CIVIL ASSET FORFEITURE - Strokemasters

Attorney General Uriel Whitlock

Date Filed: 6/5/2025
Plaintiff Name(s) and Phone Number(s): The State of San Andreas
Attorney Name(s) and Phone Number(s): Attorney General Uriel Whitlock, 5550479
Defendant Name: Strokemasters, Timothy Gentry
Date of Service (if possible): 6/5/2025

Statement for Seizure:

Following investigations and an initial injunction upon the property owned and known as Strokemasters, the State finds it within it's right to request the immediate seizure of the Strokemasters properties and the business organizations (Organization IDs 1010 and 1179). This follows the ruling of the court in State v. Leo Salvatorre in which Mr. Salvatorre was found to be utilizing stolen goods in conducting the business of Strokemasters. Due to the business being used as a facilitator for the spread of these stolen goods, the State requests seizure of the properties owned by this business as well as the business itself.

Request(s):

State seizure of the following:

33A Magellan Avenue
33B Magellan Avenue
Organization ID 1010
Organization ID 1179

Evidence (if any):

Investigations 5924, 5925, 5926
State v. Leo Salvatorre

Attorney General Uriel Whitlock

For notification purposes:

@PENTA @Tessa Walker | L. Gray-Quinn @DAO Office

A. Celestine | 187 R. O'Cop

Attorney General Uriel Whitlock - politely requesting access to Investigation: 5925 as it's the only one I'm missing.

A. Celestine | 187 R. O'Cop

Notice of entry

Annabelle Celestine entering as defence counsel, representing mr. Gentry - the sole owner of Quick Strokes, organization in charge of Strokemaster Autoshop and Dealerhsip.

Attorney General Uriel Whitlock

A. Celestine | 187 R. O'Cop You have been added.

A. Celestine | 187 R. O'Cop

Motion to Dismiss

Defense, having reviewed the State’s claim and all evidence provided, hereby moves for immediate dismissal of the civil-asset-forfeiture action brought against the brand Strokemasters, owned by Mr. Timothy Gentry.

In State v. Salvatorre, Mr. Leo Salvatorre—then employed as a mechanic at several shops, including Strokemasters—was found GUILTY of Felony Fraud | CC-251. - CC-251 expressly targets “wrongful or criminal deception intended to result in financial or personal gain from a business or institution.”

Key point: The statute itself defines the business as the victim of the fraud.
Salvatorre’s conviction, therefore, establishes that Strokemasters was defrauded, not enriched.

The State has produced no evidence showing that Strokemasters or Mr. Gentry knew of, benefited from, or encouraged Salvatorre’s criminal activity. To the contrary:

Strokemasters’ employee rules require every mechanic to remit a cut of earnings to the shop. Salvatorre failed to deposit a single dollar.
Management had already decided to fire him for those missing deposits before his arrest—proof that any misconduct was against business interests, not in furtherance of them.
Upon learning of the arrest, Strokemasters terminated Salvatorre’s employment immediately and began preparing a civil claim against him for damages.

The State obtained a 10-day injunction from the Honorable Judge Yee so it could investigate. That injunction has now run its course, yet the only documents on file are Investigations #5924, #5925, and #5926—all gathered before the injunction was granted. No new facts have appeared in the intervening twelve days of forced closure.

Consequences of the shutdown:

Shop operations frozen 12+ days
13 employees out of work
Critical community repair services halted

To seek permanent seizure of the entire enterprise because one low-level employee defrauded said business he was supposed to work for—is not merely unsupported; it is absurd.

Requested Relief
Dismiss the State’s forfeiture petition with prejudice.

Respectfully submitted,
Annabelle Celestine, representing Timothy Gentry / Strokemasters

Attorney General Uriel Whitlock

Rebuttal to Motion for Dismissal

The State welcomes the Defense to make these arguments in court should they choose. However, the State has already proven, in the verdict of the mentioned case, that Strokemasters as a business was involved in the reduction and distribution of stolen materials, then used to manufacture repair kits utilized by the business. To state otherwise is a burden placed upon the Defense in these civil proceedings.

The State DOES NOT have to provide evidence that the owner benefited. It does not need to provide evidence even that the business benefited. It only has to show that the property and the business were utilized as part of a crime. Which it has done.

The State does find it unfortunate for the individuals who may have been conducting their business in a legal and appropriate way as part of Strokemasters. However, it does not excuse criminal activity out of businesses based on people losing their jobs. Other operations exist in the state for the repair of cars and employers of mechanics. While critical, Strokemasters is not the sole provider of these services. They are not the sole provider of mechanic jobs to the populace. The State does not find a justification to dismiss these charges out of hand based upon these arguments.

A. Celestine | 187 R. O'Cop

Clarification regarding motion to dismiss

The defence would like to draw attention to the facts presented by both parties, as well as clarify the State's mischaracterization of facts found in State V Salvatorre ruling.

The State and Defense both agree that the property was used in the commission of a crime - and as per State V Salvatorre - it is strictly pointed to as a victim of said crime.
The State claims the business utilized the stolen materials, not Mr Salvatorre, yet that is expressly the opposite of what the ruling of State V Salvatorre points towards, with Mr Salvatorre being found guilty of DEFRAUDING STROKEMASTERS.

The State is actively asking for a victim of a crime, proven already in a court of law, to be punished.

That is beyond unreasonable, and the Defense believes that the amount of time taken up by the duration of the State's "investigation" makes it justifiable for us to request immediate dismissal so that good and honest people of this State can finally go back to serving the community. At the same time, the State can return to pursuing charges against actual criminals, like they've wonderfully done in the case of Mr Salvatorre.

Respectfully submitted,
Annabelle Celestine, representing Timothy Gentry / Strokemasters