State of San Andreas Vs. Jackson Miller - Jun 28, 2023

Julian Locke

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Username: Julian Locke

Defendant: Jackson Miller

The defendant was arrested in this district on the following date Jun 28, 2023

Date of Arrest Jun 28, 2023

Defendants Plea Not Guilty

Main offense charged is a: Felony

Defendant has retained counsel: No

Charges under which defendant has been booked D.F. 1001.3 - Possession of CDS w/Intent to Traffic/Sale (Grams of Weed 60+) x1
D.F. 1003 - Sale of Illegal Drugs x1
P.C. 2113 - Fraud x1
N.M. 1015 - Unlawful Possession of Contraband x1

The Grounds for this Indictment are: During routine patrol on the night of 06/14/2023, myself and 667 | Jonathan Danley, hereby referred to as 667, were dispatched to a 10-31 (Suspicious Handoff call) near Cougar Ave. and North Rockford Dr. Myself and 667 arrived on scene from the north and found an apartment complex with steps leading down to a pool and parking area along with first level apartment rooms. There was only one way in for vehicles to this complex off of Cougar Ave. I parked my vehicle north of the complex on West Eclipse Blvd by the sidewalk. Myself and 667 then jumped up onto a roof of a business north of the complex to gain better visual down into the parking area where the call originated from. Once up on the building, I along with 667 witnessed two individuals conducting what seemed to be drug sales in the parking lot. I have two confirmed handoffs (evidence A1 and A2). After confirming handoffs I requested for backup units to my location so that we may conduct an arrest as I had probable cause to believe they were selling drugs. 601 | Wil Alexander advised they would be enroute to the scene so myself and 667 exited from the rooftop and re-entered my patrol vehicle. I drove the vehicle around to the entrance to the complex parking lot on Cougar Ave where I witnessed the suspect, Mr. Jackson Miller, still standing in the same location. The other individual on the scene began to flee on foot and I called out their description to additional units. That suspect was shortly thereafter lost. After I arrived at the apartment complex parking lot, I had exited my vehicle and immediately mirandized the suspect Jackson Miller and placed them in cuffs. I questioned their actions and they admitted to selling drugs. I then removed my camera from my patrol vehicle and took it out to take pictures finding several spots of drug residue on the scene (evidence A3). I had 667 collect some of the drug residue and it has since been placed into the evidence lockers at SSSO in the basement (evidence item A4). After securing the suspect into the back of my cruiser, myself and 667 transported them to Vinewood PD for processing. Upon arrival I searched their pockets and found 103x bags of weed (evidence B1) along with other illegal items such as 1x knuckle dusters and 1x lockpick (evidence B1). The suspect also had $4,467 in cash on them and claimed it was from doing PostOp jobs all day (evidence B1). After clearing the suspects pockets, I informed them of their potential charges. The suspect then explained to me that they would like to spill information about the person that made them sell these drugs on the street. I then informed 601 of the situation to which 601 advised me to call the District Attorney, at the time this was Nick Matthews.

After calling Nick Matthews, I was told to hold the suspect at Vinewood PD until his arrival, approximately 5 minutes after calling, so that the DA may speak with the suspect about becoming a confidential informant. The suspect was read the terms and agreements of this confidential informant agreement and agreed upon confirmation that they wouldn't be charged, they could keep their money and knuckle dusters along with the lock pick they had. The DA Nick Matthews confirmed this was the case and the suspect agreed to sign the document, this was then emailed to them (evidence C1). This document was signed on the late evening hours of 06/14/2023 (evidence C2). The document states that the CI must work with the agency and controlling agent (myself). I advised the informant in the cells prior to their release back on the streets that they need to check in with me in two days with more information regarding this individual they had information on.

A few days after signing the agreement, I spoke with detective 214 | Mike Jones, and informed them on the information I recieved in the cells that night that they knew of a location in Paleto and a suspect description. 214 suggestted that we schedule a meeting with the confidential informant. The next day I created an email chain with 214, Jackson Miller, and myself informing them that I did not have their phone number and they needed to contact me to discuss the agreement signed on the 14th and submitted for record on the 15th (evidence C3). I never recieved a response. On the 21st of June I informed the suspect that they needed to contact me with substantial information or the contract would be null and void (evidence C3). The timeframe I gave the suspect has passed and I am now submitting this warrant for their arrest.

Key Witnesses Called 603 - Cheddy James
667 - Jonathan Danley
601 - Wil Alexander

Witnesses Called 603 - Cheddy James
667 - Jonathan Danley
601 - Wil Alexander

Evidence Submitted Exhibits
A1 - https://i.gyazo.com/06f223b304bc3d75438f72dd47caa0b1.jpg
A2 - https://i.gyazo.com/50856544add3adaa43daa102e82da6b0.jpg
A3 - https://i.gyazo.com/e57d3d04d8d56f312964713b787387c4.jpg
A4 - https://i.gyazo.com/d2130dc931aeefbe3a3d0994543aea5b.jpg

B1 - https://i.gyazo.com/58b58e8d755e8c31ec9dcd0f4ac8f005.jpg
B2 - https://i.gyazo.com/51e0073e14cf3a037501a0642cf7143d.jpg
B3 - https://i.gyazo.com/7b9cb18cec2714d31b99dbb739f522e1.jpg

C1 - https://i.gyazo.com/b3c61225e31c06ec5ed43eaef2b29b66.png
C2 - https://docs.google.com/document/d/1VlftROUJNc2zAR6CBhFD0nl5sbEGtTO1OFz8b4vr9HM/edit
C3 - https://i.gyazo.com/fcdb469146cd4dfef3bd907c16f6390e.png

Evidence of Positive Identification(Photograph of Fingerprint Scanner/ID etc.):
B3 - https://i.gyazo.com/7b9cb18cec2714d31b99dbb739f522e1.jpg - Fingerprint confirming identity
B1 - https://i.gyazo.com/58b58e8d755e8c31ec9dcd0f4ac8f005.jpg - Top pockets (ID confirms, Jackson Miller)

Is the defendant on bail? Yes

Bail Amount 7500.00

Yes Yes

Signature on behalf of the State of San Andreas Julian Locke on behalf of the District Attorney's Office

Time of Arrest N/A
 

Wright

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Apr 25, 2021
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DISTRICT COURT OF SAN ANDREAS
The State of San Andreas vs Jackson Miller

Case - 2023-1010

Judge Devonte Wright Presiding

Decision: The Court finds sufficient evidence to proceed to trial.

Defendants plea: Not Guilty

Charges under which the defendant has been booked:
D.F. 1001.3 - Possession of CDS w/Intent to Traffic/Sale (Grams of Weed 60+) x1
D.F. 1003 - Sale of Illegal Drugs x1
P.C. 2113 - Fraud x1
N.M. 1015 - Unlawful Possession of Contraband x1


Jackson Miller ( @ZackDaLlama ), it is highly recommended that you seek your own BAR Certified lawyer immediately and if you are unable to afford one, please reach out to the Department of Justice. If you waive your right to counsel please inform the Department of Justice.

This court will move to trial to determine guilt. Discovery will end on the 6th of July, 2023. Court will be scheduled for between the 8th of July and the
14th of July, 2023. SELECT THE COURT CASE TIME AND DATE

@Julian Locke Please make sure that all of your key witnesses are deposed with the defense counsel present. This must be done in the presence of a court clerk, court reporter, or an impartial judicial figure.

Any preliminary matters or pre-trial motions can be posted on the docket or discussed at the beginning of trial.

Key Witnesses Called - You are hereby ordered by this court to attend this trial please insert your availability in the link above.
601 Alexander ( @Wil Alexander )
603 - Cheddy James ( @Cheddy )
667 - Jonathan Danley ( @Amir Yalonde )


Witnesses Called N/A

EVIDENCE - ACCEPTED
A1 - https://i.gyazo.com/06f223b304bc3d75438f72dd47caa0b1.jpg
A2 - https://i.gyazo.com/50856544add3adaa43daa102e82da6b0.jpg
A3 - https://i.gyazo.com/e57d3d04d8d56f312964713b787387c4.jpg
A4 - https://i.gyazo.com/d2130dc931aeefbe3a3d0994543aea5b.jpg

B1 - https://i.gyazo.com/58b58e8d755e8c31ec9dcd0f4ac8f005.jpg
B2 - https://i.gyazo.com/51e0073e14cf3a037501a0642cf7143d.jpg
B3 - https://i.gyazo.com/7b9cb18cec2714d31b99dbb739f522e1.jpg

C1 - https://i.gyazo.com/b3c61225e31c06ec5ed43eaef2b29b66.png
C2 - https://docs.google.com/document/d/1VlftROUJNc2zAR6CBhFD0nl5sbEGtTO1OFz8b4vr9HM/edit
C3 - https://i.gyazo.com/fcdb469146cd4dfef3bd907c16f6390e.png

Evidence of Positive Identification(Photograph of Fingerprint Scanner/ID etc.):
B3 - https://i.gyazo.com/7b9cb18cec2714d31b99dbb739f522e1.jpg - Fingerprint confirming identity
B1 - https://i.gyazo.com/58b58e8d755e8c31ec9dcd0f4ac8f005.jpg - Top pockets (ID confirms, Jackson Miller)
 

Wright

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sure that sounds good
Sir, I've reached out to a few defenders and Ms. Miles ( @Unknown ) has graciously agreed to take this case for you. Please reach out to her immediately so you can begin your defense.
 

Unknown

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your honour, i charlotte miles have spoken to Mr Miller and will be his legal representation for this case on his behalf.
 

Julian Locke

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Blaine County Sheriff's Office
Bar Certified Attorney
Member
Jun 17, 2021
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USA
My Characters
Julian Locke - Prosecuting Attorney
Charles Beckett - Department of Corrections (BCSO)
Dominic Walker
Your Honor,

Julian Locke will be representing the State in this matter.

Thank you.
 

Unknown

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your honour the defence would kindly ask the prosecution for a bill of particulars for the following charges:
D.F. 1001.3 - Possession of CDS w/Intent to Traffic/Sale (Grams of Weed 60+) x1
D.F. 1003 - Sale of Illegal Drugs x1
P.C. 2113 - Fraud x1
 

Wright

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Apr 25, 2021
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Defense's motion for Bill of Particulars is accepted by this court. The Prosecution will respond within 48 hours.
 

Unknown

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your honour the defence motions to dismiss the following charges:

D.F. 1001.3 - Possession of CDS w/Intent to Traffic/Sale (Grams of Weed 60+) x1

D.F. 1003 - Sale of Illegal Drugs x1

P.C. 2113 - Fraud x1


The Defence is willing to pursue this motion due to Mr Millers arrest was unjust falling under Mr Millers fourth amendment right being violated under the Precedent of Terry vs Ohio. (Cl 1001)

on the 28th of June 2023 my client Mr miller was wrongfully arrested and his fourth amendment right violated. this is due to Mr miller was arrested for a crime he was allegedly believed to have carried out. this falls under reasonable suspicion vs reasonable doubt Reasonable suspicion is a step before probable cause. At the point of reasonable suspicion, it appears that a crime may have been committed. The situation escalates to probable cause when it becomes obvious that a crime has most likely been committed. it is written in the arrest report Mr miller Was searched upon arrival of the police station after being placed in cuffs and mirandized for these alleged crimes. which they had no probable cause to prove a crime had been committed. under No circumstances was Mr miller liable for a search just because he was in the approximate area of reported criminal activity. under no circumstances it is stated in the arrest statement my client was frisked on scene.

the defence would like to like to bring the states attention to evidence A1 & A2 the photographic evidence provided shows 603 Mr Cheddy James' body camera showing himself on top of a roof leaning against a wall with approximately 1.5m of solid concrete in front of his person before it reaches the edge of the rooftop. claiming he can could see my client Mr Jackson miller standing in the parking lot of the apartment complex engaging in illegal illicit transactions involving a controlled dangerous substance when all i can see is officer James facing directly forwards crouching against the wall with limited vision with a solid obstruction in the way of his vision which does not allow such view into the parking area of the apartment complex attached is the imagery provided with indications of eye level and where Mr James claiming he has clear vision of also pointing with arrows indicating what he would see in that specific position.

The defence would like to submit evidence of a video recording I took myself wearing a body camera I had purchased and attached to my clothing and stood in the same position as Mr James and attempted to peep over the top of the roof letting the camera record my efforts and to show what Mr James' police issued body camera would have picked up in the same situation. I had also asked a member of the public Mr Chad Davis to stand in the parking lot area of the same apartment complex and i asked him to look up at where I would be and if he could see me at any point as i attempted to gain a visual on him inside of the parking lot. after thanking him for his time i asked him at any point did you see me attempt to peer over the surface of the rooftop which he told me he could not see me. The Defence would kindly request to add Chad Davis as a rebuttal witness.

video taken by myself

My client tells me he was rapidly approached with lights and sirens which had startled and scared him as he did not know why he was being approached in such a manner with officers jumping out of the vehicles and approached him inside of the parking lot in rapid succession due to the spontaneous appearance of police officers placing my client in handcuffs and mirandized him as soon as they exited the vehicle put him in a very stressful situation making him exclaim a spontaneous utterance to selling cannabis.


The Defence would like to state the Evidence provided in A3 has no relation due to the state has no evidence to indicate how it was produced or by whom it was produced.
 

Attachments

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Chance Noonan

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Your honor @Wright,

Chance Noonan as Special Prosecutor for the State of San Andreas.

After reviewing the evidence and the motions/responses by the defense counsel the State is dropping all charges.
 

Wright

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Court grants states motion for dismissal. Arrest is to be immediately removed from the suspects record. @Unknown