25-LSC-04116 – Pre-Trial – Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, Staff Officers of the LSPD

Kotwica · April 19

SUPERIOR COURT OF SAN ANDREAS

COUNTY OF LOS SANTOS

CIVIL DIVISION

Case Name: Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer in his personal and professional capacity, LSPD Staff Officers in their personal and professional capacity.

Plaintiff Attorney: Juan Tzompaxtle

CIVIL CASE COVER SHEET

_______________________________________________

1. Check one box below that best describes this case:

Personal Torts

[X] Assault, battery, or unlawful contact

[ ] False imprisonment

[ ] Intentional infliction of emotional distress

[X] Deprivation of rights under color of law

Negligent Torts

[ ] Breach of duty

[ ] Negligent infliction of emotional distress

[ ] Professional or Medical Negligence

Property Torts

[ ] Trespassing or Conversion

[ ] Nuisance

[ ] Theft

[ ] Detainder

Dignitary Torts

[ ] Defamation (Slander or Libel)

[ ] Invasion of privacy

[ ] Breach of confidence

[ ] Abuse of process

[ ] Malicious prosecution

[ ] Alienation of affections

Business Torts

[ ] Fraud

[ ] Tortious interference

[ ] Conspiracy

[ ] Restraint of trade

[ ] Passing off

Contracts

[ ] Breach of Contract

[ ] Collections

Judicial Review

[ ] Denial or Revocation of Business License

[ ] Denial or Revocation of Firearms License

2. List any damages sustained or fees accrued. Include billing rate for attorneys, expert witnesses, etc.

$100,000.00 for attorney fees;
$1,150,000.00 from the LSPD Staff Officers, plus any discovery fees and attorney fees;
$3,550,000.00 from the unknown LSPD police officer;
Whatever other relief this court deems appropriate.

_______________________________________________

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 April, 2025 by:

/S/ Alan Saucedo

Alan Saucedo

Plaintiff

/S/ Juan Tzompaxtle
Juan Tzompaxtle

Attorney for Plaintiff

Kotwica · April 19

Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD.

Case Number: 25-LSC-04112

Prepared by: Juan Tzompaxtle

CIVIL CASE BRIEF FOR PLAINTIFF

_______________________________________________

Argument

1. Comes now, Alan Saucedo through legal counsel brings forth this lawsuit before this court. This court has proper jurisdiction under the San Andreas Code of Civil Procedure (S.A.C.C.P) 410.10 (2024), as the Los Santos Police Department, and the named parties are employed by the Los Santos Police Department, the events occurred within the boundaries of the jurisdiction of this court in East Los Santos.

2. On January 16, 2025, an unidentified police officer from the Los Santos Police Department struck Alan Saucedo multiple times with a shotgun at the East Los Santos S-Curve. The striking occurred when Mister Saucedo was a distance from police tape, a conservative estimate is thirty feet from the police tape. The striking is unprovoked, Mister Saucedo did not impede on any investigation during the time he was struck, there was no lawful orders when John Doe struck him multiple times.

3. The striking of Mister Saucedo falls squarely into Ex parte Young, 209 U.S. 123 (1908), where the Supreme Court held that the Government, including state agencies, are not protected by sovereign immunity when a state official enforces an unconstitutional law or acts in an unconstitutional manner.

4. The United States Supreme Court in City of Los Santos v. Lyons 461 U.S. 95 (1983), provides grounds for a court to grant a civil claim for constitutional violations committed by a law enforcement officer under 42 U.S.C. § 1983.

5. The Los Santos Police Department’s Staff Officers, namely Chief of Police Timothy Kempton, Assistant Chief of Police Lance Stanton, Deputy Chiefs Edward Morris, Andrew Antonelli, and Jayden Gibson (herein Staff Officers), were notified via their public website, specifically addressed to them, for assistance in identifying this unknown police officer on January 14, 2025 at 18:06.

6. The Los Santos Police Department’s Staff Officers, chose not to identify the unknown police officer thereby assisting in the police misconduct. The United States District Court for the Northern District of San Andreas in Allen v. City of Oakland, No. C00-4599 THE, 2006 WL 1148813 (N.D. San. Apr. 28, 2006), that when law enforcement agencies contribute by inaction, they are liable in part for the actions committed. The Los Santos Police Department’s Staff Officers by not identifying the unknown defendant meet this definition, and violate their own oaths to promote what is commonly known as the ”blue line of silence.”

7. Mister Saucedo was video taping in accordance with this court’s declaratory judgment granted against the Los Santos Police Department in Glorida Mendoza v. The Los Santos Police Department, The Los Santos Sheriff’s Department, The San Andreas Department of Corrections, and any other law enforcement agency within the State of San Andreas, 25-LSC-0411 (2025). Therefore, the claim of “interference with an investigation” by videotaping should not be permitted as a defense in this case.

8. Counsel for the Los Santos Police Department, Alexander Braithwaithe was notified of my complaint, and I requested his review of the evidence for criminal charges. Attorney Braithwaithe has not yet responded to my request.

9. The Plaintiff prays that this court put an end to the incompetence and failures of the Los Santos Police Department to put the citizens of this city first, including cooperation with lawful requests. To award the monetary value associated with the damages of the plaintiff, and to award whatever other remedies this court deems appropriate.

Exhibits

1. Video tape of the East Los Santos S-Curve incident.

(( https://imgur.com/a/uln6LR5 ((This is an album))

https://www.youtube.com/watch?v=bPApMwBIgc8

))

2. Notification to Attorney Braitwaithe

(( https://imgur.com/a/AYQvbGX))

3. Notification to the Los Santos Police Department's Staff Officers
(( https://imgur.com/wtHpgBa ))

_______________________________________________

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 April, 2025 by:

/s/ Juan Tzompaxtle
Juan Tzompaxtle

Edited April 19 by Kotwica

Tungsten · April 19

** The clerk accepts the case filing and assigns docket number 25-LSC-04116.

** The clerk assigns Judge Augustus E. Rosewater as the presiding judicial officer.

Kotwica · April 19

(( Proof of service is filed via e-file:

))

Edited April 19 by Kotwica

Prostidude · April 20

SUPERIOR COURT OF SAN ANDREAS
COUNTY OF LOS SANTOS, CIVIL DIVISION

In the matter of SAUCEDO v. AN UNKNOWN LOS SANTOS POLICE DEPARTMENT (LSPD) POLICE OFFICER, STAFF OFFICERS OF THE LSPD
Case Number: 25-LSC-04116

The Court has carefully reviewed the Civil Case Brief filed by Alan Saucedo, the Plaintiff, also the arguments presented by Mister Juan Tzompaxtle which is the Plaintiff's counsel. The Court finds that it has proper jurisdiction as the matter alleged in the complaint occurred within the boundaries of East Los Santos, which fall under the jurisdiction of this Court.

It is alleged that on 16th of January 2025 an unknown officer of the Los Santos Police Department bashed the Alan Saucedo the Plaintiff multiple times using a shotgun at the East Los Santos S-Curve. The Plaintiff claims the attack being unprovoked as he was he ensured keeping distance from the activity, approximately thirty feet from the police tape as mentioned. The Plaintiff contends that he did not commit any impediment to the investigation. It is brought before the Court in the form of deprivation of rights under color of law and assault and battery. Plaintiff maintains the actions of this officer were not only violent but also violated his constitutional rights. The Court takes these claims seriously, particularly given that the Plaintiff was filming the situation, in accordance with a previous declaratory granted judgment, which permits a citizen to videotape public officials while they perform their duty.

Regarding the videotape given by the Plaintiff. It clearly shows the officer hitting the Mister Saucedo, and it is found cogent by Court. Plaintiff claims that the officer’s actions were not only unjustified but were also carried out with an unwarranted use of force. In accordance with the tape, the Court orders the Los Santos Police Department to identify the officer involved in this incident within 72 hours from the issuance of this Order. Los Santos Police Department is also ordered to provide any additional relevant piece of evidence, including but body camera footage and reports. The Plaintiff has his right of identifying the police officer, as the court will allow no withholding of pertinent information. Concerns were raised by the Plaintiff regarding the inaction of the Staff Officers of Los Santos Police Department, also the failure to help identifying the involved officer despite being formally notified on 14th of January, 2025. Court finds that this inaction may cause complicity in misconduct, if proven of course. The Plaintiff argues that the LSPD's leadership failure of acting will perpetuate a habit of silence within the department, commonly referred to as the “blue line of silence.”.

ORDER:

The Court acknowledges the seriousness of this matter and claim, and orders that the Los Santos Police Department respond by providing a full account of their actions to the Plaintiff’s prior notification within 72 hours from the issuance of this order.

The Court denies the request of the Plaintiff for summary judgment. The court shall grant this process only when the Plaintiff proves that there is no genuine dispute as to any material fact and the Plaintiff is entitled to judgment as a matter of law. Therefore, the Court considers this motion as premature, and the dispute is unresolved since the LSPD has not fully acknowledged the aforementioned claims.

/s/ AUGUSTUS E. ROSEWATER

Superior Court Judge, County of Los Santos

20th of April, 2025

Edited April 20 by Prostidude

Kotwica · April 24

Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD.

Case Number: 25-LSC-04116

Prepared by: Juan Tzompaxtle

MOTION FOR SUMMARY JUDGMENT ON THE STAFF OFFICERS OF THE LSPD AND SEVERANCE OF DEFENDANTS

_______________________________________________

Comes now, Alan Saucedo through his legal representative requests this court to grant summary judgment against the Staff Officers of the Los Santos Police Department, and sever the claim against the Staff Officers from the Unknown LSPD Police Officer.

The plaintiff has alleged sufficient plausible facts to that meet the Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 US 544 (2007) standard. Without the defendant’s filing an appearance, have raised no triable issue of material fact as required under San Andreas Code of Civil Procedure Section 437(c). Additionally, the plaintiff is entitled to a judgment as a matter of law under the aforementioned section.

The plaintiff requests that this court require the Los Santos Police Department Staff Officers release the identity of the Unknown LSPD Police Officer in order to properly pursue justice, and if they refuse, hold them in criminal contempt. By failing to respond to this lawsuit, the plaintiff believes that the Los Santos Police Department Staff Officers have acted with malice and requests punitive damages and payment of attorney fees.

_______________________________________________

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 24 day of April, 2025 by:

/s/ Juan Tzompaxtle

Juan Tzompaxtle

elgreco · April 25

Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD.

Case number: 25-LSC-04116

Prepared by: Ibraheem A. Davis

DEFENDANT's MOTION TO STAY PROCEEDINGS PENDING INTERNAL AFFAIRS INVESTIGATION

_____________________________________________________________________________________________________________

Defendant respectfully requests a temporary stay of proceedings in the above-captioned matter, pending the completion of the ongoing Internal Affairs investigation related to the conduct of the LSPD Officer. This motion is not intended to delay proceedings unduly, but rather to ensure the Court is presented with the most complete and accurate factual record possible. The outcome of said investigation bears directly upon material issues in dispute.

I. Judicial Economy and Efficiency

Courts have long recognized the authority to stay civil proceedings when doing so would serve judicial economy, conserve resources, or avoid conflicting outcomes. In Landis v. North American Co., 299 U.S. 248 (1936), the U.S. Supreme Court affirmed that "n the exercise of its sound discretion, a court may hold one lawsuit in abeyance to abide the outcome of another which may substantially affect it or be dispositive of the issues."

II. Importance of Internal Investigative Findings in Law Enforcement Cases

In Allen v. City of Oakland (N.D. Cal.), the court underscored the critical role of internal police investigations when systemic misconduct was alleged. The resulting reforms and oversight shaped the resolution of civil claims, demonstrating that deferring litigation to await investigatory findings may enhance both accuracy and fairness.

Similarly, in O'Brien v. Chief Constable of South Wales Police ([2005] UKHL 26), the House of Lords acknowledged the probative value of internal disciplinary findings in civil claims concerning police conduct. The judgment highlighted that internal reviews often yield essential context and factual clarification relevant to civil proceedings

III. Protection of Due Process and Officer's Rights

Premature disclosure of the identity of the Unknown Officer, prior to the conclusion of the Internal Affairs investigation, would risk violating the officer's due process rights. Officers, subject to administrative or disciplinary review are entitled to a full and fair internal process, free from premature public exposure or legal assumption of guilt.

Revealing the officer's identity at this stage may also:

Undermine the integrity of impartiality of the Internal Affairs investigation;
Compromise the safety and privacy of the officer and others involved;
Diminish the Department's ability to conduct effective and unbiased internal oversight;
Violate any existing protective policies regarding officers under investigation.

This request is therefore not only consistent with legal precedent but also a necessary safeguard for constitutional and procedural fairness.

III. Risk of Premature or Fragmented Litigation

Absent a stay, the parties risk engaging in premature motion practice and discovery based on incomplete or evolving factual circumstances. This may result in the need for amendments, redundant motions, or the revisiting of rulings, all of which impose additional burdens on the Court and litigants.

IV. Good Faith Request

Defendant emphasizes that this request is made in good faith and is narrowly tailored. The requested stay is limited in scope and duration, only until the Internal Affairs Group concludes its review. The intent is not to delay this litigation indefinitely, but to ensure adjudication proceeds on a full and reliable evidentiary foundation.

V. Conclusion

WHEREFORE, Defendant respectfully prays that the Court:

GRANT a temporary stay of proceedings pending the conclusion of the Internal Affairs investigation;
SET a status review date within a reasonable timeframe to evaluate the investigation’s progress and reassess the stay’s necessity;
RETAIN full discretion to lift or modify the stay as appropriate.

Respectfully submitted,

/s/ IBRAHEEM A, DAVIS

Ibraheem A. Davis

Legal Representative
Los Santos Police Department

Kotwica · April 25

Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD.

Case Number: 25-LSC-04116

Prepared by: Juan Tzompaxtle

JOINT MOTION IN OPPOSITION TO STAYING PROCEEDINGS AND FOR ADDITIONAL SANCTIONS AND CENSURE OF IBRAHEEM DAVIS.

_______________________________________________

Comes now, Alan Saucedo through his legal representative requests this court deny the defendant's motion as untimely and censure Ibraheem Davis for use of AI tools.

The defendant outlines six arguments for a stay of proceedings, all of these requests are untimely and were filed after a motion for summary judgment. The defendant does not raise any substantive arguments that would defeat the requirements for a summary judgment motion, namely the defendant does not raise a triable issue of material fact as required under San Andreas Code of Civil Procedure Section 437(c), and the plaintiff remains entitled to a judgment as a matter of law. The defendant only asks for a stay after failing to meet the court imposed requirements of filing an answer, the plaintiff has waited six-days for a response, three-days more than required.

The Court of Appeals addressed a similar problem in Aheroni v. Maxwell, 205 S.An. App. 3d 284 (1988), where a defendant moves to vacate a default judgment. The identifies the following as the key question "whether the successful party has by inequitable conduct, either direct or insidious in nature, lulled the other party into a state of false security, thus causing the latter to refrain from appearing in court or asserting legal rights." Colich v. United Concrete Pipe Corp. 145 S. An. App.2d 102, 107 (1956). The plaintiff has not directly or insidiously lulled any party into any sense of security. The defendant's inactions speak for themselves, paired with the disingenuous filing identified below, this court should deny this request.

Mister Davis has acted in bad faith. Mister Davis has utilized artificial intelligence in drafting his response to this court. I became concerned when Mister Davis cited a United Kingdom House of Lords statement, failed to number his motion correctly (the use of two Roman numeral threes), in support of his motion. I decided to utilize QuillBot to detect whether the filing was genuine. It is not (emphasis added), 91 percent of the response is "AI generated." This defeats the truly the only substantial argument that the defendant raised, namely that it is a good faith request.

_______________________________________________

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 25 day of April, 2025 by:

/s/ Juan Tzompaxtle

Juan Tzompaxtle

Copies provided to the court and e-filed:

Edited April 25 by Kotwica

elgreco · April 25

Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD.

Case number: 25-LSC-04116

Prepared by: Ibraheem A. Davis

DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO DENY DEFENDANT'S MOTION AND CENSURE THE DEFENDANT FOR THE USE OF AI TOOLS

_____________________________________________________________________________________________________________________________________________________________________

COMES NOW, Ibraheem Davis, legal representative for the Los Santos Police Department (LSPD), and respectfully submits this response to Plaintiff's opposition to Defendant's Motion of Stay of Proceedings.

I. Introduction

Plaintiff's counsel has made several unfounded accusations that warrant immediate address. Most egregiously, counsel alleges that I have utilized artificial intelligence to draft my motions and has declared, without substantive evidence, that the "91 percent" of my filing is "AI Generated" based solely on a proprietary algorithm with known reliability issues. This allegation is both factually wrong and legally irrelevant to the merits of LSPD's motion.

II. Response to Allegations

1. The AI Detection Claim is Unreliable and Legally Irrelevant

Plaintiff's counsel relies on "Quillbot", a text analysis tool with documented limitations. Courts have consistently recognized that such AI detection tools produce unreliable results with false positive rates exceeding 25% in peer-reviewed studied. Even one of the most if not popular AI Detection tools "Turnitin" claimed themselves that their product produce false positives. The San Andreas Bar Association has not established any prohibition against drafting assistance tools, which many attorneys utilize for formatting, citation checking and language refinement; Practices equivalent to traditional tools like spelling and grammar checkers. As held in Pirelli Armstrong Tire Corp v. Raines, "Courts have never required attorneys to compose all materials from scratch"

The typing errors noted by the opposing counsel (Duplicate Roman Numbers) actually contradict their allegation of AI usage, as such errors are characteristic of human drafting. These minor typographical errors in no way diminish the substantive legal arguments presented on behalf of the LSPD. In Hamer v. Neighborhood Housing Servs. of Chicago, the Court held that "procedural rules should not be applied in a way that created meaningless procedural traps".

2. The UK Citation is Both Relevant and Appropriate

Plaintiff's objection to my citation of a House of Lords decision demonstrates a serious misunderstanding of comparative law principles. While not binding, persuasive authority from respected common law jurisdictions in routinely cited in complex procedural matters where San Andreas precedent is developing. In American Bank & Trust Co. v. Federal Reserve Bank, where Justice Holmes noted that "the Court may appropriately look to decisions of English courts for persuasive value in interpreting common law principles".

III. Defense Against Plaintiff's Claim of Untimeliness

Defendant acknowledges that the motion in question was filed after the court-imposed deadline for responses. However, Defendant respectfully submits that the delay was caused by reasonable circumstance and show not result in a dismissal of the motion.

More specifically:

Good Cause for Delay:
- The delay in filling was due to extenuating circumstances, including an unavoidable personal matter that temporarily impacted the preparation and filing of the motion. Defendant, through counsel, takes full responsibility for this oversight but emphasizes that the delay did not prejudice the Plaintiff or harm the integrity of the judicial process. As such, Defendant respectfully requests that the Court exercise its discretion and allow the motion to proceed on the merits
No Prejudice to Plaintiff
- The Plaintiff has not shown, and cannot show, any material prejudice caused by the delay. The issues raised in the motion remain relevant, and there is no indication that the delay has affected the Plaintiff's ability to respond or prepare for trial. Denying the motion on procedural grounds alone would serve no legitimate purpose and would frustrate the interests of justice.
Substantial Compliance
- Defendant has made substantial compliance with the requirements set forth by the court, and any minor delay should be excused in light of the circumstances, particularly when no harm has been done to the Plaintiff's case.

IV. Conclusion

I respectfully request that this Court:

Disregard plaintiff's unfounded allegations regarding drafting methods;
Consider the substantive merits of the stay request as outlined in our original motion;
Admonish plaintiff's counsel for engaging in personal attacks rather than addressing legal substance; and
Grant the requested stay of proceedings for the reasons outlined in our initial filing.

Respectfully submitted,

/s/ IBRAHEEM A, DAVIS

Ibraheem A. Davis

Legal Representative
Los Santos Police Department

Prostidude · April 26

SUPERIOR COURT OF SAN ANDREAS
COUNTY OF LOS SANTOS, CIVIL DIVISION

In the matter of SAUCEDO v. AN UNKNOWN LOS SANTOS POLICE DEPARTMENT (LSPD) POLICE OFFICER, STAFF OFFICERS OF THE LSPD
Case Number: 25-LSC-04116

The Court has reviewed the filings both parties have submitted, as it issues a ruling regarding the motion given by the Plaintiff seeking to deny the other parties Motion for Stay of Proceedings and to censure the Defendant.

The Plaintiff claims that the Defendant's submission was deceptively generated using Artificial Intelligence tools. The Court finds no evidence compelling malicious faith or deceit as the Court finds it unpersuasive. Therefore, the Plaintiff's motion seeking censure is respectfully denied. The Court acknowledges the admission given by the Defendant about the postponement. Nevertheless, The Court takes the explanation seriously, and the result of confusion from the filing schedule and department's internal reassignments as a reasonable cause. The delay has not prejudiced the plaintiff to have it denied in first place. Therefore, the motion is hereby granted.

The Court will now be ordering proceedings in this matter, as it shall be stayed for 7 days from the issuance of this order today 26/APR/2025 and will expire on May 3rd, 2025. unless lifted by court or extended by motion. The Court finds that it is appropriate to convene a conference on May 5th, 2025 at 21:00 PM. Both parties are expected to be prepared and attend to discuss the current status of the case. The parties shall confer in good faith and submit their statements to the Court before May 4th, 2025.

Expecting zealous advocacy, the Court discourages from personal allegations.

SO ORDERED.

/s/ AUGUSTUS E; ROSEWATER

Superior Court Judge

26th of April, 2025

Tungsten · April 26

** The clerk updates the docket to assign Judge Florence Weathers-Peterson as the presiding officer.

Tungsten · April 28

SUPERIOR COURT OF SAN ANDREAS
COUNTY OF LOS SANTOS, CIVIL DIVISION

In the matter of SAUCEDO v. AN UNKNOWN LOS SANTOS POLICE DEPARTMENT (LSPD) POLICE OFFICER, STAFF OFFICERS OF THE LSPD
Case Number: 25-LSC-04116

The previous order to stay issued in this court by Judge Rosewater is vacated. Discovery will continue immediately. Both parties are ordered to disclose all appropriate discovery before midnight on Wednesday, April 30th, 2025, and certify as having done so or face sanctions.

/s/ FLORENCE WEATHERS-PETERSON

Superior Court Judge

26th of April, 2025

Kotwica · April 30

Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, Staff Officers of the LSPD

Case Number: 25-LSC-04118

Prepared by: Juan Tzompaxtle

MOTION TO COMPEL DISCOVERY, MOTION FOR A TEMPORARY INJUNCTION.

_______________________________________________

Comes now, the plaintiff, through his counsel requests this honorable court to compel the discovery of the below mentioned items that a discovery request was issued by Juan Tzompaxtle on April 26, 2025. The defendant's counsel has willfully not complied with the order and has thereby unnecessarily prolonged the pretrial period of this case. Additionally, I received a call from the Los Santos Police Department's Internal Affairs Group who stated that they knew the name of the unknown officer but would not release it to me. This indicates that Mister Davis has willfully withheld information requested in a civil proceeding, has not communicated with me or the court about any privileges may assert, and thereby has caused additional injury and to the San Andreas Bar in it's entirety. An attorney owes a duty of professionalism and communication not only to his client but to opposing counsel. Here, Mister Davis has failed to do so in any of the cases before this court.

Due to the uncooperative nature of the Los Santos Police Department, and their attorney, the plaintiff requests that the court order the release of the following information.

(1) Identification of the unknown Los Santos Police Department Police Officer;
(2) The full unredacted internal affairs records of the unknown Los Santos Police Department Police Officer;
(3) The full unredacted training history of the unknown Los Santos Police Department Police Officer (including dates of recertification);
(4) All training materials the Los Santos Police Department utilizes for use of force training or instruction;
(5) A list (with redactions if appropriate) of how many use-of-force violations have been reported to the Los Santos Police Department since January 1, 2025 to the date of the return of this letter;
(6) All policies or statements made by the Los Santos Police Department on how to handle, treat, or otherwise interact with members of the public filming police scenes; and
(7) All policies or statements made by the Los Santos Police Department on how to handle, treat, or otherwise interact with members of the public standing outside of police tape observing a police scene.

The plaintiff further requests that if the defendants counsel does not release the aforementioned items timely (at the discretion of the court) he be sanctioned and the court allow for additional punitive damages.

Further, the plaintiff requests this court issue an injunction against the Los Santos Police Department Internal Affairs Group from closing the internal affairs investigation on the unknown officer. On a phone call on April 29, 2025. I was contacted by Detective Henriquez who informed me he wanted to speak to my client in order to complete the investigation. I informed Detective Henriquez that my client is unavailable. Detective Henriquez then stated that his Captain, a Captain Miller of the Internal Affairs Group ordered him to complete the investigation within 48 hours. I was then informed by Detective Henriquez that if my client did not contact the Los Santos Police Department Internal Affairs Group the investigation would conclude without his statement.

It is fitting that the Los Santos Police Department has dragged their feet throughout his entire process but feels they have the power to impose unnecessary time restraints on the victim of a crime to fit their "internal timeline." The victim has a right to be heard, his rights were deprived once, and the Los Santos Police Department is seeking to deprive them again. The plaintiff formally requests an injunction on the closing of the internal affairs report until Mister Saucedo has received the questions, consulted with his counsel, and return the messages to the Los Santos Internal Affairs Group. Failing to do so will result in additional injury as the Los Santos Police Department as alleged will default to protecting their own as opposed to the public who they took an oath to protect.

_______________________________________________

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 30 day of April, 2025 by:

/s/ Juan Tzompaxtle
Juan Tzompaxtle

(( Attached with the filing:

))

Edited April 30 by Kotwica

Justitiae · May 1

** The clerk reassigns the matter to the Honorable Francis J. Stoessel as the presiding judge.

Justitiae · May 1

SUPERIOR COURT OF THE STATE OF SAN ANDREAS

FOR THE COUNTY OF LOS SANTOS

ALAN SAUCEDO,

Plaintiff,

v.

AN UNKNOWN LOS SANTOS POLICE OFFICER (LSPD) POLICE OFFICER, STAFF OFFICERS OF THE LSPD,

Defendants.

Case No. 25-LSC-04116

[Assigned for all purposes to the Hon. Francis J. Stoessel, Department 1]

ORDER GRANTING MOTION TO COMPEL DISCOVERY AND MOTION FOR TEMPORARY INJUNCTION

Date: May 1, 2025

Time: 7:55 pm

Department: 1

Complaint Filed: April 19, 2025

Judge: The Honorable Francis J. Stoessel

ᅠᅠ Plaintiff Alan Saucedo has moved the Court for an order compelling discovery and issuing a temporary injunction on claims alleging deprivation of rights under color of law and failure of law enforcement leadership to intervene in or disclose police misconduct.

ᅠᅠ The Court finds the Plaintiff's discovery requests are supported under Greyhound Corp. v. Superior Court (1961) 56 San.An.2d 355, 384 and Williams v. Superior Court (2017) 3 San.An.5th 531, 541, as necessary to eliminate surprise, prevent delay, and enable the parties to ascertain the truth and prepare for trial. Disclosure of internal affairs and personnel records is not barred by statutory restriction under the laws of the State of San Andreas. To the extent privacy or confidentiality concerns exist, the Court directs the parties to confer and submit a proposed protective order to govern the handling of sensitive materials.

ᅠᅠ The Court further finds that Plaintiff is entitled to temporary injunctive relief under the standards set forth in IT Corp v. County of Imperial (1983) 35 San.An.3d 63, 69, balancing the likelihood of irreparable harm against the need for prompt internal review. Without this relief, Plaintiff risks the loss of critical evidence impairing his ability to prosecute his claims.

ᅠᅠ Having reviewed the motion and procedural record, this Court hereby GRANTS Plaintiff's Motion to Compel Discovery and ORDERS Defendants to comply within five (5) calendar days of the date of this Order. The Court further GRANTS the Motion for Temporary Injunction and orders the Defendants shall not close the misconduct review process until Plaintiff has been provided written questions, afforded no fewer ten (10) calendar days to review with counsel, and submit responses. If Plaintiff remains unavailable, Plaintiff's counsel may preserve Plaintiff's rights by submitting a statement addressing the extent of counsel's knowledge and the client's unavailability. If no responses are submitted by the deadline, the injunction shall automatically expire.

ORDER

ᅠᅠ Based on the facts provided, Plaintiff has demonstrated good cause under the San Andreas Code of Civil Procedure § 2031.310 to compel production of discovery, the Court orders the following:

1. Identification of the unknown Los Santos Police Department Police Officer;

2. Full unredacted internal affairs records of the unknown officer;

3. Full unredacted training history of the unknown officer, including recertification dates;

4. All current LSPD training materials related to use of force;

5. A list, with redactions if appropriate, of all reported use-of-force violations since January 1, 2025;

6. All policies or statements regarding members of the public filming police scenes;

7. All policies of statements regarding members of the public standing outside police tape at police scenes.

ᅠᅠ To protect the confidentiality of sensitive information produced in discovery, the Court orders covered materials may only be used for purposes of this litigation and may not be disclosed to any person or entity except the Court and its personnel; and counsel of record. Defendants shall mark all covered materials as “CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER.”

ᅠᅠ Any violations of this Order may be punishable by sanctions or contempt.

ᅠᅠ IT IS SO ORDERED.

DATED: May 01, 2025

By: /s/ Francis J. Stoessel
THE HONORABLE FRANCIS J. STOESSEL
Presiding Judge of the Superior Court,
State of San Andreas, County of Los Santos

Edited May 1 by Justitiae

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25-LSC-04116 – Pre-Trial – Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, Staff Officers of the LSPD

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Los Santos Roleplay

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