Rusty Thompson

Ash Lǐ

Date Filed: 5/9/2025
Client Name: Rusty Thompson
Client Phone #: 555 4831

Lawyer Name: Ash Li
Lawyer Phone #: 555 1969

Requesting: Investigation # 5333 , photos from witness phone.
Intent: Criminal defense
The defendant claims that the mechanic Jack Artemis was running up and taking pictures of him as he pulled up as he recognized him as a tow driver. The defendant claims he was doing this to document the parking of his vehicle to protect himself from being towed. The defense anticipates that the activity of the mechanic, Jack Artemis , particularly to his actions during the timeframe of the investigation and the officer’s presence at the Auto Exotic, can be and will be used to prove the knowledge, consent, and intent of the defendant. Therefore, the defense would like to subpoena any non-private photos taken at Auto Exotic by Jack Artemis during the timeframe of the James Hooker presence at Auto Exotic.

Magistrate HC Blake Moore

This was posted with approval from me to post directly here.

Ash Lǐ

The defense would like to amend the intent to Criminal Appeal.

Morgan Luna-Schofield

Good Morning.

I just want to have some things clarified:

How are we distinguishing "non-private" photos from his private photos? The State will not know which ones Mr. Artemis considers private or non-private. All photos taken by an individual are inherently private. Please be more specific in what you are looking for.
I am not certain this is something the phone company can provide to us. It might have to wait to be obtained through Discovery, if the State decides to use it and Mr. Artemis is forthcoming with them. I will double check to see if it is possible and update here.

Thank you!

Morgan Luna-Schofield

@Ash Lǐ

Ash Lǐ

Id like to amend 'private' to 'personal' and by that i mean pictures that would include something of personal business that would not pertain to or include any loci, events, or circumstances involving the case. If this is not something that can happen I'd like to submit a formal Request for Production for photos that fit the aforementioned description. However, I see no reason that if the phone company can not provide these records that this subpoena could not be used to compel Mr. Artemis to produce photos from his phone that fit the description. If it pleases the court for me to narrow and specify scope further, I encourage them to reach out. I would caution this route if its not necessary, as the defense has reason to believe that Mr. Artemis has motivation, and has acted in ways that suggest that evidence may be tampered with if the defendant is notified directly.

Ash Lǐ

Also I have no idea how sealing a subpoena works, I would've loved to do it but I was told no by the judge I asked. If you know anything about it Ms. Luna-Schofield I would appreciate if you opened a private discussion with me here on the docket to discuss it more.

Morgan Luna-Schofield

Ash Lǐ

The docket is public, Miss Li, so this information is not protected. In the future, if you do not wish for a subpoena to be on the docket, you can submit it directly to a District Attorney to handle if we agree the matter is sensitive and should be withheld from the public eye. These circumstances are few and far between, though.

I am still waiting to hear back from the phone company.

Also, if you wish to have a private conversation with me, please contact me directly and we can arrange a time to meet together. I am happy to do so.

Ash Lǐ

Thank you Ms. Luna-Schofield.

Morgan Luna-Schofield

Ash Lǐ

I've heard back from the phone company and I am going to need the following information to move forward:

The date this happened.
A window of time of when it happened (as concise as you can be).
What would be in the photos that you are looking to subpoena. I don't want to assume.

Ash Lǐ

This Happened May 9th, The investigation report says approx 14:45 so 15 minutes before and after that is a good window. What I'm looking for is any photo being taken between Rusty Thompson arriving and leaving the mechanic's. If there is metadata for time taken for the photos the defense would also like that. Thompson alleges that when he hooked the vehicle there was no one working on the vehicle. These pictures would help clarify Mr. Artemis's doings.

Morgan Luna-Schofield

Ash Lǐ I apologize: Do you happen to have Artemis' phone number? If not, I can check the MDT when I am in my office next. If it isn't on profile, you will have to subpoena his phone number separately. I will let you know in the morning!

Morgan Luna-Schofield

Good news! The phone company was able to retrieve this information. These are the photos taken during that time:

Uploaded on May 9, 2025 at 2:46 PM:

Uploaded on May 9, 2025 at 2:52 PM:

@Ash Lǐ