Kotwica

Montblanc v. The Los Santos Police Department Case Number: 25-LSC-04117 Prepared by: Juan Tzompaxtle SUBPOENA DUCES TECUM _______________________________________________ - 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 April 20, 2025; - 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. _______________________________________________ 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 20 day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

Montblanc v. The Los Santos Police Department Case Number: 25-LSC-04117 Prepared by: Juan Tzompaxtle CIVIL CASE BRIEF FOR PLAINTIFF _______________________________________________ Argument 1. Comes now, Laura Montblanc (Ms. Montblanc) through legal counsel brings forth this lawsuit before this court. This court has proper jurisdiction under the San Andreas Code of Civil Procedure (S.A.C.C.P) 410.10 (2024), due to the denial of a media pass by the Los Santos Police Department. 2. The United States Supreme Court in City of Los Santos v. Lyons 461 U.S. 95 (1983), provides grounds for a court to grant a civil claim for constitutional violations committed by a law enforcement officer under 42 U.S.C. § 1983. 3. Ms. Montblanc filed a Media Identification Card Application on April 18, 2025. The application identified all required information. Ms. Montblanc identified that she was an influencer and self-employed, serving as an editor-in-chief and explained her justification which includes “exclusive access.” The type of exclusive access identified by Ms. Montblanc is the types of exclusive access which LSPD grants the Media Card for. 4. On the day Ms. Montblanc filed a lawsuit against the Los Santos Police Department her Media Card application was denied, two days after it was filed, without an explanation. 5. Ms. Montblanc is a journalist, and Freedom of the Press is a right granted by the U.S. Constitution. The Los Santos Police Department denied the access of Ms. Montblanc without substantive due process, and it is the contention of the plaintiff the reason for the denial is because of the lawsuit filed against the LSPD. 6. The Los Santos Police Department by depriving Ms. Montblanc of her media pass in the manner provided is in violation of Sherill v. Knight, a case decided by the U.S. Court of Appeals for the District of Columbia Circuit, where the United States Secret Service denied a journalist a media pass to the White House. The opinion outlined that the journalist was entitled to notice, an opportunity to rebut, and a written decision. 7. The Los Santos Police Department issued a written decision. However, the written decision also violates Sherill v. Knight. The D.C. Circuit requires that “[…] the protection afforded newsgathering under the First Amendment guarantee of freedom of the press requires that this access not be denied arbitrarily or for less than compelling reasons.” Sherill v. Knight, 569 F.2d 124 (1977). 8. The Los Santos Police Department’s denial is unconstitutional as it fails to provide a notice and for an opportunity to rebut. Rather, the Los Santos Police Department has chosen to serve as both the judge, jury, and executioner. 9. By denying Ms. Montblanc the access to film news stories on unconstitutional grounds, the Los Santos Police Department has satisfied the plausibility requirement for damages required by Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), Ashcroft v. Iqbal, 556 U.S. 662 (2009). 10. The Los Santos Police Department is not entitled for grievances to be brought to their attention if they are unlawful. The proper median to prevent unlawful conduct and to recover damages is the judiciary. Exhibits 1. Application (( https://imgur.com/K2NPGYK )) 2. Denial (( https://imgur.com/qLtdLtH )) ... _______________________________________________ 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 20 day of April 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION Case Name: Montblanc v. Shakhzadov, Los Santos Police Department, et al. Plaintiff Attorney: Juan Tzompaxtle 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 [ ] 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 [X] 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. $100,000 in attorney fees. An injunction against the Los Santos Police Department from denying media licenses without a compelling government interest, narrowly tailored to achieve those ends; Issuance of a media card to Laura Montblanc; $2,500,000.00 in compensatory damages; $2,000,000.00 in punitive damages; and $1,500,000.00 in nominal 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 20 day of April, 2025 by: /S/ Laura Montblanc Laura Montblanc Plaintiff /S/ Juan Tzompaxtle Juan Tzompaxtle Attorney for Plaintiff

Montblanc v. Los Santos Police Department Police Officer Shakhzadov (61658), and the Los Santos Police Department Case Number: 25-LSC-04113 Prepared by: Juan Tzompaxtle SUBPOENA DUCES TECUM _______________________________________________ Comes now, Ms. Montblanc, through her attorney requests this Court to order the the production of the following items: - The entire Internal Affairs File of Officer Shakhzadov, including any current or previous investigations; - The entire training file of Officer Shakhzadov; - All training material related to the First Amendment produced or taught by the Los Santos Police Department; and - A summary of all Internal Affairs Complaints within the last year related to constitutional violations with a summary of how they were concluded. _______________________________________________ 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 19 day of April, 2025 by: /s/ JUAN TZOMPAXTLE Juan Tzompaxtle

Montblanc v. Los Santos Police Department Police Officer Shakhzadov (61658), and the Los Santos Police Department Case Number: 25-LSC-04113 Prepared by: Juan Tzompaxtle RESPONSE TO DEFENDANT'S RESPONSE _______________________________________________ Counter arguments: 1. The Los Santos Police Department misunderstands the statement provided in paragraph 6 of why Ex Parte Young is referenced. Ex Parte Young is mentioned solely to overcome a jurisdictional barrier if the Los Santos Police Department if they claim they are are immune to this suit under sovereign immunity. The Los Santos Police Department's "reservation of rights" is not a pleading which is required under Henderson v. United States, 517 U.S. 654, (1996). Additionally, the Los Santos Police Department remains silent on the applicability of City of Los Santos v. Lyons 461 U.S. 95 (1983) to overcome this same judicial barrier. Both of those cases on their own. Either one overcomes the sovereign immunity defense, however, the immunity request should be construed as waived because it was "reserved" and not "plead." 2. The Los Santos Police Department is not entitled to a more definitive statement. Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), Ashcroft v. Iqbal, 556 U.S. 662 (2009) requires the pass the bar of "plausibility." The plaintiff has submitted clear and convincing evidence that Ms. Montblanc's rights were deprived when a Police Officer violated her constitutional rights. Violation of constitutional rights is sufficient to satisfy a claim against the government, no additional damages are required. See Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971). 3. The Los Santos Police Department did not deny any claims in their response, therefore under Federal Rules of Civil Procedure Rule 36, and San Andreas Rules of Civil Procedure 2034, they have admitted to all of the claims aforementioned. 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 19 day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle (( OOC Note: The posts that are referenced here have been deleted by the original poster. ))

(( Proof of service is filed via e-file: ))

(( Proof of service is submitted via e-file system: ))

Montblanc v. Los Santos Police Department Police Officer Shakhzadov (61658), and the Los Santos Police Department Case Number: 25-LSC-04113 Prepared by: Juan Tzompaxtle CIVIL CASE BRIEF FOR PLAINTIFF _______________________________________________ Argument 1. Comes now, Laura Montblanc (Ms. Montblanc) through legal counsel brings forth this lawsuit before this court. This court has proper jurisdiction under the San Andreas Code of Civil Procedure (S.A.C.C.P) 410.10 (2024), as the Los Santos Police Department, and the named parties are employed by the Los Santos Police Department, the events occurred within the boundaries of the jurisdiction of this court in Market. 2. On April 18, 2025, Officer Shakhzadov (identified in the audio recording) of the Los Santos Police Department aimed a firearm at Ms. Montblanc, a citizen videotaping outside of any demarcation line by the Los Santos Police Department, peacefully, in the Market area of Los Santos. Her peaceful videotaping was abruptly cut short when Officer Shakhzadov wielded a weapon, aimed it at her and a group of peaceful observers, demanding that they leave the scene. 3. When the citizens continued to exercise their rights, Officer Shakhzadov used a police issued taser device to stun Mrs. Montblanc to prevent her recording. 4. The scene was not visible within the video, seemingly contained to the inside of a building of which the observers were not attempting to enter. 5. Officer Shakhzadov's actions are in violation of the injunction of this court under Glorida Mendoza v. The Los Santos Police Department, The Los Santos Sheriff’s Department, The San Andreas Department of Corrections, and any other law enforcement agency within the State of San Andreas, 25-LSC-0411 (2025). 6. The tasing of Mrs. Montblanc is in violation of Ex parte Young, 209 U.S. 123 (1908), where the Supreme Court held that the Government, including state agencies, are not protected by sovereign immunity when a state official enforces an unconstitutional law or acts in an unconstitutional manner. 7. The United States Supreme Court in City of Los Santos v. Lyons 461 U.S. 95 (1983), provides grounds for a court to grant a civil claim for constitutional violations committed by a law enforcement officer under 42 U.S.C. § 1983. 8. The Los Santos Police Department has failed to correct significant training defects, including properly training their officers on the protections awarded under the First Amendment of the United States Constitution. The United States Supreme Court held in Monell v. Department of Social Services, 436 U.S. 658 (1978), that municipality under the Civil Rights Act § 1983 (codified at 42 U.S.C. § 1983) can be held liable if their failure to train their officers reflects a "deliberate indifference" to the constitutional rights of individuals. 9. The Plaintiff prays that this court put an end to the incompetence and failures of the Los Santos Police Department to put the citizens of this city first, including cooperation with lawful requests. To award the monetary value associated with the damages of the plaintiff, and to award whatever other remedies this court deems appropriate. Exhibits 1. Video tape of the Market incident. (( )) _______________________________________________ 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 19 day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION Case Name: Montblanc v. Los Santos Police Department Police Officer Shakhzadov (61658), and the Los Santos Police Department Plaintiff Attorney: Juan Tzompaxtle CIVIL CASE COVER SHEET _______________________________________________ 1. Check one box below that best describes this case: Personal Torts [X] 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. $100,000.00 for attorney fees; $1,50,000.00 from the Los Santos Police Department; $3,550,000.00 from the Officer Shakhzadov; and Whatever other relief this court deems appropriate. _______________________________________________ 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 19 day of April, 2025 by: /S/ Laura Montblanc Laura Montblanc Plaintiff /S/ Juan Tzompaxtle Juan Tzompaxtle Attorney for Plaintiff

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 CIVIL CASE BRIEF FOR PLAINTIFF _______________________________________________ Argument 1. Comes now, Alan Saucedo through legal counsel brings forth this lawsuit before this court. This court has proper jurisdiction under the San Andreas Code of Civil Procedure (S.A.C.C.P) 410.10 (2024), as the Los Santos Police Department, and the named parties are employed by the Los Santos Police Department, the events occurred within the boundaries of the jurisdiction of this court in East Los Santos. 2. On January 16, 2025, an unidentified police officer from the Los Santos Police Department struck Alan Saucedo multiple times with a shotgun at the East Los Santos S-Curve. The striking occurred when Mister Saucedo was a distance from police tape, a conservative estimate is thirty feet from the police tape. The striking is unprovoked, Mister Saucedo did not impede on any investigation during the time he was struck, there was no lawful orders when John Doe struck him multiple times. 3. The striking of Mister Saucedo falls squarely into Ex parte Young, 209 U.S. 123 (1908), where the Supreme Court held that the Government, including state agencies, are not protected by sovereign immunity when a state official enforces an unconstitutional law or acts in an unconstitutional manner. 4. The United States Supreme Court in City of Los Santos v. Lyons 461 U.S. 95 (1983), provides grounds for a court to grant a civil claim for constitutional violations committed by a law enforcement officer under 42 U.S.C. § 1983. 5. The Los Santos Police Department’s Staff Officers, namely Chief of Police Timothy Kempton, Assistant Chief of Police Lance Stanton, Deputy Chiefs Edward Morris, Andrew Antonelli, and Jayden Gibson (herein Staff Officers), were notified via their public website, specifically addressed to them, for assistance in identifying this unknown police officer on January 14, 2025 at 18:06. 6. The Los Santos Police Department’s Staff Officers, chose not to identify the unknown police officer thereby assisting in the police misconduct. The United States District Court for the Northern District of San Andreas in Allen v. City of Oakland, No. C00-4599 THE, 2006 WL 1148813 (N.D. San. Apr. 28, 2006), that when law enforcement agencies contribute by inaction, they are liable in part for the actions committed. The Los Santos Police Department’s Staff Officers by not identifying the unknown defendant meet this definition, and violate their own oaths to promote what is commonly known as the ”blue line of silence.” 7. Mister Saucedo was video taping in accordance with this court’s declaratory judgment granted against the Los Santos Police Department in Glorida Mendoza v. The Los Santos Police Department, The Los Santos Sheriff’s Department, The San Andreas Department of Corrections, and any other law enforcement agency within the State of San Andreas, 25-LSC-0411 (2025). Therefore, the claim of “interference with an investigation” by videotaping should not be permitted as a defense in this case. 8. Counsel for the Los Santos Police Department, Alexander Braithwaithe was notified of my complaint, and I requested his review of the evidence for criminal charges. Attorney Braithwaithe has not yet responded to my request. 9. The Plaintiff prays that this court put an end to the incompetence and failures of the Los Santos Police Department to put the citizens of this city first, including cooperation with lawful requests. To award the monetary value associated with the damages of the plaintiff, and to award whatever other remedies this court deems appropriate. Exhibits 1. Video tape of the East Los Santos S-Curve incident. (( https://imgur.com/a/uln6LR5 ((This is an album)) https://www.youtube.com/watch?v=bPApMwBIgc8 )) 2. Notification to Attorney Braitwaithe (( https://imgur.com/a/AYQvbGX)) 3. Notification to the Los Santos Police Department's Staff Officers (( https://imgur.com/wtHpgBa )) _______________________________________________ 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 19 day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION Case Name: Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer in his personal and professional capacity, LSPD Staff Officers in their personal and professional capacity. Plaintiff Attorney: Juan Tzompaxtle CIVIL CASE COVER SHEET _______________________________________________ 1. Check one box below that best describes this case: Personal Torts [X] 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. $100,000.00 for attorney fees; $1,150,000.00 from the LSPD Staff Officers, plus any discovery fees and attorney fees; $3,550,000.00 from the unknown LSPD police officer; Whatever other relief this court deems appropriate. _______________________________________________ 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 19 day of April, 2025 by: /S/ Alan Saucedo Alan Saucedo Plaintiff /S/ Juan Tzompaxtle Juan Tzompaxtle Attorney for Plaintiff

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Gloria Mendoza v. The Los Santos Police Department, The Los Santos Sheriff's Department, The San Andreas Department of Corrections, and any other law enforcement agency within the State of San Andreas. Case Number: YY-XNNN Prepared by: Juan Tzompaxtle CIVIL CASE BRIEF FOR PLAINTIFF _______________________________________________ JURISDICTION AND APPLICABILITY OF DECLARATORY JUDGMENT: 1. The Federal Rules of Civil Procedure Rule 57 establishes the right for a Title III court to issue a declaratory judgment in the face of an actual case or controversy. to The “controversy” must necessarily be “of a justiciable nature, thus excluding an advisory decree upon a hypothetical state of facts.” Ashwander v. Tenn. Valley Auth., 297 U.S. 288, 325, (1936). The case presented is not hypothetical, Ms. Mendoza's right to film was cut short by a threat of a law enforcement officer thus depriving her of her constitutional rights. Although Ms. Mendoza was not arrested, that does not prohibit her from asserting a claim under 42 U.S.C. § 1983. The fact that Officer Love used his position to move Ms. Mendoza away from a scene that she had a legal right to observe and record, and for however short a period of time she was unable to record the scene when relocated prevented her from freely exercising her rights is not "hypothetical" in nature. Rather, those two acts give rise to a claim. This court is in a position to clarify the legality of video recording and audio recording law enforcement officers in public. However, even if the court finds that the unconstitutional threat and actions of a law enforcement officer does not establish a claim because the case is "moot," the court is permitted under Article III, Section 2, to hear the case because it is capable of repetition, yet evading review. Further, declaratory judgment is appropriate because "[a declaratory judgment] [. . .] which declares the rights of the parties or expresses the opinion of the court on a question of law, without ordering anything to be done, or requiring that an actual wrong, giving rise to a cause of action for damages, should have been committed or suffered." Stanley H. Mervis, Declaratory Judgments in Virginia, 1 Wm. & Mary Rev. Va. L. 32 (1950), https://scholarship.law.wm.edu/wmrval/vol1/iss2/2. (persuasive authority.) ARGUMENT: 1. The First Amendment to the United States Constitution protects the rights of citizens to assemble, protect the freedom of press, and protects citizens from unreasonable searches and seizures. The Courts of these United States have long concerned themselves with attempts by the government to chill the rights of citizens through intimidation. The law enforcement agencies within the State of San Andreas have taken advantage of the lack of precedent established by this Court on the topic of "obstruction of justice" when law enforcement officers are faced with a member of the public recording them. 2. On March 25th, 2025, Ms. Mendoza, was lawfully driving on a public roadway to the Idlewood Gas Station. During this drive, she lawfully parked her vehicle, dismounted the vehicle, and proceeded to a public sidewalk where she noticed a large crowd of people being detained. Ms. Mendoza decided to record the interaction, and states she was at minimum fifty feet from the scene, when a uniformed law enforcement officer, Officer Love approached her and asked what she was doing. Ms. Mendoza informed Officer Love that she was watching and filming. Officer Love requested that Ms. Mendoza leave the scene. Ms. Mendoza stated that she was over fifty feet from the incident, Officer Love persisted and threatened Ms. Mendoza stating if she did not leave "she would join them" (referring to the detained individuals). The threat is a violation of 42 U.S.C. 1983 a threat under the color of law, that for a period of time required Ms. Mendoza to move from a lawful position, and deprived her of her right to record in public the actions of law enforcement officers, giving rise to this request. The threat of arrest (or detention) is sufficient to establish a claim and controversy for declaratory relief. The facts of this case do not differ substantially from Steffel v. Thompson, 415 U.S.C. 452 (1974). In that case, a law enforcement officer threatened a Vietnam protestor with arrest when "petitioner and others were engaged in the distribution of handbills, which criticized American involvement in Vietnam, upon the exterior sidewalk of a large shopping center." Id. "Warned that they would be arrested if they continued to handbill, the group departed. However, petitioner and a friend returned 2 days later, and police again threatened them with arrest. Fearful of this prospect, petitioner left, while his companion, who remained, was arrested and charged with violation of the statute." Id. "The district court dismissed the claims of petitioner and others because it could find no active - and hence, no justiciable - controversy between the parties. Abandoning the action for injunctive relief, petitioner appealed the district court's denial of declaratory relief to the Court of Appeals for the Fifth Circuit, which affirmed, holding that to obtain declaratory relief from the threat of state prosecution petitioner was required to demonstrate irreparable injury resulting from bad faith harassment by the state." The Supreme Court of the United States reversed, holding: 1) that since petitioner faced a genuine threat of enforcement of a state criminal statute, the case presented an actual "controversy" as required by Article III of the Constitution; 2) that since no state prosecution was pending, declaratory relief was not precluded regardless of the propriety of injunctive relief; and 3) that it was irrelevant to the grant of declaratory relief whether the statute was attacked as being invalid upon its face or as applied." Steffel. Similar to Steffel, Ms. Mendoza faced a threat under the color of law. The charge of "obstruction of justice" has long been used to prevent the free exercise under the First Amendment. The role of the court is to determine the law drafted by the legislative branch, signed by the executive branch. In previous filing the state attacked the authority of this court to interpret and establish a test, or rule the practices of law enforcement agencies as unlawful. The facts presented in this case are unique to Ms. Mendoza but identify a larger need for the court to intervene and protect the rights of the citizens bestowed upon them by the Constitution. 3. The Supreme Court has held that public sidewalks, even those surrounding the Supreme Court building are a "Traditional Public Forum" See generally United States v. Grace, 461 U.S. 171 (1983). A traditional public forum receives the highest level of scrutiny when analyzing the governments action, the deference being given to the citizen. See Ward v. Rock Against Racism, 491 U.S. 781 (1989). 4. The First Circuit has clearly established that videotaping police carrying out their duties in public is constitutional in Gilk v. Cunnife, 655 F.3d 78 (1st Cir. 2011). "The First Amendment issue here is, as the parties frame it, fairly narrow: is there a constitutionally protected right to videotape police carrying out their duties in public? Basic First Amendment principles, along with case law from this and other circuits, answer that question unambiguously in the affirmative." Id. The right of a citizen to film their government and dissiminate that information is clearly affirmed throughout the opinion in Glik. The filming of government officials engaged in their duties in a public place, including police officers performing their responsibilities, fits comfortably within these principles. Gathering information about government officials in a form that can readily be disseminated to others serves a cardinal First Amendment interest in protecting and promoting “the free discussion of governmental affairs.” Mills v. Alabama, 384 U.S. 214, 218 (1966). Moreover, as the Court has noted, “[f]reedom of expression has particular significance with respect to government because it is here that the state has a special incentive to repress opposition and often wields a more effective power of suppression.’ “ First Nat'l Bank, 435 U.S. at 777 n. 11 (alteration in original) (quoting Thomas Emerson, Toward a General Theory of the First Amendment 9 (1966)). This is particularly true of law enforcement officials, who are granted substantial discretion that may be misused to deprive individuals of their liberties. Cf. Gentile v. State Bar of Nev., 501 U.S. 1030, 1035–36 (1991) (observing that “[t]he public has an interest in [the] responsible exercise” of the discretion granted police and prosecutors). Ensuring the public's right to gather information about their officials not only aids in the uncovering of abuses, see id. at 1034–35 (recognizing a core First Amendment interest in “the dissemination of information relating to alleged governmental misconduct”), but also may have a salutary effect on the functioning of government more generally, see Press–Enter. Co. v. Superior Court, 478 U.S. 1, 8 (1986) (noting that “many governmental processes operate best under public scrutiny”). 5. The law enforcement agencies of San Andreas have long ran wild with the idea that any citizen, videotaping any law enforcement officer, at anytime, can be detained or arrested. This has chilled the First Amendment, has prevented news outlets both official and unofficial from flourishing in the City of Los Santos -- and has resulted in the wrongful detention, or diminishment in the free exercise of the First Amendment -- for far too long. 6. This declaratory judgment comes after the Los Santos Police Department's Internal Affairs Group has determined that "the incident [of which Ms. Mendoza retained me] did not occur." This declaratory relief seeks to enjoin the law enforcement agencies throughout the furthest jurisdiction of this court from ever depriving citizens of their constitutional rights when recording law enforcement officers. 7. This declaratory judgment will resolve the controversy of this case, and establish a precedent allowing Ms. Mendoza, and other citizens, if any law enforcement officer chooses to act in a manner inconsistent with the federal precedent, and order of this court. 8. The plaintiff's prayer is that this court to impose a defined test for determining "obstruction" -- by defining a proximity, if one is appropriate at all, consistent with federal precedent -- of which a citizen can exercise their First Amendment rights in public by videotaping and audio recording without fear of unlawful arrest or detainment, and to adopt the First Circuit opinion that violating this test -- if the court deems one appropriate -- is grounds for defeating sovereign immunity claims against the law enforcement officer and agency. Exhibits 1. Video recording of the distance of Ms. Mendoza from the scene (( click the link for the album of the recording )). (( https://imgur.com/a/m5M1MMP )) 2. Response from the LSPD who found "the event did not occur." Witness List No witnesses are required or requested. _______________________________________________ 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 6th day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION Case Name: Glorida Mendoza v. The Los Santos Police Department, The Los Santos Sheriff's Department, The San Andreas Department of Corrections, and any other law enforcement agency within the State of San Andreas. Plaintiff Attorney: Juan Tzompaxtle 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 [ ] 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 Other [X] Declaratory Judgment/Declaratory Relief 2. List any damages sustained or fees accrued. Include billing rate for attorneys, expert witnesses, etc. N/A, declaratory judgment. _______________________________________________ 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 6 day of April, 2025 by: /S/ Gloria Mendoza Gloria Mendoza Plaintiff /S/ Juan Tzompaxtle Juan Tzompaxtle Attorney for Plaintiff

Gloria Mendoza v. The Los Santos Police Department, The Los Santos Sheriff's Department, The San Andreas Department of Corrections, and any other law enforcement agency within the State of San Andreas. Case Number: YY-XNNN Prepared by: Juan Tzompaxtle CIVIL CASE BRIEF FOR PLAINTIFF _______________________________________________ Argument 1. The First Amendment to the United States Constitution protects the rights of citizens to assemble, protect the freedom of press, and protects citizens from unreasonable searches and seizures. The Courts of these United States have long concerned themselves with attempts by the government to chill the rights of citizens through intimidation. The law enforcement agencies within the State of San Andreas have taken advantage of the lack of precedent established by this Court on the topic of "obstruction of justice" when law enforcement officers are faced with a member of the public recording them. 2. On March 25th, 2025, Ms. Mendoza, was lawfully driving on a public roadway to the Idlewood Gas Station. During this drive, she lawfully parked her vehicle, dismounted the vehicle, and proceeded to a public sidewalk where she noticed a large crowd of people being detained. Ms. Mendoza decided to record the interaction, and states she was at minimum fifty feet from the scene, when a uniformed law enforcement officer, Officer Love approached her and asked what she was doing. Ms. Mendoza informed Officer Love that she was watching and filming. Officer Love requested that Ms. Mendoza leave the scene. Ms. Mendoza stated that she was over fifty feet from the incident, Officer Love persisted and threatened Ms. Mendoza stating if she did not leave "she would join them" (referring to the detained individuals). 3. The Supreme Court has held that public sidewalks, even those surrounding the Supreme Court building are a "Traditional Public Forum" See generally United States v. Grace, 461 U.S. 171 (1983). A traditional public forum receives the highest level of scrutiny when analyzing the governments action, the deference being given to the citizen. See Ward v. Rock Against Racism, 491 U.S. 781 (1989). 4. The First Circuit has clearly established that videotaping police carrying out their duties in public is constitutional in Gilk v. Cunnife, 655 F.3d 78 (1st Cir. 2011). "The First Amendment issue here is, as the parties frame it, fairly narrow: is there a constitutionally protected right to videotape police carrying out their duties in public? Basic First Amendment principles, along with case law from this and other circuits, answer that question unambiguously in the affirmative." Id. The right of a citizen to film their government and dissiminate that information is clearly affirmed throughout the opinion in Glik. The filming of government officials engaged in their duties in a public place, including police officers performing their responsibilities, fits comfortably within these principles. Gathering information about government officials in a form that can readily be disseminated to others serves a cardinal First Amendment interest in protecting and promoting “the free discussion of governmental affairs.” Mills v. Alabama, 384 U.S. 214, 218 (1966). Moreover, as the Court has noted, “[f]reedom of expression has particular significance with respect to government because it is here that the state has a special incentive to repress opposition and often wields a more effective power of suppression.’ “ First Nat'l Bank, 435 U.S. at 777 n. 11 (alteration in original) (quoting Thomas Emerson, Toward a General Theory of the First Amendment 9 (1966)). This is particularly true of law enforcement officials, who are granted substantial discretion that may be misused to deprive individuals of their liberties. Cf. Gentile v. State Bar of Nev., 501 U.S. 1030, 1035–36 (1991) (observing that “[t]he public has an interest in [the] responsible exercise” of the discretion granted police and prosecutors). Ensuring the public's right to gather information about their officials not only aids in the uncovering of abuses, see id. at 1034–35 (recognizing a core First Amendment interest in “the dissemination of information relating to alleged governmental misconduct”), but also may have a salutary effect on the functioning of government more generally, see Press–Enter. Co. v. Superior Court, 478 U.S. 1, 8 (1986) (noting that “many governmental processes operate best under public scrutiny”). 5. The law enforcement agencies of San Andreas have long ran wild with the idea that any citizen, videotaping any law enforcement officer, at anytime, can be detained or arrested. This has chilled the First Amendment, has prevented news outlets both official and unofficial from flourishing in the City of Los Santos -- and has resulted in the wrongful detention, or diminishment in the free exercise of the First Amendment -- for far too long. 6. This declaratory judgment comes after the Los Santos Police Department's Internal Affairs Group has determined that "the incident [of which Ms. Mendoza retained me] did not occur." This declaratory relief seeks to enjoin the law enforcement agencies throughout the furthest jurisdiction of this court from ever depriving citizens of their constitutional rights when recording law enforcement officers. 7. This declaratory judgment will resolve the controversy of this case, and establish a precedent allowing Ms. Mendoza, and other citizens, if any law enforcement officer chooses to act in a manner inconsistent with the federal precedent, and order of this court. 8. The plaintiff's prayer is that this court to impose a defined test for determining "obstruction" -- by defining a proximity, if one is appropriate at all, consistent with federal precedent -- of which a citizen can exercise their First Amendment rights in public by videotaping and audio recording without fear of unlawful arrest or detainment, and to adopt the First Circuit opinion that violating this test -- if the court deems one appropriate -- is grounds for defeating sovereign immunity claims against the law enforcement officer and agency. ... Exhibits 1. Video recording of the distance of Ms. Mendoza from the scene 2. Statement from the Los Santos Police Department stating that the event did not occur. ... Witness List No witnesses are required or requested. _______________________________________________ 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 5th day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

SUPERIOR COURT OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION Case Name: Glorida Mendoza v. The Los Santos Police Department, The Los Santos Sheriff's Department, The San Andreas Department of Corrections, and any other law enforcement agency within the State of San Andreas. Plaintiff Attorney: Juan Tzompaxtle 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 [ ] 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 Other [X] Declaratory Judgment/Declaratory Relief 2. List any damages sustained or fees accrued. Include billing rate for attorneys, expert witnesses, etc. N/A, declaratory judgment. _______________________________________________ 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 5 day of April, 2025 by: /S/ Gloria Mendoza Gloria Mendoza Plaintiff /S/ Juan Tzompaxtle Juan Tzompaxtle Attorney for Plaintiff

Philip Quinteloy v. Superior Court of San Andreas, County of Los Santos Case Number: 25-1A-03107 Prepared by: Juan Tzompaxtle APPELLATE BRIEF FOR APPELLANT _______________________________________________ Question Presented: (1) Did the court err when the court in a probable cause hearing amended a charge that the State of San Andreas did not originally charge a defendant sua sponte? Argument 1. JURISDICTION: A finding of probable cause is a preliminary determination. However, when a judicial officer acts in such an egregious manner that it deprives a defendant of the rights afforded to them, those acts are immediately reviewable by an appellate court. Tumey v. Ohio, 273 U.S. 510 (1927). The Court of Appeals for the State of San Andreas is the initial Court of Appeals, thereby being the initial court that can perform an appellate review on the matter. Additionally, the Court granted immediate leave for an appeal in the probable cause hearing. 2. THE SUPERIOR COURT ERRED IN A SUA SPONTE CHANGE OF THE CHARGES PRESENTED BY THE STATE. The Fourth Amendment to the United States Constitute outlines the right of a defendant to a neutral and detached magistrate. The United States Supreme Court has repetedly held that the neutrality, independence, and detachment of a magistrate is pivotal in the right of a defendant to obtain a fair hearing and or trial. See e.g. United States v. Lefkowitz, 285 U.S. 452, 464 (1932); Giordenello v. United States, 357 U.S. 480, 486 (1958); Jones v. United States, 362 U.S. 257, 270 (1960); Katz v. United States, 389 U.S. 347, 356 (1967); United States v. United States District Court, 407 U.S. 297, 321 (1972); United States v. Chadwick, 433 U.S. 1, 9 (1977); Lo-Ji Sales v. New York, 442 U.S. 319 (1979). In addition to the long standing Constitutional requirements the Court through this action defied the Prosecutorial Discretion Doctrine. The Prosecutorial Discretion Doctrine requires the State to file initial charges, and when appropriate to amend those charges, not the court. This doctrine is related to the Fourth Amendment because a judge sua sponte amending any charge deviates from the role of the Judiciary to "not infer arguments that have not been expressly made." Larrea v. Bennet, 2002, U.S. Dist. LEXIS 10067, *40. This deviation took the judiciary out of the role of an examiner of the "four corners of the argument" in determining if probable cause exists and posed them against the defendant. If the situation was amended slightly and a judge were to coach a police officer in how they can word a search warrant affidavit in order to find probable cause any rational person would identify that the judge became a party by assisting the State in obtaining a warrant. Here, that warrant is a finding of probable cause, the same standard, but the facts are greater because the result for the defendant is detention. The Court's decision to deviate from their authorized role as a neutral arbitrator and to amend a charge to find probable cause is in fact inferring arguments that were not made. The original charge against Mister Quinteloy was reckless evading of a [sic] peace officer. Record at 16:48. That charge requires "A person who, while operating a motor vehicle, flees or attempts to elude a peace officer while driving in a reckless or dangerous fashion is guilty of a felony." The court found that the "reckless or dangerous fashion" was not met. Record at 17:22. The ramifications if this ruling is not overturned is substantial. It would forever taint the judicial body as one that is prosecutorial friendly, posing that the Court is another arm of the State, not the neutral arborator that the Constitution requires. It will erode the trust that the citizens place in an independent, impartial, and unbiased judiciary. For the reasons above we ask that the Court of Appeals overturn the finding of probable cause, thus invalidating the original charge, and the reason for the detention and require the State to return the money spent on bond. _______________________________________________ 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 31day of March, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

"Your Honor, process has been delivered to Mister Martin Hockenbeyer. He has been given ample opportunity to respond. At this time I am requesting a judgment against him be entered, that the full amount be awarded and that this judgement be made as a final judgment as the Defendant should know better and is acting in open defiance of the law and the authority this honorable court possesses. I can file my motion in writing but I don't think that it is necessary. However, it is your preference." (( @Tungsten, @almightybounter )).

https://www.youtube.com/watch?v=4dAy9u0_9nM

I'm just here because it was linked in the discord. Currently I am learning about Leases v. Secured Transactions.

"Right, well - how would you like to proceed counsel?" (( @Raven, @ImperiumXVII ))

"The notification has been received by the court. Have you been contacted by anyone in LSPD or heard anything about this case?" @Raven @nfr.ai

Superior Court of San Andreas County of Los Santos Civil Division Case Name: Mark Lim v. Los Santos Police Department Case Number: 24-CV-1036 This court issues the following orders: 1. Assignment of Docket Number The case is provisionally assigned the docket number 24-CV-1036, pending implementation of the Unified Docket System. When a new docket number is available, this court will notify all parties. 2. Order to Serve Parties Xavier Castenda, is ordered to serve the Los Santos Police Department, the Defendant, with process notifying him of this proceeding. The Defendant is to be notified in-person, by mail, by email, or by another suitable form of service that gives reasonable notice to the defendant within 10 days prior to the scheduled date for the beginning of proceedings. (( Send as a PM to all parties and include the assigned Judge. )) 3. Scheduling of Proceedings This case is scheduled to proceed to pre-trial motions four days after the serving of parties. The judge to oversee this case will be assigned at a later time when resources permit. This date is subject to change with at least 14 days of notice to all parties. The parties are further ordered to preserve and take reasonable steps to prevent the destruction of all relevant evidence. Witnesses are ordered to remain in the state beginning 10 days before the beginning of proceedings through the final disposition of this matter. The parties are additionally ordered to begin the process of disclosure issuing subpoenas pursuant to Fed. R. Civ. P. 45, and the clerk shall issue any necessary subpoenas to facilitate this process. Copies of all subpoenas shall be filed with this court. SO ORDERED. Dated: November 15th, 2024 /s/ Jeffrey Berd Magistrate, Civil Division, 2nd District Superior Court of San Andreas (( @nrf.ai ))

"The court has been delivered proof of service of process."

(( @almightybounter, @Userone, @Fabi, @ScubaStef ))