Motion for Return of Property: Rory Owens

187 R. O'Cop

Date Filed: 26th of June, 2025

Client information:

Name: Rory Owens
Phone #: (555)-0131

Attorney information:

Name: Annabelle Celestine
Phone #: (555)-1328

Summary:

Miss Owens is requesting the return of cash ($165,000) seized during her arrest on the 26th of June. My client shares evidence of funds' origin, and explains their origin as lifelong savings - the results of both Odd Jobs helping people of our State, as well as hunting trips, she collected over her stay in Los Santos. Funds were withdrawn with the desire to treat herself and purchase a new vehicle at a nearby used car dealership, which, of course, never had a chance to occur, as my client was arrested immediately after the withdrawal.

Evidence:

Kinsley Murphy

Motion of Entry:

DA Kinsley Murphy entering for the State.

Your Honor,

Due to the nature of the arrest the State does believe this still falls under the Civil Forfeiture and should remain in until after the Courts decide if Ms. Owens is innocent or guilty.

Regards,

DA Kinsley Murphy

187 R. O'Cop

Kinsley Murphy rebuttal to the aforementioned:

To quote the State in State v. Lopez et al. (HUT):

"The State will also be seeking civil asset forfeiture on Rory Owens' $165,000 unless proven obtained legally. This should be easy for Ms. Owens given that she is an "investor" of a little mom and pop diner called Last Stop Diner that is certainly open enough to have this kind of interest paid to Ms. Owens!"

The State has no active link between the cash found on Miss Owens and the crimes she was alleged to have committed. The State actively encouraged the defendant to prove that the funds were obtained through legal means, which she's doing in the motion in question. Whether Miss Owens is found guilty or innocent of the crimes alleged in State v. Lopez et al. is not at all relevant for this motion, and even the State will not seek its seizure if valid evidence is provided, as per their own words.

To respect the court's time, we bring this motion forward now, as we believe it to be a straightforward case to settle, given that the State that is responsible for the seizure in question appears to agree.

187 R. O'Cop

Motion for Summary Judgment

21 days later, well past the results of the above-mentioned arrest, which resulted in a plea deal, in which the funds named above were not mentioned at all, we're still stuck here.

Due to the State actively encouraging the return of funds to Miss Owens if she can prove their legal source, coupled with zero argument against the return offered by the State in this motion other than awaiting results of an unrelated court case, we will be motioning for summary judgment based on our original argument, which was not disputed.

The State signed a plea deal in which they decided to forfeit the seizure of funds they were originally seeking due to the arrest. The case has been settled, the State gave up seizure of the funds, therefore, there is nothing stopping their immediate return.

respectfully submitted,
Annabelle Celestine, representing Rory Owens

[deleted]

MSJ Granted

Pursuant to the plea deal signed by the State: "The State confirms that no civil asset forfeiture proceedings will be initiated now or in the future against the defendant’s property in connection with this case, including after the defendant has completed their sentence."

As such, BCSO shall return the property back to Ms. Owens within 7 days.

@187 R. O'Cop