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A little roleplay I had with Tyler_Barron and Carter_Sloan. Backstory: The duo caught Gaspar taking landscape photography of Los Santos and demanded to have a picture taken of them. **IC: The picture surfaces on all social medias**

/ Sixes Tavern, Tyding everything up /

Sixes Tavern / Peace & Quiet

Sister in Arms / First Shot, First Step I Sister in Arms / First Shot, First Step II Sister in Arms / First Shot, First Step III

Clock's Ticking / EHC Deal (Reload.) Clock's Ticking / EHC Deal I

Breaking Bread / 38St Plug VI Breaking Bread / 38St Plug VII

New Order / Blocks & Borders I New Order / Blocks & Borders II New Order / Blocks & Borders III

Flavors of the Past / Casa Nechta I Flavors of the Past / Casa Nechta II

Scumpy and the crew are doing some great work.

WIP

PD should take notes. When are we gonna see some Tenpenny and Pulaski roleplay?

Talks from the East / Paper Cranes & Product Trails V Talks from the East / Paper Cranes & Product Trails VI

This thread follows the journey of Benny Galante

SUPERIOR COURT OF THE STATE OF SAN ANDREAS FOR THE COUNTY OF LOS SANTOS LAURA MONTBLANC, Plaintiff, v. AKHMAD SHAKHZADOV, LOS SANTOS POLICE DEPARTMENT, et al, Defendants. Case No. 25-LSC-04117 ORDER REGARDING MOTION TO COMPEL, MOTION TO DISMISS AND MOTION FOR SUMMARY JUDGMENT Date: May 9, 2025 Time: 6:09 pm Department: 1 ᅠᅠ The Court, having reviewed the pleadings on file, including Plaintiff’s Motion to Compel, Defendant’s Opposition and Motion to Dismiss, and Plaintiff’s responsive filings and Motion for Summary Judgment, IT IS ORDERED: Plaintiff’s Motion to Compel is GRANTED IN PART and DENIED IN PART; Defendants’ Motion to Dismiss is DENIED in its entirety; Plaintiff’s Request for Summary Judgment is DENIED WITHOUT PREJUDICE. STANDARD ᅠᅠ Under Rule 12(b)(6) of the Federal Rules of Civil Procedure, a complaint survives dismissal when the well-pleaded facts “plausibly suggest an entitlement to relief.” (Ashcroft v. Iqbal (2009) 556 U.S. 662, 681; Bell Atlantic Corp. v. Twombly (2007) 550 U.S. 544, 570.) The Court disregards rote legal conclusions, but assumes the veracity of factual averments and draws every reasonable inference in the plaintiff’s favor. (See Knievel v. ESPN 9th Cir. 2005 393 F.3d 1068, 1072.) ᅠᅠ A government agency is liable only when an official policy, long standing practice, or ratification by a final policymaker causes the deprivation. (Monell v. Department of Social Services (1978) 436 U.S. 658, 690–691; AE ex rel. Hernandez v. County of Tulare (9th Cir. 2010) 666 F.3d 631, 636-638.) A municipality may not be held vicariously liable under § 1983 for a single officer’s misconduct on a theory of respondeat superior. (City of Canton v. Harris (1989) 489 U.S. 378, 385). ᅠᅠ Rule 26(b)(1) permits discovery “relevant to any party’s claim or defense and proportional to the needs of the case,” unless protected by privilege or otherwise restricted for good cause. Balancing privacy interests against litigants’ need for information, the Court may order redaction, in-camera review, or protective conditions. (Fed. R. Civ. P. 26(c); San. An. Code Civ. Proc. § 2017.020(a); cf. Kelly v. City of San Jose (N.D. San.An. 1987) 114 F.R.D. 653.) In the absence of codified Pitchess statutes, peace officer personnel and internal affairs records are reviewed under a balancing framework grounded in privilege, due process, and the need for judicial oversight. ᅠᅠ A finding of spoliation requires evidence of intentional destruction or alteration of relevant evidence and resulting prejudice. (Silvestri v. General Motors Corp. (4th Cir. 2001) 271 F.3d 583, 590-593.) Sanctions under Rule 37 include preclusion or terminating relief, but only upon a predicate showing of willfulness or bad faith (Cedars-Sinai Medical Center v. Superior Court (1998) 18 San.An.4th 1, 11-12; Williams v. Russ (2008) 167 San.An.App.4th 1215.). ANALYSIS ᅠᅠ Defendants move to dismiss the Complaint pursuant to Rule 12(b)(6), arguing: (1) Plaintiff fails to plead a plausible claim for municipal liability under Monell v. Department of Social Services (1978) 436 U.S. 658; (2) the denial of Plaintiff’s Media Card was not retaliatory; and (3) the resignation of Officer Shakhzadov precludes agency liability for his actions. ᅠᅠ Plaintiff opposes the motion and contends that the Complaint sufficiently pleads a pattern of unconstitutional conduct and retaliatory intent on the part of the Department, especially against outspoken critics of the Los Santos Police Department (“LSPD”); that the denial was undertaken pursuant to a department policy or custom; and that senior officials ratified the decision. Accepting those allegations as true, the Complaint plausibly alleges an institutional custom of retaliatory credentialing. Such allegations suffice at the pleadings stage to pass Monell’s policy-or-practice filter. Whether the proof ultimately substantiates these contentions is a question for summary judgment or trial, nor Rule 12(b)(6) dismissal. ᅠᅠ Plaintiff alleges she engaged in protected expression—filming arrest, vlogging criticism of LSPD tactics, and filing a prior public-records lawsuit—after which her Media Card application was uniquely denied. The chronology supports a plausible inference of retaliatory animus under Nieves v. Bartlett (2019) 139 S.Ct. 1715, 1723. The motion thus fails as to the First Amendment claim. ᅠᅠ Defendants’ argue that because Officer Shakhzadov resigned, municipal exposure evaporates. The argument misconstrues Monell: a municipality’s liability flows from its policy, not the tenure of the offending employee. If Plaintiff proves that decision-makers condoned or turned a blind eye to the retaliation, or employs an unconstitutional policy or custom resulting in the violation of the Plaintiff’s rights, the municipality/agency remains answerable. The resignation or continued employment of Officer Shakhzadov has no bearing on this legal framework. (See Long v. County of Los Santos (9th Cir. 1990) 442 F.3d 1178, 1186.) ᅠᅠ Plaintiff’s reliance on Owen v. City of Independence (1980) 445 U.S. 622 is misplaced. Owen held that municipalities are not entitled to qualified immunity, but did not alter Monell's core requirement that municipal liability under § 1983 must be based on institutional action or omission. Local municipal agencies remain liable only when the Plaintiff pleads and ultimately proves that a policy, custom, or ratification by a final policymaker caused the constitutional injury. Thus, respondeat superior is unavailable for § 1983 liability. As for the Defendants’, reliance on qualified immunity is also misplaced. Qualified immunity shields individual officers sued for damages; it is unavailable to municipal entities. The Department therefore cannot avoid suit by arguing that “no clearly established right to a press credential exists.” Its only two proper defenses under § 1983 should be (a) that no constitutional violation occurred, and (b) that no policy, custom, or ratification caused the alleged violation—both of which must be substantiated through discovery. ᅠᅠ The requested documents speak directly to Plaintiff’s theory that retaliatory measures were condoned or ratified. Whilst Defendants' concern about third-party privacy is legitimate, assertion of a nebulous “law-enforcement privilege” is unavailing absent a specific statutory basis and does not bar disclosure altogether. Privacy interests may be adequately protected by redaction and a protective order under Rule 26(c) (See Britt v. Superior Court, 20 San.An.3d 844 (1978); Board of Trustees v. Superior Court, 119 San.An.App.3d 516 (1981).) The Court orders production with redaction of personal data and is subject to a two-tier protective order limiting dissemination to counsel, experts, and the Court. ᅠᅠ Plaintiff seeks credential applications from 1 January 2025 through 30 April 2025, including outcomes. The Court finds that documents related to press credential applications are discoverable. To the extent privacy concerns exist, those concerns may be addressed through appropriate redaction of identifying information. Comparator data may be essential to establishing disparate treatment, and the relevance of such evidence outweighs any minimal privacy intrusion under the circumstances. Defendants’ may also substitute unique numeric identifiers for applicant names. ᅠᅠ The Court orders the production of all current written directives governing press interaction, citizen filming, or credential issuance as they reflect official municipal policy. Objections premised on “public-safety sensitivity” are overruled where no specific operational details are implicated. ᅠᅠ Plaintiff moves to compel records for every SWAT deployment since 18 April 2025, contending such data “may reveal” retaliatory patterns. The connection between tactical demployments and credential denials is too attenuated. The request is substantially overbroad. Without a narrowed showing—such as incidents where Plaintiff sought on-scene access and was excluded—the request is DENIED. ᅠᅠ Plaintiff asserts that delayed production of documents evidences or constitutes spoliation. Delay alone, absent a showing of destruction or alteration, does not warrant sanctions. The Court admonishes Defendants that continued dilatory tactics could support Rule 37 sanctions, including evidence preclusion, but the present record is insufficient for such relief. ᅠᅠ Plaintiff requested summary judgment “on the undisputed constitutional violation.” Discovery has only recently begun; numerous factual issues—policy existence, causation, damages—remain unresolved. Consistent with Rule 56(d), the request is DENIED WITHOUT PREJUDICE to renewal after completion of core discovery and compliance with the Court’s scheduling order. ᅠᅠ While the Court declines to impose sanctions, it will not countenance continued stonewalling. Should Defendants’ fail to meet the production deadlines or file a deficient privilege log, Plaintiff may move ex parte for monetary and evidentiary sanctions. The Court specifically reserves authority under Fed. R. Civ. P. 37(b) and San Andreas Code Civ. Proc. § 2031.310(h) to adverse-inference instructions, or issue preclusion upon a showing of bad-faith non-compliance. ORDER ᅠᅠ Defendants’ Motion to Dismiss under Rule 12(b)(6) is DENIED as to all claims. However, the Court emphasizes that any theory of respondeat superior liability under § 1983 is foreclosed as a matter of law, and Plaintiff’s claims against the Department must ultimately rest on proof of an unconstitutional policy, custom, or practice. ᅠᅠ Plaintiff’s Motion to Compel is GRANTED IN PART and DENIED IN PART. Defendants shall produce all internal affairs records and investigative materials pertaining to Officer Akhmad Shakhzadov and any personnel materially involved in the denial of Plaintiff’s Media Card. Such records are discoverable and relevant to the claims of constitutional deprivation and potential retaliation. Any claimed privileges shall be supported by a detailed privilege log. The Court reserves the right to conduct in camera review if necessary. Defendants shall produce a list of all Media Card applications submitted between January 1, 2025 and April 30, 2025, including the outcome (granted or denied). Names may be redacted subject to a protective order to be issued separately by the Court. Defendants shall also produce all current written policies, procedures, and training materials regarding the issuance of Media Cards and engagement with the press. These are facially relevant and proportional to the claims at issue. Plaintiff’s request for records of SWAT deployments, gang interactions, and other “newsworthy incidents” from April 18 to present is DENIED on the grounds of overbreadth and insufficient nexus to the specific harms alleged in this matter. ᅠᅠ To the extent Defendants seeks summary judgment, such motion is premature. The Court will not entertain dispositive relief until completion of initial discovery. ᅠᅠ No sanctions are imposed at this time, though the Court notes that Defendants' non-compliance with earlier discovery requests came dangerously close to justifying remedial measures. Future failures may result in sanctions under Rule 37 and San Andreas Code Civ. Proc. § 2031.310(h). The Court will not impose adverse evidentiary inferences or preclude summary judgment on the basis of discovery disputes absent a showing of bad faith or actual destruction of evidence. ᅠᅠ All production compelled herein shall be completed no later than May 16, 2025. Defendants shall comply with the production deadlines and in camera submission schedule as set forth herein. ᅠᅠ IT IS SO ORDERED. DATED: May 09, 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

WIP

Using /r is the preferred method of communication unless it's not possible (such as driving during a pursuit). Once a situation is static members are expected to use in-game communication instead of speaking over teamspeak. We won't fault anyone for using teamspeak in a situation which it was impossible to type such as being shot at or driving in a pursuit.

He opened his mouth, now he's got a hole in his head.

Wrapping It Up / A Bitter Pill to Swallow

/me sheds a tear

OUT OF CHARACTER INFORMATION The thread is going to follow the development of Jayceon Jordan and and Ricardo Morales. Both characters are born and raised in vicious neighborhoods however the two have chosen unorthodox career paths and became priests from a young age. Now in their late 60's, both of them would like to indulge in bringing peace between rival gangs and furthermore bring peace to the city.