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People v. Anthony Abruzzo
Case Number: 23B-010
Prepared by: Deputy District Attorney I Jeremy Ruzek
CRIMINAL COMPLAINT
_______________________________________________
Plaintiff Argument
I. PARTIES TO THE CASE AND THEIR RELATIONS
1. The plaintiff in this case are The People of San Andreas (hereinafter as "The People"). The alleged crime committed by the Defendant endangers the public as a whole, therefore we believe that the Office of District Attorney (Hereinafter as "ODA") is not only entitled but also required to file this complaint.
2. ODA is, under Section III of Addendum II of the San Andreas State Constitution, authorised to charge for Crimes on behalf of The People.
3. Anthony Abruzzo (hereinafter as "The Defendant") is a Citizen of the great State of San Andreas and has been arrested for alleged crime of Assault with a deadly weapon.
II. FACTS OF THE CASE
4. On Monday, August 25 of 2023, at 09:41 PM in front of the establishment Pit Stop Bar located in the West Vinewood area, there was a conflict between one Natalia Badalamenti (hereinafter as "The Victim") and The Defendant. From the CCTV recordings (Seek Plaintiff Exhibit 1) there are no indication that such altercation has been initiated by The Victim. On the contrary, The People believe that the conflict was started by The Defendant.
5. During the conflict, The Defendant has grabbed The Victim's hood of a jacket she was wearing, to which The Victim has responded with turning around and slapping The Defendant. The People believe that this response was appropriate to the initial invasion of personal space.
6. After this slap, The Defendant is seen punching The Victim to her face, which The People see as significantly disproportionate to the slap.
7. Following this, The Victim has pushed The Defendant back in what can be only called as reaction to the initial hit and completely reasonable to the attack it was reacting to. The Defendant has repeated the hit, leading this to a fight.
8. After a few seconds of this fight, The Defendant is seen reaching for his Concealed Weapon and discharging the gun in the general direction of The Victim. The Victim fell after the shot.
9. After this, the nearby LSCSD's Deputies have responded to the scene and arrested The Defendant.
10. The Victim has been transported to the Mount Zonah Medical Center for immediate medical help.
III. LEGAL ANALYSIS AND CONCLUSION
11. Therefore The People believe, that the Defendant has committed an Assault with a deadly weapon, a FELONY pursuant to PC § 105, when he has attacked The Victim after grabbing The Victim's hoodie and following it with hits, which he has intensified with reaching for his weapon and discharging said weapon.
IV. ADDITIONAL INFORMATION
12. The People would like to emphasize that even if they wanted to call The Victim to the stand, currently she is deceased. Her death is, as the people believe, unrelated to this case directly, since The Victim has been released from hospital and has met Deputies in their professional capacity in unrelated situations that took place after this crime has occured.
Plaintiff Exhibits
1. Relevant MDC records of Mr. Abruzzo
(( https://imgur.com/zN73ALz ))
2. CCTV recordings from the scene
(( https://www.youtube.com/watch?v=hxU7JaFfHEQ, https://imgur.com/S34iWpR, https://i.gyazo.com/ca549b11bd81eb2f19f13cf7a6a4f1f4.mp4, https://i.gyazo.com/7cc000231a0fe5efa734a4cd61b69b1a.mp4 - All are meant to be one CCTV recording, I was given this all tho. ))
3. Hospital Record of Natalia Badalamenti after the attack
(( Since I do not know who the person is OOCly and I do not have information on any medical roleplay taking place, I do not know how to get it as of now. It would have been subpoenaed and attached to the complaint. ))
4. Arrest Record
(( https://imgur.com/kPVHnly ))
5. The Confiscated Weapon
(( As mentioned in the Arrest Record ))
6. Death Certificate of Natalia Badalamenti
(( She is CKed and it was said to me that it's Roleplayed as death. ))
Plaintiff Witness List
1. Deputy Sheriff Cooper Pierce
(( @Fiendfyre ))
2. Deputy Sheriff Frank Ventura
(( @almightybounter ))
3. Lieutenant Mark Bowen
(( @matt ))
_______________________________________________
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 1st day of September, 2023 by:
/s/ J. Ruzek
Jeremy Ruzek
Lead Prosecutor
/s/ Matthew Cromwell
Matthew Cromwell
2nd chair... Additional Attorney Signature
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People v. ANTHONY ABRUZZO
Case Number: 23B-010
Prepared by: Deputy District Attorney I Jeremy Ruzek
MOTION TO EXTEND TIME
_______________________________________________
The people move to extend time to file the Criminal Complaint.
The reasons for this are, among other things, Congestion of the Office of the District Attorney for the County of Los Santos and additional investigations taking place.
The people believe that even in light of Defendant's right to speedy trial, it is also crucial that the Justice is served in the process. As Justice Sonya Sotomayor has said, justice is served when a guilty man is convicted and an innocent man is not. Therefore the People believe that it is indeed necessary to ensure that any and all eventual evidence to come is collected before the trial starts, if it is not in conflict with the aforementioned Right to Speedy Trial.
The People do understand the inconvenience to both the Court and the Defendant with their Counsel, but the reasons behind this Motion to Extend Time are, as the People believe, reasonable.
The People therefore request additional 24 hours to file the Criminal Complaint
_______________________________________________
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 31st day of August, 2023 by:
/s/ J. Ruzek
Jeremy Ruzek
Lead Prosecutor
/s/ Matthew Cromwell
Matthew Cromwell
2nd chair... Additional Attorney Signature
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** Jeremy Ruzek would stand up and straighten his suit before adressing the judge. **
Your honour, there must have been a clerical error on our side, I will make sure that the paperwork is correct when we file the Complaint.
* Jeremy Ruzek sits down while sipping from a paper cup before him. **
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SUPERIOR COURT OF SAN ANDREAS
COUNTY OF LOS SANTOS
CRIMINAL DIVISION
Case Name: People of the State of San Andreas v. Anthony Abruzzo
Lead Prosecuting Attorney: Jeremy Ruzek
CRIMINAL CASE COVER SHEET
_______________________________________________
The People of the State of San Andreas charge the defendant, ANTHONY ABRUZZO, with the following offenses:
1. Assault with a deadly weapon, a FELONY, pursuant to PC § 105
Is the Defendant currently in custody?
[ ] YES
[X] NO
Does the prosecuting attorney have reason to believe the Defendant poses a risk of flight or interference with these proceedings if granted bail?
[ ] YES
[X] NO
_______________________________________________
Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein and in the attached Complaint is truthful to the best of his knowledge.
Sworn this 30th day of August, 2023 by:
J. Ruzek
Jeremy Ruzek
Lead Prosecutor
Matthew Cromwell
Matthew Cromwell
2nd chair... Additional Attorney Signatures
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** After Jeremy Ruzek is given a copy by a Bailiff, he would read it over and after that he would stand up and say the following. **
Your honour, I will stand by what I've said before. I'm sorry for the delay.
** Jeremy Ruzek would sit down and wait for what comes next. **
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** Jeremy Ruzek would stand up after Jerry Roux's argument. He would wear a three-piece-suit in the Navy Blue colour. **
Your honour, there must have been come clerical error because I did not get a copy of this motion beforehand. May I have a copy and a few seconds to go over it?
But before I waste any more of the valuable judicial time, in preparation to this case we have made a little analysis of our own and I believe that the Defenses' arguments will not vary much.
Even though the wording of the statute may seem vague, the People don't believe that the words are so vague that an average citizen would not understand clearly what the law implies. The statute states that any state employee, which the Defendant clearly is, as we believe has been proven beforehand, who drives under any influence of drugs or alcohol is committing a crime. It's as simple as that. If you want to not commit a crime as a state employee, don't drink and drive.As per the discrimination, we believe that even though it might look like discrimination, it really isn't. There are many examples of law and even sections of the Penal Code which set special rules on special classes of people. And by class I don't mean a social group or some sort of property census, but Peace Officers and State Employees, as is the case in this instance. The People do not believe that the beforementioned categories fall under the Protected Classes that are protected by the 14th Amendment, therefore we disagree with this argument in it's entirety. If my memory serves correctly, the Supreme Court has never ruled that this kind of statutes would be unconstitutional. The State Employee, as well as Peace Officers, have taken a state office, or some sort of power arising from it, and therefore they should be held to a higher standard, as I argued in the initial Criminal Complaint.
Therefore we believe that the motion is baseless and the People compel the state to overrule this motion and continue with the case as it is.
I'd also like to reserve a right to address the motion after I have the time to analyse it.
Thank you, your honour.
** Jeremy Ruzek would sit down while looking over the documents on his desk. He'd be patiently awaiting Bailiff to bring copy of the motion to him. **
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Case Number: 23B-009
Prepared by: Deputy District Attorney I Jeremy Ruzek
CRIMINAL COMPLAINT
_______________________________________________
Plaintiff Argument
1. The plaintiff in this case are the People of San Andreas. The alleged crime committed by the Defendant endangers the public as a whole, therefore we believe that the Office of District Attorney (Hereinafter as "ODA") is not only entitled but also required to file this complaint.
2. ODA is, under Section III of Addendum II of the San Andreas State Constitution, authorised to charge for Crimes on behalf of The People.
3. Mr. Paul Jenkins (Hereinafter as "The Defendant") is a State Employee as defined in PC 013 since he is employed as Traffic Sergeant with LSDOT and he was driving a state's vehicle. (Seek Plaintiff Exhibits 1, 2 and 3)
4. The Defendant has been arrested after a traffic stop that has been initiated by Deputy Sheriff Cooper Pierce #40358 after he saw the vehicle driven by the Defendant has failed to stop before multiple STOP signs in the city which endangered many people on the street. After the traffic stop was initiated, the Defendant showed signs of alcohol intoxication that has been later proven by Blood sample test performed in Mount Zonah Medical Center (Hereinafter as "MZMC"). (Seek Plaintiff Exhibits 4, 5 and 6)
5. The follow up Breathalyzer test has shown that The Defendant had 0.076 % BAC. This difference between the result of the Breathalyzer test and the MZMC Blood test can be explained by the accuracy of the breathalyzer, which can be inaccurate up to 15 %, and by the time period that has taken place between the blood and breathalyzer test.
6. As per the legal qualification, PC 703 (b) states that a state employee who drives under (any) influence of (...) alcohol is guilty of a felony (...). It does not state that the limit should be the same as for PC 703 (a) (meaning 0.08 %) and using argumentum a rubrica with PC 703 (c) which sets its own limit for commercial vehicle operators, we have to insist that the legislative body of this great state has decided that State Employees are subject to stricter rules than those not employed by the state.7. The People believe that they are able to prove all of the above mentioned using the evidence and witness testimonies beyond any reasonable doubt, therefore the ODA has decided to press charges.
Plaintiff Exhibits
1. MDC record of Paul Jenkins
(( https://imgur.com/Es72V9L ))2. Employment Record of Paul Jenkins
(( https://imgur.com/QKnObsb ))
3. MDC record of vehicle, license plate 0WEL710
(( https://imgur.com/wEEt8Lb ))4. Los Santos County Sheriff's Department Major Crimes Bureau Crime Report filed by Deputy Sheriff Cooper Pierce #40358
(( https://imgur.com/a/cTUNKdb ))
5. Dashboard footage from unit David 4 Boy 2
(( https://youtu.be/VqiwLRw8FTQ ))
6. Hospital records from Mount Zonah Medical Center
(( * Hospital tests would show Paul's blood being above the legal limit for alcohol ))
Plaintiff Witness List
1. Deputy Sheriff Cooper Pierce #40358
(( https://community.ls-rp.com/profile/306-fiendfyre/ ))
2. Deputy Sheriff Samuel Mejia
(( https://community.ls-rp.com/profile/172-kendrick/ ))
3. Sergeant Jason Siurek(( https://community.ls-rp.com/profile/5-dadoj/ ))
_______________________________________________
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 21st day of August, 2023 by:
/s/ J. Ruzek
Jeremy Ruzek
Lead Prosecutor
/s/ Matthew Cromwell
Matthew Cromwell
2nd chair... Additional Attorney Signature
-
SUPERIOR COURT OF SAN ANDREAS
COUNTY OF LOS SANTOS
CRIMINAL DIVISION
Case Name: People of the State of San Andreas v. Paul Jenkins
Lead Prosecuting Attorney: Jeremy Ruzek
CRIMINAL CASE COVER SHEET
_______________________________________________
The People of the State of San Andreas charge the defendant, PAUL JENKINS, with the following offenses:
1. Driving Under the Influence, a FELONY, pursuant to PC 703 (b)
Is the Defendant currently in custody?
[ ] YES
[X] NO
Does the prosecuting attorney have reason to believe the Defendant poses a risk of flight or interference with these proceedings if granted bail?
[ ] YES
[X] NO
_______________________________________________
Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein and in the attached Complaint is truthful to the best of his knowledge.
Sworn this 20th day of August, 2023 by:
J. Ruzek
Jeremy Ruzek
Lead Prosecutor
Matthew Cromwell
Matthew Cromwell
2nd chair... Additional Attorney Signatures
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Trinitrotoluene
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Did you know, that the character on Discord's 404 page is a robot hamster named Nelly?
What colour is the battle flag of France?
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And let me ask with another song title...
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On 4/13/2022 at 3:34 PM, Venta said:
Doesn't require much OOC regulations in my opinion. They just need to balance out how much cash "appears" and "disappears", as a closed-circuit economy is not possible.
By OOC regulation I mean that more then 1 crew has access to the weapons/drugs/whatever scheme, so they don't have the monopoly this way. If more crews are gonna sell 'to the public,' they'll try to compete on the market and .... You've got the image, I suppose... But I believe that's not gonna be a problem really.
What might be a trouble is if all the crews with access to one of those rackets form some sort of alliance, and sell way over reasonable price, and that's when I'd feel like having some OOC intervention might be in place. Or maybe it's clear IC stuff? I dunno really how to eventually act up on that... I just know that on some smaller communities this sometimes was a problem...
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Set some anti-monopoly policies & regulations, both ICly for legel stuff and OOCly for illegal ones, and the prices will establish themselves.
Setting them in stone, as someone mentioned before, is pretty bad idea. Demand/Supply is a better trend setter then ppl consciously.-
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<insert answer>
How do I cure flu? -
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Just install 'em.
How do I know if I have eyes?
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You don't.
Where do I find Fantastic Beasts online?
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I think yellow.
How does one change a lightbulb?
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So astronauts can be confused after returning from the outer space.
https://youtu.be/PVxaL8CAO4M
What is the answer to the Ultimate Question of Life, the Universe, and Everything? -
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People of the State of San Andreas v. Anthony Abruzzo
in Archive
Posted
SUPERIOR COURT OF SAN ANDREAS
COUNTY OF LOS SANTOS
CRIMINAL DIVISION
Case Name: People of the State of San Andreas v. Anthony Abruzzo
Lead Prosecuting Attorney: Jeremy Ruzek
CRIMINAL CASE COVER SHEET
_______________________________________________
The People of the State of San Andreas charge the defendant, ANTHONY ABRUZZO, with the following offenses:
1. Aggravated Battery, a FELONY, pursuant to PC § 110 (b)
Is the Defendant currently in custody?
[ ] YES
[X] NO
Does the prosecuting attorney have reason to believe the Defendant poses a risk of flight or interference with these proceedings if granted bail?
[ ] YES
[X] NO
_______________________________________________
Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein and in the attached Complaint is truthful to the best of his knowledge.
Sworn this 2nd day of September, 2023 by:
J. Ruzek
Jeremy Ruzek
Lead Prosecutor
Matthew Cromwell
Matthew Cromwell
2nd chair
... Additional Attorney Signatures