Kotwica

Subject: RE: Request for In Camera Review To: Judge Stoessel From: [email protected] CC: [email protected] Your honor, for the purpose of appeal we object to determination that an in camera review is applicable. United States v. Zolin 491 U.S. 554 (1989), which deals with the question of whether in-camera reviews is appropriate. None of the information identified is attorney-client privileged or otherwise privileged in a manner that would make it non-discoverable in a civil proceeding. This tactic, and I use that word purposefully seeks to elongate the proceeding which increases the cost to the plaintiff. /s/ Juan Tzompaxtle.

Tzompaxtle v. Los Santos Police Department Case Number: 25-LSC-05121 Prepared by: Juan Tzompaxtle MOTION FOR DISMISSAL OF CRIMINAL CHARGES, VIOLATION OF THE RIGHT TO A SPEEDY TRIAL. _______________________________________________ The defendant in this case, the Los Santos Police Department who brought the aforementioned illegal charges against me failed to respond timely (and within the timeline established by this court). I request that the criminal charges be dealt with on their merits in the below-mentioned argument. However, for the purpose of appeal and further lawsuits, I also claim that my rights to a speedy trial have been violated by the same named defendants. The Plaintiff, pro hac vica requests this court to dismiss the aforementioned charges as they are facially unlawful. As counsel pled, the San Andreas Vehicle Code 502 ("driving without headlights") provides that a police agency "shall issue an infraction." It is unequivocally unlawful for a law enforcement agency to decide to charge "obstruction of justice" for a repeat offense of driving without headlights. The legislative branch of San Andreas identifies two circumstances where obstruction of justice can occur. (1) 610(a) a person who shows a clear and motivated attempt to prevent or delay a state employee from conducting their duties. Officer Bates was not prevented or delayed in conducting his duties. Officer Bates disengaged after the initial traffic stop, patrolled around the city, and only after 10-15 minutes reengaged with me north of Pershing Square. Officer Bates chose at that time to violate my constitutional rights by arresting me for a vehicle infraction. The fact that Officer Bates chose to pursue criminal charges, and even engage in a separate traffic stop is within his "officer discretion." Officer Bates initiated the traffic stop thereby invalidating any argument that he was prevented from conducting his duties. If the court decides otherwise, any person at any time could be arrested for a previous offense they committed however slight it is because at some point they were "put on notice." (2) 610(b) a person who fails to comply with a peace officer's lawful orders is also not applicable in this case for the reasons aforementioned in the complaint paragraphs 14-16. The legislator of this state never intended for 610(b) to be utilized to prevent infractions. Additionally, there is no history or tradition in the United States that any legislative body would permit the use of a criminal charge to effectuate compliance with traffic infractions. The last sentence in the argument against the applicability of 610(a) also applies here. The plaintiff encourages the court to examine the constitutionality of 610(b) on the grounds of adequate notice. This request for the dismissal of criminal charges is not intended to have an impact on the arguments of the constitutionality of driving without headlights as pled in the complaint or civil damages against the LSPD and Officer Bates and Knox. _______________________________________________ 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 13 day of May, 2025 by: /s/ JUAN TZOMPAXTLE Juan Tzompaxtle

** Proof of service updated via E-File ** (( ))

FILED - CASE STATUS UPDATE The Chambers of Judge Stoessel Antonin Scalia Courthouse Market, Los Santos, SA. CC: Ibrahem Davis, Esq. Los Santos Police Department NOTIFIED VIA E-MAIL. REF: Case No. 25-LSC-04116. Your honor, have requested the following clarifications from Mister Ibraheem Davis. (1) Exhibit B shows only an internal affairs report from the incident of this lawsuit. We requested "The full unredacted internal affairs records of the unknown Los Santos Police Department Police Officer." In Officers Boulevard's career has he only had one internal affairs report? If he has more you did not comply with our production request. (2) Exhibit C does not comply with the request for "Full unredacted training history of the unknown Los Santos Police Department Police Officer (including dates of recertification)." This is only a picture of a badge and unknown ribbons. (3) Exhibit F, when was this issued? A date is required with all of these requests. If you would please instruct your clerk to amend the proceeding title to Saucedo v. Officer Boulevard and the LSPD Staff Officers. In regards to the internal affairs request; I have consulted with my client and returned the LSPD internal affairs request for information with our objections noted above. /s/ Juan Tzompaxtle Juan Tzompaxtle.

Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD. Case Number: 25-LSC-04112 Prepared by: Juan Tzompaxtle MOTION FOR DEFAULT JUDGMENT AGAINST THE STAFF OFFICERS OF THE LSPD, IMPOUNDMENT OFPERSONNEL FILES, AND SANCTIONS The plaintiff is not in possession of any of the records mentioned by the defendant at the time of the original filing or at the time of this filing. We renew our request for a default judgment, impoundment, and sanctions. Even if they complied with the order (which they did not), they have unnecessarily delayed this trial, and continue to do so. /s/ Juan Tzompaxtle Juan Tzompaxtle

Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD. Case Number: 25-LSC-04112 Prepared by: Juan Tzompaxtle MOTION FOR DEFAULT JUDGMENT AGAINST THE STAFF OFFICERS OF THE LSPD, IMPOUNDMENT OF PERSONNEL FILES, AND SANCTIONS The Plaintiffs requests sanctions, impoundment of personnel and internal affairs files,, and a default judgment against the Los Santos Police Department Staff Officers. The defendants have failed to produce any of the information which they have been compelled to supply. The court is permitted to grant a default judgment under Federal Rules of Civil Procedure Rule 37, and Sardini Group, Inc. v. Imperial Pacific International (CNMI), LLC, 1:20-cv-00007 (D.N. Mar. I. Sept. 30, 2023). Additionally, the plaintiff requests that this court order, or pursue criminal charges against Mr Ibraheem Davis for contempt of court for his blatant disregard for this courts orders. Additionally, the plaintiff requests an impoundment order for all personnel files, internal affairs files, as well as the compelled information requested in this lawsuit, and for an increase in punitive damages to account for the time it will take the plaintiff to identify the police officer. The plaintiff requests this impoundment order of electronic files be executed by the Los Santos Sheriff’s Department on the Los Santos Police Department’s data servers, and on the work computer of Captain Miller, Commander of the Internal Affairs Group. The plaintiff requests then that either the court or the plaintiffs counsel inspect the electronically stored information to obtain the requested information. This order is appropriate based on this courts findings of the good cause for the requested information, and the plaintiff has exhausted all other remedies to obtain the requested information. /s/ Juan Tzompaxtle Juan Tzompaxtle

SEALED - CONFIDENTIAL CHAMBERS FILING The Chambers of Judge Stoessel Antonin Scalia Courthouse Market, Los Santos, SA. CC: Ibrahem Davis, Esq. Los Santos Police Department NOTIFIED VIA E-MAIL. REF: Case No. 25-LSC-04116. Your Honor, in reference to your May 1st order, the plaintiff has not yet received the discovery items. However, I did receive questions from the Los Santos Police Department Internal Affairs Group for my client. Those questions I am providing to you under seal to not compromise any information that the defendant may find privileged. In my personal opinion I do not believe any of the questions are privileged. However, I will leave that to your determination. My larger concern is the relevance of these questions and the tone of these questions. We have alleged that my client was battered by a uniformed police officer. I view these questions to be substantially unrelated to an administrative or legal determination by the internal affairs group. What my client was doing at East Los Santos, if my client was aware of a police operation, etc., and the other questions are irrelevant. My concern is that the defendant is using this request to somehow substitute or obtain information from my client to support their legal defense, which if that is the case, should be filed to this court and subjected to the rules of evidence. Additionally, the fact that the Los Santos Police Department is performing an internal affairs investigation suggests that they know who the unnamed officer in this lawsuit is, and which you ordered them to reveal. I would like to note my objection on the record to the following questions and notify the court of what I believe the actual purpose of this request. ** The following document is sealed in an inner enveloped and marked with "REQUESTED TO BE SEALED UNTIL A DETERMINATION OF THE COURT" ** /s/ Juan Tzompaxtle Juan Tzompaxtle Attorney for the Plaintiff SEALED - CONFIDENTIAL CHAMBERS FILING

Montblanc v. Shakhzadov, Los Santos Police Department, et al. Case Number: 25-LSC-04117 Prepared by: Juan Tzompaxtle RESPONSE TO DEFENDANT'S ANSWER AND SUMMARY JUDGMENT MOTION. The defense has responded with an array of statements that the plaintiff thoroughly denies. Among these are that (1) internal affair records are not discoverable; (2) plaintiff’s requests are overly broad and unduly burdensome; (2) personnel records and application files implicate privacy interests. The responds as follows: (1) Internal Affair Records Are Discoverable Opposing counsel is disingenuous in filing the argument that they believe internal affair records are not discoverable when they later claim that a Pitchess motion is required to obtain “confidential internal affairs records.” It is an established principle borrowing from the invocation of the Federal Rules of Civil Procedure, Rule 26(3)(B) that if the court orders the disclosure of documents and tangible things, the only items protected against disclosure are (i) mental impressions; (ii) conclusions; (iii) opinions; or (iv) legal theories of the party’s attorney or other representative concerning the litigation. Internal affairs reports are discoverable under Upjohn Co v. United States, 449 U.S. 383 (1981). The precedent that follows that case establishes that internal investigations are only privileged if the primary purpose is to obtain legal advice. See In re Kellogg Brown & Root Inc. 756 F.3d 754 (D.C. Cir. 2014). See also Harding v. Dana Transport, Inc. 914 F. Supp. 1084 (D.N.J. 1996). (2) Plaintiff’s Requests are Not Overly Broad or Burdensome. The plaintiff firmly establishes that they believe the request is unduly broad and burdensome. The main requirements for determining an unduly broad request is relevance and proportionality. (i) All SWAT deployments and newsworthy incidents from April 18 to present is not unduly broad or burdensome, the volume of the documents or information is not “enormous.” The denial of the plaintiff’s media card prohibits her from attending SWAT deployments and other incidents of significance and this request directly corresponds to the damages alleged. If the defense concedes that the plaintiff suffered damages on not reporting on incidents because of this denial, the plaintiff can and will strike this request. (ii) All media cards applications and determinations are not unduly broad or burdensome, this is information available to the department through applications. A determination of if a license was issued or not is not burdensome or overly broad. This request is relevant because it permits the plaintiff to determine what the pattern of approval or denials are, and what additional factors are accounted for. The plaintiff is asserting that the denial of her media card is retaliatory. The facts of this case will show that her application was denied even when the same information was provided on a previous application that was accepted. Only two items changed during that time (1) the plaintiffs employer; (2) the lawsuit filed against the LSPD. Denying the plaintiff on either of these grounds would be a Constitutional violation. (iii) All policies and procedures related to the Freedom of the Press. This request is self-evident, is not overly burdensome and is relevant to the case. The defense then asserts wrongly asserts the Ashcroft v. Iqbal standard. Ashcroft v. Iqbal requires a plausible cause of action, not an action with specificity. (3) Personnel Records and Application Files Implicate Privacy Interests: The defendant cites to 6254(c) of the Constitution. This would be a relevant standard if this case was not the subject of litigation. The purpose of the constitutional right is to safeguard privacy and confidentiality concerns. However, as an officer of the court I have alleged that the requested items are relevant to ongoing litigation. Courts have held that the need for discovery generally outweighs privacy concerns in civil litigation. Schiavone v. Town of Wappinger, 2015 U.S. Dist. LEXIS 109702 (S.D.N.Y. Aug. 19, 2015). The proper remedy (if one is appropriate at all) would be for the court to order a Rule 26(c) protective order. In the Defendant’s motion to dismiss, the defense emphasizes that Officer Shakhzadov’s termination (which has not yet been proven) by the Los Santos Police Department somehow alleviates them of all responsibilities related to his conduct while a police officer for the Los Santos Police Department, this theory is interwoven with the rejection of the Monell applicability. This motion to dismiss raises additional concerns for the plaintiff as to why the Los Santos Police Department did not seek to charge Officer Shakhzadov criminally if the opportunity for an internal affairs investigation was terminated upon his alleged departure. (4) Monell Standard is Appropriate: The Los Santos Police Department has been sued six times in the past two weeks where different officers have displayed the same unlawful, unconstitutional behaviors. The defense either does not know, or willfully withheld from the court that Monell is applicable for violations resulting from official policies OR CUSTOMS, and the toleration of a policy or custom that causes the violation. The Los Santos Police Department was served with multiple subpoenas, and court orders requiring them to provide their training records on an array of constitutional issues, they have refused and are still refusing to comply even with this cases subpoena request. If this court were to consider the Motion to Dismiss, the court would have to consider the discovery not provided as spoliated. If relevant evidence is destroyed or withheld, courts apply an adverse inference standard, that the destroyed or withheld evidence would impact the claims or defenses of the party who destroyed or withheld the evidence. See Zubulake v. UBS Warburg LLC, 220 F.R.D. 212 (S.D.N.Y. 2003); Silvestri v. Gen. Motors Corp., 271 F.3d 583 (4th Cir. 2001); Breast Cancer Fund v. U.S. Department of Health & Human Services, 264 F.R.D. 56 (D.D.C. 2010). The Los Santos Police Department by failing to provide this relevant information is self-defeating in their claim that there is no Monell liability. The plaintiff does not oppose a summary judgment motion on the grounds that the defendant’s unwillingness to share the discovered information would defeat all defenses and claims they have asserted. (5) Officer Shakhzadov's Alleged Termination Does Not Overcome Respondeat Superior. The defense spends the rest of their brief arguing that Respondeat Superior is not an established legal principle. This court knows that the mere termination of an employee does not alleviate the Department’s responsibility in the actions both generally but also under Monell, the Supreme Court has ruled in support of the plaintiff’s position in Owen v. City of Independence, 445 U.S. 622 (1980), where the City of Independence was held liable for constitutional violations even when the employee was not an employee of the city at the time of the violation. (6) The Denial of Media Cards: The fact that the defendant claims that their process is neutral, standardize, and applied consistently does not make it true. The defense is required to elaborate on that process, and the determination is made by the court. The defense cites to Nieves, which they contain supports their argument because “the denial off [sic] credentials, without more, is insufficient to establish a constitutional claim […]” the plaintiff has contended that this has unduly impacted the plaintiff’s livelihood as a reporter, and again the subpoena which the defense has failed to comply with would establish damages. The plaintiff is correct that you do not need a media card for reporting, recording, publishing, or speaking. However, the media card permits members of the public who meet some sort of arbitrary police standard the right to attend “high risk” events, as described in the media card application process. The defense is not incorrect that the LSPD is not the White House (albeit this is self-evidence). However, the defense is seemingly unaware of how precedent is applied in the legal system. The Sherill v. Knight case establishes that even the federal government while dealing with the national security have to apply a neutral, standardized, and consistently applied standard when choosing to deny a party the right to report. If any department or agency would be given deference by the courts, it would be the White House. The Court did not grant deference to the White House, rather the Court established the standard that the plaintiff is requesting the Los Santos Police Department to follow. If the White House is required to follow this requirement there is no excuse why the Los Santos Police Department should not. If the Los Santos Police Department is claiming that they are complying with the precedent they have an obligation to prove that compliance. Facially it appears the Los Santos Police Department denied the same application an individual submitted previously when only two factors changed, who they were employed by, and that they sued the Los Santos Police Department. (7) Conclusion: In conclusion, the defense is not opposed to a summary judgment motion if the court agrees that the refusal to provide the requested information amounts to a spoliation of evidence. That spoliation of evidence would thereby invalidate all defenses by the Los Santos Police Department and would return a judgment in favor of the plaintiff. Although the plaintiff does believe there is a genuine dispute of material fact and that the Los Santos Police Department is not entitled to a judgment as a matter of law. Respectfully submitted, /s/ Juan Tzompaxtle Juan Tzompaxtle Attorney for the Plaintiff

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION MICHELLE JEFFERSON, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT, AND OFFICER GREGORY HUNTINGTON Defendants. Case No. 25-LSC-04119 ───────────── RESPONSE BRIEF IN REPLY TO DEFENDANT’S ANSWER AND MOTION FOR SUMMARY JUDGMENT ───────────── Juan Tzompaxtle, State Bar No. 1483094 Los Santos, San Andreas 90071 Attorney for Defendant MICHELLE JEFFERSON TABLE OF CONTENTS I. PRIOR RESTRAINT UPON PLAINTIFF’S SPEECH............................................................................................................. II. NO ENTITLEMENT TO QUALIFIED IMMUNITY......................................................................................... III. MONELL LIABILITY AND SOVEREIGN IMMUNITY EXCEPTION............................................................................................... IV. ENTITLEMENT TO PUNITIVE DAMAGES....................................................................................................... V. RIGHT TO SUMMARY JUDGMENT....................................................................................................... VI. CONCLUSION.................................................................................................................. PRIOR RESTRAINT UPON PLAINTIFF’S SPEECH Defendant Los Santos Police Department implies numerous times that because no arrest was made there is no constitutional violation. However, the mere threat of an arrest is itself prior restraint upon a person’s freedom of speech, including when that speech is vulgar or offensive. Near v. Minnesota, 283 U.S. 697 (1931); Organization for a Better Austin v. Keefe, 402 U. S. 415, 402 U. S. 419 (1971); Cohen v. San Andreas, 403 U.S. 15 (1971); Baumgartner v. United States, 322 U. S. 665, 322 U. S. 673-674 (1944) ("[o]ne of the prerogatives of American citizenship is the right to criticize public men and measures - and that means not only informed and responsible criticism, but the freedom to speak foolishly and without moderation."). Officer Huntington’s speech inordinately chilled Plaintiff’s speech by placing her on notice that continuing her speech would cause her to become subject to arrest. He further implied a threat that continuing to record the traffic stop in progress may subject her to arrest, presumably for Obstruction of Justice. However, such an arrest would have been in flagrant violation of the order imparted in Mendoza v. Los Santos Police Department, 25-LSC-04111, decided less than one month ago in this court. Accordingly, a clearly-established right has been violated by the conduct of Officer Huntington who represents duly Defendant Los Santos Police Department. NO ENTITLEMENT TO QUALIFIED IMMUNITY Defendant Los Santos Police Department represents that under Harlow v. Fitzgerald, 457 U.S 800 (1982), there must be a violation of a clearly established constitutional right in order for this court to waive qualified immunity. However, this court must also evaluate such facts in a light that is most favorable to the plaintiff in this action. Saucier v. Katz, 533 U.S 194 (2001). In review of the facts, this court will find that the actions of Officer Huntington did in fact violate the clearly-established constitutional right to both record officers, including from a close distance that is not physically obstructive, and to speak freely, including where such speech is vulgar or offensive. Fordyce v. City of Seattle, 840 F. Supp. 784 (W.D. Wash. 1993); Cohen v. California, 403 U.S. 15 (1971); Baumgartner v. United States, 322 U. S. 665, 322 U. S. 673-674 (1944); Mendoza v. Los Santos Police Department, 25 S.A. 1d. 4111. Plaintiff’s actions were not physically obstructive to the actions of Officer Huntington because she did not directly get in the way of an action Huntington was attempting to perform. Her actions of recording the police did not physically prevent the officer from performing his duties, as evidenced by the fact that he completed the objective of the traffic stop at hand without any referenceable issue. As such, her activities are consistent with existing and widely-accepted precedent concerning the recording of police in public. See also Fordyce; Gilk v. Cunniffe, 655 F.3d 78, 84 (1st Cir. 2011). Speech tiself cannot be obstructive because each officer presumably has the physical and mental ability to ignore speech. Further, speech itself cannot subject one to arrest except where such speech crosses the line into "fighting words" such as threats to harm. Chaplinsky v. New Hampshire, 315 U.S. 568 (1942). Speech is a core tenant of American society and the public enjoys the right to speak freely in criticism of the government. New York Times Co. v. Sullivan, 376 U.S. 254 (1964). Subjective enforcement of laws based on the content of one's speech is specifically prohibited by existing precedent - such enforcement can only be in response to a legitimate time, manner, and place restrictions and not because such speech is deemed offensive. National Rifle Association of America v. Vullo, 602 U.S. ___ (2024); Hill v. Colorado, 530 U.S. 703 (2000). Officer Huntington violated clearly established law in both his prior restraint upon the Plaintiff's speech by threatening arrest for Plaintiff's vulgar speech and also by implying a threat of arrest for recording the traffic stop from a "close distance." MONELL LIABILITY AND SOVEREIGN IMMUNITY EXCEPTION Defendant Los Santos Police Department argues that Monell liability does not apply here because “no evidence of any LSPD policy or custom that condones the conduct alleged” and “[Officer Huntington’s] conduct was not ratified by any supervisor or Department policy”. However, Monell liability does not only bind in the case of policy or custom but the lack thereof as well. In the vacuum of policymaking and adequate training, employees are free to make their own decisions that may well be in flagrant violation of law or tangentially in violation of existing policies despite such policies not directly addressing the conduct. Defendant Los Santos Police Department is therefore required to have established policy, or at least adequate training, on matters as crucial as constitutional rights. Such policy-making need not be extensive documentation in a departmental manual, but potentially even as minimal as policy guidance documents or required reading for officers as a means of plausible deniability. Defendant has done none of this and therefore has not adequately trained their officers. Following the decision in Mendoza, Defendant should have taken concrete steps to inform officers of the decision and should have created documentation to guide their officers in abiding by the injunction therein. They did not. Resultantly, Defendant’s officers have violated the injunction here, and in other cases that are currently pending before this court, and therefore bear Monell liability. Defendant Los Santos Police Department is exempted from receiving sovereign immunity under Section 3(A) of the San Andreas Sovereign Immunity Act of 2018, which states: “state agencies aren't directly responsible for the actions of their employees when they have taken reasonable steps to ensure the employees actions were legal, such as proper and consistent training and policy which upholds rule of law and legal standards”. As previously discussed, Defendant has not taken reasonable steps to ensure their employees’ actions were legal because they have neither held proper, consistent training nor created policy upholding the rule of law as established in Mendoza, Fordyce, and Glik. ENTITLEMENT TO PUNITIVE DAMAGES Plaintiff is entitled to punitive damages under San Andreas Code of Civil Procedure § 3294 because there is ample evidence of malice. Malice, as defined in the preceding section, is “conduct which is intended by the defendant to cause injury to the plaintiff or despicable conduct which is carried on by the defendant with a willful and conscious disregard of the rights or safety of others”. Officer Huntington’s actions caused injury by means of a chilling effect upon her free speech rights, and his actions were carried out with willful disregard of a right that has been clearly established. Mendoza, supra. RIGHT TO SUMMARY JUDGMENT Plaintiff is entitled to summary judgment under Rule 3.1350 because there is no genuine dispute of material fact, only legal argument. Plaintiff moves therefor. Respectfully submitted, Juan Tzompaxtle Attorney for Plaintiff

Montblanc v. Shakhzadov, Los Santos Police Department, et al. Case Number: 25-LSC-04117 Prepared by: Juan Tzompaxtle MOTION TO COMPEL _______________________________________________ Comes now, the plaintiff, through his counsel requests this honorable court to compel the discovery of the below mentioned items that a subpoena duces tecum was issued by Juan Tzompaxtle in this court filings on April 20, 2025. The defendant's counsel has willfully not complied with the order and has thereby unnecessarily prolonged the pretrial period of this case. The plaintiff requests the court to order the plaintiff to release the following discovery items: - All information related to the denial of Laura Montblanc's Media Card; - All procedures, policies, and information related to the decision making process to grant or deny a Media Card; - All SWAT deployments, large scale incidents (defined as any incident where three or more officers responded), gang interactions, and other information that in the discretion of the Los Santos Police Department is "newsworthy," from April 18, 2025 to today's date; (AMENDED FROM SUBPOENA REQUEST TO ACCOUNT FOR DELAY) - All policies, procedures, and trainings offered by the Los Santos Police Department related to Freedom of Press; - All internal affairs records of the Los Santos Police Department employees related to the denial of Ms. Montblanc's Media Card; - A list of all Media Cards that have been requested of the Los Santos Police Department along with the determination; and - A list of the applicants of Media Cards and their employer at the time of requesting the Media Card. The plaintiff further requests that if the defendants counsel does not release the aforementioned items timely (at the discretion of the court) he be sanctioned and the court allow for additional punitive damages. _______________________________________________ Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein is truthful to the best of his knowledge. Sworn this 30 day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, Staff Officers of the LSPD Case Number: 25-LSC-04118 Prepared by: Juan Tzompaxtle MOTION TO COMPEL DISCOVERY, MOTION FOR A TEMPORARY INJUNCTION. _______________________________________________ Comes now, the plaintiff, through his counsel requests this honorable court to compel the discovery of the below mentioned items that a discovery request was issued by Juan Tzompaxtle on April 26, 2025. The defendant's counsel has willfully not complied with the order and has thereby unnecessarily prolonged the pretrial period of this case. Additionally, I received a call from the Los Santos Police Department's Internal Affairs Group who stated that they knew the name of the unknown officer but would not release it to me. This indicates that Mister Davis has willfully withheld information requested in a civil proceeding, has not communicated with me or the court about any privileges may assert, and thereby has caused additional injury and to the San Andreas Bar in it's entirety. An attorney owes a duty of professionalism and communication not only to his client but to opposing counsel. Here, Mister Davis has failed to do so in any of the cases before this court. Due to the uncooperative nature of the Los Santos Police Department, and their attorney, the plaintiff requests that the court order the release of the following information. (1) Identification of the unknown Los Santos Police Department Police Officer; (2) The full unredacted internal affairs records of the unknown Los Santos Police Department Police Officer; (3) The full unredacted training history of the unknown Los Santos Police Department Police Officer (including dates of recertification); (4) All training materials the Los Santos Police Department utilizes for use of force training or instruction; (5) A list (with redactions if appropriate) of how many use-of-force violations have been reported to the Los Santos Police Department since January 1, 2025 to the date of the return of this letter; (6) All policies or statements made by the Los Santos Police Department on how to handle, treat, or otherwise interact with members of the public filming police scenes; and (7) All policies or statements made by the Los Santos Police Department on how to handle, treat, or otherwise interact with members of the public standing outside of police tape observing a police scene. The plaintiff further requests that if the defendants counsel does not release the aforementioned items timely (at the discretion of the court) he be sanctioned and the court allow for additional punitive damages. Further, the plaintiff requests this court issue an injunction against the Los Santos Police Department Internal Affairs Group from closing the internal affairs investigation on the unknown officer. On a phone call on April 29, 2025. I was contacted by Detective Henriquez who informed me he wanted to speak to my client in order to complete the investigation. I informed Detective Henriquez that my client is unavailable. Detective Henriquez then stated that his Captain, a Captain Miller of the Internal Affairs Group ordered him to complete the investigation within 48 hours. I was then informed by Detective Henriquez that if my client did not contact the Los Santos Police Department Internal Affairs Group the investigation would conclude without his statement. It is fitting that the Los Santos Police Department has dragged their feet throughout his entire process but feels they have the power to impose unnecessary time restraints on the victim of a crime to fit their "internal timeline." The victim has a right to be heard, his rights were deprived once, and the Los Santos Police Department is seeking to deprive them again. The plaintiff formally requests an injunction on the closing of the internal affairs report until Mister Saucedo has received the questions, consulted with his counsel, and return the messages to the Los Santos Internal Affairs Group. Failing to do so will result in additional injury as the Los Santos Police Department as alleged will default to protecting their own as opposed to the public who they took an oath to protect. _______________________________________________ Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein is truthful to the best of his knowledge. Sworn this 30 day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle (( Attached with the filing: ))

Reddington v. Los Santos Police Department Officers Mercer, Ostragna, and Detective Monaghan, and the Los Santos Police Department Case Number: 25-LSC-04118 Prepared by: Juan Tzompaxtle MOTION TO COMPEL DISCOVERY _______________________________________________ Comes now, the plaintiff, through his counsel requests this honorable court to compel the discovery of the below mentioned items that a subpoena duces tecum was issued by Juan Tzompaxtle in this court filings on April 21, 2025. The defendant's counsel has willfully not complied with the order and has thereby unnecessarily prolonged the pretrial period of this case. The plaintiff requests the court to order the plaintiff to release the following discovery items: - The names of Officer Mercer, Ostragna, and Detective Monaghan; - The personnel files to include all internal affairs files on Officers Mercer, Ostragna, and Detective Monaghan; - All training files on Officers Mercer, Ostragna, and Detective Monaghan; - The unredacted internal affairs report, investigator interviews, and determinations related to internal affairs file "CF25-12642" filed on February 11, 2025; - All training materials taught, or published by the Los Santos Police Department related to probable cause warrants, extenuating circumstances, hot pursuit, and their limitations; and - All training materials taught, or published by the Los Santos Police Department related to the Fourth Amendment. The plaintiff further requests that if the defendants counsel does not release the aforementioned items timely (at the discretion of the court) he be sanctioned and the court allow for additional punitive damages. _______________________________________________ Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein is truthful to the best of his knowledge. Sworn this 30 day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

(( Proof of service filed with the Clerk of Court via e-file: ))

Jefferson v. Officer Gregory Huntington and the Los Santos Police Department Case Number: 25-LSC-04119 Prepared by: Juan Tzompaxtle CIVIL CASE BRIEF FOR PLAINTIFF _______________________________________________ Argument 1. On April 27, 2025, Plaintiff Ms. Michelle Jefferson (Ms. Jefferson), was videotaping members of the Los Santos Police Department within her rights granted by the Constitution, and by this courts ruling in Gloria Mendoza v. The Los Santos Police Department, et al., San.An.1d 25-LSC-04111 (2025). During Ms. Jeffersons protected activity, a uniformed officer of the Los Santos Police Department, later identified as Gregory Huntington, approached Ms. Jefferson as she was filming a police traffic stop. 2. Officer Huntington positioned himself behind Ms. Jefferson, who was of no threat to the Police Officers where he engaged in a short but threatening conversation with Ms. Jefferson where he threatened that he would "[...] arrest you (referring to Ms. Jefferson) on God." This threat is in clear violation of the First Amendment to the United States Constitution and the court's ruling in Mendoza. Further, Officer Huntington instructs Ms. Jefferson to "stop interacting with police." Uniquely, Officer Huntington engaged the interaction with Ms. Jefferson by approaching her during the traffic stop. The statement of "stop interacting with police" has a chilling effect, and also violates Ms. Jefferson's rights. 3. Although Ms. Jefferson was not arrested, an arrest is not required in order to establish a 42 U.S.C. § 1983 violation. See Hufford v. McEnaney, 249 F.3d 1142 (9th Cir. 2001), see also Stearns v. Clarkson Valley, 615 F.3d 898 (8th Cir. 2010); Barna v. Board of School Directors, 143 F.3d 807 (3d Cir. 1998); and Copeland v. Vance, 893 F.3d 101 (2d Cir. 2018). 6. The Defendants cannot establish a qualified immunity claim. The Ninth Circuit in Hufford v. McEnaney, 249 F.3d 1142 (9 Cir. 2001) held that qualified immunity is determined by whether “[a] constitutional right would have been violated were [the plaintiff’s] allegations established,” the next step in evaluating a claim to qualified immunity “is to ask whether the right was clearly established.” Saucier v. Katz, 533 U.S. 194, 201 (2001). “Whether an official protected by qualified immunity may be held personally liable for an allegedly unlawful official action generally turns on the ‘objective legal reasonableness’ of the action assessed in light of the legal rules that were ‘clearly established’ at the time it was taken.” Anderson v. Creighton, 483 U.S. 635, 639 (1987) (citing Harlow v. Fitzgerald, 457 U.S. 800, 818-19 (1982). Here, not only are Police Officers presumably instructed in the police academy about the First Amendment but the Los Santos Police Department was subject to an injunction which "[...] establishes that recording the police while standing in a public area or private area, on which a person has a right or privilege of presence, and which has not been established as a clearly restricted boundary. Clearly restricted boundaries shall constitute those areas of public or private property which are clearly marked as a crime scene or an emergency scene and shall be marked with police tape, emergency vehicles, clearly marked signage with writing in English, or peace officers preventing access to an area by means of blocking a sidewalk or other point of egress or entry to a particular area." Mendoza. 7. The plaintiff requests request for punitive damages is warranted as the Los Santos Police Department continues to violate the rights of citizens even after a court order explicitly prohibiting the conduct of Officer Huntington. 8. The continuous constitutional violations shows that the Los Santos Police Department is either ignorant to the law or indifferent to the law. This purposeful ignorance or indifference gives rise to a claim against the Los Santos Police Department under the theory of respondeat superior but also under the Monell v. Department of Social Services, 436 U.S. 658 (1978), standard that a government agency can be held liable if the department's failure to train their officers reflects a "deliberate indifference" to the constitutional rights of individuals. Exhibits 1. Video of the interaction between Ms. Jefferson and Officer Gregory Huntington Witness List 1. N/A _______________________________________________ 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 29 day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION Case Name: Jefferson v. Officer Gregory Huntington and the Los Santos Police Department Plaintiff Attorney: Michelle Jefferson CIVIL CASE COVER SHEET _______________________________________________ 1. Check one box below that best describes this case: Personal Torts [ ] Assault, battery, or unlawful contact [ ] False imprisonment [ ] Intentional infliction of emotional distress [X] Deprivation of rights under color of law Negligent Torts [ ] Breach of duty [ ] Negligent infliction of emotional distress [ ] Professional or Medical Negligence Property Torts [ ] Trespassing or Conversion [ ] Nuisance [ ] Theft [ ] Detainder Dignitary Torts [ ] Defamation (Slander or Libel) [ ] Invasion of privacy [ ] Breach of confidence [ ] Abuse of process [ ] Malicious prosecution [ ] Alienation of affections Business Torts [ ] Fraud [ ] Tortious interference [ ] Conspiracy [ ] Restraint of trade [ ] Passing off Contracts [ ] Breach of Contract [ ] Collections Judicial Review [ ] Denial or Revocation of Business License [ ] Denial or Revocation of Firearms License 2. List any damages sustained or fees accrued. Include billing rate for attorneys, expert witnesses, etc. $1,500,000.00 in punitive damages $100,000.00 in attorney fees _______________________________________________ Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein is truthful to the best of his knowledge. Sworn this 29 day of April, 2025 by: /S/ Juan Tzompaxtle, on behalf of Michelle Jefferson Michelle Jefferson Plaintiff /S/ JUAN TZOMPAXTLE Juan Tzompaxtle Attorney for Plaintiff