'I No. a (_) i_I

IN THE

SUPREME COURT OF THE UNITED STATES

ORIG I NAL Supreme Court, U.S.

FILED

OCT 2 2 2018

OFFICE OF THE CLERK

Gone.t C.. fc- - PETITIONER (Your Name)

vs.

bcvey v'cAc- Ckoviec- - RESPONDENT(S)

ON PETITION FOR A WRIT OF CERTIORARI TO

(NAME OF COURT THAT LAST RULED ON MERITS OF YOUR CASE)

PETITION FOR WRIT OF CERTIORARI

(Your Name)

Ci-AfO&PcoyIOO (Address)

SOCJCa..O1 Cc,. 51310 (City, State, Zip Code)

9~ (Phonmber)

QUESTION(S) PRESENTED

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LIST OF PARTIES

[ ] All parties appear in the caption of the case on the cover page.

[1' ll parties do not appear in the caption of the case on the cover page. A list of all parties to the proceeding in the court whose judgment is the subject of this petition is as follows:

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TABLE OF CONTENTS

OPINIONSBELOW........................................................................................................1

JURISDICTION...................................................................................................................

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED .................................

STATEMENT OF THE CASE ............................................................................................

REASONS FOR GRANTING THE WRIT..........................................................................

CONCLUSION....................................................................................................................

INDEX TO APPENDICES

APPENDIX A- - SC(r JJ cc- f PC e 1c pev'e. C j jof +4; CJc-k S-vcS

APPENDIX B U*'4-c (vc +kCuk Peccv f'r 0Li

APPENDIX C- io'f Cr4s ckiJ

APPENDIX D- Tc cc-'ps f sCvdc).. h—cI v\c.

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APPENDIX F

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TABLE OF AUTHORITIES CITED

CASES PAGE NUMBER

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STATUTES AND AND RULES

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IN THE

SUPREME COURT OF THE UNITED STATES

PETITION FOR WRIT OF CERTIORARI

Petitioner respectfully prays that a writ of certiorari issue to review the judgment below.

OPINIONS BELOW

[11' For cases from federal courts:

The opinion of the United States court of appeals appears at Appendix A to the petition and is

[ ] reported at ; or, [ ] has been designated for publication but is not yet reported; or, [4"is unpublished.

The opinion of the United States district court appears at Appendix to the petition and is

[I reported at ; or, [ ] has been designated for publication but is not yet reported; or, [.( is unpublished.

[ ] For cases from state courts:

The opinion of the highest state court to review the merits appears at Appendix ( to the petition and is

[1 reported at ; or, [ ] has been designated for publication but is not yet reported; or, [Xis unpublished.

The opinion of the 4j c ( Cc'c- court appears at Appendix C to the petition and is

[ II reported at ; or, [ ] has been designated for publication but is not yet reported; or, [vT is unpublished.

IF

V

JURISDICTION

[47For cases from federal courts:

The date on which the United States Court of Appeals decided my case was rr/,zfi7

[ I No petition for rehearing was timely filed in my case.

[ A timely petition for rehearing was denied by the United States Court of Appeals on the following date: Avuit 2-14L 2,044 , and a copy of the order denying rehearing appears at Appendix A

{v"in extension of time to file the petilion for a writ of certiorari was granted to and including .J: (date) on ___________________ (date) in Application No.'

The jurisdiction of this Court is invoked under 28 U. S. C. § 1254(1).

H{For cases from state courts:

The date on which the highest state court decided my case was ' I ZO (( A copy of that decision appears at Appendix C.

[ ] A timely petition for rehearing was thereafter denied on the following date: and a copy of the order denying rehearing

appears at Appendix

[ ] An extension of time to file the petition for a writ of certiorari was granted to and including (date) on ________________ (date) in Application No. A_______

The jurisdiction of this Court is invoked under 28 U. S. C. § 1257(a).

-7

CST1UTOr4AL #NNO STATUTORY ppOVSiOS INVOLVED

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the same incident. Three prior felony convictions were alleged in Support

of this count. (Pen. Code, § 12021, subd. (a)(l).). (1 CT 94.) In count 111,

it was charged that appellant dissuaded a witness, Danielle Martinez. It

was further alleged that such act was accompanied by force and an express

and implied threat of force and violence upon her. (Pen. Code, § 136. 1,

subds. (a) & (b)(l).) (1 CT 95.)

It was also alleged as to all counts, pursuant to Penal Code section

186.22, subdivision (h)(l)(C), that the offenses were committed for the

benefit of, at the direction of, and in association with a criminal street gang

(1 CT 95.)

It was also alleged, pursuant to Penal Code sections 667, subdivision

(a)(I), 667, subdivisions (b) through (i), and 1170.12, subdivisions (a)

through (d), that appellant had suffered a prior felony conviction in 2002.

(1 CT 96.)

Trial of the prior convictions was bifurcated. (1 CT 130.) Trial was

by jury. (1 CT 130-139, 171-172, 206-207.) Thejury found appellant

guilty of second degree robbery, as charged in count 1. The jury found the

allegation the a principal personally used a handgun, pursuant to Penal

Code section 12022.53, subdivisions (b) and (e), to be true. It found the

allegation that he personally used a handgun within the meaning of Penal

Code section 12022.53, subdivision (b), to be not true. The allegation

pursuant to Penal Code section 186.22, subdivision (b)(i)(C), was also

found to be true. (1 CT 200.)

Appellant was found guilty of possession of a firearm by a felon, as

charged in count 11. The allegation pursuant to Penal Code section 186.22,

subdivision (b)(l)(C), was found to be true. (1 CT 201.) He was also

found guilty of dissuading a witness, as charged in count III. The allegation

pursuant to Penal Code section 186.22, subdivision (b)(1)(C), was found to

2

STATEMENT'OF THE CASE

In an information filed in the Los Angeles Superior Court on

October 5, 2011, appellant was charged, in count I, with the robbery of

Danielle Martinez on August 25, 2011. (Pen. Code, § 211.) (1 CT 94.) It

was alleged that a principal personally used a firearm - a handgun. (1 CT

94; Pen. Code, § 12022.53, subds. (b) and (e)(1).) In count II, appellant was

charged with being a felon in possession of a firearm, in connection with

minute and a half, they returned, got into their van, and left. (2 RT 365.)

The thieves took her money, her blowdryer, her driver's license, and her

credit cards. (3 RT 611-612.) Later, she told police officers that one of the

men wrote down her license plate number (2 RT 369.) At trial, she was

positive that neither man told her that they had her personal information,

and knew where to find her if she told anyone what happened. (2 RT 371.)

The police came within a few minutes. Just before the police

arrived, Contreras returned. She asked him what was going on, and who

those men were. Contreras told her he did not know them, and had no idea

what was going on. She told the police she had been robbed. (3 RT 616-

617.) They took her to the station and interviewed her there. (3 RT 618.)

When she was interviewed by the police an hour or so after the

incident, she told the officer she did not recognize anyone in the

photographic arrays he showed her. (2 .RT 375-376.) During the first

interview, the officer told her to ho ahead and circle the picture, even if she

was not sure of the identification. (3 RT 644-646.)

In Martinez's first police interview on the night of the robbery, she

told the officer that the driver was the one with the handgun, and also the

one who hit her. Later, when she was less upset, she realized she had not

been hit with a gun. The blow to her head was not hard enough. (3 RT

633.) She pointed to one of the pictures in the second lineup and told the

officer it resembled one of the men. 1-Ic told her to circle the picture. When

- she spoke with Detective Avila four days later, she told Avila that the

person she circled might not be the robber. (3 RI 636-637,648.) At the first

interview, she described the van as a light-colored Toyota. (3 RI 674.)

Prior to the robbery, Contreras and she had been friends for a few years. (3

RT 659.) After the robbery, she heard there were people trying to reach

Contreras. She thought she 'might have been set up. (3 RT 664.) She

El

jumped back in the van and left. The police came within a few minutes. (3

RT 780-781.) The people in the van never chased him. (3 RT 782.) He

thought "maybe" one of them had a shaved head. When he approached

Martinez, she said they robbed her. He asked her if she was all right. (3 RT

783-784.)

When the police arrived, they separated Contreras and Martinez.

They interviewed Contreras about what had happened. (3 RT 786.) Later

that night, they showed him some photographic lineups. 3 RT 787-788.)

He could not recall the conversation with the officers. He admitted that he

recognized one picture as that of a person he had seen at a friend's house.

(3 RT 790-791.) When they showed him the second lineup, they told him to

point out anyone who looked familiar. He recognized the photograph of

appellant. (3 RT 792-793.) He picked appellant's photograph because be

thought the vehicle used in the robbery looked like appellant's. (3 RT 794.)

Contreras stated that, if one sells drugs for a gang, one must pay a

"tax" to the gang on the prcf; He knew Azusa 13 fairly well from having

lived in the city for eleven years. To his knowledge, appellant belonged to

the gang. He called appellant "G" for gangster. (3 RT 80 1-802.) Contreras

knew that appellant had a tattoo on the back of his head that read, "Azusa.'

(3 RT 803.)

He "could have" told Avila that appellant was after him because his

lost appellant's money a month before in Chino Hills. At trial, Contreras

said that the money confiscated in Chino Hills belonged to him. He

affirmed that the Chino Hills case did not involve appellant. (3 RT 804-

805.) A recording of a telephone conversation with Avila (People's Exhibit

No. 3) was played for the jury. (4 RT 912-913.)

Avila told Contreras that his only interest was in the robbery, so he

should be honest. Contreras said that he knew who robbed Martinez. (1 CT

6

r.

Officer Jason Kirnes of the Azusa Police Department responded to

1107 Calle de las Estrellas in Azusa at about 11:51 p.m., on the night of the

robbery. He interviewed Contreras, who told him three people came out of

a car and chased him, and he fled. The pursuers were driving a black and

- gray Mazda van. Contreras told him that one of them was appellant. (4 RT

1014-1015.) Appellant was the driver of the van. Contreras said that

appellant and three friends approached him, and then he ran. The then

drove the van to where Martinez was sitting in her parked car. Appellant

removed a black handgun from underneath the hood of the vehicle.

Appellant and his friends grabbed Martinez as she sat inside the car. (4 RT

1016.)

Contreras told Kimes appellant was an Azusa 13 gang member who

went by the moniker 'Gangster." (4 RT 1016-1017.) He and Officer Chivas

returned about an hour later to talk to Contreras For the first time, he said

he sold drugs, and might be targeted because of money

issues. (4 RT 1021-1022.)

Officer Robert Chivas interviewed Martinez, who explained that she

was there to see her friend, and had just parked her vehicle when another

vehicle came up to her. The occupants of the other vehicle got out, and

robbed her at gun point. (4 RI 1024-1025.) She described two male

Hispanics with shaved heads. She said that the vehicle they used was a

van, possibly a Toyota. The gun they used was similar to his service

- weapon, but smaller. She said it had a silver handle. One of the men lifted

his shirt to show her he was armed. Later, he pulled out the gun and hit her.

(4 RI 1026-1027.) One of them wrote down her license plate number on

his hand, and said they knew how to find her if she told anyone. She could

not say who had the gun. (4 RI 1028.)

When he took her to the police station she identified appellant in the

(8

.io.

analyzing certain cell phone records. (3 RI 702-705.) Using a list of cell

towers, with their longitude and latitude, it is possible to determine where

the cell phone was located when the call was made. (3 RI 731, 75-736.)

Antoinette Nunez was the senior lead analyst for the Department of Justice

Task who analyzed call records provided by Azusa Police Department. (4

RT 993.) She used the data to create cell tower maps. The result was

People's Exhibit No. 27, a map of all the cell phone towers hit by this

phone from August 1st to August 29th of 2011. (4 RI 997-998.) The map

contained a red circle that mapped a mile radius around the Calle de las

Estrellas address where the robbery occurred. A second, purple, circle

mapped a three-mile radius centered on the same address. At 11:34 p.m.,

on the night of the robbery, there was a call made to a 626 number using

tower MCA 60481R. It was a regular call in the vicinity of the address. (4

RI 1003-1004.)

Avila also testified as a gang expert. (5 RT 1222.) Azusa 13

originated after World War 11 as a Hispanic turf gang. At present, it has

about 375 people, only twenty or thirty of whom are are active members.

It's symbol is anything containing the letter "A." It's name is Barrio Azusa

13, Azusa 13, or A-13. The hand sign for the gang is formed by forming

the letter "A" with the fingers. (5 RT 1227-1229.) The primary activities of

the gang are graffiti, assaults, battery, vandalism, illegal drug sales,

robbery, possession of firearms, attempted murder, and murder. The

prosecution introduced certified copies of two minute orders that showed

- that two members of Azusa 13 were convicted of robbery in 2011, and

attempted murder in 2010. (5 RT 1229-1235.) Avila performed a

background check on appellant, and concluded that appellant was an Azusa

13 member. (5 RI 1236.)

Avila was given a hypothetical in which a gang associate owed a

10

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STATEMENT OF THE CASE

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CONCLUSION

The petition for a writ of certiorari should be granted.

Respectfully submitted,

Date: 7

110.