[CV-184] UNITED STATES vs. Charles Mctavish

[Steven Collin]

UNITED STATES OF AMERICA

DEPARTMENT OF JUSTICE

UNITED STATES OF AMERICA v. CHARLES MCTAVISH

CRIMINAL NO. 020727-A

I. OPENING STATEMENT

Your Honor,

The United States of America, acting through the Department of Justice and the Federal Bureau of Investigation, hereby brings the following criminal charges against the Defendant, Charles McTavish.

On July 4th, 2026, the Federal Bureau of Investigation, acting on evidence supplied by an undercover agent embedded within the group known as National Balla Association, hereinafter abbreviated as "NBA", executed a search warrant on a property registered to the Defendant under GPS marker NR 1307. The search recovered a quantity of restricted and surveillance-grade items, including a Vault Key count that exceeds the federal search warrant threshold on its own. A second property under the Defendant's control, marked NR 236, was found actively operating as an indoor cannabis production line, fitted with cultivation pots consistent with unlawful manufacture of a controlled substance.

The same undercover operation that identified the Defendant's residences also placed the Defendant at the National Balla Association headquarters on multiple occasions, where he was directly observed handling, storing and loading items later confirmed to be contraband. This activity formed the basis for a subsequent raid on the National Balla Association headquarters itself, which recovered a substantial cache of heavy firearms, explosive ordinance and controlled substances.

The Defendant was taken into custody on July 13th, 2026.

The Bureau submits that the totality of evidence recovered from both properties, combined with the undercover agent's direct observations of the Defendant's involvement with the NBA, establishes that Charles McTavish knowingly possessed multiple categories of federally and state-restricted items, manufactured a controlled substance, and knowingly assisted an organization engaged in the movement and storage of illegal items.

II. CHARGES

[5x] SA-PSC § VI.3 - Possession of Restricted Miscellaneous & Surveillance Items [F]
The Defendant was found in possession of the following items at NR 1307, none of which may be lawfully possessed by a private citizen under this section: 1x Drone, 1x Foldable Ballistic Shield, 1x Hacking Laptop, 1x Space Suit, and 15x Vault Keys.

[1x] U.S. CODE TITLE V, Section (C) Currency, Subsection (4)
The Defendant was found in possession of $6,400 in marked currency at NR 1307, an amount for which zero possession is permitted under this section regardless of quantity.

[1x] U.S. CODE TITLE VII, Section (E) Controlled Items, Subsection (4)(A)
Property NR 236 was confirmed to be operating as an active Cannabis production and cultivation site, fitted with pots consistent with the growing of Cannabis. Permitted manufacture of Cannabis Indica or Sativa under this subsection is zero regardless of quantity or intended use.

[1x] USC Title VI, Section (F) - Accomplice
The Defendant was directly observed by an undercover federal agent storing and loading items at the NBA headquarters, knowingly assisting the organization in the handling of illegal firearms, explosive ordinance and controlled substances later recovered in the raid on the headquarters. Under this title, an accomplice receives the same sentence as the principal offense assisted.

III. EVIDENCE

Exhibit A: Search Warrant Execution & Inventory Log NR 1307

Exhibit A: NR 1307 Inventory Log

Code: Select all

04-07-2026 21:01:10 - [ITEM] (script -> Steven_Collin (32)(60)) Drone [1][property:1307][had:1][robber:0,cop:1,admin:0][1010.31,2413.95,1501.07]
04-07-2026 21:01:44 - [ITEM] (script -> Steven_Collin (32)(60)) Folded Shield [1][property:1307][had:1][robber:0,cop:1,admin:0][1010.31,2413.95,1501.07]
04-07-2026 21:01:51 - [ITEM] (script -> Steven_Collin (32)(60)) Hacking Laptop [1][property:1307][had:2][robber:0,cop:1,admin:0][1010.31,2413.95,1501.07]
04-07-2026 21:01:59 - [ITEM] (script -> Steven_Collin (32)(60)) Marked Money [6400][property:1307][had:8000][robber:0,cop:1,admin:0][1010.31,2413.95,1501.07]
04-07-2026 21:02:17 - [ITEM] (script -> Steven_Collin (32)(60)) Space suit [1][property:1307][had:1][robber:0,cop:1,admin:0][1010.31,2413.95,1501.07]
04-07-2026 21:02:32 - [ITEM] (script -> Steven_Collin (32)(60)) Secret Vault Key [15][property:1307][had:19][robber:0,cop:1,admin:0][1010.31,2413.95,1501.07]

Exhibit B: Photographic Evidence Cannabis Grow House, NR 236

Exhibit B: NR 236 Grow House Photography

Exhibit C: NBA Surveillance, Apprehension & Processing Record

Exhibit C: NBA Surveillance, Apprehension & Processing Record

C.1 Undercover Surveillance Evidence

C.1: UC Agent Surveillance

Charles Mctavish loading illegal items form the NBA GS9 HQ storage

Charles Mctavish storing illegal items into the NBA GS9 HQ storage

C.2 Booking Photographs

C.2: Mugshots

C.3 Processing Logs

C.3: Processing Documentation

Code: Select all

[10:41:37] * Jak Petisi Wears a pair of latex gloves
[10:41:44] * Jak Petisi searches Charles Mctavish for weapons and items.
[10:42:11] Jak Petisi says [Afro-American accent]: For some reason I will need to Seize your licensed gun
[10:42:16] * Jak Petisi searches Charles Mctavish for weapons and items.
[10:42:20] You seized a(n) Desert eagle (53 ammo) from Charles Mctavish.
[10:42:20] * Jak Petisi seizes a(n) Desert eagle from Charles Mctavish.
[10:42:29] * Jak Petisi shows their FBI badge: FBI Agent Jak_Petisi.
[10:42:34] Charles Mctavish says: For a desert eagle?
[10:42:38] Jak Petisi says [Afro-American accent]: now stand in the middle
[10:42:46] Jak Petisi says [Afro-American accent]: here
[10:43:19] * Jak Petisi Turns on the camera , aims it at the Male's Face.
[10:43:24] Charles Mctavish says: Are you guys trying to find something on me?
[10:43:37] Jak Petisi says [Afro-American accent]: left
[10:43:47] Jak Petisi says [Afro-American accent]: left
[10:44:19] Jak Petisi says [Afro-American accent]: come here
[10:44:54] Jak Petisi says [Afro-American accent]: come here
[10:45:08] * Jak Petisi Turns one the Scanner Machine
[10:45:43] * Jak Petisi Release Male's Left hand and Places it on the scanner machine
[10:45:49] * 1/5 Scanning (Jak Petisi)
[10:45:54] * 2/5 Scanning (Jak Petisi)
[10:45:59] * 3/5 Scanning (Jak Petisi)
[10:46:02] * 4/5 Scanning (Jak Petisi)
[10:46:06] * 5/5 Scanning (Jak Petisi)
[10:46:20] * Jak Petisi Release Male's Right hand and Places it on the scanner machine
[10:46:23] * 1/5 Scanning (Jak Petisi)
[10:46:26] * 2/5 Scanning (Jak Petisi)
[10:46:29] * 3/5 Scanning (Jak Petisi)
[10:46:32] * 4/5 Scanning (Jak Petisi)
[10:46:35] * 5/5 Scanning (Jak Petisi)
[10:47:02] * Identified as Charles Mctavish in the Database (Jak Petisi)
[10:47:16] Jak Petisi says [Afro-American accent]: face ne
[10:47:18] Jak Petisi says [Afro-American accent]: face me
[10:47:40] * Jak Petisi Takes out a cotton swab in the Drawer
[10:47:47] Jak Petisi says [Afro-American accent]: open your mouth
[10:47:59] * Charles Mctavish open mouth.
[10:48:29] * Jak Petisi Places the Cotton swab in the Male's Mouth , Start collecting his saliva
[10:48:42] * the cotton swab would be wet. (Jak Petisi)
[10:49:04] * Jak Petisi Places the cotton swab in an Evidence bag 
[10:49:12] * Jak Petisi drags Charles Mctavish along.
[10:49:24] Jak Petisi says [Afro-American accent]: You have the right to remain silent. Anything you say can and will be used against you in a court of..
[10:49:24] Jak Petisi says [Afro-American accent]: You have the right to an attorney. If you cannot afford one, one will be provided for you.
[10:49:24] Jak Petisi says [Afro-American accent]: Do you understand these rights?
[10:49:26] Jak Petisi says [Afro-American accent]: all good?
[10:49:26] Charles Mctavish says: yeah

Exhibit D: NBA Headquarters Raid Report

Exhibit D: NBA HQ Raid Documentation

Code: Select all

04-07-2026 19:11:51 - [ITEM] (script -> Steven_Collin (60)(60)) Sniper [8][property:844][had:10][1261.52,-782.78,1091.90]
04-07-2026 19:11:55 - [ITEM] (script -> Steven_Collin (60)(60)) AK47 Case [25][property:844][had:57][robber:0,cop:1,admin:0][1261.52,-782.78,1091.90]
04-07-2026 19:12:11 - [ITEM] (script -> Steven_Collin (60)(60)) M4 Case [7][property:844][had:17][robber:0,cop:1,admin:0][1261.52,-782.78,1091.90]
04-07-2026 19:12:21 - [ITEM] (script -> Steven_Collin (60)(60)) Marked Money [3939][property:844][had:8754][robber:0,cop:1,admin:0][1261.52,-782.78,1091.90]
04-07-2026 19:12:31 - [ITEM] (script -> Steven_Collin (60)(60)) Molotov Cocktail [5][property:844][had:13][robber:0,cop:1,admin:0][1261.52,-782.78,1091.90]
04-07-2026 19:12:41 - [ITEM] (script -> Steven_Collin (60)(60)) Oxycodone [17][property:844][had:39][robber:0,cop:1,admin:0][1261.52,-782.78,1091.90]
04-07-2026 19:12:48 - [ITEM] (script -> Steven_Collin (60)(60)) Percocet [16][property:844][had:37][robber:0,cop:1,admin:0][1261.52,-782.78,1091.90]
04-07-2026 19:13:00 - [ITEM] (script -> Steven_Collin (60)(60)) RPG case [8][property:844][had:18][robber:0,cop:1,admin:0][1261.52,-782.78,1091.90]
04-07-2026 19:13:17 - [ITEM] (script -> Steven_Collin (60)(60)) Xanax [4][property:844][had:10][robber:0,cop:1,admin:0][1261.52,-782.78,1091.90]

This cache, recovered from NBA headquarters, supports the Accomplice charge in Section II. It is not separately charged as personal possession against the Defendant, as it was recovered from the organization's premises rather than his own person or property.

Exhibit E: Net Worth Verification at Time of Warrant Execution

Exhibit E: Net Worth Snapshot

Confirmed net worth at time of warrant execution: $72,470,997

Exhibit F: Total Confiscated Items Tied to Charged Offenses

Spoiler

Drone: 1 count
Folded Shield: 1 count
Hacking Laptop: 1 count
Marked Money (NR 1307): $6,400
Secret Vault Key: 15 count
Space suit: 1 count

Note: A Desert Eagle (licensed) was seized from the Defendant's person incident to arrest and remains in Bureau custody pending review; it is not charged as an independent offense in this filing.

IV. DEMANDS

• The Defendant to be imprisoned for a minimum of 15 years and a maximum of 20 years, the statutory ceiling applicable under USC Title VII (E) for the underlying Controlled Items and Accomplice charges, reflecting the severity of the NBA-linked enterprise activity and the aggravating Vault Key quantity recovered at NR 1307;
• The Defendant to be monetary fined $24,000,000, proportional to his confirmed net worth of $72,470,997 as established in Exhibit E;
• The property NR 1307 to be permanently seized and forfeited to the federal government, along with all Marked Money and Vault Keys recovered therein;
• Property NR 236 to be condemned and the cultivation equipment destroyed;

V. SETTLEMENT OFFER

The Federal Bureau of Investigation is prepared to offer the following, contingent upon a full guilty plea to all charges:

• If the Defendant pleads guilty, the Prosecution is willing to reduce the requested prison sentence from 20 years to 12 years.
• If the Defendant pleads guilty, the Prosecution is willing to lower the requested fine from $24,000,000 to $20,000,000.
• Seizure of the NR 1307 contraband and condemnation of NR 236 remain non-negotiable regardless of plea.

The Defendant must justify to the Court why any offered settlement would be unreasonable.

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VI. SIGNATORY

Dated: July 25th, 2026
Respectfully Submitted,
Steven Collin
Federal Prosecutor

[Mysha Basundhara]

State of San Andreas
First Judicial District Court
United States Courthouse
3321 Downtown Avenue, Los Santos, San Andreas

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United States
v.
Charles McTavish

CASE # CV-184
HONORABLE TRIAL JUDGE PRESIDING:
Mysha Basundhara

The First Judicial District Court recognises this Federal Lawsuit as submitted by Special Agent in Charge of Federal Bureau of Investigation Steven Collin, henceforth the Plaintiff, against the defendant Charles McTavish.. We do not recognise a registered lawyer present acting on behalf of the Defendant. Please either confirm whether you will be acting as your own legal counsel, or provide the details of your lawyer. Let it be recognised that the court has assigned this case ID # CV-184.

To the Defendant:
You have forty-eight (48) hours to confirm whether you will be represented by a legal counsel or intend to defend yourself in this case. If you have hired legal counsel, please have them reply to this court communique with their details. Failure to confirm these details within the 48 hour window will result in this court issuing a summons for your appearance. Failure to appear before this court does not invalidate this case and we will proceed without you if we need to.

(( Please forum PM me if there's a particular reason as to why this timeframe is unreasonable ))

To the Plaintiff:
You have the next 48 hours to provide this court with a witness list that you intend to call upon.

(( Please forum PM me with any supporting evidence that confirms the IC validity of your evidence ))

*Bangs her gavel.*

Signed,
Honorable Trial District Judge Mysha Basundhara

[Joaquin Trimino]

To the Honorable Judge Basundhara,

I, Theodore Carmichael, have been appointed to represent the defendant, Mr. Charles Mctavish, in the case currently before this court. I submit this to inform you that this is in relation to case ID # CV-184 brought against him by the Federal Bureau of Investigation's prosecution.

Any paper correspondence may be addressed at my private office, or if digital, may be sent to my email address.

Kind regards,
Theodore Carmichael
State Attorney at Law

[Steven Collin]

UNITED STATES OF AMERICA
v.
CHARLES MCTAVISH

Your honour,
The prosecution will call the following witnesses to the stand:

• Agent Thomas Buckley
• Special Agent Antonio Hernandez
• Special Agent Kiki Hunter (testimony limited to the arrest of the Defendant on July 13th)

Agent Buckley, Special Agent Hernandez and myself were present during execution of the search warrant.

Signed,

Steven Collin
Federal Prosecutor

[Mysha Basundhara]

State of San Andreas
First Judicial District Court
United States Courthouse
3321 Downtown Avenue, Los Santos, San Andreas

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UNITED STATES
v.
Charles Mctavish

CASE # CV-0184
HONORABLE TRIAL JUDGE PRESIDING:
Mysha Basundhara

The First Judicial District Court recognises the witness list provided by the Plaintiff, being; Mr. Thomas Buckley, Mr. Antonio Hernandez, Mr. Kiki Hunter.

The Court also acknowledges that Mr. Theodore Carmichael have been appointed to represent the defendant case.



The Plaintiff may start with their opening statement. Please begin.

Signed,
Honorable Trial District Judge Mysha Basundhara

[Steven Collin]

UNITED STATES OF AMERICA
v.
CHARLES MCTAVISH

Your Honor,
this case is simple. It’s about three locations and one man who ties them all together: Mr. Mctavish.

On July 4th, we executed a search warrant to search his home at NR 1307. Inside, we found 15 vault keys, a hacking laptop, a drone, a shield, a space suit, and $6,400 in marked cash. Normal people don't have these items and by law, regular citizens aren't allowed to own them.

He also owned a second property, NR 236. This wasn't a house but it was an active, working weed farm with plants in pots ready to go.
These two finds came from a longer undercover investigation into a gang called the National Balla Association. Undercover agents actually saw Mr. Mctavish at the gang's headquarters multiple times. He was actively loading and storing a stash of guns and drugs that we later grabbed during a raid on the building including rifles, explosives, and illegal drugs etc. He wasn't just watching but he was doing the work.

You don't have to take our word for it. Every item from his home is logged in evidence. The raid, the undercover photos, the arrest and the booking are all in the court record for you to see.
When you put it all together, Your Honor, you have a man storing illegal gear at home, running an illegal weed farm and helping a gang move weapons and drugs. That isn't bad luck it's a routine.

Once you see the evidence, the answer will be very clear.

Thank you, Your Honor.

Signed,

Steven Collin
Federal Prosecutor

[Joaquin Trimino]

MOTION TO DISMISS

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To the Honorable Court of San Andreas,

The defense respectfully moves this Court to dismiss the charges filed against Mr. Charles McTavish. This motion is grounded in several inconsistencies within the prosecution's case, namely reliance on unsubstantiated speculation, absent concrete evidence, and the concealment of an inadmissible interrogation.

I. A concealed interrogation took place and was never disclosed to this Court.

Upon consultation with Mr. Charles, it came to the defense's attention that an interrogation relevant to this case was conducted but never disclosed. This interrogation was conducted in a coercive manner and in the absence of proper procedures. Mr. Charles was not read his rights, nor was he informed of his right to have counsel present. Furthermore, the defendant attempted to coerce him into signing a document under the false pretense that doing so would secure his release which is a clear attempt to extract an admission of guilt outside the bounds of lawful procedure. The defense respectfully requests that the Court order the plaintiff to produce the interrogation recording.

II. The prosecution has brought multiple charges founded entirely on speculation.

The charge under USC Title VI, Section (F), Accomplice rests entirely on speculation. The plaintiff alleges that Mr. Charles directly assisted a crime organization known as the "National Balla Association," yet has failed to provide concrete evidence establishing any direct link between Mr. Charles and said organization.

The charge under U.S. Code Title V, Section (C), Currency, Subsection (4) is similarly invalid. The precise wording of the statute in federal law requires that marked bills be obtained through either an ATM robbery or a bank robbery. Mr. Charles was not a participant in either offense, and maintains that he had no knowledge of the money's origin. Funds obtained through ATM robbery typically range between $8,000 and $12,000, while funds from a bank robbery are usually gold bars. The sum recovered from the property in question totals only $6,400, an amount insufficient to prove his link to either crimes. The charge doesn't fall under Subsection (2) either, as no evidence has been presented that the funds were ever used, or attempted to be used, in payments.

III. An unlawful demand brought by the prosecution.

The prosecution's request for the permanent seizure and condemnation of two properties, designated NR 1307 and NR 236, constitutes an unconstitutional demand. It stands as a direct violation of Section 3, Article 1 of the Bill of Rights, which guarantees all citizens the free ownership of property. The nationalization of property must be appealed before Congress, not this Court, and requires demonstrable proof that such action would serve the betterment of the surrounding citizens. The prosecution has offered no such proof.

IV. Request for dismissal.

For the aforementioned reasons, the defense respectfully requests the full or partial dismissal of the charges against Mr. Charles McTavish.

Should the Court decline to grant full dismissal, the defense respectfully requests that the Court:

• Strike down any invalid charges, particularly those enumerated above;
• Compel production of the recordings from the concealed interrogation;
• Revise the prosecution's demands, as they are excessive and unlawful in their current form.

Kind regards,
Theodore Carmichael
State Attorney-at-Law