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24-CV-1034 - Trial - Jefferson vs City of Los Santos, et al.


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Michelle Jefferson v. City of Los Santos, Alexander Blair, Los Santos Police Department, Samuel Gonzales, Los Santos County Sheriff’s Department, and Roderick Hayward, in their official capacities,
Amber Moore, Christopher Kaminski, and Marvin Low, in their individual and official capacities

Case Number: 24-CV-1034

Prepared by: Donald J. Wright
 

MOTION FOR THE SEQUESTERING OF WITNESSES

_______________________________________________
 

Comes now, the plaintiff requests this court in accordance with Federal Rules of Evidence 615, a standing motion is hereby filed with the court for a rule 615 motion.

 


The court is hereby requested to develop and deliver the order with notice to all parties.

 

_______________________________________________

Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein is truthful to the best of his knowledge.

 

Sworn this 19 day of October, 2024

 

/s/ dj47
Donald J. Wright

(( @almightybounter, @NotCraft, @Jacob Rabinowitz ))

Edited by Kotwica
Juan Tzompaxtle, Esq.
Partner of Tzompaxtle, Goldmann, and Barbieri LLP.
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Michelle Jefferson v. City of Los Santos, Alexander Blair, Los Santos Police Department, Samuel Gonzales, Los Santos County Sheriff’s Department, and Roderick Hayward, in their official capacities,
Amber Moore, Christopher Kaminski, and Marvin Low, in their individual and official capacities

Case Number: 24-CV-1034

Prepared by: Donald J. Wright
 

MOTION FOR THE COURT TO TAKE JUDICIAL NOTICE

_______________________________________________
 

Comes now, the plaintiff requests this court in accordance with Federal Rules of Evidence 201, a motion for the court to take judicial notice of the binding authority of the following cases on this court, and that such binding authority is not waivable, and deviation from the laws they establish would be a violation of binding precedent. 

 

Graham v. Connor, 490 U.S. 386 (1989)

Torres v. Madrid, 592 U.S. ___ (2021)
Briscoe v. LaHue, 460 U.S. 325 (1983)
Heien v. North Carolina, 574 U.S. 54 (2014)
United States v. Grace, 461 U.S. 171 (1983)

Gitlow v. New York, 268 U.S. 652 (1925)

Cox v. New Hampshire, 312 U.S. 569 (1941)

Hague v. Committee for Industrial Organization, 307 U.S. 496 (1939)

Pierson v. Ray, 386 U.S. 547 (1967)

Harlow v. Fitzgerald, 457 U.S. 800 (1982)

Feiner v. New York, 340 U.S. 315 (1951)

Smith v. Wade, 461 U.S. 30 (1983)

Monell v. Department of Soc. Svcs., 436 U.S. 658 (1978)

Florida v. Jardines, 569 U.S. 1 (2013)

Payton v. New York, 445 U.S. 573 (1980)

United States v. Santana, 427 U.S. 38 (1976)

Terry v. Ohio, 392 U.S. 1 (1968)

Mapp v. Ohio, 367 U.S. 643 (1961)

Brady v. Maryland, 373 U.S. 83 (1963)

Strickler v. Greene, 527 U.S. 263 (1999)

Armstrong v. Toler, 24 U.S. 258 (1826)


The court is hereby requested to develop and deliver the order with notice to all parties.

 

_______________________________________________

Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein is truthful to the best of his knowledge.

 

Sworn this 19 day of October, 2024

 

/s/ d..j47
Donald J. Wright

(( @almightybounter, @NotCraft, @Jacob Rabinowitz ))

 

Edited by Kotwica
Juan Tzompaxtle, Esq.
Partner of Tzompaxtle, Goldmann, and Barbieri LLP.
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On 10/19/2024 at 3:00 PM, Kotwica said:

Michelle Jefferson v. City of Los Santos, Alexander Blair, Los Santos Police Department, Samuel Gonzales, Los Santos County Sheriff’s Department, and Roderick Hayward, in their official capacities,
Amber Moore, Christopher Kaminski, and Marvin Low, in their individual and official capacities

Case Number: 24-CV-1034

Prepared by: Donald J. Wright
 

MOTION FOR THE ISSUANCE OF DUCES TECUM SUBPEONAS

_______________________________________________
 

Comes now, the plaintiff requests this court in accordance with Federal Rules of Civil Procedure Rule 45(c) to issue the following subpoenas against the Los Santos Sheriffs Department:
 

I. Full unredacted internal affairs files/personnel files/training files for:
(1) Roderick Hayward
(2) Christopher Kaminski
(3) Marvin Low

 

II. Training documents related to Constitutional Rights.

 

III. Procedures related to Constitutional Rights.

 

IV. Training documents related to arrest procedures.

 

V. Procedures related to arrest procedures.

 

VI. Dates of when each procedure went into effect.

 

VII. All eyewitness accounts.

 

VIII. All arrest records relating to Michelle Jefferson’s arrests stemming from these events.

 

IX. All inventory records from custodial searches on Michelle Jefferson stemming from these events.

 

X. All CCTV/video tapes of Pershing Square on the applicable dates.

 

XI. Any and all dashcam footage from LSSD vehicles stemming from these events.


The court is hereby requested to develop and deliver the order with notice to all parties.

 

_______________________________________________

Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein is truthful to the best of his knowledge.

 

Sworn this 19 day of October, 2024

 

/s/ dj47
Donald J. Wright

 

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this Motion for Issuance of Subpoena was served on all parties involved in this case on October 19, 2024. 
/s/ dj47

(( @NotCraft, @almightybounter, @Jacob Rabinowitz ))

 

 

The defense has no issues with providing this information however it will take time to process the request as there is years of information to go through and provide to the plaintiff. 

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"The plaintiff will be unable to agree to any such delay. This court has prematurely forced this case to move forward, as a result we are being forced to make arguments without proper time for discovery. This court was not satisfied with our filing, and through mental gymnastics moved a case to oral arguments without allowing time for proper discovery under the threat of dismissing the case on their own accord. 

Mister Silverman, from attorney-to-attorney I apologize for the unprecedented, and ludicrous pressure this court is putting you through because of their erroneous, and to quote this court "idiotic" decisions. However we will be forced to file a motion to compel if you are unable to get us everything we requested within the next 24 hours."

(( @NotCraft, @almightybounter, @Jacob Rabinowitz ))

Edited by Kotwica
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Juan Tzompaxtle, Esq.
Partner of Tzompaxtle, Goldmann, and Barbieri LLP.
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Michelle Jefferson v. City of Los Santos, Alexander Blair, Los Santos Police Department, Samuel Gonzales, Los Santos County Sheriff’s Department, and Roderick Hayward, in their official capacities,
Amber Moore, Christopher Kaminski, and Marvin Low, in their individual and official capacities

Case Number: 24-CV-1034

Prepared by: Jacob E. Rabinowitz III
 

MOTION TO COMPEL

_______________________________________________
 

Comes now, Jacob E. Rabinowitz for the Plaintiff, respectfully moves this court to compel the defense to produce documents in keeping with an issued subpoena duces tecum.

 

In keeping with Fed. R. Civ. P. 45(a)3, clause 2 ("An attorney also may issue and sign a subpoena if the attorney is authorized to practice in the issuing court"), both counsel of record are permitted to sign and issue subpoenas duces tecum. Having done so, and requested prompt production thereof, we move for enforcement of this order under penalty of contempt pursuant to Fed. R. Civ. P. 45(g).

 

Production of the following items has been requested:

 

I. Full unredacted internal affairs files/personnel files/training files for:
(1) Roderick Hayward
(2) Christopher Kaminski
(3) Marvin Low

 

II. Training documents related to Constitutional Rights.

 

III. Procedures related to Constitutional Rights.

 

IV. Training documents related to arrest procedures.

 

V. Procedures related to arrest procedures.

 

VI. Dates of when each procedure went into effect.

 

VII. All eyewitness accounts.

 

VIII. All arrest records relating to Michelle Jefferson’s arrests stemming from these events.

 

IX. All inventory records from custodial searches on Michelle Jefferson stemming from these events.

 

X. All CCTV/video tapes of Pershing Square on the applicable dates.

 

XI. Any and all dashcam footage from LSSD vehicles stemming from these events.

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jacob ezekiel rabinowitz III, esq.
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Donald J. Wright rises.

 

"To make a record since it appears our judge has decided to vanish without telling anyone where he is going.

Is this court prepared to do anything besides waste our time? It's over a week since this court did anything, you have multiple outstanding motions after rushing the plaintiff to trial. You rushed us, for what? To be another bureaucrat and delay due process? This is becoming a habitual occurrence with this court, namely this judge who in a previous case with the same government agency did the same thing. I am disappointed in the absurd biasness that this court has shown, and continues to show by their lack of sound reasoning, lack of proper judgment, and their lack of showing up like any other citizen and work a normal job, this has to stop."

(( @almightybounter, @NotCraft, @Jacob Rabinowitz )) 

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Juan Tzompaxtle, Esq.
Partner of Tzompaxtle, Goldmann, and Barbieri LLP.
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Michelle Jefferson v. City of Los Santos, Alexander Blair, Los Santos Police Department, Samuel Gonzales, Los Santos County Sheriff’s Department, and Roderick Hayward, in their official capacities,
Amber Moore, Christopher Kaminski, and Marvin Low, in their individual and official capacities

Case Number: 24-CV-1034

Prepared by: Jacob E. Rabinowitz III
 

MOTION FOR DISCRETIONARY RECUSAL

_______________________________________________
 

Comes now, Jacob E. Rabinowitz for the Plaintiff, respectfully moves this court for recusal of the honorable Judge Hockenbeyer.

 

The grounds for our motion are as follows, and are joined in spirit by the defendants.

 

1. His honor has failed to meet several procedural deadlines;

2. His honor has failed to rule on several motions within a timely manner;

3. His honor is reasonably believed to have used AI-assisted tools for both legal analysis and writing decisions and opinions;

 

As such, in the interest of public justice, we believe it is in order, and are joined in spirit by the defendants, in this motion for voluntary recusal his honor on his own discretion, pursuant to 28 CFR § 2200.68(a). If his honor does not rule on this motion in a timely manner, we intend to file an emergency appeal with the appellate jurisdiction for disqualification and mistrial.

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(( Hello, sorry to be the bearer of bad news but @almightybounter has been having trouble lately accessing the forums due to a Cloudflare issue. I am unsure when the issue will be resolved but he will continue handling the case when it is. Apologies to the involved parties for any inconvenience this has caused. ))

Edited by Justitiae
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DIVISION CHIEF ROBERT E. GEISBAUER
CHIEF OF STAFF

Los Santos County Sheriff's Department — "A Tradition of Service"
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Donald J. Wright stands.


"Not that the court is present, nor will it be seemingly for the foreseeable future. The plaintiff is meeting with the LSSD for the purpose of a potential resolution. It's likely that this court is incapable of resolving these issues. However, the default is still an item this court will need to rule on."

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Juan Tzompaxtle, Esq.
Partner of Tzompaxtle, Goldmann, and Barbieri LLP.
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  • Tungsten changed the title to 24-CV-1034 - Trial - Jefferson vs City of Los Santos, et al.
  • 1 month later...

(( This case is being closed because there are no longer any judges who can review it without an apparent OOC conflict of interest. ))

gone now are the days of old

don't be sad that it's over

be glad that it happened

 

lsrp is now a glorified DM server with a /me command

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