Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Felix Svensson
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Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Felix Svensson »

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San Andreas Judicial Branch

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Personal Information:
DEFENDANTS NAME: Felix Noonham
DEFENDANTS PHONE: 4861466
DEFENDANTS ADDRESS: NA
ATTORNEY NAME:
ATTORNEY PHONE:
General Information:
OFFICERS NAME: Jason Steel
RANK: Captain
BADGE NUMBER: 6520
ATTORNEY NAME:
ATTORNEY PHONE:

OFFICERS NAME: Grace Steel
RANK: Detective I
BADGE NUMBER: 13542
ATTORNEY NAME:
ATTORNEY PHONE:
Incident Information:
DATE AND TIME OF INCIDENT(s): 29/OCT/2021 - 02:30 ((UTC))

CHARGES BEING APPEALED:
  • WM03 - Possession of Weapon Modifications.
  • WF03 - Possession of Illegal Firearms/Weapons.
  • VC08 - Failure To Yield (to a TCD).
DEFENDANTS STORY/OPENING STATEMENTS:

I was driving the speed limit while being tailed by Captain Steel, after being followed for about a mile he pulled me over on Las Lagunas Blvd and conducted a 10-55 while requesting multiple units to assist him. I was compliant the whole time and offered no fuss at all, I have never been convicted of a violent crime but Jason still saw fit to withdraw his Carbine rifle which goes against the ATD Carbine rifle deployment but I digress. Once he got to my vehicle he immediately ordered me to get off my motorcycle. I began to argue, I am aware of probable cause and told him he had no reason to ask me to step off the bike, he did not inform me at all of what I was being detained for nor the reason of the traffic stop. When I explained to him that he cannot tell me to get off my bike unless I am under reasonable suspicion of an arrestable offense. (Which is still standing according to my knowledge).

When I explained this, Mr. Steel began to get irate and raised his voice, ordering me once again. With the fear of getting a failure to comply charge I got off the bike and walked to the side walk. After a short conversation to which I was only told "I committed a serious traffic violation" I was placed in cuffs for "my own safety" I once again protested and explained that a citation is not enough probable cause to get somebody off their vehicle and search them. When I asked what crime I was suspected to having committed they, they simply told me "In regards to a DB case-file".

In terms of the "serious traffic violation", I was told that I had committed a failure to yield to a TCD which is completely untrue. I slowed down at the intersection just before the location of the 10-55 and another vehicle came blazing through causing me to have to slam my breaks on even more and swerve. I believe the reason for the traffic stop was completely bogus and unfounded and there was 0 evidence to suggest that I have committed any crime or traffic violation. I once again voiced my complaint to Detective Grace Steel that the search was unlawful to which she responded very arrogantly with "Welcome to the criminal life Felix". Affirming the search was illegal but because I have past convictions, I deserve it.

Once I had been searched, an illegal firearm and a silencer was found in a bag that was stored inside of my bike. The search was completely unlawful and goes against not only the Police Departments own Probable Cause protocols but I would argue that my human rights were violated by being forced off out of my vehicle and placed in cuffs due to a simple traffic violation which I did not commit along with it being fruit of the poisonous tree, making the charges that were placed onto myself consequently null and void. I will be forwarding a copy of this IA report to the Justice Bureau and intend on taking this further than just a simple Internal Affairs report.

((I also have the footage of the incident for your own use when the RP is completed of gathering the body-cams from each officer involved. I understand that doing /me and /do for CCTV, the information can sometimes be mis-leading or conveyed incorrectly. Please note that I do not have bodycam and have no RP'd putting 1 on. This is simply to be used to ensure the validity of all RP that is given hence forth. ))

This is a direct copy of the statement from the IA report that I placed again Detectives Jason and Grace Steel. In summary:
  • I feel the search was unlawful, I was taken off my bike and placed in cuffs whilst being pulled over for a simple traffic violation which I was not informed of until after the fact and to which I deny. I was searched illegally and was under no suspicion of having, currently or going to commit a crime as per the penal code of Los Santos. Due to the nature of the search being unlawful, all evidence found during said search being fruit of the poisonous tree, the charges that I faced should be dropped and I would like to pursue the charge of GM22 - False Imprisonment to be placed on Mr. Jason Steel and Mrs. Grace Steel.

    The Penal code states under said charge "No person may restrain, detain, or confined another person without his/her consent unless such action is in relation to legal detainment done by a civilian (citizen's arrest), police, or certified medical personnel." They key word being 'legal', due to the nature of the detainment being a made up reason (that of a traffic violation I did not commit) I whole-heartedly believe the detaining of myself to be illegal in itself.
Signed,
Felix Noonham

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Last edited by Judith Mason on Mon Feb 07, 2022 4:46 am, edited 2 times in total.
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Re: Felix Noonham | (29/OCT/2021) | Docket # _____________

Post by Maximilian Fitzgerald »

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Re: Felix Noonham | (29/OCT/2021)
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  • Your Honor,

    My name is Maximilian Alexander Fitzgerald III and I will be acting as counsel for the Los Santos Police 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.

    Sincerely,

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    Maximilian Alexander Fitzgerald III
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Re: Felix Noonham | (29/OCT/2021) | Docket # _____________

Post by Maximilian Fitzgerald »

((@Felix Noonham I have removed the link to the video just because what exactly happened shouldn't really be seen by anyone until bodycam/cctv rp has been done. I didn't even watch it myself, because it's an active IC case, the info shouldn't be shared to prevent any sort of potential metagaming or influencing the case on an OOC level from either side.

Simply saying you have footage should it be needed for RP is enough for now. - DrPathetic))
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Re: Felix Noonham | (29/OCT/2021) | Docket # _____________

Post by Colt Daniels »

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Re: Felix Noonham | (29/OCT/2021) | Docket #
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  • Your Honor,

    As the District Criminal Defense Attorney I will be taking on the case as counsel for Felix Noonham. I am requesting the judge on the case to be Chief Justice Hyland as I believe that this case has the making to be a precedent moving forward. I have already taken the time to meet with my client and am ready to proceed as soon as the case becomes active. I will also let it be known by the court that Captain Jason Steel contacted me earlier today on the 29th of October 2021 asking me to be his attorney for the case. I later informed him that I am unable to take the case representing him as I am the appointed District Criminal Defense Attorney and need to take cases on the side of the appellant and all things pertaining to the case from the side of the LSPD need to go through District Attorney Fitzgerald III.

    From
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Re: Felix Noonham | (29/OCT/2021) | Docket # _____________

Post by Colt Daniels »

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

Honorable : Bret Hyland
  • 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.
    Felix Noonham vs. The LSPD
    Assigned Court Case Number: N/A
    Requesting Party: Defense
    Party Members: Felix Noonham, Colt Daniels
    Discovery from: The LSPD

    Type of Discovery: Document Request
    • The Detective Bureau Case-File used to detain the appellant.
    Detailed reasoning:
    • This case-file will show the legitimacy of the detention of my client & the entirety of the case is based on if the LSPD had probable cause to detain and search my client and his vehicle.

    Thank you for your consideration.
Sincerely
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Re: Felix Noonham | (29/OCT/2021) | Docket #21-10-29-AP-013

Post by Judith Mason »

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Re: Felix Noonham | (29/OCT/2021) | Docket #21-10-29-AP-013
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  • 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 presiding over this case at the direction of Associate Justice Bret Hyland.

    I see there is a Motion to Compel Discovery submitted from the defense, before I submit the necessary documents, I ask that any other pre-trial Motions be submitted in a timely manner so I may request the information in bulk. From there, responses will be disseminated to both sides and submitted to the public docket.

    Respectfully,

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    Judith Mason
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Re: Felix Noonham | (29/OCT/2021) | Docket #21-10-29-AP-013

Post by Colt Daniels »

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

Honorable : Judith Mason
  • We the defemse 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.
    Felix Noonham vs. The LSPD
    Assigned Court Case Number: 21-10-29-AP-013
    Requesting Party: Defense
    Party Members: Felix Noonham, Colt Daniels
    Discovery from: LSPD

    Type of Discovery: Document Request
    • Bodycam Footage, Officer Statements, Arrest Report, & Situation Report.
    Detailed reasoning:
    I would like to see the footage of how the situation unfolded and what reasoning the detectives gave Mr. Noonham to detain him and search his person and property. I would also like to have statements from the detectives and officers involved explaining their interpretations of what took place during this situation. I would also like to see all reports filed as a result of this arrest (Arrest Report and Situation Report) to see if it includes any information that would be useful to the case.

    Thank you for your consideration.
Sincerely
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Re: Felix Noonham | (29/OCT/2021) | Docket #21-10-29-AP-013

Post by Colt Daniels »

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Felix Noonham | (29/OCT/2021) | Docket #21-10-29-AP-013
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  • To whom it may concern,

    After talks with my client and Judith Mason it has been approved that State Attorney Fitz Keegan will be acting as co-council for my client Mr. Felix Noonham, as this case goes forward if anything is needed from the defense please reach out to both Attorney Keegan and myself. Thank you.
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Re: Felix Noonham | (29/OCT/2021) | Docket #21-10-29-AP-013

Post by Colt Daniels »

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Re: Felix Noonham | (29/OCT/2021) | Docket #21-10-29-AP-013
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  • To whom it may conern,

    From this point forward Attorney Keegan will be the primary council for this case and I will no longer be working on it. As he was co-council he already has all the information needed to move forward from this point. Thank you.

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Re: Felix Noonham v. Police Department | Docket #21-10-29-AP-013

Post by Judith Mason »

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Re: Felix Noonham v. Police Department | Docket #21-10-29-AP-013
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  • To whom it may concern,

    Thank you all, again, for your patience regarding this matter - I would like to begin moving forward starting with confirmation of representation for both sides of this appeal.

    Once that has been taken care of, I would like to handle the pending motions of this case. So far, the following motions have been submitted:
    • Motion to Compel Discovery for the Detective Bureau Case-File used to detain the appellant
    • Motion to Compel Discovery for Bodycam Footage, Officer Statements, Arrest Report, & Situation Report
    Should the Los Santos Police Department wish to oppose these motions, I would ask that it be made known on the public docket, otherwise the motions will be granted and a Notice of Action will be submitted to obtain the requested information.

    If either side would like to submit any additional motions for this case, please ensure you make this known to the court when responding confirming your representation. Thank you.

    Respectfully,

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    Judith Mason
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Re: Felix Noonham v. Police Department | Docket #21-10-29-AP-013

Post by Felix Svensson »

I can confirm that my representation will be that from 1 @Fitz Keegan. Unless Mr. Keegan is no longer employed by the Judicial Branch of the Los Santos Government, I believe we are ready to proceed.

Many Thanks.

Felix Newnham
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Re: Felix Noonham v. Police Department | Docket #21-10-29-AP-013

Post by Judith Mason »

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Re: Felix Noonham v. Police Department | Docket #21-10-29-AP-013
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  • Parties,

    I must inform you that Attorney Fitz Keegan has resigned from the San Andreas Judicial Branch effective today suddenly leaving Mr. Noonham 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: Felix Noonham v. Police Department | Docket #21-10-29-AP-013

Post by Dakota Macaw »

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Re: Felix Noonham v. Police Department | Docket #21-10-29-AP-013
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  • Honorable court,

    After liasoning with Mr. Felix Newnham I have begun work as counsel for the appellate on this case. I will be picking up where the previous counsel has left off shortly, and am ready to continue at the court's discretion. Before the case resumes fully, I would like to request that the record for this case is amended in relation to my client's surname. The spelling of the appellant's full name is Felix Newnham, not Noonham as the documentation currently shows in some places. Thank you again, I look forward to bringing this case to it's conclusion.

    Respectfully,

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    Attorney Dakota Macaw
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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Judith Mason »

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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013
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  • Counselor,

    Thank you for updating the court on the appellant's correct legal name - the docket will be updated and all further correspondence will reference the spelling as 'Newnham.'

    This case will move forward once the assigned representative has gotten in touch with the Los Santos Police Department and informed the court on the public docket.

    Respectfully,

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    Associate Justice
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Last edited by Judith Mason on Mon Feb 14, 2022 9:34 am, edited 1 time in total.
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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Rasheed Briggs »

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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013
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  • To whom it may concern,

    I will be representing the LSPD in the case Felix Newnham v. Police Department.

    Respectfully,
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    Attorney Briggs
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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Judith Mason »

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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013
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  • Parties,

    As both sides now have representation and have had a chance to meet with their clients, I am now opening the discovery phase for the next seven (7) days, bringing discovery to a close at 8:30pm (( UTC )) on 21/FEB/2022.

    As we have two pending motions to compel discovery previously submitted, I would ask of the Police Department's counsel to either provide the information asked or submit a request for a hearing in order for the Court to hear arguments for and against the disclosure of the information the defense seeks.

    Thank you.

    Respectfully,

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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Judith Mason »

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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013
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  • Parties,

    Let it be known that the Los Santos Police Department has indicated to me that they will be moving forward with self-representation in this case.

    As details on court motions and the current court process have not yet been made publicly available, I will be SUSPENDING the discovery phase until the information is posted in the Self-Representation Database. Once that happens, the discovery phase will open for a full seven days, or prior to then provided both parties are ready to move forward.

    Respectfully,

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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Dakota Macaw »

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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013
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  • Honorable court,

    At this time I would like to retract a motion to compel discovery by the previous counselor. Although the discovery period is currently suspended, I would like the motion below to be retracted for the next discovery period.

    "Motion to Compel Discovery for the Detective Bureau Case-File used to detain the appellant"

    Respectfully,

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    Attorney Dakota Macaw
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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Judith Mason »

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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013
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  • Parties,

    At this point in time, I will be reopening the discovery phase of this case for seven days. Please submit any pretrial motions and we will get this case moving forward again.

    Respectfully,

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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Jason Steel »

Motion for Discovery
San Andreas Judicial Branch
Motion for Discovery

Honorable Judith Mason,

  • We the Respondent in the case below are presenting our discovery to the court.
    Felix Newnham v. Police Department
    Assigned Court Case Number: #21-10-29-AP-013
    Requesting Party: Defendant
    Party Members: Police Captain II Jason Steel, Police Detective I Grace Steel
    Exhibit #1: LSPD
    Type of Discovery: Physical Evidence
    • Written report submitted by a sworn officer about their interaction with the appellant a short amount of time before the incident being appealed.
    Spoiler
    All Information from the Discovery This evidence is highly relevant as it occurred a short amount of time prior to the incidents that are being disputed by the appellant, and it shows the individuals disposition to flee from law enforcement, information which other officers, including Detective Steel and Captain Steel would've had access to.
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      Los Santos Police Department

      TRAFFIC STOP REPORT
      "TO PROTECT AND SERVE"

      • TRAFFIC STOP DETAILS
        • Location: Bay City Avenue
          Narrative: Reckless Operation
          Additional Units: 23-S-2
          Approx. Time and Date: 23/OCT/2021, 20:20

        VEHICLE DETAILS
        • Vehicle Driver: Felix Noonham
          Vehicle Owner: Felix Noonham
          License Plate: F3LIX
          Vehicle Model: Issi Sport
          Vehicle Color: Silver
          Vehicle Passengers (If Applicable): N/A

        TRAFFIC STOP OUTCOME
        Please add a "X" all relevant areas. When issuing a citation, license suspension (length), or charge, amend "Specify" inside the parenthesis.

        • Action Taken:
          [ ] Verbal Warning
          [ ] Citation (Specify)
          [ ] Demerit
          [X] License Suspension (2 days)
          [X] Charge (VM03 - Reckless Operation of a Road or Marine Vehicle)
        • Stop Verdict:
          At approximately 2015 I pulled over an individual in silver/gray Issi Sport for flying down the Bay City Avenue whilst going 158 km/h. I was suggested by an SAM unit to arrest the individual for reckless operation, considering the speed and the amount of road he was airborne. I informed individual to step out of the vehicle since he is being under arrest. After hearing those words, Felix Noonham decided to disobey my direct orders and felony evade from the scene. We initiated a pursuit in TAC 1 & requested for a high speed unit. The pursuit continued for around 20 minutes throughout the city and on Del Perro Freeway. After driving recklessly for quit a bit, suspect collided with a building and was arrested by first arriving units.
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    Exhibit #2: LSPD
    Type of Discovery: Physical Evidence
    • Picture of the appellant on the scene of his arrest on the 23rd of October, wearing extremely similar (if not identical) clothing as the day when he was searched by the defendants.
    Spoiler
    All Information from the Discovery This is supporting evidence for Exhibit #1, showcasing the defendants clothing was not a one-time fluke but a uniform that he wore proudly whenever he committed crimes against the the penal code, and which he was wearing during the incident which is being appealed.
    • Image


Sincerely,

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Jason Steel
Police Captain II, Los Santos Police Department
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Last edited by Jason Steel on Sun Feb 27, 2022 12:55 am, edited 1 time in total.
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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Jason Steel »

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

Honorable Judith Mason,

  • 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.
    Felix Newnham v. Police Department
    Assigned Court Case Number: #21-10-29-AP-013
    Requesting Party: Defendant
    Party Members: Police Captain II Jason Steel, Police Detective I Grace Steel
    Discovery from: Plaintiff

    Type of Discovery: Deposition
    • We would like the plaintiff to clearly admit or refute the fact that, at the time of the events, he was affiliated with a criminal organization.
    Detailed reasoning: [Provide a detail explanation as to the relevance of the discovery request]
    • The plaintiff failed to address the accusation that he is affiliated with a criminal organization, and we believe that it is highly relevant when his initial statement is attempting to paint him as a regular citizen whom is just minding his own business, when in actuality, he was armed with a loaded firearm, with a suppressor in his possession and was sporting the uniform of a criminal organization. We believe that his membership in a criminal organization is highly relevant to the narrative being pushed by the plaintiff and we would like him to speak on record about it.


Sincerely,

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Jason Steel
Police Captain II, Los Santos Police Department
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Last edited by Jason Steel on Sun Feb 27, 2022 12:54 am, edited 1 time in total.
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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Dakota Macaw »

Motion to Suppress
San Andreas Judicial Branch
Motion to Suppress

Honorable Judith Mason,

  • We the Appellant in the case below are requesting that certain evidence be inadmissible in court.
    Felix Newnham v. Police Department
    Assigned Court Case Number: #21-10-29-AP-013
    Requesting Party: Appellant
    Party Members: Felix Newnham, Dakota Macaw
    Requested Evidence to Suppress: Exhibit #1 "Written report submitted by a sworn officer about their interaction with the appellant a short amount of time before the incident being appealed."
    Detailed explanation:
    The Appellant's previous history with law enforcement is inconsequential to the search and or seizure of the appellant's property or person. Whether or not an individual has a criminal history or not does not change the inherent protections that all citizens may enjoy when conducting their day-to-day activities. Criminal history is not admissible as sufficient probable cause, and although there are many precautions that the Police Department and law enforcement in general may take when confronting repeat-offenders, they may not conduct searches and or seizure without valid probable cause.


Sincerely,

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Attorney Dakota Macaw
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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Dakota Macaw »

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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013
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  • Honorable Judith Mason,

    I would like to submit a brief response to the pending motion to compel discovery from the respondent. My client is not obligated to submit any form of testimony in this case, and at this time does not intend to in the case of this particular question that the respondent has submitted.

    Respectfully,

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    Attorney Dakota Macaw
    San Andreas Judicial Branch
    (909) 419-3141 — [email protected]
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Jason Steel
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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Jason Steel »

Hearing Request
San Andreas Judicial Branch
Hearing Request
"HERE FOR YOU | SAFE FOR YOU"
Honorable Judith Mason,

  • We the Respondent in the case below are requesting a hearing to be scheduled for oral arguments to be made, please find a detailed reason as to our request below.
    Felix Newnham v. Police Department
    Assigned Court Case Number: #21-10-29-AP-013
    Requesting Party: Defendant
    Party Members: Police Captain II Jason Steel, Police Detective I Grace Steel
    Detailed explanation:
    We would like a hearing to settle the issue of the Motion to Suppress filed by Attorney Macaw regarding Exhibit #1; The appellant clearly referenced in his testimony that him being asked to step off the bike was unreasonable and unlawful. We wish to make further oral arguments that support the original discovery motion and refute Attorney Macaw's claim of inconsequentiality.
    Thank you for your consideration.

Sincerely,

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Jason Steel
Police Captain II, Los Santos Police Department
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Last edited by Jason Steel on Sun Feb 27, 2022 12:54 am, edited 1 time in total.
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Dakota Macaw
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Re: Felix Newnham v. Police Department | Docket #21-10-29-AP-013

Post by Dakota Macaw »

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

Honorable Judith Mason,

  • Firstly I would like to concur with the respondent's request for a hearing and look forward to meeting in hearing soon.

    Before this though, 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.
    Felix Newnham v. Police Department
    Assigned Court Case Number: #21-10-29-AP-013
    Requesting Party: Appellant
    Party Members: Dakota Macaw, Felix Newnham
    Discovery from: LSPD

    Type of Discovery: Physical Evidence
    • We the Appellant Request the firearm and all related contraband that was allegedly found in Mr. Newnham's vehicle to be submitted to evidence.
    Detailed reasoning:
    • As the charges that are being appealed are based off of this exact evidence, proof of their existence (and clarification of any serial numbers) will be necessary to continue with the case.


Sincerely,

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Attorney Dakota Macaw
San Andreas Judicial Branch
(909) 419-3141 — [email protected]
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