your consideration.
Sincerely
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Hank Holt »

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  • The motion to compel discovery has been granted. A notice of action has been sent to the relevant parties via secure government email to compel discovery of the requested evidence. Once the documents have been submitted to this court, a redacted version with any personal information will be published to the court docket.

  • Respectfully,


    Hank Holt
    Court Clerk
    San Andreas Judicial Branch
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Hank Holt »

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San Andreas Judicial Branch

Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal
"HERE FOR YOU | SAFE FOR YOU"

  • A copy of the parole contract terms was provided for by the Los Santos Sheriff's Department, and disseminated to both counselors. Due to the personal nature of some of the conditions contained within, as well as due to the request of the Detention and Parole Bureau, this document has been filed under seal and will thus not be made available in the public docket.

  • Respectfully,


    Hank Holt
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    San Andreas Judicial Branch
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Judith Mason »

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San Andreas Judicial Branch

Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal
"HERE FOR YOU | SAFE FOR YOU"

  • To whom it may concern,

    My name is Judith Mason, I am a Court Clerk with the San Andreas Judicial Branch and I will be taking over this case from Mr. Holt following his resignation from the branch. I thank you for your patience regarding this case, I understand that a number of changes have been made regarding the branch staff involved.

    At this time, I will ask that the attorneys on the case respond to this with who they will be representing so that the public record is up to date. We will then move forward when both parties have had a chance to meet with their respective clients and prepare for trial.

    Respectfully,

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    Judith Mason
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Colt Daniels »

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San Andreas Judicial Branch

[21-10-12-AP-009] OSAMA BAKIR | CHARGES APPEAL
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  • Court Clerk Mason,

    I will still be acting council on the behalf of Osama Bakir in this appeal. I have submitted everything necessary for this case in regards to the defense and am ready to proceed to trail at your direction.

    From
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    District Criminal Defense Attorney
    San Andreas Judicial Branch
    (909) 402-9713 — [email protected]
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Ophelia Panes »

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San Andreas Judicial Branch

Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal
"HERE FOR YOU | SAFE FOR YOU"

  • Court Clerk Mason and all relevant parties,
    I, Ophelia Panes will be taking over the position of counsel to the Los Santos Sheriff's Department in the wake of the information of Mr. LaBlazes's departure from the branch. I truly do appreciate all parties' patience in regards to this case as there have been multiple changes in the standings of the case as well as in the branch as a whole. Do allow for me to have a few more days to familiarize myself with the case and to finalize reaching out to my client if they wish to provide any further statements in regards to the case prior to proceeding to trial. An update will be provided accordingly when this has happened.

    Cheers,

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    Ophelia Panes
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    San Andreas Judicial Branch
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Ophelia Panes »

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San Andreas Judicial Branch

Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal
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  • Court Clerk Mason and all relevant parties,

    Good Evening. I have taken time to be able to meet with my client and discuss the case. We are both ready to proceed to trial accordingly and are open to begin planning for a day to have the trial.

    Cheers,

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    Ophelia Panes
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Colt Daniels »

Form 3.0.5 - Motion to Suppress
San Andreas Judicial Branch
Motion to Suppress
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Honorable : Judith Mason
  • We the defense in the case below are requesting that certain evidence be inadmissible in court.
    Assigned Court Case Number: 21-10-12-AP-009
    Requesting Party: Defense
    Party Members: Colt Daniels, Osama Bakir
    Requested Evidence to Suppress: Bodycam Footage 1:19 - 1:36
    Detailed explanation: Sheriff Wallace asked Mr. Osama Bakir questions in regards to a criminal investigation in the hopes or desire to use my clients statements as evidence against him before my client was read his rights.

    Thank you for your consideration.
Sincerely
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Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal

Post by Colt Daniels »

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San Andreas Judicial Branch

Re: [21-10-12-AP-009] Osama Bakir | Charges Appeal
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  • To whom it may concern,

    This case is now being taken over by Attorney Fitz Keegan as council for Mr. Bakir. I have spoken with Mr. Bakir and he is up to speed with the position this case is currently in. Please allow some time for Attorney Keegan and myself to meet and get him completely up to speed with what has transpired in this case and give him my notes. Thank you

    From
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    San Andreas Judicial Branch
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Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009

Post by Judith Mason »

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San Andreas Judicial Branch

Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009
"HERE FOR YOU | SAFE FOR YOU"

  • To whom it may concern,

    First off, I'd like to thank everybody for their patience in this matter.

    Secondly, I would like to confirm representation for both sides as it has been some time since the beginning of this case. Am I still correct in stating that representation for Mr. Bakir is Attorney Fitz Keegan, and representation for the Los Santos County Sheriff's Department is Attorney Ophelia Panes? Please confirm this in a response to the public docket.

    Next, I see a Motion to Suppress evidence in regards to a portion of the bodycamera footage provided by the Sheriff. I am inclined to grant this motion on the grounds that Mr. Bakir had not been read his rights and thus his statements made prior to the reading of his rights would be considered inadmissible at trial. Unless the prosecution is able to present an argument to contest this, that is how the court will be moving forward at this time.

    Finally, I would ask that when counsel for both sides respond to this message confirming their representation, that they make it known to the court if they have any additional motions they would like to submit, or if they are ready to proceed to trial.

    Respectfully,

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    Judith Mason
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Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009

Post by John Wallace »

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Los Santos County Sheriff's Department

Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009
"A TRADITION OF SERVICE"

  • January 19th, 2022
    Court Clerk Mason,

    We have been unable to get in contact with Ms. Panes for multiple weeks as she neither returns our calls nor emails. Therefore, we do not consider us currently represented within this matter and request the court to assign proper representation to us.

    Since we are currently not represented in this court, I am hereby requesting the motion to suppress evidence to be denied. The motion presented has no legal basis. There is no law or regulation in the State of San Andreas which requires miranda rights to be read during a traffic stop. Further, the Sheriff's Department operates within regulations approved by the Board of Commissioners which state:

    3.6 Traffic Stop Protocol:
    "At every stage of the Traffic Stop, the suspect is legally considered to be detained. If they request information on why you initiated the Traffic Stop, you can inform them at the time or later in the situation. You can also ask the driver to give their opinion on why they have been stopped, often providing additional evidence or even a confession for offenses the officer may not have directly witnessed."

    The Board of Commissioners has approved this procedure and does not require any additional miranda rights.

    We ask therefore, that the motion to suppress evidence is denied for not being based on any legal, approved and acknowledged procedure or law in the State of San Andreas.

  • From
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    Sheriff John Wallace
    Los Santos County Sheriff's Department
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Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009

Post by Judith Mason »

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San Andreas Judicial Branch

Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009
"HERE FOR YOU | SAFE FOR YOU"

  • Sheriff Wallace,

    Thank you for your response.

    I will be in touch with you via email regarding your representation to ensure a fair trial.

    In regards to the Motion to Suppress Evidence, I will hold my final decision pending a hearing as I would now like to hear oral arguments regarding this matter on the record. This hearing will be scheduled once proper representation has made it known as a response on the public docket.

    Respectfully,

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    Judith Mason
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    San Andreas Judicial Branch
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Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009

Post by Hugh Allgood »

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San Andreas Judicial Branch

Osama Bakir | Charge Appeal
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  • San Andreas Appellate Court,

    After consulting with Sheriff John Wallace via e-mail, I will be taking on the case on behalf of the Sheriff's Department.

    After my review of the case, I agree with Sheriff Wallace on the lack of legal foundation for the motion to suppress, and will be prepared to defend this position in any subsequent hearings held on this matter.

    From


    Hugh R. Allgood
    State Attorney
    San Andreas Judicial Branch
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Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009

Post by Judith Mason »

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San Andreas Judicial Branch

Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009
"HERE FOR YOU | SAFE FOR YOU"

  • Parties,

    I must inform you that Attorney Fitz Keegan has resigned from the San Andreas Judicial Branch effective today suddenly leaving Mr. Bakir without representation. The necessary arrangements are being made to promptly appoint effective counsel and allow them to familiarize themselves with the case. I thank you for your patience.

    Respectfully,

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    Judith Mason
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Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009

Post by Judith Mason »

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San Andreas Judicial Branch

Re: Osama Bakir v. Sheriff's Department | Docket #21-10-12-AP-009
"HERE FOR YOU | SAFE FOR YOU"

  • Parties,

    It has come to my attention that the appellant in this case has not been available via phone nor email to his perspective defense counsel that has been appointed by the branch. I will be giving Mr. Bakir 72 hours to either post on the docket, or get in contact with Attorney Dakota Macaw to post on his behalf, to confirm his intentions on moving forward with this appeal. If there is no confirmation by the deadline, this case will be dismissed and archived.

    Respectfully,

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