Tungsten

Perhaps i’m looking back with rose-tinted glasses, then! In my first couple of years though we saw some amazing factions! While I was a P1 in the PD, the great MS13 riot happened. Then we got a hurricane soon after! Those memories are still vivid for me! Roleplay scenes on LSRP have brought me many emotions over the years. I’ve laughed, I’ve cried, and everything in between … but not for a while. It feels like things are only surface deep nowadays, but perhaps I can find that top tier roleplay if I look harder! I’ll take your word that it’s there, I’ve just got to find it!

Hello folks, I am wondering if folks think it is possible to return to the “Golden Age of LSRP” that we saw in 2012-2018? Back then, there were so many factions it’d make your head spin! There was top tier roleplay on every street corner, and LSRP was widely considered to be the cream of the crop. People longed to be a part of this community and the application queue was sometimes in the hundreds. Now, we seem to be in the dark ages. There’s still good roleplay to be had, but you really have to search for it. If you don’t have a friend who is doing that top tier faction roleplay, it seems impossible to find. Those of us trying our hardest to create interesting roleplay are easily taken advantage of by those playing surface-level or avataristic characters. There seem to be no IC consequences for repeated major crime, and people don’t think twice before committing heinous acts. Is it possible to get back to this golden age? What can be done to get there?

Subject: Order to Show Cause; Deadline Exceeded; Motion for Summary Judgment To: Francis Stoessel <[email protected]> From: [email protected] CC: [email protected] The parties have exchanged motions and briefs enough to make the point of what we are trying to achieve here. The Los Santos Police Department has unfortunately breached the terms of your order to show cause and filed their response three days late. This has resulted in further denial of Mr. Tzompaxtle's right to a fair and speedy trial. We respectfully request that, for all of the reasons previously filed, your honor reject the recent briefs that were filed late and issue summary judgment as there is no genuine dispute of material fact – only legal argumentation. Respectfully, JACOB E. RABINOWITZ Attorney for Plaintiff Juan Tzompaxtle Tzompaxtle, Rabinowitz, and Barbieri LLP

Randall "Randy" Winters U.S. Army Veteran and Recovering Addict

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION WILLIAM ANDERSON, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT, et al. Defendants. Case No. 25-LSC-04117 ───────────── AMENDED COMPLAINT ───────────── Jacob E. Rabinowitz, State Bar No. 081000067 [email protected] 2793 Sunset Avenue Los Santos, San Andreas 90071 555-9999 Attorney for Defendant WILLIAM ANDERSON Bench Trial Demand 1. Pursuant to San Andreas Code of Civil Procedure § 631(f)1, Plaintiff waives his right to a Jury Trial and demands a bench trial in the above-entitled action concerning the underlying state criminal action People of the State of San Andreas v. William Anderson, disposition pending, in the Criminal Division of the Superior Court for the County of Los Santos. Jurisdiction 2. This court has jurisdiction over plaintiff's state and federal claims pursuant to San Andreas Code of Civil Procedure § 410.10. This court has supplemental jurisdiction over plaintiff's state claim of deprivation of civil rights under color of law pursuant to 28 U.S.C. § 1367 and San Andreas Code of Civil Procedure § 52.1. (( Actions under 42 U.S.C. § 1983 are typically federal claims, however we do not have a federal court on LS-RP so they must be introduced as state claims. )) 3. Venue in the Superior Court of San Andreas, County of Los Santos, Civil Division is proper pursuant to San Andreas Code of Civil Procedure § 395.5. 4. Plaintiff is entitled to submit a single amended complaint without leave of this court pursuant to San Andreas Code of Civil Procedure § 472. Parties 5. Plaintiff William Anderson is an individual who resides at 1659 Market Street in Los Santos, San Andreas. 6. Defendant Los Santos Police Department is a municipal corporation headquartered at 1 Pershing Square in Los Santos, San Andreas. Facts 7. Plaintiff is a lawful holder of a License to Purchase a Firearm ("PF License" or "PF"), License to Carry a Concealed Weapon ("CCW License" or "CCW"), and a San Andreas Guard Card ("GC License" or "GC"). 8. On or about April 20th, 2025, Plaintiff was visiting a nightclub in the City of Los Santos when he was physically assaulted, unprovoked, by an unknown individual. 9. In response to being assaulted, Plaintiff defended himself physically using his hands. Security escorted the assaultive individual out and Plaintiff followed behind to give a statement to security in the hopes of having that individual formally trespassed. 10. The assaultive individual then engaged in an aggravated battery, a felony pursuant to San Andreas Penal Code § 110(a), against Plaintiff dealing continued and severe harm to him and causing him to fear for his life and bodily integrity. 11. In response to the continued and severe harm being inflicted upon him, and causing fear of death or serious bodily injury, Plaintiff drew his lawfully-possessed weapon and fired upon the individual. Plaintiff stood his ground in defending himself and gave no warning to the individual as he is not required to retreat by any statute of this state and doing so would risk additional injury or even possibly death by blunt physical force. 12. The assaultive individual was incapacitated but was not later pronounced deceased. According to Plaintiff's knowledge, the assaultive individual survived his injuries and is still walking the streets of Los Santos. 13. In response to the discharge of deadly force, the Los Santos Police Department responded to the location. 14. Without proper investigation, the responding officer(s) concluded that Plaintiff had committed multiple crimes and placed him under arrest. The responding officer(s) did not take the assaultive individual into custody. 15. The arresting officer(s) did not review CCTV footage, interview Plaintiff, or take witness testimony else they would have likely concluded that Plaintiff was being seriously assaulted and therefore in reasonable fear for his life or of serious bodily injury. 16. As an immediate result of this arrest, Plaintiff's PF License, CCW License, and GC License were all revoked; Plaintiff's firearm and ammunition were also seized. Plaintiff is now ineligible to purchase or carry a firearm and is not lawfully able to work as a security guard in the State of San Andreas. 17. As a proximate result of this arrest, Plaintiff has been denied a multitude of constitutionally-protected rights including his second amendment right to bear arms, fifth amendment right to due process under the law, sixth amendment right to a fair trial under the law, and fourteenth amendment right to equal protection under the laws of both this state and of the United States of America. 18. Defendant Los Santos Police Department was issued a Subpoena Duces Tecum on April 30th, 2025. As an attorney admitted to the bar and therefore an officer of the court, issuance of this subpoena is lawful under San Andreas Code of Civil Procedure §§ 1985–1987.3. This subpoena ordered production of the following discoverable items: 1. The arrest record of Mr. William Anderson from April 2025 that resulted in the revocation of his PF, CCW, and GC licenses, including the names of the arresting officers, their ranks, and their total number of months in service with the Los Santos Police Department; due May 5th, 2025 or 3 days before assigned court date (whichever is later). 2. Evidentiary record for the seizure of Mr. William Anderson's firearm and ammunition arising from the aforementioned arrest; due May 5th, 2025 or 3 days before the assigned court date (whichever is later). 3. Sworn affidavit summary of the Los Santos Police Department's policy on arrests arising from self-defense incidents and seizure of firearms arising therefrom; due May 5th, 2025 or 3 days before the assigned court date (whichever is later). 4. Sworn affidavit summary of the Los Santos Police Department's policy on the use of force, specifically around the level of force of "arrest"; due May 5th, 2025 or 3 days before the assigned court date (whichever is later). 5. Sworn affidavit summary of the Los Santos Police Department's policy on investigation of private claims, probable cause, and arrests without a warrant; due May 5th, 2025 or 3 days before the assigned court date (whichever is later). 19. Plaintiff and Defendant Los Santos Police Department entered into settlement negotiations on May 3rd, 2025. Plaintiff indicated that acceptable terms of a settlement would include restoration of Plaintiff's licenses to purchase a firearm, carry a concealed firearm, and act as a security guard (guard card). In addition, Plaintiff requested a sum of $100,000 in compensation; $50,000 for attorney's fees, and; commitment to issue formal admonishment to the involved officers. In consideration, Plaintiff offered to dismiss this action and to enter into non-disclosure, confidentiality, and mutual non-disparagement agreements. 20. Counsel for Plaintiff received a letter from Defendant Los Santos Police Department on May 4th, 2025 indicating a willingness to settle the matter out of court. The Los Santos Police Department offered a settlement of restoring the relevant weapons licenses; compensation of $100,000; attorney's fees of $50,000, and; issuance of a non-formal administrative admonishment of the involved officers. In consideration for this offer, the Los Santos Police Department demanded the same agreements as proposed by Plaintiff. Approximately 23 minutes later, Defendant Los Santos Police Department retracted their offer via email stating an unwillingness to settle. An email from Counsel for Plaintiff was already scheduled to be issued and therefore was sent, indicating acceptance of the offer, three minutes after the retraction. On May 9th, 2025, Counsel for Plaintiff transmitted a letter indicating an unwillingness to negotiate a settlement and an intent to pursue all legal remedies by proceeding to trial. 21. As stated in the subpoena, the due date for these items was May 5th, 2025 or 3 days before the assigned court date. Since no court date has been assigned, the due date of this subpoena defaults to May 5th, 2025. Defendant Los Santos Police Department has failed to produce the required discovery to comply with this lawful order of an officer of the court. Further, Defendant Los Santos Police Department has failed to submit a timely Motion to Quash to this court thereby relinquishing their right to quash the terms of the subpoena under San Andreas Code of Civil Procedure § 2025.140. First Claim 42 U.S.C. § 1983; San Andreas Code of Civil Procedure § 52.1; San Andreas Constitution, Article 1 §§ 7, 13, and 17 – Against all defendants 22. Plaintiff incorporates paragraphs 7 through 21 by reference as if fully rewritten herein. 23. Defendants at all times relevant to this action were acting under color of state law. Defendants Two Unknown Officers of the Los Santos Police Department are both jointly and severally liable for their actions taken on behalf of Defendant Los Santos Police Department. 24. Defendant Los Santos Police Department unlawfully deprived Plaintiff of his right to due process, a fair trial, and to equal protection of the laws by arresting him without the necessary and proper degree of evidence to establish probable cause for arrest. Miranda v. Arizona, 384 U.S. 436 (1966); Gideon v. Wainwright, 372 U.S. 335 (1963); Illinois v. Gates, 462 U.S. 213 (1983). Under Illinois v. Gates, this court must apply a "totality of the circumstances" test when determining the presence of probable cause. Any arrest absent a warrant is de-facto unconstitutional unless probable cause can be shown. If this court determines, through the required test, that probable cause is not present then all following actions taken including, but not limited to, the seizure of Plaintiff's licenses, firearms, and ammunition are de-facto unconstitutional seizures as well. 25. Defendant Los Santos Police Department engaged in excessive force against Plaintiff through unlawful, warrantless arrest. Graham v. Connor, 490 U.S. 386 (1989). Under Graham v. Connor, this court must apply an objective reasonableness standard with three prongs known as the "Graham factors": (1) the severity of the crime at issue; (2) whether the suspect was actively resisting or attempting to flee; (3) whether the suspect's actions pose an immediate threat to the officer or to others. Because the elements of the underlying crime of assault with a deadly weapon are not met on grounds of actus reus or mens rea, Plaintiff did not commit a crime. Therefore, the Graham test fails on the first prong as there is no severity where there is no crime. 26. Plaintiff William Anderson was not the initial aggressor of the conflict and himself engaged in self defense proportionate to the danger he was faced with. United States v. Peterson, 483 F.2d 1222 (D.C. Cir. 1973). Applying the non-binding but widely accepted standard established in United States v. Peterson, Plaintiff's actions were proportionate because he was being severely overpowered by the attacker and reasonably feared he may sustain serious bodily harm. Plaintiff need not match fists with fists – the purpose of a concealed weapon is to defend oneself from serious bodily harm up to and including death, and Plaintiff reasonably feared this because he was being repeatedly punched in his body and face. 27. Defendant Los Santos Police Department, and representatives thereof, engaged in a warrantless seizure of a firearm and ammunition belonging to and lawfully possessed by Plaintiff William Anderson, in violation of the Guidelines published by the Los Santos Police Department. See also Firearms Licensing Division, PF License Usage Regulations ("Must not be in possession of any firearms other than the ones they applied for"); Firearms Licensing Division, CCW License Usage Regulations ("Must not reveal their firearm unless an active threat to life is occurring or there is a clear and potential imminent threat to life which could be averted by revealing the CCW firearm. In the case of law enforcement arriving on scene or being on scene, the CCW holder must take care to comply with law enforcement orders"). 28. Defendant Los Santos Police Department, and representatives thereof, engaged in a warrantless seizure of a PF License, CCW License, and GC License without lawful justification as described in Paragraph 22 above. 29. Defendant Los Santos Police Department is not entitled to sovereign immunity under the San Andreas Sovereign Immunity Act of 2018 due to an exemption under Section 3(A) therein, which reads (emphasis applied): "Sovereign immunity does not apply when an employee commits any illegal or tortious action in accordance with his duty. It is the recognition that state agencies aren't directly responsible for the actions when they have taken reasonable steps to ensure the employees actions were legal, such as proper and consistent training and policy which upholds the rule of law and legal standards." Defendant Los Santos Police Department did not adequately train their officers in the requirement of both reasonable articulable particularized suspicion (RAPS) as well as probable cause (PC) to support a warrantless arrest. Due to the lack of formal training in this area, defendant has failed to take reasonable steps to ensure legality of the employees actions. 30. Defendant Los Santos Police Department is not entitled to sovereign immunity under the San Andreas Sovereign Immunity Act of 2018 due to an exemption under Section 3(B)3 therein, which reads: "[(B) Sovereign Immunity will either partially apply, or not apply at all, given one or multiple of following cases: ...] (3) In the case where the action(s) was committed by violating some defined legal standard or law, and that action was not in accordance to an established policy, the actor(s) may be held responsible. Sovereign immunity shall apply to the agency, but not its actor(s)." Defendants Two Unknown Officers of the Los Santos Police Department violated a defined legal standard of the requirement of clear probable cause or a warrant of arrest to conduct a seizure by arrest of a person. Defendant Los Santos Police Department's failure to adequately train these officers gives rise to this exemption under Monell v. Department of Soc. Svcs., 436 U.S. 658 (1978). This section states that sovereign immunity shall apply, however the agency is exempted from sovereign immunity for reasons described in Paragraph 23 and therefore may not receive it. 31. Defendant Los Santos Police Department is not entitled to sovereign immunity under the San Andreas Sovereign Immunity Act of 2018 due to an exemption under Section 3(B)5 therein, which reads: "[(B) Sovereign Immunity will either partially apply, or not apply at all, given one or multiple of following cases: ...] (5) In the case where a wrongful act or omission shown that resulted in injury, the actor(s) may be held responsible and sovereign immunity shall not apply. Sovereign immunity shall apply to the agency." Defendants Two Unknown Officers of the Los Santos Police Department inflicted legal injury upon Plaintiff by depriving him of his freedom and therefore of wages he would have reasonable earned as an employee of Roze Enterprise. His employment as a security guard was interrupted by the revocation of his Guard Card and he could not therefore lawfully work as a security guard at any of Roze Enterprise's client businesses. This deprivation of wages is an injury as defined in common law. This section states that sovereign immunity shall apply, however the agency is exempted from sovereign immunity for reasons described in Paragraph 23 and therefore may not receive it. 32. Plaintiff is entitled to compensation for the loss of his firearms and ammunition under Section 4(E) of the San Andreas Sovereign Immunity Act of 2018, which reads (emphasis applied): "In any cases where sovereign immunity is waived, and compensation of items seized shall be granted, all firearms’ value shall not be added to the judgement, unless the claimant has legally obtained the appropriate licenses, legally obtained the firearms and the possession of such firearms is not prohibited by the San Andreas Penal Code, in which case they shall be returned their firearms or receive fair market value for legally obtaining such firearms." 33. Plaintiff is entitled to receive his PF, CCW, and GC Licenses back, or compensation therefore, under Section 4(F) of the San Andreas Sovereign Immunity Act of 2018, which reads: "In any cases where sovereign immunity is waived, and compensation of items seized shall be granted, all narcotics’ value shall not be added to the judgement, unless they are legally prescribed to the claimant, in which case they shall receive fair market value for legally obtaining such medicine." 34. Plaintiff is entitled to the reversal of all criminal charges and full criminal acquittal for reasons described in Paragraph 20. Where the elements of a crime are not met, there is no probable cause; where there is no probable cause, there can be no criminal charges or arrest following therefrom. Second Claim Tortious Breach of Contract 35. Plaintiff incorporates paragraphs 7 through 21 by reference as if fully rewritten herein. 36. A contract consists of five elements: offer, acceptance, capacity, consideration, and legality. 37. Plaintiff's communication of a settlement proposal to Defendant Los Santos Police Department constitutes an offer in tort. The negotiable aspects of the proposal outlined areas in which Plaintiff was willing to be flexible in the offer. 38. Defendant Los Santos Police Department communicated an acceptance of the offer in writing, thereby constituting an acceptance in tort. 39. Plaintiff has the capacity to enter into such a contract because neither Plaintiff nor his counsel has been duly adjudged mentally incompetent. Lucy v. Zehmer, 196 Va. 493 (1954); Sparrow v. Demonico, 960 N.E.2d 296 (2011); Smalley v. Baker, 262 Cal.App.2d 824,69 Cal.Rptr. 521. Neither has demonstrated personal or legal incompetence, therefore their capacity to contract is valid and unvoidable. 40. Defendant Los Santos Police Department has the capacity to enter into such a contract because it is a municipal corporation that is not capable of being adjudged incompetent to contract. Its representative, Ibraheem A. Davis, has not been adjudged legally incompetent in his practice as an attorney. Therefore, the capacity of Defendant Los Santos Police Department is valid and unvoidable. Oubre v. Entergy Operations, Inc., 522 U.S. 422 (1998). 41. Both Plaintiff and Defendant in their communication expressed consideration for the other, detailing exact terms to be exchanged. Defendant accepted the terms of consideration in part and amended one portion of the terms which was negotiable in the proposed settlement agreement. 42. The proposed settlement agreement complies with all laws of this state and of the United States of America. 43. With all five elements of a valid contract being met – offer, acceptance, consideration, capacity, and legality – the exchange of terms between both Plaintiff and Defendant constitutes a valid and binding, enforceable contract. 44. The withdrawal of the settlement agreement by Defendant Los Santos Police Department only minutes after its offer constitutes a breach of that contract because the contract was already accepted and enforceable from the time it was transmitted. The negotiable items indicated that Plaintiff was willing to be flexible and therefore acceptance by the Plaintiff is automatic. 45. The actions of Defendant Los Santos Police Department constitute a material breach of the contract between Plaintiff and Defendant. Therefore, Plaintiff is entitled to recovery and enforcement of the settlement agreement as offered by Defendant Los Santos Police Department. Prayer for Relief WHEREFORE, Plaintiff prays for the following relief: A. On his first claim, a judgment for compensatory and punitive damages in an amount to be determined at trial, plus reasonable attorney fees pursuant to San Andreas Code of Civil Procedure §§ 1030 and 1021.4, and return of or compensation for the loss of PF, CCW, and GC licenses arising from the events described in this complaint. B. On his second claim, a judgment enforcing the terms of the settlement agreement between Plaintiff and Defendant. C. If no judgment effectuating enforcement of the settlement agreement described in his second claim is issued, Plaintiff prays for a bench trial on all issues, an award of costs and expenses against the Defendants, and; reversal of all criminal charges stemming from the events described in this complaint. D. Any and all other relief this court may deem appropriate. Respectfully submitted, Jacob E. Rabinowitz Attorney for Plaintiff

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION WILLIAM ANDERSON, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT, et al. Defendants. Case No. 25-LSC-04117 ───────────── MOTION TO COMPEL DISCOVERY AND REQUEST FOR SANCTIONS ───────────── Jacob E. Rabinowitz, State Bar No. 081000067 [email protected] 1 Market Street Los Santos, San Andreas 90071 555-9999 Attorney for Defendant WILLIAM ANDERSON BACKGROUND Defendant Los Santos Police Department was issued a Subpoena Duces Tecum on April 30th, 2025. As an attorney admitted to the bar and therefore an officer of the court, issuance of this subpoena is lawful under San Andreas Code of Civil Procedure §§ 1985–1987.3 (( Link )). This subpoena ordered production of the following discoverable items: 1. The arrest record of Mr. William Anderson from April 2025 that resulted in the revocation of his PF, CCW, and GC licenses, including the names of the arresting officers, their ranks, and their total number of months in service with the Los Santos Police Department; due May 5th, 2025 or 3 days before assigned court date (whichever is later). 2. Evidentiary record for the seizure of Mr. William Anderson's firearm and ammunition arising from the aforementioned arrest; due May 5th, 2025 or 3 days before the assigned court date (whichever is later). 3. Sworn affidavit summary of the Los Santos Police Department's policy on arrests arising from self-defense incidents and seizure of firearms arising therefrom; due May 5th, 2025 or 3 days before the assigned court date (whichever is later). 4. Sworn affidavit summary of the Los Santos Police Department's policy on the use of force, specifically around the level of force of "arrest"; due May 5th, 2025 or 3 days before the assigned court date (whichever is later). 5. Sworn affidavit summary of the Los Santos Police Department's policy on investigation of private claims, probable cause, and arrests without a warrant; due May 5th, 2025 or 3 days before the assigned court date (whichever is later). Plaintiff and Defendant Los Santos Police Department entered into settlement negotiations on May 3rd, 2025. Plaintiff indicated that acceptable terms of a settlement would include restoration of Plaintiff's licenses to purchase a firearm, carry a concealed firearm, and act as a security guard (guard card). In addition, Plaintiff requested a sum of $100,000 in compensation; $50,000 for attorney's fees, and; commitment to issue formal admonishment to the involved officers. In consideration, Plaintiff offered to dismiss this action and to enter into non-disclosure, confidentiality, and mutual non-disparagement agreements. Counsel for Plaintiff received a letter from Defendant Los Santos Police Department on May 4th, 2025 indicating a willingness to settle the matter out of court. The Los Santos Police Department offered a settlement of restoring the relevant weapons licenses; compensation of $100,000; attorney's fees of $50,000, and; issuance of a non-formal administrative admonishment of the involved officers. In consideration for this offer, the Los Santos Police Department demanded the same agreements as proposed by Plaintiff. Approximately 23 minutes later, Defendant Los Santos Police Department retracted their offer via email stating an unwillingness to settle. An email from Counsel for Plaintiff was already scheduled to be issued and therefore was sent, indicating acceptance of the offer, three minutes after the retraction. On May 9th, 2025, Counsel for Plaintiff transmitted a letter indicating an unwillingness to negotiate a settlement and an intent to pursue all legal remedies by proceeding to trial. As stated in the subpoena, the due date for these items was May 5th, 2025 or 3 days before the assigned court date. Since no court date has been assigned, the due date of this subpoena defaults to May 5th, 2025. Defendant Los Santos Police Department has failed to produce the required discovery to comply with this lawful order of an officer of the court. Further, Defendant Los Santos Police Department has failed to submit a timely Motion to Quash to this court thereby relinquishing their right to quash the terms of the subpoena under San Andreas Code of Civil Procedure § 2025.140 (( Link )). PROPOSED ORDER In light of Defendant Los Santos Police Department's failure to comply with the terms of a lawful order of this court by an attorney of record authorized to issue such order, Plaintiff proposes that this court issue the following orders: An order to show cause issued to the Los Santos Police Department requiring production of a valid and lawful reason for non-compliance with the subpoena, or an order mandating production of the requested evidence and; An order issuing sanctions to the attorney of record for the Los Santos Police Department, Ibraheem A. Davis, for failure to comply with the terms of a lawful order of this court issued by an attorney of record in this action. Respectfully submitted, /s/ Jacob E. Rabinowitz JACOB EZEKIEL RABINOWITZ Attorney for Plaintiff William Anderson

** Service of Process is provided. (( ))

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION JUAN TZOMPAXTLE, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT Defendants. Case No. 25-LSC-05121 ───────────── CIVIL COMPLAINT AND PETITION FOR WRIT OF HABEAS CORPUS ───────────── Jacob E. Rabinowitz, State Bar No. 820510100 [email protected] Attorney for Defendant JUAN TZOMPAXTLE Introduction 1. Plaintiff ᅠᅠJuan Tzompaxtle, defendant in the underlying action People of the State of San Andreas v. Juan Tzompaxtle, hereby petitions this court for a Writ of Habeas Corpus pursuant to Rule 4.551. Jurisdiction ᅠᅠ2. This Court has jurisdiction under the San Andreas Constitution and the Code of Civil Procedure, including but not limited to Code Civ. Proc. § 410.10 and under Rule 4.551. Parties 3. Plaintiff Juan Tzompaxtle is an individual who resides in the County of Los Santos in the State of San Andreas. 4. Defendant Los Santos Police Department is a municipal corporation headquartered at 1 Pershing Square in Los Santos, San Andreas. Facts ᅠᅠ5. In the late hours of May 3rd, 2025, at a time before the sun had officially set, officers of the Los Santos Police Department engaged in a traffic stop of Plaintiff. 6. Defendant's officers informed Plaintiff that the reason for the traffic stop was driving without the use of headlights during the hours between sunset and sunrise, an infraction pursuant to San Andreas Vehicle Code § 502 ("VC 502"). Plaintiff concedes that the street lights were activated at the time of the traffic stop. 7. Plaintiff was issued citations for both allegedly driving without the use of headlights and operating a vehicle without automotive insurance as required by San Andreas Vehicle Code § 301 ("VC 301"). Plaintiff was also advised by the officer to turn his vehicle's headlights on. 8. A short time after the traffic stop had ended Plaintiff was once again pulled over by the same officer, again at a time before the sun had officially set but while the street lamps were activated. This time, however he was arrested for Obstruction of Justice, a misdemeanor pursuant to San Andreas Penal Code § 610(b) ("PC 610(b)"). 9. The officer explained to Plaintiff at the time of arrest that he was being arrested for a failure to obey a lawful order. Plaintiff presumes the lawful order was the officer's prior advisement to turn on the headlights. 10. Plaintiff was transported to the state prison and placed into the custody of the San Andreas Department of Corrections for a misdemeanor offense. VC 509 is Vague and Ambiguous 11. The rule of lenity, otherwise known as the statute of strict construction, requires that when any statute or regulation is vague or ambiguous, the court should apply it in a way that is most favorable to the defendant in a criminal action. 12. VC 509 is vague and ambiguous because it relies on two conflicting states. First, it states that when the street lamps are activated a person must drive using their headlights. Second, it states that headlights must be activated between sunset and sunrise. 13. Plaintiff interpreted VC 509 to mean that both conditions must be present – the street lamps must be activated and the sun must have set. Logically, it does not make sense to activate one's vehicle headlights at a time while there are still adequate lighting conditions to operate a motor vehicle safely. The purpose of VC 509 is clearly to enable safe operation of motor vehicles, not to create grounds for arbitrary traffic stops by peace officers. An Order to Activate Headlights is Not a Lawful Order 14. A "lawful order" is any order that is sufficiently underpinned and readily citable by a statute or regulation, though an officer need not cite the statute or regulation at the time of the order. 15. If an order given by a peace officer is not sufficiently underpinned by such a statute or regulation, it is not a lawful order. The mere fact that a peace officer gives an order does not inherently make that order a "lawful order". If this were true, we would certainly live in a police state wherein peace officers could arbitrarily order any person to do any thing under threat of arrest, regardless of the legality of the action they are ordering the person to perform. 16. PC 610(b) states one single element of a presumably general intent crime: "A person [must fail] to comply with a peace officer's lawful orders". The clear requirement is that there must be a lawful order that a person fails to comply with. If there is no lawful order, the person is not required to comply with it and therefore failure to comply with that order cannot be a violation of PC 610(b). VC 502 is an Infraction, Not a Misdemeanor 17. Violation of VC 502 is an infraction offense which is independently punishable by a citation. To cite a person for the offense of failing to use their headlights then subsequently arrest them shortly thereafter for Obstruction is to effectively elevate VC 502 to the level of a misdemeanor despite it being defined as an infraction in the laws of this state. 18. If, for example, a person were cited for Speeding, an infraction under San Andreas Vehicle Code § 401, then later is pulled over for Speeding again, we would not expect a person to then be arrested for Obstruction of Justice. Rather, we would expect that person to once again be cited for Speeding. The clearly-defined punishment for Speeding is a citation, not arrest. 19. To charge a person with Obstruction of Justice for a repeated vehicular offense is to enable an officer to re-write any infraction into a misdemeanor. This vests additional powers to the Executive branch of government, to which the officer's enforcement powers belong, that typically belong to the Legislative branch of government. This foremost violates the separation of powers doctrine on which this entire country's governance is based. Prayer for Relief ᅠᅠ20. Plaintiff prays for reversal of all underlying criminal charges relevant to this complaint. 21. If reversal is not granted, Plaintiff then prays for a Writ of Habeas Corpus mandating that the Los Santos Police Department present any and all evidence supporting the relevant arrest for Obstruction of Justice, including the officer's affidavit of arrest and any DICV footage of both traffic stops and the subsequent arrest. 22. If reversal of the underlying criminal charges is granted, Plaintiff prays for compensatory damages for the time he spent imprisoned. Since is is employed as an attorney and actively representing multiple clients in multiple cases of record before this court, and he was imprisoned, he was unable to log billable hours against such clients. Plaintiff's typical rate per billable day is $50,000 as defined by policies of the Tzompaxtle, Rabinowitz, and Barbieri law firm. Plaintiff was deprived of the ability to bill for 3 total days spread between his cases and therefore deprived of $150,000 in income. 23. If reversal of the underlying criminal charges is granted, Plaintiff prays for declaratory relief clarifying VC 502's ambiguous language and for an order that the Los Santos Police Department both distribute a memorandum notifying all officers of this clarification and provide proof of such distribution to this court. 24. If reversal of the underlying criminal charges is granted, Plaintiff prays for special damages in the amount of $100,000 in reasonable attorney fees for two billable days of work at a rate of $50,000 per billable day, as defined by policies of the Tzompaxtle, Rabinowitz, and Barbieri law firm. DATED: May 03, 2025 Respectfully Submitted, /s/ Jacob E. Rabinowitz Jacob E. Rabinowitz Attorney for Plaintiff Juan Tzompaxtle

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION Case Name: JUAN TZOMPAXTLE v. LOS SANTOS POLICE DEPARTMENT Plaintiff Attorney: Jacob E. Rabinowitz CIVIL CASE COVER SHEET _______________________________________________ 1. Check one box below that best describes this case: Personal Torts [ ] Assault, battery, or unlawful contact [X] 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. Compensatory damages in the amount of $50,000, broken down as follows: Remuneration for billable hours not able to be logged due to the imprisonment of Plaintiff, an attorney who represents clients in multiple actions before this court. Special damages in the amount of $150,000, broken down as follows: Billing rate for services rendered by the law firm Tzompaxtle Rabinowitz & Barbieri LLP, at $50,000 per billable day, preemptively estimated at approximately 3 billable days, totaling to $150,000. Additional prayer for relief: Declaratory relief adjudging the facial unconstitutionality of San Andreas Vehicle Code § 502. Reversal and remand of all criminal charges in the underlying action People of the State of San Andreas v. Juan Tzompaxtle. _______________________________________________ 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 2nd day of May, 2025 by: /S/ JACOB E. RABINOWITZ Jacob E. Rabinowitz Attorney for Plaintiff Signing on behalf of self and plaintiff Juan Tzompaxtle

** A subpoena has been filed in duplicate with the court clerk. (( Sent to "Timothy Kempton" via LSPD Forums. Proof available upon request. ))

** Proof of Service has been filed with the court clerk. (( OOC Proof ))

IN THE SUPERIOR COURT OF SAN ANDREAS, COUNTY OF LOS SANTOS WILLIAM ANDERSON, Plaintiff v. LOS SANTOS POLICE DEPARTMENT, Defendant COMPLAINT Bench Trial Demand 1. Pursuant to San Andreas Code of Civil Procedure § 631(f)1, Plaintiff waives his right to a Jury Trial and demands a bench trial in the above-entitled action concerning the underlying state criminal action People of the State of San Andreas v. William Anderson, disposition pending, in the Criminal Division of the Superior Court for the County of Los Santos. Jurisdiction 2. This court has jurisdiction over plaintiff's state and federal claims pursuant to San Andreas Code of Civil Procedure § 410.10. This court has supplemental jurisdiction over plaintiff's state claim of deprivation of civil rights under color of law pursuant to 28 U.S.C. § 1367 and San Andreas Code of Civil Procedure § 52.1. (( Actions under 42 U.S.C. § 1983 are typically federal claims, however we do not have a federal court on LS-RP so they must be introduced as state claims. )) 3. Venue in the Superior Court of San Andreas, County of Los Santos, Civil Division is proper pursuant to San Andreas Code of Civil Procedure § 395.5. Parties 4. Plaintiff William Anderson is an individual who resides at 1485 Market Street in Los Santos, San Andreas. 5. Defendant Los Santos Police Department is a municipal corporation headquartered at 1 Pershing Square in Los Santos, San Andreas. Facts 6. Plaintiff is a lawful holder of a License to Purchase a Firearm ("PF License" or "PF"), License to Carry a Concealed Weapon ("CCW License" or "CCW"), and a San Andreas Guard Card ("GC License" or "GC"). 7. On or about April 20th, 2025, Plaintiff was visiting a nightclub in the City of Los Santos when he was physically assaulted, unprovoked, by an unknown individual. 8. In response to being assaulted, Plaintiff defended himself physically using his hands. Security escorted the assaultive individual out and Plaintiff followed behind to give a statement to security in the hopes of having that individual formally trespassed. 9. The assaultive individual then engaged in an aggravated battery, a felony pursuant to San Andreas Penal Code § 110(a), against Plaintiff dealing continued and severe harm to him and causing him to fear for his life and bodily integrity. 10. In response to the continued and severe harm being inflicted upon him, and causing fear of death or serious bodily injury, Plaintiff drew his lawfully-possessed weapon and fired upon the individual. Plaintiff stood his ground in defending himself and gave no warning to the individual as he is not required to retreat by any statute of this state and doing so would risk additional injury or even possibly death by blunt physical force. 11. The assaultive individual was incapacitated but was not later pronounced deceased. According to Plaintiff's knowledge, the assaultive individual survived his injuries and is still walking the streets of Los Santos. 12. In response to the discharge of deadly force, the Los Santos Police Department responded to the location. 13. Without proper investigation, the responding officer(s) concluded that Plaintiff had committed multiple crimes and placed him under arrest. The responding officer(s) did not take the assaultive individual into custody. 14. The arresting officer(s) did not review CCTV footage, interview Plaintiff, or take witness testimony else they would have likely concluded that Plaintiff was being seriously assaulted and therefore in reasonable fear for his life or of serious bodily injury. 15. As an immediate result of this arrest, Plaintiff's PF License, CCW License, and GC License were all revoked; Plaintiff's firearm and ammunition were also seized. Plaintiff is now ineligible to purchase or carry a firearm and is not lawfully able to work as a security guard in the State of San Andreas. 16. As a proximate result of this arrest, Plaintiff has been denied a multitude of constitutionally-protected rights including his second amendment right to bear arms, fifth amendment right to due process under the law, sixth amendment right to a fair trial under the law, and fourteenth amendment right to equal protection under the laws of both this state and of the United States of America. First Claim 42 U.S.C. § 1983; San Andreas Code of Civil Procedure § 52.1; San Andreas Constitution, Article 1 §§ 7, 13, and 17 – Against all defendants 17. Plaintiff incorporates the preceding paragraphs by reference as if fully rewritten herein. 18. Defendants at all times relevant to this action were acting under color of state law. Defendants Two Unknown Officers of the Los Santos Police Department are both jointly and severally liable for their actions taken on behalf of Defendant Los Santos Police Department. 19. Defendant Los Santos Police Department unlawfully deprived Plaintiff of his right to due process, a fair trial, and to equal protection of the laws by arresting him without the necessary and proper degree of evidence to establish probable cause for arrest. Miranda v. Arizona, 384 U.S. 436 (1966); Gideon v. Wainwright, 372 U.S. 335 (1963); Illinois v. Gates, 462 U.S. 213 (1983). Under Illinois v. Gates, this court must apply a "totality of the circumstances" test when determining the presence of probable cause. Any arrest absent a warrant is de-facto unconstitutional unless probable cause can be shown. If this court determines, through the required test, that probable cause is not present then all following actions taken including, but not limited to, the seizure of Plaintiff's licenses, firearms, and ammunition are de-facto unconstitutional seizures as well. 20. Defendant Los Santos Police Department engaged in excessive force against Plaintiff through unlawful, warrantless arrest. Graham v. Connor, 490 U.S. 386 (1989). Under Graham v. Connor, this court must apply an objective reasonableness standard with three prongs known as the "Graham factors": (1) the severity of the crime at issue; (2) whether the suspect was actively resisting or attempting to flee; (3) whether the suspect's actions pose an immediate threat to the officer or to others. Because the elements of the underlying crime of assault with a deadly weapon are not met on grounds of actus reus or mens rea, Plaintiff did not commit a crime. Therefore, the Graham test fails on the first prong as there is no severity where there is no crime. 20. Plaintiff William Anderson was not the initial aggressor of the conflict and himself engaged in self defense proportionate to the danger he was faced with. United States v. Peterson, 483 F.2d 1222 (D.C. Cir. 1973). Applying the non-binding but widely accepted standard established in United States v. Peterson, Plaintiff's actions were proportionate because he was being severely overpowered by the attacker and reasonably feared he may sustain serious bodily harm. Plaintiff need not match fists with fists – the purpose of a concealed weapon is to defend oneself from serious bodily harm up to and including death, and Plaintiff reasonably feared this because he was being repeatedly punched in his body and face. 21. Defendant Los Santos Police Department, and representatives thereof, engaged in a warrantless seizure of a firearm and ammunition belonging to and lawfully possessed by Plaintiff William Anderson, in violation of the Guidelines published by the Los Santos Police Department. See also Firearms Licensing Division, PF License Usage Regulations ("Must not be in possession of any firearms other than the ones they applied for"); Firearms Licensing Division, CCW License Usage Regulations ("Must not reveal their firearm unless an active threat to life is occurring or there is a clear and potential imminent threat to life which could be averted by revealing the CCW firearm. In the case of law enforcement arriving on scene or being on scene, the CCW holder must take care to comply with law enforcement orders"). 22. Defendant Los Santos Police Department, and representatives thereof, engaged in a warrantless seizure of a PF License, CCW License, and GC License without lawful justification as described in Paragraph 22 above. 23. Defendant Los Santos Police Department is not entitled to sovereign immunity under the San Andreas Sovereign Immunity Act of 2018 due to an exemption under Section 3(A) therein, which reads (emphasis applied): "Sovereign immunity does not apply when an employee commits any illegal or tortious action in accordance with his duty. It is the recognition that state agencies aren't directly responsible for the actions when they have taken reasonable steps to ensure the employees actions were legal, such as proper and consistent training and policy which upholds the rule of law and legal standards." Defendant Los Santos Police Department did not adequately train their officers in the requirement of both reasonable articulable particularized suspicion (RAPS) as well as probable cause (PC) to support a warrantless arrest. Due to the lack of formal training in this area, defendant has failed to take reasonable steps to ensure legality of the employees actions. 24. Defendant Los Santos Police Department is not entitled to sovereign immunity under the San Andreas Sovereign Immunity Act of 2018 due to an exemption under Section 3(B)3 therein, which reads: "[(B) Sovereign Immunity will either partially apply, or not apply at all, given one or multiple of following cases: ...] (3) In the case where the action(s) was committed by violating some defined legal standard or law, and that action was not in accordance to an established policy, the actor(s) may be held responsible. Sovereign immunity shall apply to the agency, but not its actor(s)." Defendants Two Unknown Officers of the Los Santos Police Department violated a defined legal standard of the requirement of clear probable cause or a warrant of arrest to conduct a seizure by arrest of a person. Defendant Los Santos Police Department's failure to adequately train these officers gives rise to this exemption under Monell v. Department of Soc. Svcs., 436 U.S. 658 (1978). This section states that sovereign immunity shall apply, however the agency is exempted from sovereign immunity for reasons described in Paragraph 23 and therefore may not receive it. 25. Defendant Los Santos Police Department is not entitled to sovereign immunity under the San Andreas Sovereign Immunity Act of 2018 due to an exemption under Section 3(B)5 therein, which reads: "[(B) Sovereign Immunity will either partially apply, or not apply at all, given one or multiple of following cases: ...] (5) In the case where a wrongful act or omission shown that resulted in injury, the actor(s) may be held responsible and sovereign immunity shall not apply. Sovereign immunity shall apply to the agency." Defendants Two Unknown Officers of the Los Santos Police Department inflicted legal injury upon Plaintiff by depriving him of his freedom and therefore of wages he would have reasonable earned as an employee of Roze Enterprise. His employment as a security guard was interrupted by the revocation of his Guard Card and he could not therefore lawfully work as a security guard at any of Roze Enterprise's client businesses. This deprivation of wages is an injury as defined in common law. This section states that sovereign immunity shall apply, however the agency is exempted from sovereign immunity for reasons described in Paragraph 23 and therefore may not receive it. 26. Plaintiff is entitled to compensation for the loss of his firearms and ammunition under Section 4(E) of the San Andreas Sovereign Immunity Act of 2018, which reads (emphasis applied): "In any cases where sovereign immunity is waived, and compensation of items seized shall be granted, all firearms’ value shall not be added to the judgement, unless the claimant has legally obtained the appropriate licenses, legally obtained the firearms and the possession of such firearms is not prohibited by the San Andreas Penal Code, in which case they shall be returned their firearms or receive fair market value for legally obtaining such firearms." 27. Plaintiff is entitled to receive his PF, CCW, and GC Licenses back, or compensation therefore, under Section 4(F) of the San Andreas Sovereign Immunity Act of 2018, which reads: "In any cases where sovereign immunity is waived, and compensation of items seized shall be granted, all narcotics’ value shall not be added to the judgement, unless they are legally prescribed to the claimant, in which case they shall receive fair market value for legally obtaining such medicine." 28. Plaintiff is entitled to the reversal of all criminal charges and full criminal acquittal for reasons described in Paragraph 20. Where the elements of a crime are not met, there is no probable cause; where there is no probable cause, there can be no criminal charges or arrest following therefrom. Prayer for Relief WHEREFORE, Plaintiff prays for the following relief: A. On his first and only claim, a judgment for compensatory and punitive damages in an amount to be determined at trial, plus reasonable attorney fees pursuant to San Andreas Code of Civil Procedure §§ 1030 and 1021.4, and return of or compensation for the loss of PF, CCW, and GC licenses arising from the events described in this complaint. B. A bench trial on all issues; C. An award of costs and expenses against the Defendants; D. Reversal of all criminal charges stemming from the events described in this complaint; E. Any and all other relief this court may deem appropriate. Respectfully submitted, Jacob E. Rabinowitz Attorney for Plaintiff

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION Case Name: WILLIAM ANDERSON v. LOS SANTOS POLICE DEPARTMENT and TWO UNKNOWN POLICE OFFICERS OF THE LOS SANTOS POLICE DEPARTMENT Plaintiff Attorney: Jacob E. Rabinowitz CIVIL CASE COVER SHEET _______________________________________________ 1. Check one box below that best describes this case: Personal Torts [ ] Assault, battery, or unlawful contact [X] 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 [X] Abuse of process [ ] Malicious prosecution [ ] Alienation of affections Business Torts [ ] Fraud [ ] Tortious interference [ ] Conspiracy [ ] Restraint of trade [ ] Passing off Contracts [X] Breach of Contract [ ] Collections Judicial Review [ ] Denial or Revocation of Business License [X] Denial or Revocation of Firearms License 2. List any damages sustained or fees accrued. Include billing rate for attorneys, expert witnesses, etc. Compensatory damages in the amount of $140,000, broken down as follows: Criminal charges and difficulties with employment as a security guard and lost wages following therefrom amounting to approximately $30,000 per night for two nights, totaling $60,000 in lost wages; Wrongful arrest and imprisonment, resulting in significant emotional distress arising from confinement; Seizure of a firearm and ammunition jointly valued at approximately $25,000; Seizure of a license to purchase a firearm, resulting in effective loss of application fees amounting to $10,000; Seizure of a license to carry a concealed weapon, resulting in effective loss of application fees amounting to $25,000, and; Seizure of a guard card license, resulting in effective loss of application fees amounting to $20,000. Special damages in the amount of $100,000, broken down as follows: Billing rate for services rendered by the law firm Rabinowitz and Sons, P.C., at $20,000 per billable day, preemptively estimated at approximately 5 billable days, totaling to $100,000. Punitive damages sought in an amount deemed appropriate by the court for malicious prosecution, abuse of process, and deprivation of civil rights, with a request of at least $1,500,000. Additional prayer for relief: Restoration of License to Purchase a Firearm, License to Carry a Concealed Weapon, and Guard Card License; No contact order between the plaintiff in this action and the arresting officer for a period of 6 months. _______________________________________________ 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 30th day of April, 2025 by: /S/ JACOB E. RABINOWITZ Jacob E. Rabinowitz Attorney for Plaintiff Signing on behalf of self and plaintiff William Anderson

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

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

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS, <CRIMINAL/CIVIL/PROBATE> DIVISION Case No. 25-LSC-04117 In the Matter of Montblanc v. Los Santos Police Department _____________________________________________________________________________ MEMORANDUM Plaintiff's Motion for Sanction and Censure of opposing counsel for use of artificial intelligence tools is denied. While this court does not recommend the use of artificial intelligence tools for drafting documents, such is not prohibited under the rules of court as long as confidential information is not input into a public system. If such information was provided to an artificial intelligence tool, sanctions and censure would not be within this court's jurisdiction but within the jurisdiction of the State Bar of San Andreas. This court recognizes the helpfulness of artificial intelligence tools provided that the attorney signing off on the document has proofread the document – this court will not permit retraction of documents if any errors of argument are later found to have been caused by the use of artificial intelligence. Signed, FLORENCE WEATHERS-PETERSON Judge Superior Court of San Andreas, County of Los Santos ENTERED: April 25th, 2025 08:00 PM

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS, <CRIMINAL/CIVIL/PROBATE> DIVISION Case No. 25-LSC-04117 In the Matter of Montblanc v. Los Santos Police Department _____________________________________________________________________________ MEMORANDUM Plaintiff's Motion for Summary Judgment is overruled. It is the position of this court that it is in the best interest of public justice to hear this matter in its entirety in order to ascertain facts. The public has a right to know through these proceedings whether the allegations are true. Motion to stay proceedings is granted; this court will stay proceedings until April 30th, 2025. Defense is ordered to produce all discovery before that time or file another motion to stay if necessary. Signed, FLORENCE WEATHERS-PETERSON Judge Superior Court of San Andreas, County of Los Santos ENTERED: April 25th, 2025 03:13 PM

** The clerk accepts the filing and assigns docket number 25-LSC-04118; Trent Caldwell, presiding.