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Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD. Case number: 25-LSC-04116 Prepared by: Ibraheem A. Davis DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO DENY DEFENDANT'S MOTION AND CENSURE THE DEFENDANT FOR THE USE OF AI TOOLS _____________________________________________________________________________________________________________________________________________________________________ COMES NOW, Ibraheem Davis, legal representative for the Los Santos Police Department (LSPD), and respectfully submits this response to Plaintiff's opposition to Defendant's Motion of Stay of Proceedings. I. Introduction Plaintiff's counsel has made several unfounded accusations that warrant immediate address. Most egregiously, counsel alleges that I have utilized artificial intelligence to draft my motions and has declared, without substantive evidence, that the "91 percent" of my filing is "AI Generated" based solely on a proprietary algorithm with known reliability issues. This allegation is both factually wrong and legally irrelevant to the merits of LSPD's motion. II. Response to Allegations 1. The AI Detection Claim is Unreliable and Legally Irrelevant Plaintiff's counsel relies on "Quillbot", a text analysis tool with documented limitations. Courts have consistently recognized that such AI detection tools produce unreliable results with false positive rates exceeding 25% in peer-reviewed studied. Even one of the most if not popular AI Detection tools "Turnitin" claimed themselves that their product produce false positives. The San Andreas Bar Association has not established any prohibition against drafting assistance tools, which many attorneys utilize for formatting, citation checking and language refinement; Practices equivalent to traditional tools like spelling and grammar checkers. As held in Pirelli Armstrong Tire Corp v. Raines, "Courts have never required attorneys to compose all materials from scratch" The typing errors noted by the opposing counsel (Duplicate Roman Numbers) actually contradict their allegation of AI usage, as such errors are characteristic of human drafting. These minor typographical errors in no way diminish the substantive legal arguments presented on behalf of the LSPD. In Hamer v. Neighborhood Housing Servs. of Chicago, the Court held that "procedural rules should not be applied in a way that created meaningless procedural traps". 2. The UK Citation is Both Relevant and Appropriate Plaintiff's objection to my citation of a House of Lords decision demonstrates a serious misunderstanding of comparative law principles. While not binding, persuasive authority from respected common law jurisdictions in routinely cited in complex procedural matters where San Andreas precedent is developing. In American Bank & Trust Co. v. Federal Reserve Bank, where Justice Holmes noted that "the Court may appropriately look to decisions of English courts for persuasive value in interpreting common law principles". III. Defense Against Plaintiff's Claim of Untimeliness Defendant acknowledges that the motion in question was filed after the court-imposed deadline for responses. However, Defendant respectfully submits that the delay was caused by reasonable circumstance and show not result in a dismissal of the motion. More specifically: Good Cause for Delay: The delay in filling was due to extenuating circumstances, including an unavoidable personal matter that temporarily impacted the preparation and filing of the motion. Defendant, through counsel, takes full responsibility for this oversight but emphasizes that the delay did not prejudice the Plaintiff or harm the integrity of the judicial process. As such, Defendant respectfully requests that the Court exercise its discretion and allow the motion to proceed on the merits No Prejudice to Plaintiff The Plaintiff has not shown, and cannot show, any material prejudice caused by the delay. The issues raised in the motion remain relevant, and there is no indication that the delay has affected the Plaintiff's ability to respond or prepare for trial. Denying the motion on procedural grounds alone would serve no legitimate purpose and would frustrate the interests of justice. Substantial Compliance Defendant has made substantial compliance with the requirements set forth by the court, and any minor delay should be excused in light of the circumstances, particularly when no harm has been done to the Plaintiff's case. IV. Conclusion I respectfully request that this Court: Disregard plaintiff's unfounded allegations regarding drafting methods; Consider the substantive merits of the stay request as outlined in our original motion; Admonish plaintiff's counsel for engaging in personal attacks rather than addressing legal substance; and Grant the requested stay of proceedings for the reasons outlined in our initial filing. Respectfully submitted, /s/ IBRAHEEM A, DAVIS Ibraheem A. Davis Legal Representative Los Santos Police Department

Montblanc v. Shakhzadov, Los Santos Police Department, et al. Case number: 25-LSC-04117 Prepared by: Ibraheem A. Davis DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO DENY DEFENDANT'S MOTION AND CENSURE THE DEFENDANT FOR THE USE OF AI TOOLS _____________________________________________________________________________________________________________________________________________________________________ COMES NOW, Ibraheem Davis, legal representative for the Los Santos Police Department (LSPD), and respectfully submits this response to Plaintiff's opposition to Defendant's Motion of Stay of Proceedings. I. Introduction Plaintiff's counsel has made several unfounded accusations that warrant immediate address. Most egregiously, counsel alleges that I have utilized artificial intelligence to draft my motions and has declared, without substantive evidence, that the "91 percent" of my filing is "AI Generated" based solely on a proprietary algorithm with known reliability issues. This allegation is both factually wrong and legally irrelevant to the merits of LSPD's motion. II. Response to Allegations 1. The AI Detection Claim is Unreliable and Legally Irrelevant Plaintiff's counsel relies on "Quillbot", a text analysis tool with documented limitations. Courts have consistently recognized that such AI detection tools produce unreliable results with false positive rates exceeding 25% in peer-reviewed studied. Even one of the most if not popular AI Detection tools "Turnitin" claimed themselves that their product produce false positives. The San Andreas Bar Association has not established any prohibition against drafting assistance tools, which many attorneys utilize for formatting, citation checking and language refinement; Practices equivalent to traditional tools like spelling and grammar checkers. As held in Pirelli Armstrong Tire Corp v. Raines, "Courts have never required attorneys to compose all materials from scratch" The typing errors noted by the opposing counsel (Duplicate Roman Numbers) actually contradict their allegation of AI usage, as such errors are characteristic of human drafting. These minor typographical errors in no way diminish the substantive legal arguments presented on behalf of the LSPD. In Hamer v. Neighborhood Housing Servs. of Chicago, the Court held that "procedural rules should not be applied in a way that created meaningless procedural traps". 2. The UK Citation is Both Relevant and Appropriate Plaintiff's objection to my citation of a House of Lords decision demonstrates a serious misunderstanding of comparative law principles. While not binding, persuasive authority from respected common law jurisdictions in routinely cited in complex procedural matters where San Andreas precedent is developing. In American Bank & Trust Co. v. Federal Reserve Bank, where Justice Holmes noted that "the Court may appropriately look to decisions of English courts for persuasive value in interpreting common law principles". III. Defense Against Plaintiff's Claim of Untimeliness Defendant acknowledges that the motion in question was filed after the court-imposed deadline for responses. However, Defendant respectfully submits that the delay was caused by reasonable circumstance and show not result in a dismissal of the motion. More specifically: Good Cause for Delay: The delay in filling was due to extenuating circumstances, including an unavoidable personal matter that temporarily impacted the preparation and filing of the motion. Defendant, through counsel, takes full responsibility for this oversight but emphasizes that the delay did not prejudice the Plaintiff or harm the integrity of the judicial process. As such, Defendant respectfully requests that the Court exercise its discretion and allow the motion to proceed on the merits No Prejudice to Plaintiff The Plaintiff has not shown, and cannot show, any material prejudice caused by the delay. The issues raised in the motion remain relevant, and there is no indication that the delay has affected the Plaintiff's ability to respond or prepare for trial. Denying the motion on procedural grounds alone would serve no legitimate purpose and would frustrate the interests of justice. Substantial Compliance Defendant has made substantial compliance with the requirements set forth by the court, and any minor delay should be excused in light of the circumstances, particularly when no harm has been done to the Plaintiff's case. IV. Conclusion I respectfully request that this Court: Disregard plaintiff's unfounded allegations regarding drafting methods; Consider the substantive merits of the stay request as outlined in our original motion; Admonish plaintiff's counsel for engaging in personal attacks rather than addressing legal substance; and Grant the requested stay of proceedings for the reasons outlined in our initial filing. Respectfully submitted, /s/ IBRAHEEM A, DAVIS Ibraheem A. Davis Legal Representative Los Santos Police Department

Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD. Case number: 25-LSC-04116 Prepared by: Ibraheem A. Davis DEFENDANT's MOTION TO STAY PROCEEDINGS PENDING INTERNAL AFFAIRS INVESTIGATION _____________________________________________________________________________________________________________ Defendant respectfully requests a temporary stay of proceedings in the above-captioned matter, pending the completion of the ongoing Internal Affairs investigation related to the conduct of the LSPD Officer. This motion is not intended to delay proceedings unduly, but rather to ensure the Court is presented with the most complete and accurate factual record possible. The outcome of said investigation bears directly upon material issues in dispute. I. Judicial Economy and Efficiency Courts have long recognized the authority to stay civil proceedings when doing so would serve judicial economy, conserve resources, or avoid conflicting outcomes. In Landis v. North American Co., 299 U.S. 248 (1936), the U.S. Supreme Court affirmed that "n the exercise of its sound discretion, a court may hold one lawsuit in abeyance to abide the outcome of another which may substantially affect it or be dispositive of the issues." II. Importance of Internal Investigative Findings in Law Enforcement Cases In Allen v. City of Oakland (N.D. Cal.), the court underscored the critical role of internal police investigations when systemic misconduct was alleged. The resulting reforms and oversight shaped the resolution of civil claims, demonstrating that deferring litigation to await investigatory findings may enhance both accuracy and fairness. Similarly, in O'Brien v. Chief Constable of South Wales Police ([2005] UKHL 26), the House of Lords acknowledged the probative value of internal disciplinary findings in civil claims concerning police conduct. The judgment highlighted that internal reviews often yield essential context and factual clarification relevant to civil proceedings III. Protection of Due Process and Officer's Rights Premature disclosure of the identity of the Unknown Officer, prior to the conclusion of the Internal Affairs investigation, would risk violating the officer's due process rights. Officers, subject to administrative or disciplinary review are entitled to a full and fair internal process, free from premature public exposure or legal assumption of guilt. Revealing the officer's identity at this stage may also: Undermine the integrity of impartiality of the Internal Affairs investigation; Compromise the safety and privacy of the officer and others involved; Diminish the Department's ability to conduct effective and unbiased internal oversight; Violate any existing protective policies regarding officers under investigation. This request is therefore not only consistent with legal precedent but also a necessary safeguard for constitutional and procedural fairness. III. Risk of Premature or Fragmented Litigation Absent a stay, the parties risk engaging in premature motion practice and discovery based on incomplete or evolving factual circumstances. This may result in the need for amendments, redundant motions, or the revisiting of rulings, all of which impose additional burdens on the Court and litigants. IV. Good Faith Request Defendant emphasizes that this request is made in good faith and is narrowly tailored. The requested stay is limited in scope and duration, only until the Internal Affairs Group concludes its review. The intent is not to delay this litigation indefinitely, but to ensure adjudication proceeds on a full and reliable evidentiary foundation. V. Conclusion WHEREFORE, Defendant respectfully prays that the Court: GRANT a temporary stay of proceedings pending the conclusion of the Internal Affairs investigation; SET a status review date within a reasonable timeframe to evaluate the investigation’s progress and reassess the stay’s necessity; RETAIN full discretion to lift or modify the stay as appropriate. Respectfully submitted, /s/ IBRAHEEM A, DAVIS Ibraheem A. Davis Legal Representative Los Santos Police Department

Montblanc v. Shakhzadov, Los Santos Police Department, et al. Case number: 25-LSC-04117 Prepared by: Ibraheem A. Davis DEFENDANT's MOTION TO STAY PROCEEDINGS PENDING INTERNAL AFFAIRS INVESTIGATION _____________________________________________________________________________________________________________ Defendant respectfully requests a temporary stay of proceedings in the above-captioned matter, pending the completion of the ongoing Internal Affairs investigation related to the conduct of Officer Akhmad. This motion is not intended to delay proceedings unduly, but rather to ensure the Court is presented with the most complete and accurate factual record possible. The outcome of said investigation bears directly upon material issues in dispute. I. Judicial Economy and Efficiency Courts have long recognized the authority to stay civil proceedings when doing so would serve judicial economy, conserve resources, or avoid conflicting outcomes. In Landis v. North American Co., 299 U.S. 248 (1936), the U.S. Supreme Court affirmed that "n the exercise of its sound discretion, a court may hold one lawsuit in abeyance to abide the outcome of another which may substantially affect it or be dispositive of the issues." II. Importance of Internal Investigative Findings in Law Enforcement Cases In Allen v. City of Oakland (N.D. Cal.), the court underscored the critical role of internal police investigations when systemic misconduct was alleged. The resulting reforms and oversight shaped the resolution of civil claims, demonstrating that deferring litigation to await investigatory findings may enhance both accuracy and fairness. Similarly, in O'Brien v. Chief Constable of South Wales Police ([2005] UKHL 26), the House of Lords acknowledged the probative value of internal disciplinary findings in civil claims concerning police conduct. The judgment highlighted that internal reviews often yield essential context and factual clarification relevant to civil proceedings III. Risk of Premature or Fragmented Litigation Absent a stay, the parties risk engaging in premature motion practice and discovery based on incomplete or evolving factual circumstances. This may result in the need for amendments, redundant motions, or the revisiting of rulings, all of which impose additional burdens on the Court and litigants. IV. Good Faith Request Defendant emphasizes that this request is made in good faith and is narrowly tailored. The requested stay is limited in scope and duration, only until the Internal Affairs Group concludes its review. The intent is not to delay this litigation indefinitely, but to ensure adjudication proceeds on a full and reliable evidentiary foundation. V. Conclusion WHEREFORE, Defendant respectfully prays that the Court: GRANT a temporary stay of proceedings pending the conclusion of the Internal Affairs investigation; SET a status review date to evaluate the investigation’s progress and reassess the stay’s necessity; RETAIN full discretion to lift or modify the stay as appropriate. Respectfully submitted, /s/ IBRAHEEM A, DAVIS Ibraheem A. Davis Legal Representative Los Santos Police Department

Montblanc v. Los Santos Police Department Police Officer Shakhzadov (61658), and the Los Santos Police Department Case Number: 25-LSC-04113 Prepared by: Ibraheem A. Davis DEFENDANTS’ MOTION FOR EXTENSION OF TIME TO FILE RESPONSE, SUPPLEMENT IMMUNITY DEFENSE, AND COMPLY WITH SUBPOENA _______________________________________________ The Defendant, Los Santos Police Department, by and through undersigned counsel, and respectfully move this Honorable Court to grant an additional 72 hours to: Supplement the sovereign immunity pleading as directed by the Court, and To produce responsive documents as outlined in the Court’s Subpoena Duces Tecum. In support of this Motion, the Defendant state the following: The Court has granted Defendants 48 hours to supplement the immunity defense; however, additional time is necessary to review applicable precedents cited by the Plaintiff and provide a more detailed brief. The production of documents in response to the Subpoena requires coordination with internal records personnel, and proper redaction of sensitive information in accordance with Department and legal standards. This is the Defendants’ first request for an extension and is made in good faith, not for the purpose of delay. No prejudice will result to the Plaintiff, and the extension will promote a more complete and just record before the Court. WHEREFORE, Defendants respectfully request that the Court grant a 72 hour extension, extending the current deadline to 23 April 2025, for the supplementation of the sovereign immunity defense and compliance with the Subpoena Duces Tecum. Respectfully submitted, /s/ IBRAHEEM A, DAVIS Ibraheem A. Davis Legal Representative Los Santos Police Department

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Περιμενω screenshot με Γιωργο Μαζωνακη σαν Σεριφης

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