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IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS LOS SANTOS POLICE DEPARTMENT, Petitioner and Appellant, v. 59TH AND HARLOW BLOODS GANG, Respondent. Superior Court Case No. 25-LSC-04113 PETITION FOR CIVIL GANG INJUNCTION ───────────── LOS SANTOS POLICE DEPARTMENT *Alexander C. Braithwaite IV, State Bar No. 00000 [email protected] 1886 Hopkins Ave, 2nd Floor Los Santos, San Andreas 272-3544 Attorney for Plaintiff THE PEOPLE OF THE STATE OF SAN ANDREAS Petitioner LOS SANTOS POLICE DEPARTMENT TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. II. JURISDICTION................................................................................................................ III. GANG OVERVIEW......................................................................................................... A. Summary of Facts................................................................................................... 1. Rise in Gang Activity..................................................................................... 2. Critical Incidents in March 2025.................................................................... 3. Murder of Police Sergeant I Miguel Ruano................................................... IV. CRIMINAL PATTERN & PUBLIC SAFETY IMPACT ................................................. V. PRAYER FOR INJUNCTIVE RELIEF............................................................................ A. KNOWN MEMBERS (as documented in SanGang)............................................. B. SAFETY ZONE (Injunction Area) VI. CONCLUSION.................................................................................................................. I. INTRODUCTION ᅠᅠ I, DIEGO OBREGON, being duly sworn, declare that I am a Police Captain III and Commanding Officer of the Los Santos Police Department's Gang and Narcotics Division. I have been with the Los Santos Police Department for 26 years, with 20 years specifically dedicated to gang enforcement and investigation. ᅠᅠ I submit this affidavit in support of a Gang Injunction against the 59th & Harlow Bloods (59HB), a criminal street gang operating primarily in Idlewood area of Los Santos, San Andreas. This affidavit is based on my personal knowledge, training, experience, and information provided to me by other law enforcement officers and investigators involved in this investigation. ᅠᅠ The requested injunction is necessary to disrupt 59HB's criminal activities, prevent further violence, and restore safety to the affected neighborhoods. Without court intervention, 59HB will continue to terrorize the community, perpetuate violence, and expand their criminal operations. ᅠᅠ This injunction is necessary to disrupt the gang's operations, prevent further violence, and restore safety to the affected neighborhoods. II. JURISDICTION ᅠᅠ This Court has jurisdiction over this matter pursuant to the laws of San Andreas governing public nuisance abatement and gang injunctions. The criminal activities of the 59th & Harlow Bloods described in this affidavit have occurred within the City of Los Santos, San Andreas, placing this matter squarely within the Court's jurisdiction. III. STATEMENT OF THE CASE ᅠᅠ A. Summary of Facts. ᅠᅠ The 59th & Harlow Bloods (59HB) is a documented Bloods gang operating primarily in the Idlewood area of Los Santos. Following the dismantling of the Crystal Garden Bloods, law enforcement has observed a significant resurgence of gang-related criminal activity in the area as 59HB and associated street gangs appear to be filling the resulting power vacuum. ᅠᅠ Intelligence gathered by the Los Santos Police Department indicates ongoing alliances between 59HB and ████████████. This alliance was evidenced on March 9, 2025, when officers observed members of both gangs attending a party hosted by 59HB at a strip club in their territory. During this encounter, Sergeant Miguel Ruano spoke with ████████ high council member ████████, who confirmed the gathering was hosted by 59HB and attended by multiple gangs that appeared to be at peace with one another. This interaction further confirms the ties between ████ and 59HB. ᅠᅠ The 59HB maintains a strong presence in several key locations within Idlewood, including: Idlewood Go-Gas station Winona Avenue Martin Luther King Boulevard 2. Critical Incidents in March 2025. ᅠᅠ In March 2025 alone, there were several critical incidents involving members of the 59th & Harlow Bloods that demonstrate the escalating danger posed by this criminal organization: March 9, 2025 - Gang Gathering Incident ᅠᅠ At approximately 23:00 hours, Sergeant Ruano, Officer ████████, Officer ████████, and Officer ████████ were conducting a gang suppression patrol when they encountered a large group at the Idlewood Gas Station, including documented 59HB member Tavarius Johnson and numerous affiliates. During this encounter, officers documented Jamal Baker into the SanGang system after observing multiple 59HB gang tattoos on his body and obtaining his self-admission of gang affiliation. During this interaction, members of ████████████, including high council members ████████████ and ████████████, arrived at the location, further confirming the alliance between these criminal organizations. March 10, 2025 - Gang Brawl ᅠᅠ At approximately 01:00 hours, Officer ████████████ and Officer ████████████ responded to a backup request regarding a gang brawl at Imperial Avenue and 38th Street. Upon arrival, they observed two members of the 38th Street gang, identified as ████████████ and ████████████, physically assaulting two individuals identified as 59HB affiliates based on their clothing and prior observations. This incident demonstrates the ongoing territorial disputes and violence perpetrated by 59HB and rival gangs in the area. March 18, 2025 - Assault and Weapons Incident ᅠᅠ Shortly before midnight, Sergeant Ruano, Sergeant ███████████, and Officer ████████ were patrolling Idlewood when they encountered a large group of 59HB affiliates assaulting a white male victim. During the intervention, officers pursued and apprehended Bao Ling, who had been previously observed with known 59HB affiliates. A search incident to arrest revealed Ling was carrying a handgun. During processing, Ling admitted his affiliation with 59HB, leading to his documentation in the SanGang system. February 25, 2025 - Armed Suspect Incident ᅠᅠ At approximately 22:30 hours, Officer ████████████ responded to a backup request from Sergeant ████████████ regarding an armed suspect fleeing southbound on Crenshaw Boulevard. The suspect, later identified as Tavarius Johnson, was apprehended on Martin Luther King Boulevard. A Glock 19 handgun was recovered from Johnson's possession. During processing at Harbor Community Police Station, officers observed tattoos on Johnson's body referencing 59HB affiliation. 3. Murder of Police Sergeant I Miguel Ruano. ᅠᅠ On March 26, 2025, Sergeant Miguel Ruano, assigned to the Harbor Gang Enforcement Detail (GED), was abducted in broad daylight while conducting a routine traffic stop. Digital In-Car Video (DICV) footage from Sergeant Ruano's police vehicle shows him stopping a black Premier vehicle when a black Burrito van without license plates arrived at the scene. Two masked and gloved suspects exited the van—one armed with an M4 rifle and the other with a shotgun. The suspects forcibly subdued and restrained Sergeant Ruano before placing him in the van's rear compartment. The Burrito was last seen traveling northbound on Palmwood Avenue into Jefferson. ᅠᅠ Sergeant Ruano's body was later discovered at the abandoned airport in Las Venturas. He had sustained gunshot wounds consistent with an execution-style homicide. METRO SWAT responded to the location and discovered not only Sergeant Ruano's body but also the body of LaVonn Mosley, who had sustained multiple gunshot wounds during the law enforcement response. Tavarius Johnson, a documented member of 59HB, was arrested at the scene for accessory to murder but was later released on parole. ᅠᅠ Following Sergeant Ruano's homicide, the Los Santos Police Department launched Operation Rock Hill, a coordinated enforcement effort targeting 59HB and their criminal enterprises. Detectives continue to analyze forensic evidence and pursue leads to identify and apprehend all suspects responsible for the murder. IV. CRIMINAL PATTER & PUBLIC SAFETY IMPACT ᅠᅠ The 59th & Harlow Bloods have established a clear pattern of criminal activity that poses a significant threat to public safety in the Idlewood area and beyond. Their criminal enterprises include: Narcotics Trafficking: Intelligence gathered by LSPD indicates 59HB is heavily involved in the distribution of controlled substances throughout their territory Illegal Firearms Possession: Multiple incidents documented in this affidavit demonstrate 59HB members routinely carry and use firearms, including the February 25, 2025 incident involving Tavarius Johnson (Glock 19 handgun) and the March 18, 2025 incident involving Bao Ling (handgun). Violent Assaults: The March 18, 2025 incident where officers observed multiple 59HB affiliates assaulting a civilian demonstrates the gang's propensity for violence against community members. Gang-Related Violence: The March 10, 2025 brawl between 59HB affiliates and 38th Street gang members illustrates the ongoing territorial disputes that endanger uninvolved community members. Murder: The execution-style killing of Sergeant Ruano represents the most extreme example of 59HB's violent capabilities and complete disregard for human life and law enforcement. ᅠᅠ The presence of 59HB in Idlewood has led to a surge in violent crime, with frequent shootings and armed confrontations that put both law enforcement and the public at serious risk. Residents in the affected areas live in fear, and legitimate businesses suffer as criminal activity drives away customers and discourages economic development. ᅠᅠ V. PRAYER FOR INJUNCTIVE RELIEF A. KNOWN MEMBERS (as documented in SanGang). 1. BAO LING / MEMBER 2. TAVARIUS JOHNSON / MEMBER 3. JAMAR BAKER / MEMBER 4. DEIMOS GRIM / MEMBER 5. RASHAD MOSLEY / MEMBER B. B. SAFETY ZONE (Injunction Area) ᅠᅠ The requested injunction would apply to the following areas of Idlewood, where 59HB has established a strong presence: Artesia Avenue Lennox Avenue Winona Avenue ᅠᅠ Within this Safety Zone, I request that the Court prohibit the following activities by documented 59HB members: ᅠᅠ [X] Denial of association: All subjects sitting, standing,walking, driving, gathering or appearing anywhere in public view or any place accessible to the public with any known member of the 59th & Harlow Bloods but not including: when all members are inside a school attending class, on school business or when inside of a church, providing that this prohibition against associating apply while travelling to said locations. ᅠᅠ [X] No guns or dangerous weapons: Anywhere in public view or anywhere accessible to the public. Carrying any gun or illegal weapon as defined in penal code sections (9)01, (9)02,(9)04,(9)05, (9)07 and (9)09. Knowingly remaining in the presence of such a weapon or gun or a person possessing such a weapon or gun. ᅠᅠ [X] No intimidation: Confronting, intimidating, harassing, annoying, threatening, challenging, provoking, assaulting or committing battery against any person engaged in lawful or peaceful business within the safety zone without due cause or reason. ᅠᅠ [X]No Graffiti or Graffiti tools: Damaging, defacing or marking any public or private property of another or possessing any graffiti capable device, including spray paint and markers. ᅠᅠ [X] Stay away from drugs: Without a prescription, selling, possessing or using any controlled substance or related paraphernalia, including but not limited to rolling paper and pipes for drug use. Knowingly remaining in the presence of any controlled substance or related paraphernalia or knowingly remaining in the presence of anyone possessing controlled substances or paraphernalia. ᅠᅠ [X] No drug sales activities: Loiter anywhere in public view or anyplace accessible to the public in a manner and under circumstances manifesting the purpose and with the intent to commit an offense specified in penal code sections (6)03 and (6)04. Circumstances that may be considered in determining whether a person has the requisite intent to engage in such drug sales activity include: Acting as a "Lookout", transferring small objects or packages for currency in a furtive manner, trying to conceal him or herself or any object that reasonably could be involved in an unlawful drug-related activity, uses signals or language indicative of summoning purchasers of illegal drugs, repeatedly beckons to, stops, attempts to stop, or engages in conversations with passersby, whether on foot or in a motor vehicle, indicative of summoning purchasers of illegal drugs. Repeatedly passes to or receives from a passerby, whether on foot or in a motor vehicle, money or small objects. Has been convicted of any offense within this State within five months prior to a violation of this provision, of any violation of penal code sections(6)03 and (6)04. and is currently subject to any order prohibiting his or her presence in any high drug activity geographic area. ᅠᅠ [X] Stay away from alcohol: Anywhere in public view or any place accessible by the public, except on properly licensed premises the possession of an open alcohol container of an alcoholic beverage or knowingly remaining in the presence of such a container and substance or knowingly remaining in the presence of someone in possession of such a container or substance. ᅠᅠ [X] No Trespassing: Being present on or in any property not open to the general public except: with the prior written consent of the owner or person who is in lawful possession of the property or in the presence of the owner of the person who is in lawful possession of the property. ᅠᅠ [X] No loitering: Loitering in public view or any place accessible to the general public for the purpose of engaging in graffiti, drug-related or other illegal activities. ᅠᅠ [X] No lookouts: Acting as a lookout by whistling, yelling, or otherwise signaling, by any means, to warn another person engaged in unlawful or nuisance activity of the approach of law enforcement officers or soliciting, employing or coercing another person to act as such lookout. ᅠᅠ [X] No Obstructing Traffic: Obstructing, impeding or blocking the passage of any vehicle or person on any street, walkway, sidewalk, alleyway, driveway, parking lot or other areas of public access. ᅠᅠ [X] No recruiting children: Soliciting or recruiting anyone under the age of 18 to join, actively participate in, or associate with the intent to join the 59th & Harlow Bloods. ᅠᅠ [X] 59th & Harlow Bloods members and affiliates are to stay away from Artesia Avenue, Lennox Avenue, and Winona Avenue: Being present on or in Artesia Avenue, Lennox Avenue, and Winona Avenue. For purposes of this provision, LOCATION includes properties, sidewalks and adjacent parking lots to LOCATION. ᅠᅠ [X] Do not Obstruct, resist or Delay any Peace Officer: Knowingly obstructing, resisting or delaying any peace officer when that peace officer is effectuating or attempting to effectuate lawful detention or arrest. This includes but is not limited to: Running from a peace officer in an attempt to evade lawful detention or arrest and providing false identifying information to any peace officer in an attempt to evade proper identification by the peace officer. ᅠᅠ [X] Obey all laws: Obey all laws and sections of the penal code. V. CONCLUSION ᅠᅠ Based on my training, experience, and the facts set forth in this affidavit, I believe that the 59th & Harlow Bloods constitute a public nuisance that significantly threatens the safety and welfare of the Los Santos community, particularly in the Idlewood area. The gang's involvement in narcotics trafficking, illegal firearms possession, violent assaults, and the murder of Sergeant Miguel Ruano demonstrates their ongoing criminal enterprise and complete disregard for public safety and the law. ᅠᅠ The requested injunction is necessary to disrupt 59HB's criminal activities, prevent further violence, and restore safety to the affected neighborhoods. Without court intervention, 59HB will continue to terrorize the community, perpetuate violence, and expand their criminal operations. ᅠᅠ DATED: April 15, 2025 By: /s/ Alexander C. Braithwaite IV Alexander C. Braithwaite IV Chief Prosecutor LOS SANTOS POLICE DEPARTMENT

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