Your Honor,
The Prosecution respectfully submits the following Heads of argument to the Defendant's Exceptio.
I. Pattern of erratic behaviour from Sheriff Deputy Mia Townsend
In Sheriff Deputy Mia Townsend's interaction with Ms. Piper Lynch, there is a clear aggressive stance in Sheriff Deputy Mia Townsend trying to enforce the illegal order. We refer you to Evidence III - Exhibit B your Honor in the interrogation. Kindly note the following from the body won camera of the Deputy:
[20:38:56] Mask_38279 shouts [British accent]: Hello?!
[20:39:05] Mask_38279 shouts [British accent]: Do ya hear me!
[20:39:11] Mask_44431 shouts [Redneck accent]: DO YOU HEAR ME!
[20:39:14] Mask_44431 shouts [Redneck accent]: GET OUT?!
[20:39:17] Mask_38279 says [British accent]: I hear you but you don't
[20:39:19] Mask_44431 shouts [Redneck accent]: Out of the room!
[20:39:21] Mask_38279 says [British accent]: What's your name and badge
[20:39:24] Screenshot Taken - sa-mp-094.png
[20:39:25] Mask_44431 shouts [Redneck accent]: Get Out!
In part of her interaction, at no point did Sheriff Deputy Mia Townsend approach Ms. Piper Lynch and explain her legal standing in asking to be followed outside. This is demonstrated again in
Evidence III Exhibit B
***[20:38:20] Mask_38279 says [British accent]: Yo?
[20:38:22] Mask_44431 says [Redneck accent]: Allright sir or ma'am or what ever
[20:38:26] Mask_44431 says [Redneck accent]: please follow me outside
[20:38:28] Mask_38279 says [British accent]: Yes?
[20:38:30] Mask_38279 says [British accent]: For what?
[20:38:37] Mask_44431 says [Redneck accent]: You're going out
[20:38:41] Mask_38279 says [British accent]: For?
[20:38:44] Alexander Gianascoli (microphone) [American accent]: This city is being used for criminal activities alot.
[20:38:52] Mask_38279 says [British accent]: Hello?
[20:38:55] Alexander Gianascoli (microphone) [American accent]: And the law enforcement agents are hardly trying to stop this.
Ms. Piper Lynch, an accredited journalist, asked twice, we'll quote her verbatim, "For what?". It is prudent to state that as a Peace Officer, whence enforcing your powers as a Peace Officer, upon another person. In this case, Ms. Piper Lynch. You are mandated to explain to them exactly why they are being escorted out of the premises. Ms. Piper Lynch asked not only once, but twice what is she being asked outside for. The only simple nonchalant response was "You're going out". Ms. Piper Lynch received zero explanation.
Your Honor, we move to take you to a second instance of the erratic behaviour from the Deputy. In her ongoing interaction with Sheriff Deputy Mia Townsend. Ms. Piper Lynch asked for the Sheriff Deputy's name and badge number twice to which, Sheriff Deputy Mia Townsend took exactly 1 minute 39 seconds to identify herself, in a situation that only requires a few seconds of doing so. The interaction of such an instance is provided for below
Evidence III, Exhibit B:
[20:39:21] Mask_38279 says [British accent]: What's your name and badge
[20:39:24] Screenshot Taken - sa-mp-094.png
[20:39:25] Mask_44431 shouts [Redneck accent]: Get Out!
[20:39:27] * Mask_38279 records the officer.
[20:39:32] Mask_38279 says [British accent]: What is your badge?
[20:39:41] Mask_38279 says [British accent]: And what the order is about?
[20:39:44] Alexander Gianascoli (microphone) [American accent]: Okay guys, let's pause this for a moment.
[20:39:45] Mask_44431 says [Redneck accent]: I've been asked by the candidate's men to get out
[20:39:51] Mask_44431 says [Redneck accent]: Now leave
[20:39:55] Mask_38279 says [British accent]: Candidate's men?
[20:40:06] Mask_44431 says [Redneck accent]: Leave the room
[20:40:06] Mask_38279 says [British accent]: Candidate's men ordering you to kick out a press?
[20:40:17] Mask_44431 says [Redneck accent]: you'll be charged with failure to obey a law enforcer
[20:40:18] Mask_38279 says [British accent]: This is not his private properly?
[20:40:21] Mask_44431 says [Redneck accent]: That'll be your own risk
[20:40:30] Mask_38279 says [British accent]: I'll leave but can you show me your badge
[20:40:30] Mask_44431 says [Redneck accent]: Now leave the room sir
[20:40:41] Mask_44431 says [Redneck accent]: Inspector Townsend badge 123
Your Honor, again kindly takes a fervent note of how Sheriff Deputy Mia Townsend only bothered to cite any legalese jargon after 2 minutes and 6 seconds after she initially said "please follow me outside". Even with such consideration of your Honor, Sheriff Deputy Mia Townsend wholly threatened Ms. Piper Lynch with "failure to obey an officer of the law". If it pleases this Court, your Honor, I would like to take this Court to "SA-PSC § II.26. Failure to Obey a Law Enforcement Officer". Reads as follows:
"It is unlawful for any person to fail or refuse to comply with any lawful order or direction of any Law Enforcement Officer." Your honor, I submit to this Court that Sheriff Deputy Mia Townsend not only was aggressive in her diction towards Ms. Piper Lynch, but she had no legal standing to enforce this law which is provided for in the San Andreas State Code. When Sheriff Deputy Mia Townsend threatened Ms. Piper Lynch with enforcement of such, at no point in time did Ms. Piper Lynch offer any physical resistance, nor pose any threatening manner towards the Sheriff Deputy. Your Honor, the enforcement of Sheriff Deputy Mia Townsend's powers in this regard does not stand the reasonable person's test in law, wherein conduct, judgment, and character are pitted against an objective standard.
Your Honor, I move to the third instance, demonstrating erratic behaviour by Sheriff Deputy Mia Townsend. If we recall from
Evidence III, Exhibit B. Sheriff Deputy then proceeds to pull out her taser in response to Ms. Piper Lynch's genuine concerns around her abrupt removal from the room. Whilst conducting our research on the manual of procedure for Sheriff Deputy Mia Townsend's respective Sheriff’s Department. There is not a clear and set official policy on the scales of force which leaves much to be desired on Sheriff Deputy Mia Townsend's training. Thus, we were compelled to seek alternative Peace Officer resources, that being of the San Andreas Police Department, as both SAPD and SASD are held to the same legal standards. Kindly note this excerpt from the San Andreas Police Department's Manual of Procedure on the Scales of force:
020. USE OF FORCE POLICY
020.10 USE OF DE-ESCALATION TECHNIQUES
It is the policy of this department that, whenever feasible, officers shall use techniques and tools to reduce the intensity of any encounter with a suspect and to maintain control of the situation.
020.11 VERBAL WARNINGS
Where feasible, a peace officer shall, prior the use of any force, make reasonable efforts to identify themselves as a peace officer and to warn that force may be used, unless the officer has objectively reasonable grounds to believe the person is aware of these facts.
020.12 SITUATION EVALUATION
A peace officer shall evaluate a situation, prior the use of any force, while taking the following factors into account. Factors include but are not limited to:
Outstanding charges on the suspect;
Availability of officers on the scene;
Amount of potential accomplices or aiders;
Ability of fleeing the scene in case of escalation.
020.13 DRAWING OR EXHIBITING FIREARMS
Unnecessarily exhibiting a firearm limits an officer's alternatives in controlling a situation, creates unnecessary anxiety, and may result in an unwarranted discharge of a firearm. Officers shall not exhibit and point a firearm unless the circumstances warrant the usage of deadly force.
020.20 NON-DEADLY FORCE
It is the policy of this department that officers shall use empty-handed techniques or less than lethal equipment upon another person only when the officer reasonably believes, based on the totality of circumstances, that such force is necessary for one of the following reasons:
Defend themselves or others;
Effect an arrest or detention;
Prevent escape or overcome resistance.
020.30 DEADLY FORCE
It is the policy of this department that officers shall use lethal equipment upon another person only when the officer reasonably believes, based on the totality of circumstances, that such force is necessary for one of the following reasons:
Defend against an imminent threat of death or serious bodily injury to oneself or another person;
Apprehend a fleeing person for any felony that resulted in death or serious bodily injury to oneself or another officer.
In Volume II, section 020, subsection 020.12 stated as Situation Evaluation the policy outlines 4 clear sets of instances that an officer ought to meet before escalating matters. Your Honor, I move you to subsection 020.13, Drawing or Exhibiting Firearms :
Unnecessarily exhibiting a firearm limits an officer's alternatives in controlling a situation, creates unnecessary anxiety, and may result in an unwarranted discharge of a firearm. Officers shall not exhibit and point a firearm unless the circumstances warrant the usage of deadly force.
This policy clearly states how unnecessarily exhibiting a firearm, in this case that would be substituted for a taser, limits an officer's ability to control a situation and creates an environment of anxiety. Officers shall not exhibit and point a firearm unless the circumstances the usage of such force. In this instance, your Honor, not only did Ms. Piper Lynch pose no physical threat to the Deputy and the people around her, she demonstrated her dissatisfaction and inquisitive native in a calm manner by asking the correct question of the Sheriff Deputy Mia Townsend. Instead, Ms. Piper Lynch was met with hostilities from the very instance of being shouted at by the Sheriff Deputy to get out, to the point at which Sheriff Deputy Mia Townsend deployed her taser in a situation that did not warrant the deployment of such. Ms. Piper Lynch, throughout this whole traumatic event, maintained a calm demeanor in a situation that would have otherwise created angst and anxiety.
Following these instances of erratic behaviour, I bring to this Court to submit the Prosecution's last instance in a bid to demonstrate beyond a reasonable doubt that Sheriff Deputy Mia Townsend has demonstrated a clear pattern of erratic behaviour. In Sheriff Deputy Mia Townsend’s interrogation with Special Agent Garnet from
Evidence III, Exhibit C, she mentioned she took orders from one of the Candidate’s "men" referred herein as the aids in the following statement below:
[21:49:14] Mia Townsend says [Redneck accent]: So Ms.Kirisame's asistant whispered to me to get the news reporter out of the confenrece ..
[21:49:14] ..room
[21:49:26] Lance Garnet says: How many times did she ask the candidate? Did she disturb the campaign event? Did she disrupt the campaign..
[21:49:26] .. event?
[21:49:40] Lance Garnet says: Who's the assistant? I need a name.
[21:49:42] Mia Townsend says [Redneck accent]: I guess the campagin were running short of time
[21:50:14] Mia Townsend says [Redneck accent]: Honestly i do not remember,many days have passed from that event
[21:50:43] Lance Garnet says: I will give you a name, and you confirm it, did Alexander Gianascoli order you to escort Piper Lynch out o..
[21:50:43] ..f the building?
[21:50:53] Mia Townsend says [Redneck accent]: I guess so
[21:50:56] Mia Townsend says [Redneck accent]: Not sure
[21:50:57] Lance Garnet says: Is that a yes or no?
[21:51:00] Lance Garnet says: Alright.
[21:51:03] Mia Townsend says [Redneck accent]: it rings a bell.
[21:51:13] Lance Garnet says: Is he your superior?
[21:51:52] Mia Townsend says [Redneck accent]: Well they were running the campaign to it's their own decision weather to keep people ins..
[21:51:52] ..ide the room or not
If it pleases this Court, kindly take note of the highlighted in red moments of the interview transcript. Wherein, Sheriff Deputy Mia Townsend is wholly unsure herself where the order came from. This is in stark contrast to the Defendant's counsel, who stated the order came from the Sheriff's Department Sergeant Kondo Tadao. I put it to the Defendant, which is it? Was it the Sergeant, or was it the Candidate’s aide. This once again, your Honor, is clear and incontrovertible evidence of Sheriff Deputy Mia Townsend failing to correctly identify where the order came from.
I put it before this Court that does this sound like the actions of a well trained and competent officer in light of all the evidence levelled against her? The Plaintiff has clearly demonstrated beyond reasonable doubt in this regard to Sheriff Deputy Mia Townsend's incompetence and insufficient training from her respective department. Considering the fact that Ms. Mia Townsend has been employed in different law enforcement agencies throughout the past years of her service, the lack of experience is no excuse.
It is also prudent to mention that the Defendant's Counsel asserts that Sheriff Deputy Mia Townsend received her orders from Sheriff's Department Sergeant Kondo Tadao to extricate Ms. Piper Lynch from the premises. Say for a second we entertain this fallacious assertion. If we may refer this Court to the San Andreas Police Department's manual of procedure & San Andreas Sheriff's Department Contract:
010.20 ACCOUNTABILITY
010.21 RESPONSIBILITY FOR ACTIONS
An officer is always accountable for their actions and decisions in performing their daily duties. Misuse of authority or conduct unbecoming of an officer is subjected for review and a minimum punishment of a suspension.
SECTION 1 | DUTIES AND OBLIGATIONS
Employee's duties and obligations shall include but not be limited to:
• Obligation of abiding lawful orders issued by superiors.
San Andreas Sheriff's Department Contract:
Section I - Obligations
Employee's obligations shall include, but not be limited to:
The obligation of abiding by the regulations, protocols, and procedures imposed by the department.,
The obligation of abiding lawful orders issued by superiors.
These three sections clearly state that an officer is to always to be held accountable for their actions at all times. This is in line with the law itself. If your Honor pays close attention to section I, it clearly states that an officer is to abide by lawful orders issued by superiors. Once again, your Honor, the legal standards remain the same across agencies. An officer, in this case a Sheriff Deputy, is to abide by lawful orders from their superiors. As we have established beyond a reasonable doubt that the orders allegedly issued by the Sheriff's Department Sergeant Kondo Tadao are unlawful in this regard, following the rationale that we have put forth above.
II. Inconsistency in Departmental Practices
Your Honor, in this matter, we as the Plaintiff move to assert that the San Andreas Sheriff's Department, with regard to Sheriff Deputy Mia Townsend, demonstrated a rather unusual practice, upon Ms. Piper Lynch complaining about Sheriff Deputy Mia Townsend's unlawful actions to Sheriff's Department Sergeant Kondo Tadao. She was rather unsatisfied with the handling of the matter and then proceeded to file an official complaint to the San Andreas Sheriff's Department website on Sheriff Deputy Mia Townsend's actions to the Department's Internal Affairs to investigate the matter. After a rather paltry handling of the matter by the Department's Internal Affairs, Ms. Piper Lynch sought to seek justice from the United States Senate to which the United States Senate issued a directive to the Federal Bureau of Investigation to conduct an investigation into the matter attached below:
To make it abundantly clear to this Court. Sheriff Deputy Mia Townsend was initially issued an official warning for actions on the day of handling Ms. Piper Lynch's matter. Thereafter the Internal Affairs team reverted their initial official warning to a 14 day suspension of active duty. Pursuant to the 14 day suspension, Sheriff Deputy Mia Townsend was then allowed to resume her official duties on the 13th day, a mere 1 day before her suspension was set to expire. It is evident she was relieved of her suspension by leadership of the department. Such practices in themselves raises serious questionable practices. It is also prudent that this Court notes that the punishment issued by the Department is an admission that Deputy Mia Townsend's actions not only were illegal, but were also unjustified as per departmental policy.
III. Constitutionality
Your Honor, the Plaintiff submits before you that we have a crisis of constitutionality. Civil rights that are enshrined in the United States Federal laws. Press freedoms have been trampled upon. Journalistic freedoms have been suppressed in this regard. Might I remind this Court that the Media is generally referred to as the "Fourth Estate" in regards to the government, albeit not officially. The media act as the public's accountability watchdog to hold members of government, public office holders and potential suitors of such a position. Ms Piper Lynch was merely conducting her journalistic duty in holding the a potential suitor for the executive role, Candidate Mayor of Las Venturas.
Your Honor, I refer you to:
"U.S. Code Title IX Section (A) Conspiracy against civil rights
(1) Any person which conspires to injure, oppress, threaten or intimidate any person in any state, territory, or district in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States shall be imprisoned for no less than 5 and no more than 10 years."
"U.S. Code Title IX Section (B) Deprivation of rights under color of law
(1) Any person which under color of any law, statute or ordinance, regulation or custom, willfully subjects any person in any state, territory, or district, to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of United States, or to different punishments, pains or penalties, on account of such person being an alien, or by reason of his color, or race, shall be imprisoned for no less than 5 and no more than 10 years."
The Plaintiff submits before this Court that Sheriff Deputy Mia Townsend's illegal actions have already been set in stone not only through her repeated violation of scale of force, but also the San Andreas Sheriff's Department sanction issued against herself in the form of the 14 day suspension. Duly affirms our assertion that Deputy not only oppressed Ms. Piper Lynch's ability to conduct her journalistic duty, but Sheriff Deputy Mia Townsend also threatened Ms. Piper Lynch through her deployment of the taser, thus restricting her ability to enjoy her civil right.
Your Honor, I bring you to the following federal law:
"U.S. Code Title V Section (A) Bribery, corruption and abuse of power
(1) Any person which offers any form of bribery to a public official, witness or a victim shall be imprisoned for no less than 1 year and no more than 20 years based on severity and position. Any individual who accepts a bribe shall be equally guilty of this charge and serve the same punishment. Anybody accepting bribe in a position, whether law enforcement official, emergency service official, government official, or judicial official shall be removed. Bribery is considered the act of offering, giving, soliciting, or receiving of any item of value as a means of influencing the actions of an individual;
(2) Any person in a position of power, whether a law enforcement official, emergency service official, government official or a judicial official, who maliciously uses power shall be removed from the position and imprisoned for no less than 1 year and no more than 20 years;
(3) Any official who uses his position or power maliciously for foreign, private or other interests which are not beneficial for the well-being of the United States shall be imprisoned for no less than 20 years and no more than a life sentence, and removed from positions"
Subsection of this title code is clear about malicious intent. Once again, your Honor, as previously mentioned, Sheriff Deputy Mia Townsend's action demonstrates malicious intent through her handling of the matter.
Your Honor, we also bring the following state laws of San Andreas to the Court:
"SA-PSC § II.1. Corruption and misuse of public office*** [F]
The act of misusing the powers of public office for personal or someone's gain.
This charge has an accessory punishment coupled with arrest, see SA-PSC § VIII.5."
"SA-PSC § VIII.5. Expulsion of corrupted government officials
Any individual part of any governmental organization, be it local, state or federal, who has been found to have committed an act of corruption or the misuse of his powers for foul reason, is to be expelled from said office and be barred from enlisting in others for a minimum period of time of two weeks."
Clearly states the misuse of public office, in this case being a peace officer, to the benefit of an individual is illegal. These two cited laws work in conjunction with each other as we have previously demonstrated malicious intent from Sheriff Deputy Mia Townsend. The Deputy Candidate in question was therefore able to provide a brief speech despite the alleged disruption and attack.
IV. The Perjury Argument & Double Standard in Justification
Your Honor, the Defense has tried, rather desperately, might I add, to paint Ms. Piper Lynch's voice projection as indicative of "disruption". However, let us not forget the environment in which this occurred. The Candidate's event was a noisy public gathering, with an audience, background chatter, and amplified speakers.
It is not only understandable, but necessary, that Ms. Lynch had to raise her voice to be heard, not to provoke, not to disrupt, but simply to perform her duty as a journalist which is asking questions and covering the event.
Now contrast this with Sheriff Deputy Mia Townsend, who, as the evidence from bodycam footage and recordings shows, raised her voice repeatedly, shouted at Ms. Lynch, and gave abrupt, unexplained orders. Yet the Defense seems to regard the Deputy's raised tone as appropriate and professional, while condemning Ms. Lynch's attempt to communicate in a crowd as unacceptable and disruptive.
This is a blatant double standard. Your Honor, if raising one's voice in a public press room is to be interpreted as disruption, then surely both parties are equally culpable, or as we assert, neither are, because context matters. But only one of them was coercively threatened and unlawfully removed.
Off Topic
***(( OOC clarification regarding the use of /s by Piper Lynch:
Due to script limitations in interior environments, the proximity range of normal local chat /l is significantly reduced in order to prevent excessive spam. As a result, once Piper Lynch realized that the candidate on stage could not hear her using /l, she resorted to /s to ensure her chat could be heard or seen and particularly since there was distance, ambient noise, and crowd presence in the room.
It's also worth noting that in most real world press events, credentialed journalists are either provided a designated area close to the stage or are given a microphone or opportunity to ask questions during or after the event. In this case, no such accommodation was offered nor restricted beforehand, so the use of /s was a necessary adaptation to the RP and server scripts.
Thank you for understanding the IC actions in context with the OOC limitations. ))
Perhaps the most baffling and disturbing element in the Defense's position is the obvious disregard to the unwanted harm caused to Ms. Piper Lynch. While she was not only a credentialed journalist, she was also a victim of the very assassination attempt that took place at that campaign event.
And yet, somehow, the Defense wishes to present this same journalist, who regained her footing and sought to document the aftermath, as a threat to screening? As a disruption? As someone whose voice needed to be silenced by force? It defies reason. How can one reconcile this contradiction? That the injured journalist, one who has every right to seek truth and transparency in the aftermath of a traumatic public incident, is instead treated as the threat?
What danger did Ms. Lynch pose? She was not armed, she was not aggressive, she was credentialed, she was engaged in lawful reporting, she was asking questions, not disrupting the integrity of the event, and above all, she had just suffered from the same threat as everyone else endured.
This is a clear abuse of control, where the journalist who dared raise her voice, literally, was silenced for the convenience and desire of the "Candidate's men", not necessity. Her only act was to stand back up and do her job, and for that, she was threatened with a charge, illegally removed from the scene, and had a taser pulled out against her.
The Defense would astonishingly have this Court believe that Ms. Piper Lynch suffered no "actual harm". That statement alone is deeply concerning that the Defendant's legal counsel does not consider the deployment of a taser against an unarmed journalist, who posed no physical threat, to be a harm. That they do not see the threat of an unlawful charge, nor the deliberate misuse of power in singling out a credentialed journalist amidst a crowd, as harm. That they fail to acknowledge the impact of being forcibly removed while doing one's job, shortly after being knocked unconscious during an assassination attempt, as harm.
What then would the Defense require to acknowledge an "actual harm"? Physical injury beyond taser deployment? Unlawful detainment? Suppression of her rights by excessive force? Must a journalist be bruised, bloodied, or jailed for it to count? If this behavior is not considered harmful by the Defense, we must question whether they recognize the very meaning of civil rights, press freedom, and due process at all.
It is not merely about the force used, it is the context in which it was applied, the authority that was abused, and the rights that were violated. And we submit, Your Honor, that those harms are very real and they matter. The Federal Law is not arbitrary.
VI. Closing Arguments
Your Honor, as we conclude our heads of argument, it is vital to note the following:
1. Constitutionally guaranteed Civil Rights are not merely suspended because of "Exigent" circumstances unless and until martial law is instituted by the president.
2. There is nowhere within these borders of the United States Constitution (federal law) nor San Andreas State law that provisions for "exigent" circumstances in law. Personal interpretation does not equate law. That is why it is the duty of Peace Officers to work within the confines of the law.
3. To further exacerbate how the "exigent" assertion, which has no legal basis in law, does not apply in this regard. The Deputy Candidate was therefore able to conduct a brief speech even after the main Candidate was assassinated, thus the situation was safe enough to conduct such business.
4. Members of the public cannot be trespassed in any property of the state. Even so called restricted areas in any public building cease to become "restricted" when members of the public are allowed access into them to conduct any business of the day.
5. Federal Law, in this case, the civil rights enshrined in the Constitution, will always supersede any counterarguments, within reason, of course.
6. Ms. Piper Lynch was not a threat in any manner possible, nor was she being belligerent in conducting her journalistic duties. We refer this Court to the video surveillance below:
[20:15:56] Enzo Brix shouts [Chinese accent]: NIGGER NIGGER I HATE NIGGER!
[20:22:13] John Jatt shouts: go go marisa will win!
[20:22:14] John Jatt shouts: go go marisa will win!
[20:22:15] John Jatt shouts: go go marisa will win!
[20:22:21] Mask_26903 shouts: Marisa!
[20:22:21] Mask_26903 shouts: Marisa!
The video shows 3 separate individuals engaging in belligerent behaviour that can be construed as disruptive. Yet only Ms. Piper Lynch was singled out.
7. The use of emergency powers is wholly justified when the life of an individual is in immediate danger. As we have previously demonstrated, the Deputy Candidate had the opportunity to deliver a brief speech, and Ms. Piper Lynch posed no threat.
The Prosecution does not falter in its position, in fact, we stand even more resolute in light of such a request. We respectfully urge this Court not only to reject the Defense's motion for acquittal but to dismiss the Defense's arguments themselves, most of which are built on outright contradictions to the record before this Court.
We assert that the record, the testimony, the evidence, and the conduct displayed in this case point clearly and convincingly toward a violation of civil rights, coercive conduct, unnecessary use of force, and misuse of authority.
And so, with respect, we now ask this Court to proceed without hesitation to issue summary judgment in favor of the Prosecution and in doing so, send a clear message that silencing the truth especially when spoken by one who survived violence to uncover it will never be tolerated.
We have faith in this Court that it will find the overwhelming amount of evidence, coupled with law, is more than sufficient to stand the legal standard.
We therefore rest our heads of argument for the time being.
VII. SIGNATORY
Dated: 3rd June, 2025
Respectfully Submitted,
Lance R. Garnet
Federal Prosecutor
Assistant United States Attorney
United States Department of Justice
Jim McDonnell
Federal Prosecutor
United States Attorney
United States Department of Justice
