Motion for Return of Property: Timothy Gentry

A. Celestine | 187 R. O'Cop

Motion for Return of Property:
Timothy Gentry (Quick Strokes owner),
representing STROKEMASTERS.

Date Filed: 21st of June, 2025

Client information:
Name: Timothy Gentry
Phone: (555)-6567
Attorney information:
Name: Annabelle Celestine
Phone: (555)-1328

Summary:
Based on the ruling in CIVIL ASSET FORFEITURE - Strokemasters, we're requesting return of all items seized during STROKEMASTERS SEARCH AND SEIZURE, completed on May 25th, 2025, excluding items found within a locked crate labeled “Leo Salvatorre”.

List of priority items:

67x Basic Repair Kit
13x Normal Repair Kit
15x Pro Repair Kit
7x Cleaning Kit
14x Tyre Repair Kit
3x Lock Replacement Kit
8x Basic Restoration Kit
3x Improved Restoration Kit
1x Pro Restoration Kit
2x Spray Kit
24,708x Plastic
11,650x Metal
17,522x Wood
7,203x Components
17,577x Cloth
3,745x Processed Metal
5,258x Processed Plastic
315x Processed Wood
358x Glue
162x Acrylic Coat

Attorney General Uriel Whitlock

Notice of Entry

Attorney General Uriel Whitlock entering for the State.

Theodore Lars

@Attorney General Uriel Whitlock Please go ahead and give an initial rebuttal

Attorney General Uriel Whitlock

The State continues to contend that the Plaintiff has not provided any proof, as the State would deem it necessary, that the items being requested are not proceeds of a crime. There are no records, receipts, witness testimony to compare with the testimony provided in the State v. Leo Salvatorre case that the use of illegal goods is commonplace. It has not been established that these items were not gathered in an illegal way or were not created utilizing illegal components. It is the burden of the plaintiff to establish these facts and they have not done so in any of their filings other than the assertion of "nuh uh".

Theodore Lars

@A. Celestine | 187 R. O'Cop Can you show proof of legal or 'yet to be proven to be illegal' suppliers and purchasers of materials. A proportion? Regardless of the prior court ruling on the injunction and siezure, the State did prove a source of illegal supplies. Just like a pawn shop, those I'll gotten goods can be legally seized.

A. Celestine | 187 R. O'Cop

Theodore Lars

Below is the evidence and reasoning supporting the party's motion:

Materials wholly unrelated to the criminal process that Mr Salvatorre was found guilty of:
24,708x Plastic
17,522x Wood
7,203x Components
17,577x Cloth
5,258x Processed Plastic
315x Processed Wood
358x Glue
162x Acrylic Coat
7x Cleaning Kit
14x Tyre Repair Kit

None of the items in the abovementioned list has any link to an act of catalytic converter theft or the melting of said parts, which is what Mr Salvatorre was caught doing and admitted to.

List of items linked to metal that could be obtained from melting catalytic converters, yet were obtained lawfully:
67x Basic Repair Kit
13x Normal Repair Kit
15x Pro Repair Kit
3x Lock Replacement Kit
8x Basic Restoration Kit
1x Pro Restoration Kit
2x Spray Kit
11,650x Metal
3,745x Processed Metal

List of Supporting Evidence:

Internal company rules requiring all employees to supply their materials
Testimony of employees who themselves scavenge for materials in a legal manner.
Strokemasters Mechanics advertising the purchase of materials.
Lack of any deposits of earnings by Mr Salvatorre.
Business expenditure withdrawals by the Owner:
(March - April)
(April - May)
List of some of Strokemasters' most common suppliers (not exhaustive):
Dan Fitzpatrick, Miles Hallowway, Scott Matt, Shawn Davis, Tom Miller, Vlasic Bane

Arguments for materials' legality:

The fact that metal is the only material difficult to get a hold of due to overwhelming demand is widely known to anyone remotely connected to the industry. A greater amount of other supplies is available for any amount of metal found. Such is further supported by the proportions of materials found on the property, with metal being present in numbers less than that of plastic or cloth, despite being required in much greater amounts for any and all mechanical tools.
Mr Salvatorre, as a simple employee, lacked access to the storage of the entire shop, instead only being able to access a single locked box on the property. No material or item found outside of it would by itself suggest anything illicit. Vehicle parts found inside the general storage are purchasable at U-tool or the Pawn Store for a low price, and their existence by itself by no means suggests they've been acquired illegally.
Most of the supplies at hand are self-supplied by the workers, to maximize their profits, and a lack of purchase proof is in no way evidence of illicit origin.
Lack of Salvatorre's earnings deposited to Strokemasters' ownership, unlike in a case of other employees, coupled with being found guilty of defrauding Strokemasters, asserts that no materials outside of Mr Salvatorre's private box upon property would be of his origin, as he abused Strokemasters' property for his gain, hence why Strokemasters has no reason or desire to request the return of anything found within said box.
The 2-month window before the incident in question shows business expenses totalling $1,316,327.
Removing contracted payments to the previous owner of $850,000 leaves $466,327.
With that amount in mind, as only the owner's material purchases, not including any materials bought or gathered by other employees, a stock of materials valued at ~$650,000 is perfectly reasonable to be found inside the business.

Respectfully submitted,
Annabelle Celestine, representing STROKEMASTERS

Theodore Lars

@A. Celestine | 187 R. O'Cop

So, each Employee keeps their own individual materials? It's not the businesses?

A. Celestine | 187 R. O'Cop

Each employee was issued a locked box only they had access to, and as stated above each employee was responsible for acquiring their own materials (either by hand or purchase). → the mechanics would turn those materials into tools they needed for repairs, and used them to render services to STROKEMASTERS' clients, after which a cut of the repair earnings would be deposited to the owner. — that is why no illegal items were found on the property, and why STROKEMASTERS is not requesting to have items that originated from Mr Salvatorre returned either.

If your Honor is asking about the pure technical nature of ownership, STROKEMASTERS owns everything on the property. The closest comparison I can think of is equipment issued by state agency to its employees. Deputy's revolver might be locked in a locker room only said deputy has access to and is there to be used by the deputy, but at the end of the day the revolver belongs to BCSO, and the deputy is simply using it to render services they're being paid to provide.

If there's any further clarification required, I'll try my best to answer it. As a person who only recently rescued myself from being knee-deep in mechanic's business, I can only assume how confusing some things can be to people without years of experience in the trade.

Theodore Lars

You can claim Strokemasters owns everything, but you are claiming each individual employee brings their own to work as well. The materials are not issued to them. You are undermining your own argument. You are trying to pick and chose liability where it is convenient.

Because of this, I can not in good faith have you represent the entire stash with 1 client, this isn't a class action, and each individual would be responsible for sourcing the materials. This business structure inherently is obfuscating this away from your business. Due to this, I must grant the State the forfeiture in part.

The state will be allowed to keep 33% (1/3rd) that could be tainted by the proven actions of the employee, because this has not proven that these materials are collected, strictly supervised, or really owned by, Timothy Gentry. I am sympathetic however to the closure of the business and workers there in so I will be allowing the return of 2/3rds of materials of those reasonably caught in the crossfire and due to the longstanding closure.

Note: This applies to ALL materials, not just metals.

Theodore Lars

(The State may round UP to the next unit)

Theodore Lars

excluding items found within a locked crate labeled “Leo Salvatorre”. The State keeps those.

A. Celestine | 187 R. O'Cop

Thank you, your Honor.

For the sake of clarity I will provide a list of materials that represent 2/3rd of seized items (rounded down in State's favor):

44x Basic Repair Kit
8x Normal Repair Kit
10x Pro Repair Kit
4x Cleaning Kit
9x Tyre Repair Kit
2x Lock Replacement Kit
5x Basic Restoration Kit
2x Improved Restoration Kit
0x Pro Restoration Kit
1x Spray Kit
16,472x Plastic
7,766x Metal
11,681x Wood
4,802x Components
11,704x Cloth
2,496x Processed Metal
3,505x Processed Plastic
315x Processed Wood
238x Glue
108x Acrylic Coat

Once your Honor signs off on those numbers, we'll work with the District Attorney's Office and Blaine County Sheriff's Office to have the partial return fulfilled.

With kind regards,
Annabelle Celestine, representing Strokemasters.

A. Celestine | 187 R. O'Cop

Apologies Your honor, couldn't pass an opportunity to have fun with some late night math.