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Everything posted by Iudex
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(Juliette Naviaux presents the document.) Your honor, not sure what wool they are speaking of. This is the agreement they signed and it was in effect since 2023. It's on the City Government's portal. Your honor, it is one thing to display the strike system's functions, but it is another to showcase what the revocation reasons can be. We wholeheartedly assert we are correct and have even displayed evidence that supports it may be revoked. A strike system does not necessarily constitute what the revocation system is. We have shown what the revocation system is through the agreement the Petitioners signed and the statement from the Licensing Division. @joxii@Levy
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Your honor, we have not received a response from the City Government despite our attempt to reach out. We assert that we are not responsible for the collection of law, but rather this responsibility falls upon the Petitioner as the burden of proof falls upon them. We wholeheartedly assert that the Department member had the right to revoke the license pursuant the policies enshrined currently and anything to argue against it falls against the Petitioner to achieve. Therefore, we urge the Court to levy the burden of proof upon the Petitioner, in this matter and we reinforce our motion to dismiss on the basis of the Petitioner failing to show any malice in the revocation of the PF thus far. We must remember who the burden falls upon in civil cases. However, will additionally enter into evidence the statement that everyone signs prior to obtaining a PF. This has certain parts highlighted. SECTION 3 - PF License Conditions and Restrictions The licensee is responsible for all liability for, injury to, or death of any person, or damage to any property which may result through any act or omission of either the licensee or the agency that issued the license. In the event, any claim, suit, or action is brought against the agency that issued the license, its chief officer, or any of its employees, by reason of, or in connection with any such act or omission, the licensee shall defend, indemnify, and hold harmless the agency that issued the license, its chief officer or any of its employees from such claim, suit, or action. The licensee authorizes the issuing agency to investigate, as they deem necessary, the licensee's record and character to ascertain any and all information which may concern his/her qualifications and justification to be issued a license to purchase a firearm and release said agency of any and all liability arising out of such investigation. Violate any of the license usage or prohibition criteria guidelines Consume any alcoholic beverage. Be in a place having the primary purpose of dispensing alcoholic beverages for on-site consumption. Be under the influence of any medication or drug, whether prescribed or not. Carry a firearm in public without a proper permit (CCW). Pursuant to U.S. Government Code — Title 49, Chapter 26, Section 1472(1) and Federal Aviation Regulation 121.583, a license to purchase a firearm does not authorize a person to carry a firearm or any dangerous weapon aboard commercial airlines. Such a violation can result in arrest by law enforcement. Any violation of these restrictions or conditions may invalidate the PF license and may void any further use of the license until reinstated by the licensing authority. Any arrest for a felony or serious misdemeanor, including driving under the influence of alcohol and/or drugs, is cause for invalidating the license. SECTION 4 - Agreement to Restrictions and to Hold Harmless I hereby accept and assume all responsibility and liability for, injury to, or death of any person, or damage to any property which may result through any act or omission of either the licensee or the agency that issued the license. In the event any claim, suit, or action is brought against the agency that issued the license, its chief officer or any of its employees, by reason of, or in connection with any such act or omission, the licensee shall defend, indemnify, and hold harmless the agency that issued the license, its chief officer or any of its employees from such claim, suit, or action. I understand that the acceptance of my application by the licensing authority does not guarantee the issuance of a license and that fees and costs are not refundable if denied. I further understand that if my application is approved and I am issued a license to purchase a firearm, that the license is subject to restrictions placed upon it and that misuse of the license will cause an automatic revocation and possible arrest and that the license may also be suspended or revoked at the discretion of the licensing authority at any time. I am aware that any use of a firearm may bring criminal action or civil liability against me. I have read, understand, and agree to the PF license liability clauses, conditions, and restrictions stated in this Application and Agreement to Restrictions and to Hold Harmless. @Levy@joxii
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Your honor, regardless of a point or strike system, the Petitioner admitted fault. We're just going in circles here. The stenographer transcribed the following: "Firstly, the defendants retrieved their weapons from safe storage within their vehicle. [...]" The PF Regulations state: Furthermore, the criteria for revocation is: Also, again, the American Rule prohibits collection of attorney fees. We reiterate our motion to dismiss. @joxii@Levy, Bell & Weinstein
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Your honor, We are currently working on obtaining these documents to showcase. However, the letter presented does not absolve the party of their guilt in the matter. We will present the evidence below: Exhibit A: Complaint submitted by Petitioners. We need to look no further than what is stated in the complaint: "[...] It is important to add that SO's Horvat and Buck were PF only license owners and openly-carried their firearms inside the holsters on their duty belts." Your honor, even in the complaint the Petitioners showcase and admit their fault in the very issue they wish to claim relief from, thus we reinforce our motion to dismiss. @joxii@Suffering
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Infamous Pension Pincher Big Dukes
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They took Marvin Low's gun
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@joxii@Levy, Bell & Weinstein MOTION TO DISMISS Respondent: Los Santos County Sheriff's Department. Comes now the Respondent to respectfully request dismissal of the above-captioned matter. In support of this request, the Respondent asserts as follows: INTRODUCTION The Los Santos County Sheriff's Department through its Department personnel has revoked the Petitioner's Purchase a Firearm License (PF). During an incident on June 2nd 2024, Mr. Buck Sloan & Eustace Horvat were found to have been at an incident at Market Street outside the Mall. Deputy Sheriff Bradley Murphy & Deputy Sheriff Nicholas Edson occupying Department vehicle 240 William 1 were in the immediate area of patrol by the Mall and responded to a 911 call detailing that a person was shot by two guys in suits, r.e. the Petitioners. Upon their arrival, they saw the Petitioners stood next to a body who had been shot. The Deputies detained the Petitioners above discovering they were open carrying handguns. They further founded out during their investigation that Mr. Eustace Horvat had discharged his firearm at the person who was on the ground. This was pursuant an investigation documented on the arrest report. Eustace was found to have shot the civilian while open carrying his firearm. LICENSE REVOCATION On the matter of License Revocation, we must look no further than the definition of (9)13. CCW / PF Violation; Both individuals were in violation of the following clause under the aforementioned law, A person who carries concealed a legal, registered firearm that is not authorized as a conceal-carry weapon. Therefore, the reason to revoke the license was unequivocally correct and pursuant the charge's definition and stipulations, it allows for the revocation of a license under the following pretenses as defined: - Penal Code (9)13 is a misdemeanor punishable [...] as well as weapon license revocation upon Officer Discretion. This entire charge also falls under Officer Discretion. Wherefore, for the aforementioned we deny the Petitioners ability to claim relief on the basis of restoration for a PF license when it was founded that they violated the the stipulations of the license. Furthermore, the Open Carry act was not enacted until June 10th, 2024, yet the incident took place June 2nd, 2024. ATTORNEY FEES & LOST WAGES The Respondent wholeheartedly refutes the Petitioners' ability to claim attorney fees on the basis of the default American Rule being in effect in the State of San Andreas. Pursuant the American Rule, in the event there is no default for the collection of Attorney Fees, no party may claim restitution or assert any sort of claim r.e. Attorney Fees in a civil suit. Each party is responsible for its own fees of litigation. There is no statue or contract between the Respondent and Petitioners that would obligate the Respondent to pay attorney fees. Therefore, the Respondent refutes the ability to claim such relief. On the matter of lost wages, the Respondent asserts that the Petitioners' claim is inherently flawed due to the fact that lost wages cannot be claimed when a detainment or lawful arrest had taken place. Wherefore, we refute the ability to claim relief pursuant the aforementioned section. CONCLUSION The Respondent seeks to have the matter dismissed immediately with prejudice based on the aforementioned factors. Respectfully submitted, ___________________________ Juliette Naviaux State Bar #299
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Need more info about the Market incident
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this goes hard