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SUPERIOR COURT OF SAN ANDREAS, COUNTY OF LOS SANTOS PLAINTIFF: Stefan Castillo DEFENDANT: Los Santos County Sheriff's Department CASE NUMBER: LCS-CV-2024-001 ORDER GRANTING MOTION FOR JUDGEMENT AS A MATTER OF LAW _______________________________________________ This matter is before the Court for consideration of Plaintiff Stefan Castillo's Motion for Judgement as a Matter of Law. For the reasons stated herein, the aforementioned motion is GRANTED. OVERVIEW OF ACTION A. Factual Background Plaintiff Stefan Castillo worked as a sergeant for the Defendant, the Los Santos County Sheriff's Department. Defendant is a law enforcement agency duly organized, existing, and operating under the laws of the State of San Andreas. This case disputes the legality of Plaintiff Stefan Castillo's detention during the aftermath of a deputy-involved shooting incident. A. Procedural History The case is an action brought by Stefan Castillo (hereinafter "Plaintiff") against the Los Santos County Sheriff's Department (hereinafter "Defendant") on June 30th, 2024, alleging deprivation of rights under color of law. Plaintiff challenges the adequacy of the interview he has been taken on June 26th. On July 10th, a Motion to Modify Counsel was forwarded by Mr Donald J. Wright on behalf of the Plaintiff, which was granted. On the same day, a Motion for Summary Judgement was also forwarded by the Plaintiff, which was denied. A reconsieration was also requested, which was denied as well. Trial commenced with witness examination. During the examination of then-Sgt Elise Crawford, the Court noted the failure of the aforementioned witness to answer questions after a certain point. A request for spoliation was forwarded by the Plaintiff on September 23rd, which was replaced by a renewal of the Motion for Judgement as a Matter of Law on September 27th, 2024. The Court held a hearing for this last Motion, which is now ripe for review. FINDINGS OF FACTS During the night of June 25th, Plaintiff observed Mr Deandre Lawrence pursuing Mr Franklin Mejora with a baseball bat in their hand. Mr Lawrence proceeded to takle Mr Mejora on the ground, assaulting him with the aforementioned baseball bat. Plaintiff took action, discharging their service weapon at Mr Lawrence in an act of usage of force. Mr Lawrence was then detained successfully by Plaintiff and administered aid. Both Mr Lawrence and Mr Mejora were transported to medical facilities by the Los Santos County Sheriff's Department deputies. During the aftermath of the shooting, Plaintiff was questiond by the corresponding internal affairs structure of the department. The interview concludes with the placement of Plaintiff of administrative leave until June 30th. LEGAL STANDARD A. Judgement as a Matter of Law Judgment as a matter of law is appropriate when “a party has been fully heard on an issue during a jury trial and the court finds that a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue. . .” Fed. R. Civ. P. 50(a)(1); see also Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 149 (2000). The court “should review all of the evidence in the record," but "may not make credibility determinations or weigh the evidence." Id. see also Josephs v. Pac. Bell, 443 F. 3d 1050, 1062. The court should give credence to the evidence favoring the non-moving party, as well as that evidence supporting the moving party that is uncontradicted or unimpeached, to the extent that it comes from disinterested witnesses. Reeves, 530 U.S. at 151. The test applied is whether the evidence permits only one reasonable conclusion, and that conclusion is contrary to the jury's verdict. Josephs, 443 F.3d at 1062. The verdict must be upheld if the evidence is adequate to support the jury's conclusion, even if it is also possible to draw a contrary conclusion from the same evidence. Johnson v. Paradise Valley Unified Sch. Dist., 251 F.3d 1222, 1227. However, judgment as a matter of law is appropriate when the jury could have relied only on speculation to reach its verdict. Lakeside-Scott v. Multnomah County, 556 F.3d 797, 803. The standard for judgment as a matter of law “mirrors” that for granting summary judgment. Reeves, 530 U.S. at 150. Such judgement should be granted if “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). Material facts are those that may affect the outcome of the case. Nat’l Ass’n of Optometrists & Opticians v. Harris, 682 F.3d 1144, 1147 (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248. A dispute is genuine “if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson, 477 U.S. at 248. B. Basis for Motion Based on the presented arguments, witness examinations and other exhibits, the Court understands that the interview of Plaintiff that has occurred on June 26th was in relation to the shooting that has happened one day before. During this interrogation, the Plaintiff was administered a Garrity warning. The Court ackwnoledges law enforcement personnel "do not receive a watered down version of Constitutional Rights." Garrity v. New Jersey, 385 U.S. 493. Furthermore, the Court distinguishes between the Garrity Rights, utilized in administrative proceedings, and Miranda Rights, used in criminal ones. Corroborating these facts, due to the criminal nature of the acts committed by Plaintiff, the Court finds it reasonable that Plaintiff should have been administered the Miranda admonishment in the same way as any other person of the public would have been. In regard to the nature of the interrogation, the Court hence finds it to be custodial. In order to draw such a conclusion, the Court makes use of the test established by precent: "(1) a person is in custody or feels that their otherwise deprived of his freedom of action in any significant way, (2) was questioned." Miranda v. Arizona, 384 U.S. 436, 444. "A reasonable person would have felt he or she was not at liberty to terminate the interrogation and leave." Thompson v. Keohane, 516 U.S. 99, 112. Derriving from the above-referenced facts, while it is uncontested that the Miranda admonishment does not constitute a costitutional requirement, equal protection of rights does. When it comes to the allegations related to deprivation of Due Process via refusal to answer questions upon the Court's instruction to do so and questionable attitude in regard to negotiations, the Court finds the deprivation of Due Process to be existent and hereby issues fines to both Sophie Thyne and Elise Crawford (( Considering the holiday of Michael and the real-life issues of Kayayday, I understand the need to prioritize real life over a game. The fines are symbolic and shall be used for roleplay purposes, however, no actual punishments will be issued due to the above-referenced considerations )). DAMAGES AND FEES A. Compensatory damages The purpose of damages is to put the plaintiff in the position he would have been in if the tort had not been committed — restitutio in integrum. Damages are not awarded to over-enrich a plaintiff far beyond his actual losses. The reverse is also the case — the plaintiff should not get far less than his actual loss. Furthermore, a wide range of reporting about both public officials and candidates is protected. Certainly, the conduct of official duties by public officials is subject to the widest scrutiny and criticism. Rosenblatt v. Baer, 383 U.S. 75, 85. But the Court has held as well that criticism that reflects generally upon an official’s integrity and honesty is protected. According to different statutes, the term “public official” means, inter alia, "any elected official, appointed official, or employee of a Federal, State, or local unit of government in the United States". Plaintiff would be entitled to overtime lost wages, however, no documents have been forwarded to the Court that would prove such a loss. As such, the Court will evaluate these damages to the best of its ability. Due to the fact that administrative leave was issued for four days, the Court finds it reasonable to award $12,500 per day, meaning $50,000. B. Emotional damages and distress Taking into consideration stress caused by an unproper investigative process and violation of Due Process during multiple instances, the Court finds the requested sum of $500,000 to be more than reasonable. As such, the Court awards the said sum of $500,000 under this category. C. Attorney fees The court, in its discretion, may allow the prevailing party, other than the United States, a reasonable attorney's fee as part of the costs. A prevailing party is one who succeeds on "any significant issue in litigation which achieve[d] some of the benefit the parties sought in bringing suit...." Texas State Teachers Ass'n v. Garland Independent School Dist., 489 U.S. 782, 788, quoting Nadeau v. Helgemoe, 581 F.2d 275, 278-79. For there to be liability there must be a violation of a federal rights, not merely a violation of federal law. Golden State Transit Corp. v. Los Santos 493 U.S. 103, 106.. In Blessing v. Freestone, et al. 520 U.S. 329, the Court discussed the elements needed for a finding of a violation of a federal right: “[T]he provision giving rise to the asserted right must be couched in mandatory, rather than precatory." The Court finds a violation of such federal rights. Under Hensley, 461 U.S. 424, the starting point for determining the amount of a reasonable fee is reached by multiplying the number of hours reasonably expended on the litigation times a reasonable hourly rate. This figure is known as the "lodestar." Lipsett v. Blanco, 975 F.2d 934. Attorneys must exercise reasonable billing judgment, and public interest attorneys must exercise the reasonable billing judgment used in the private sector. Hensley, 461 U.S. at 434. Outrageous lack of billing judgment may result in no fees. Lewis v. Kendrick 940 F.2d 25. However, given the circumstances of the case, regardless that the fees seem to be lacking judgement, they will be lowered by the Court accordingly. Considering the length of the case, its complexity, number of motions, nature of witness examinations, the Court finds an hourly rate of $10,000 to be multiplied by 20 billable hours, totalling to $200,000 in attorney fees. In addition to that, the Court entitles Plaintiff to costs of travel of $50,000 considering the aforementioned factors. Attorney fees should total at $250,000. ORDER Accordingly, it is HEREBY ORDERED THAT: Plaintiff's Motion for Judgement as a Matter of Law is GRANTED. Plaintiff is entitled to compensatory damages in the sum of $50,000; emotional and distress damages in the sum of $500,000; and attorney fees in the sum of $250,000. Plaintiff's administrative leave is to be expunged from his record. Then-Sergeant Elise Crawford is recommended to be investigated for the conduct during the interview of Plaintiff. Both Ms Sophie Thyne and Ms Elise Crawford shall be fined for contempt of court (( see above )); _______________________________________________ IT IS SO ORDERED. DATE: OCTOBER 3, 2024 Hon. Sergio Robleto Judge Superior Court of Los Santos (( @Michael @Kayayday @Kotwica @ScubaStef - It is more of a rushed judgement. My apologies but my free time has become limited. ))

"Recess until the Court rules on the motion." (( @Kotwica @Michael ))

"Due to the given circumstances and continous unncessary delay, the Defendant is granted 24 hours to provide a response to this motion. Then we'll have a recess until the Court renders a judgement on this motion." (( @Michael @Kotwica ))

"Opposing counsel, anything in response to Mister Wright's request?" (( Since tomorrow's the 25th, we'll wait as common courtesy and then we'll hopefully get this moving at a proper speed. Our apologies for all the inconviniences. @Michael @Kotwica ))

@Kayayday

COURT OF APPEALS, SECOND APPELLATE DISTRICT DIVISION ONE PLAINTIFF: Michelle Jefferson DEFENDANT: Los Santos Police Department et. al. CASE NUMBER: B19736 Appellant, ORDER GRANTING INTERLOCUTORY APPEAL AND PETITION FOR PERMANENT INJUNCTION _______________________________________________ This matter is before the Court for consideration of Ms Michelle Jefferson, through and by Mr Jacob E. Rabinowitz III's and Mr Donald J. Wright's (hereinafter "Appellant") for an emergency interlocutory appeal of an immediately reviewable matter occurring within Case 24-CV-1034 and Appellant's petition for a permanent injunction enjoining the trial court from restricting further appointment of counsel. For the reasons stated herein, the above-referenced emergency interlocutory appeal and petition for permanent injunction are GRANTED insofar as the Court finds them necessary to address the legal deficiencies arrising through the interlocutory orders issued by the trial court. OVERVIEW OF ACTION The case is a class action brought by Michelle Jefferson against the Los Santos Police Department under 42 U.S.C § 1983 on September 14th, 2024, alleging violations of the fundamental rights of the United States Constitution and laws. Plaintiff challenges the adequacy of the her arrests and citations issued to her throughout the months of August and September of this year. On September 16th, a Motion for Addition of Counsel was forwarded by Mr Jacob E. Rabinowitz III and Mr Donald J. Wright pursuant to 28 U.S.C. §1654 and Fed. R. Civ. P. 44. The Motion was denied on the same day by the Honorable Judge Martin Hockenbeyer. On September 17th, a Motion to Stay was filed by the aforementioned attorneys, which was also denied by Judge Hockenbeyer. An interlocutory appeal was lastly forwarded to this Court on September 19th. SUMMARY OF DECISION Under the the Sixth Amendment of the United States Constitution, 28 U.S.C. §1654 and Fed. R. Civ. P. 44, the Plaintiff has the right to appoint counsel. As such, the Plaintiff the right to appoint, supplement, or dismiss counsel using her own judgement and discretion. Limiting this right, the trial court stated that it "possess broad discretion to make determinations that preserve the integrity of the judicial process, including the authority to limit the participation of counsel when it is necessary to prevent potential conflicts, confusion, or delay". The Court acknowledges the usage of discretion in order to guarantee the preservation of the judicial process' integrity, including, under very limited and exigent circumstances, the limitation of of participating counsel. However, based on the presented facts, the complex nature of the case and the lack of hearings on the matters, the Court finds no objective reason to believe risk of prejudice exists and hence, due to the vitality of this fundamental rights, the Court find imposing such a limitation without proper basis to be abuse of discretion. The Court finds that a permanent injunction is necessary to force the trial court to adequately safeguard the fundamental rights of the Plaintiff, having found no solid legal basis for the denial of additional counsel given the circumstances. ORDER The Court finds that trial court has been deliberately indifferent towards the protection of fundamental right to counsel of the Plaintiff within the meaning of the Sixth Amendment of the United States. For the reasons stated herein, Plaintiff’s interlocutory appeal and petition for permanent injunction are GRANTED. The Court further finds the Plaintiff have established by a preponderance of the evidence that a permanent injunction is appropriate and necessary. The Court specifically finds that Plaintiff have suffered or will suffer irreparable injury if a permanent injunction is not issued. The permanent injunction enjoins the trial court from restricting further appointment of counsel. Appellant factually has a right to appoint counsel of her choosing in the enumeration she so chooses, _______________________________________________ IT IS SO ORDERED. DATE: SEPTEMBER 20, 2024 Hon. Michael Rouker Associate Justice Court of Appeals, Second District, Division One (( @Kotwica @Jacob Rabinowitz @almightybounter @John Gilbane @nfr.ai @Userone ))

COURT OF APPEALS, SECOND APPELLATE DISTRICT DIVISION ONE PLAINTIFF: Michelle Jefferson DEFENDANT: Los Santos Police Department et. al. CASE NUMBER: B19736 Appellant, ORDER GRANTING INTERLOCUTORY APPEAL AND PETITION FOR PERMANENT INJUNCTION _______________________________________________ This matter is before the Court for consideration of Ms Michelle Jefferson, through and by Mr Jacob E. Rabinowitz III's and Mr Donald J. Wright's (hereinafter "Appellant") for an emergency interlocutory appeal of an immediately reviewable matter occurring within Case 24-CV-1034 and Appellant's petition for a permanent injunction enjoining the trial court from restricting further appointment of counsel. For the reasons stated herein, the above-referenced emergency interlocutory appeal and petition for permanent injunction are GRANTED insofar as the Court finds them necessary to address the legal deficiencies arrising through the interlocutory orders issued by the trial court. OVERVIEW OF ACTION The case is a class action brought by Michelle Jefferson against the Los Santos Police Department under 42 U.S.C § 1983 on September 14th, 2024, alleging violations of the fundamental rights of the United States Constitution and laws. Plaintiff challenges the adequacy of the her arrests and citations issued to her throughout the months of August and September of this year. On September 16th, a Motion for Addition of Counsel was forwarded by Mr Jacob E. Rabinowitz III and Mr Donald J. Wright pursuant to 28 U.S.C. §1654 and Fed. R. Civ. P. 44. The Motion was denied on the same day by the Honorable Judge Martin Hockenbeyer. On September 17th, a Motion to Stay was filed by the aforementioned attorneys, which was also denied by Judge Hockenbeyer. An interlocutory appeal was lastly forwarded to this Court on September 19th. SUMMARY OF DECISION Under the the Sixth Amendment of the United States Constitution, 28 U.S.C. §1654 and Fed. R. Civ. P. 44, the Plaintiff has the right to appoint counsel. As such, the Plaintiff the right to appoint, supplement, or dismiss counsel using her own judgement and discretion. Limiting this right, the trial court stated that it "possess broad discretion to make determinations that preserve the integrity of the judicial process, including the authority to limit the participation of counsel when it is necessary to prevent potential conflicts, confusion, or delay". The Court acknowledges the usage of discretion in order to guarantee the preservation of the judicial process' integrity, including, under very limited and exigent circumstances, the limitation of of participating counsel. However, based on the presented facts, the complex nature of the case and the lack of hearings on the matters, the Court finds no objective reason to believe risk of prejudice exists and hence, due to the vitality of this fundamental rights, the Court find imposing such a limitation without proper basis to be abuse of discretion. The Court finds that a permanent injunction is necessary to force the trial court to adequately safeguard the fundamental rights of the Plaintiff, having found no solid legal basis for the denial of additional counsel given the circumstances. ORDER The Court finds that trial court has been deliberately indifferent towards the protection of fundamental right to counsel of the Plaintiff within the meaning of the Sixth Amendment of the United States. For the reasons stated herein, Plaintiff’s interlocutory appeal and petition for permanent injunction are GRANTED. The Court further finds the Plaintiff have established by a preponderance of the evidence that a permanent injunction is appropriate and necessary. The Court specifically finds that Plaintiff have suffered or will suffer irreparable injury if a permanent injunction is not issued. The permanent injunction enjoins the trial court from restricting further appointment of counsel. Appellant factually has a right to appoint counsel of her choosing in the enumeration she so chooses, _______________________________________________ IT IS SO ORDERED. DATE: SEPTEMBER 20, 2024 Hon. Michael Rouker Associate Justice Court of Appeals, Second District, Division One

COURT OF APPEALS, SECOND APPELLATE DISTRICT DIVISION ONE PLAINTIFF: Michelle Jefferson DEFENDANT: Los Santos Police Department et. al. CASE NUMBER: B19736 Appellant, ORDER GRANTING PETITION FOR TEMPORARY INJUNCTION _______________________________________________ This matter is before the Court for consideration of Ms Michelle Jefferson, through and by Mr Jacob E. Rabinowitz III's and Mr Donald J. Wright's (hereinafter "Appellant") for an emergency interlocutory appeal of an immediately reviewable matter occurring within Case 24-CV-1034. After considering the submissions of the parties and the applicable law, the Court will grant the petiton for a temporary injunction granting a stay of the trial court proceedings, pending the final order of the Court. ORDER The Court finds that the Appellant has met the burden of proof necessary for requesting a temporary stay of proceedings in accordance with 28 U.S.C. § 2283. The petition requesting that the trial court proceeding is stayed until the Court rules on the remaining listed prayer for relief forwarded by the Appellant is GRANTED. _______________________________________________ IT IS SO ORDERED. DATE: SEPTEMBER 19, 2024 Hon. Michael Rouker Associate Justice Court of Appeals, Second District, Division One (( Tags handled in the other topic. ))

COURT OF APPEALS, SECOND APPELLATE DISTRICT DIVISION ONE PLAINTIFF: Michelle Jefferson DEFENDANT: Los Santos Police Department et. al. CASE NUMBER: B19736 Appellant, ORDER GRANTING PETITION FOR TEMPORARY INJUNCTION _______________________________________________ This matter is before the Court for consideration of Ms Michelle Jefferson, through and by Mr Jacob E. Rabinowitz III's and Mr Donald J. Wright's (hereinafter "Appellant") for an emergency interlocutory appeal of an immediately reviewable matter occurring within Case 24-CV-1034. After considering the submissions of the parties and the applicable law, the Court will grant the petiton for a temporary injunction granting a stay of the trial court proceedings, pending the final order of the Court. ORDER The Court finds that the Appellant has met the burden of proof necessary for requesting a temporary stay of proceedings in accordance with 28 U.S.C. § 2283. The petition requesting that the trial court proceeding is stayed until the Court rules on the remaining listed prayer for relief forwarded by the Appellant is GRANTED. _______________________________________________ IT IS SO ORDERED. DATE: SEPTEMBER 19, 2024 Hon. Michael Rouker Associate Justice Court of Appeals, Second District, Division One (( @Kotwica @Jacob Rabinowitz @almightybounter @John Gilbane @nfr.ai @Userone ))

"Miss Crawford, please answer the given questions. And any upcoming ones." (( @Kayayday @Kotwica @Michael ))

** Sergio Robleto briefly bops his head. ** "That is fine, counselor. You may do so." (( @Kayayday @Michael @Kotwica ))

"Very well. This Court recalls Miss Crawford for the purpose of examination. Begin with the aforementioned questions, meaning questions 29-to-37." (( @Kayayday @Michael @Kotwica ))

"Counselor Wright, I have already ruled on the incident of contempt and I shall maintain my decision, hence your motion is hereby denied. Ths includes the request for damages. Additionally, this Court does not find the aforementioned writing as an admission to improper conduct per se, due to the lack of basis for such an action. This is the last time I am going to request you to file your motion to compel you've mentioned or we are going to move forward with the witness examinations. (( @Michael @Kotwica ))

"Counselor Thyne, I do not really understand how the document that has been sent to the Plaintiff constitutes intra-departmental correspondence, looking at Plaintiff's Exhibit two. It is reasonable to believe that it is a settlement officer sent to Mister Castillo. Out of courtesy, I will only issue an admonishment to the counsel for the Defendant, on the record, for contemptous conduct by violating the Federal Rules of Civil Procedure Rule 11(b). Further similar conduct will result in a citation for contempt. Counselor Wright, please file your motion. (( @Kotwica @Michael ))

* Sergio Robleto accepts the copy from the bailiff, darting his eyes around its contents briefly before settling it on his bench. He sighs, pinching the bridge of his nose. * We're going to pause on the witness examination until we conclude with all issues related to the alleged settlement negotiations, as I do not wish this to turn into chaos. Counselor Thyne, please provide your response to the Plaintiff's attorney. Counselor Wright, your requests regarding Plaintiff's exhibits one and two are granted. Do you still wish to pursue a reconsideration for your motion to compel? If so, I'd ask that you opt to amend the motion and re-file it so we avoid any further confusion in regard to what you wish to compel. Should you wish to now abandon the reconsideration, please state so accordingly, for the record. (( @Michael @Kotwica ))