Eclipse Government

DEFENDANTS NAME: Charlie Bankshot
DEFENDANTS PHONE: 283-9593
DEFENDANTS ADDRESS: 178 Weazel Plaza
ATTORNEY NAME: Hugh R. Allgood
ATTORNEY PHONE: 235-6076

OFFICERS NAME: Unknown, But Staff Sgt. Christopher Porter was present
RANK: DS3
BADGE NUMBER: 10823
ATTORNEY NAME:
ATTORNEY PHONE:

DATE AND TIME OF INCIDENT(s): Nighttime, 10/8/2021

CHARGES BEING APPEALED:
Felony Evading

DEFENDANTS STORY/OPENING STATEMENTS:
While trying to return my friend's bike, I was offroading it on the side of the highway. Never on the pavement, always on the dirt or hills. SD pulled me over for absolutely no reason. Feeling I would be in trouble for having a bike that wasn't mine, I tried to leave the scene. However, I have been informed that if the traffic stop was bad, all other parts of the conviction are un-usable.

I would like to be compensated my court fees, my prison fines as well as $10,000 for emotional pain and suffering.
Signed,
Charlie Bankshot

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• To whom it may concern,
  
  I am Court Clerk Roy Duke-Judge and I will be the presiding judge on this case. This case is now marked as ACTIVE. Before any motions start getting submitted to the docket I would like both sides to have appropriate representation. I will be reaching out to Attorneys to find the Los Santos County Sheriff's department proper representation, once an Attorney has been assigned and that is made clear on the public docket I will then give each side (7) Seven Days to submit any evidence and motions to the court. Once that is done, I will send appropriate notices of action and a hearing will be scheduled.

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• From
  
  Court Clerk Roy Duke-Judge
  San Andreas Judicial Branch
  San Andreas Government

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• Your Honor,
  
  My name is Oliver Jenkins and i will be taking over as acting counsel for the Los Santos Sheriff's Department in this case. I am familiarizing myself with the case and will reaching out to the client to gather more information

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Respectfully,


Oliver Jenkins
State Attorney
San Andreas Judicial Branch
300-6543

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• Counsel,
  
  Now that both sides have adequate representation, as stated you will have (7) Seven Days to submit any evidence and motions to the court and we will move forward with this case.

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• Regards,
  
  Court Clerk Roy Duke-Judge
  San Andreas Judicial Branch
  San Andreas Government

San Andreas Judicial Branch
Motion to Compel Discovery

Honorable : Roy Duke-Judge

• We the appellant 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.

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  Charlie Bankshot vs. Los Santos County Sheriff's Department
  Assigned Court Case Number: 21-10-09-AP-016
  Requesting Party: Appellant
  Party Members: Charlie Bankshot & Los Santos County Sheriff's Department

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  Discovery from: Los Santos County Sheriff's Department
  
  Type of Discovery: Deposition / Witness Statement
  • Witness Statement from both Christopher Porter and Deputy badge # 10823
  Detailed reasoning: [Provide a detail explanation as to the relevance of the discovery request]
  • In Ms. Bankshot's appeal application, she mentions being pulled over by SD and mentions Staff Sergeant Christopher Porter as being present along with Deputy badge # 10823. I would like written statements from all of these Deputies about their involvement in this case.

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  Thank you for your consideration.

Sincerely

State Attorney Hugh R. Allgood
Attorney for Charlie Bankshot

San Andreas Judicial Branch
Motion to Compel Discovery

Honorable : Roy Duke-Judge

• We the appellant 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.

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  Charlie Bankshot vs. Los Santos County Sheriff's Department
  Assigned Court Case Number: 21-10-09-AP-016
  Requesting Party: Appellant
  Party Members: Charlie Bankshot & Los Santos County Sheriff's Department

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  Discovery from: Los Santos County Sheriff's Department
  
  Type of Discovery: Report / Video evidence
  • Arrest report of Charlie Bankshot
  • Body & dash camera from both Christopher Porter and Deputy badge # 10823
  Detailed reasoning: [Provide a detail explanation as to the relevance of the discovery request]
  • I would like to review the arrest report and body camera from both Christopher Porter, and badge # 10823 from this incident, who are both listed in the appeal as being involved in someway. I believe this evidence will serve as the foundation for my defense of Ms. Bankshot.

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  Thank you for your consideration.

Sincerely

State Attorney Hugh R. Allgood
Attorney for Charlie Bankshot

San Andreas Judicial Branch
Discovery

Honorable : Roy Duke-Judge

• We the respondent in the case below are presenting our discovery to the court.

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  Charlie Bankshot vs. Los Santos County Sheriff's Department
  Assigned Court Case Number: 21-10-09-AP-016
  Requesting Party: Appellant
  Party Members: Charlie Bankshot represented by Hugh. R. Allgood.

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  Exhibit #1: Los Santos Sherriff's Department
  Type of Discovery:
  • Arrest Report
  ► Show Spoiler

  All Information from the Discovery
  Below is the arrest report from the arresting officer on the 09/OCT/2021.

  • 
    ARREST REPORT
    

    MUGSHOT

    SUSPECT 1 DETAILS

    • 
      Full Name: Charlie Bankshot
      Licenses Revoked: No
      Charges:
      • VF01 - Felony Evading
      How did the suspect plea to the above charges?
      Suspect pleaded guilty to all charges.
      Additional Details (Suspect's vehicle, etc.) :
      The suspect was operating a blue BF400

    DEPUTY DETAILS

    • Full Name: Sergio Livanos
      Badge Number: 10823
      Callsign: 12-C-19

    INCIDENT DETAILS

    • Date of Arrest: 2021-10-09
      Deputies Involved: Staff Sergeant Christopher Porter, Deputy Sheriff II Alex Mathews, Deputy Sheriff I Trent Williams
      
      Provide details of the incident leading up to the arrest
      • She was driving on the emergency lane on Senora Freeway, incorrect in order to do an illegal u-turn, upon turning on my lights and sirens she tried to evade but was caught eventually after falling from the bike and being injured

    EVIDENCE DETAILS

    • Exhibit A:

    ARRESTING DEPUTY SIGNATURE
    
    

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  Signed hereof,

Sincerely

State Attorney Oliver Jenkins
San Andreas Judicial Branch

San Andreas Judicial Branch
Motion to Compel Discovery

Honorable : Roy Duke-Judge

• We the respondent 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.

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  Charlie Bankshot vs. Los Santos Sheriff's Department
  Assigned Court Case Number: #21-10-09-AP-016
  Requesting Party: Respondent
  Party Members: Oliver Jenkins representing the Los Santos Sheriff's Department

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  Discovery from: Appellant Charlie Bankshot's Party
  
  Type of Discovery: Physical Evidence & Document Request
  • Physical Evidence: Any bodycam recordings if available.
    Document Request: Any document that have been submitted to the court.
  Detailed reasoning: [Provide a detail explanation as to the relevance of the discovery request]
  • We, the respondent, are requesting any evidence that the appellant has submitted to the court that may support the respondent's case.

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  Thank you for your consideration.

Sincerely

State Attorney, Oliver Jenkins
San Andreas Judicial Branch

San Andreas Judicial Branch
Discovery

Honorable : Roy Duke-Judge

• We the respondent in the case below are presenting our discovery to the court.

  ---

  Charlie Bankshot vs. Los Santos County Sheriff's Department
  Assigned Court Case Number: 21-10-09-AP-016
  Requesting Party: Appellant
  Party Members: Charlie Bankshot represented by Hugh. R. Allgood.

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  Exhibit #1: Los Santos Sherriff's Department
  Type of Discovery:
  • Witness Statement
  ► Show Spoiler

  

  

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

  Case Information

  • Case Number: #21-10-09-AP-016
    Incident Date: [08/OCT/2021]

  Witness Information

  • Name: Christopher Porter
    Date of Birth: 05/12/1998
    Phone Number: 343-9683
    Occupation: Lieutenant Porter, Los Santos County Sheriff's Office

  Witness Statement

  • During the evening of October 8th 2021, I was on duty and responded to a report of a BF 400 Evading. I arrived on scene minuets into the pursuit as she had been evading for some time, long enough to realize we were trying to stop Mrs.Bankshot. I arrived when Mrs.Bankshot was being apprehended after she had crashed. We had no body cam dating back that far per our policy.
    
    End of Statement
    -----------------------------------------------------------------------------------------------------------------------
    
    Where as Mrs. Bankshot wants compensation she has been imprisoned over 30+ Times for serious felony's, serious crimes against officers and others. She seems to have admitted to the crime already and she obviously was not emotionally scared from this incident as DOC and being arrested seems like a revolving door. I don't there's much else to say here.

  Witness Affirmation

  • I, Christopher Porter, 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 coersion. ((I affirm that all information submitted has been obtained via In-Character means.))
    
    Signed,
    From
    
    Lieutenant Christopher Porter
    Los Santos County Sheriff's Department
    North Patrol / Commanding Officer
    Highway Enforcement Division / Commanding Officer
    Internal Investigations
    
    [/b]
    Date: 01/18/2022

  

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  Signed hereof,

Sincerely

State Attorney Oliver Jenkins
San Andreas Judicial Branch

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• Your Honor,
  
  Due to the date of the incident, my client does not have any bodycam footage of the incident.
  
  Additionally, the main arresting officer is no longer with the Los Santos Sheriff's Department and is not available to get in contact with at this time. I sent them emails but they may not return them.

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• Regards,
  
  State Attorney Oliver Jenkins
  San Andreas Judicial Branch
  San Andreas Government

San Andreas Judicial Branch
Motion for Summary Judgement
"HERE FOR YOU | SAFE FOR YOU"

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Honorable : Roy Duke-Judge

• We the respondent in the case below are requesting a summary judgement.

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  Assigned Court Case Number: #21-10-09-AP-016
  Requesting Party: Respondent
  Party Members: Los Santos Sheriff's Department represented by Oliver Jenkins

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  Reasoning: Traffic Stop was legitimate and appellant stated they ran from police.

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  Detailed explanation:
  The arrest report states that the appellant, Charlie Bankshot, was driving in the emergency lane to perform an illegal U-turn. Even if the appellant drove the motorcycle close to the road, it is reasonable for an officer of the state to conduct a traffic stop to check for a license. It is also likely that this was not the first time the vehicle was driving on the pavement as it could have been observed by another officer. Charlie Bankshot was pulled over by Former Master Deputy Sergio Livanos. Rather than talk to the officers, they decided that it would be best to flee from the Sheriff's Department in a high speed chase on the highway. The appellant risked many lives on the road including their own and those of the Sheriff's Department simply because the motorcycle they were driving was not theirs. The carelessness and recklessness of the actions the appellant took gave them the Felony Evading charge which is justified by the pursuit the appellant started.

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  Thank you for your consideration.

Sincerely

State Attorney, Oliver Jenkins

San Andreas Judicial Branch
Motion to Suppress
"HERE FOR YOU | SAFE FOR YOU"

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Honorable : Roy Duke-Judge

• We the appellate in the case below are requesting that certain evidence be inadmissible in court.

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  Assigned Court Case Number: 21-10-09-AP-016
  Requesting Party: Hugh R. Allgood, attorney for Charlie Bankshot
  Party Members: Charlie Bankshot vs. Los Santos County Sheriff's Department

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  Requested Evidence to Suppress: The arrest of Charlie Bankshot and any evidence obtained afterwards.

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  Detailed explanation:
  According to my client, she was stopped by the Sheriff's Department after riding a friend's bike off-road. It is not illegal to ride a bike off-road, and road-rules do not apply in this locale. Former Deputy Sergio Livanos stated my client was riding in the incorrect lane of travel to make an illegal U-turn. The two statements are in direct conflict from one another. From Deputy Livano's statement, it is not clear if my client did indeed make this U-turn. As a result, there is not clear evidence of the legal reason for Deputy Livanos to attempt to even stop my client.
  
  The only statement I received in response to my motion for discovery was from Lieutenant Porter who was not involved in anything other than the pursuit following the stop. Without a statement from Deputy Livanos, or something to show which version of events is correct, we are left not knowing. I seek to suppress the evidence obtained from Lieutenant Porter on grounds of the invalid traffic stop, and the arrest of Ms. Bankshot entirely.
  
  It is the burden of the Sheriff's Department to prove these charges against my client, however, the very nature of the traffic stop is unclear from the arrest report, and I have not received any response back on my request for discovery from Deputy Livanos.
  

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  Thank you for your consideration.

Sincerely

State Attorney Hugh R. Allgood
Attorney for Charlie Bankshot

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• San Andreas Appellate Court,
  
  I just spoke with Ms. Bankshot.
  
  In response to the motion filed by Attorney Jenkins, Ms. Bankshot does not have any video footage of this incident. Therefore, we are unable to turn over any evidence in response to this motion. Any documentation which would have been submitted to the court, is already in this public docket.
  
  From
  
  
  Hugh R. Allgood
  State Attorney
  San Andreas Judicial Branch

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• Your Honor,
  
  Sorry for my delay as I was on Leave of Absence. I have tried to contact the arresting officer multiple times but was unable to even have my emails viewed. Unfortunately, there may be no way to get in contact with him at this point. All other evidence I have collected is posted on the public docket.

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• Regards,
  
  State Attorney Oliver Jenkins
  San Andreas Judicial Branch
  San Andreas Government

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• After a preliminary hearing on 30/01/2022, the court heard motions for supression and for summary judgement in the case of Charlie Bankshot v. Los Santos County Sheriffs Department and the following was ruled:
  
  • The court denies the motion for suppression due to no legal precedent regarding traffic stops by law enforcement officers
  • The court grants the motion for summary judgement due to the case being built on the basis of the legality of the traffic stop and thus having no legal precedent

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• From
  
  Court Clerk Roy Duke-Judge
  San Andreas Judicial Branch
  San Andreas Government

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• The case of 21-10-09-AP-016 - Charlie Bankshot v. Los Santos County Sheriffs Department has hereby been resolved.
  
  The charges applied are found to be valid and appropriately placed. The appellant will face no additional sentencing or Fines.
  
  After a lengthy review of all evidence and statements collected a Summary Judgement was passed that the charge of Felony Evasion on the 9th of October, 2021 was the correct change & the evidence provided by the Los Santos County Sheriff's Department and the Appellant confirmed that.
  
  • CHARGES BEING APPEALED: Felony Evasion
  
  
  
  Appellate Judge
  Appeals Court
  San Andreas Judicial Branch