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State v. Kartal

John Paul Kartal has been charged by criminal complaint with a number of crimes, including burglary, robbery, and assault, that arose from an incident the home of Sarah Ramsey.
Publisher: NITA
Case File :Softbound, 147 pages
$38.00
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In Stock
ISBN: 9781601561404
Publisher: NITA
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John Paul Kartal has been charged by criminal complaint with a number of crimes, including burglary, robbery, and assault, that arose from an incident the home of Sarah Ramsey. On the evening of the incident, Ramsey arrived home and encountered a person inside her house. Ramsey yelled to the person that she had called the police. The person ran past her and knocked her down as he left her home. The burglar ran to a car parked in front of Ramsey's house. While Ramsey cannot positively identify the defendant as the person she encountered, he does match the description she gave to the police. Police Officer Marty Oliver was the first to arrive at the Ramsey home. Ramsey told Officer Oliver that the burglar was carrying a baseball bat when he ran out of her home, wore blue jeans, a black windbreaker, tan gloves, a dark baseball cap that was worn backwards, and a red bandana over the lower part of his face. Ramsey said her jewelry, $500 in cash, and a new stereo was taken from her living room. Ramsey also said her small jewelry box with her initials on the bottom was taken. Ramsey then gave a description of the burglar's vehicle. Ramsey and Officer Oliver prepared a diagram of Ramsey's home, yard, driveway, and street. Officer Oliver took a picture of the wood chisel that was found laying on the carpet inside the front door. There was no indication of a break-in or that the chisel had been used. Ramsey said the chisel was not hers.

Officer Oliver later discovered a car matching the description given by Ramsey outside the home where John Paul Kartal lived. Officer Oliver conducted a search of that car and discovered a jewelry box matching Ramsey's description on top of litter on the floor behind the passenger's seat. Officer Oliver prepared a diagram of Kartal's car and prepared a separate diagram of the front of the residence where he lives, showing the location of Kartal's car. Officer Oliver spoke to Kartal, arrested him in his home, and accompanied him to his bedroom so he could get dressed. Then Officer Oliver searched the bedroom and found a dark baseball cap and a dark windbreaker. The jewelry, a baseball bat, or bandana were not found. Officer Oliver also prepared a diagram of Kartal's bedroom that was searched when he was arrested, showing the locations of the baseball cap and windbreaker discovered during the search. At a lineup that was held later at the police station, Sarah Ramsey identified John Paul Kartal as a person who "looked like" the burglar she saw running from her home.

John Paul Kartal is twenty years old and a citizen of Turkey. He is an exchange student in his second year at Midstate University in the State of Nita. Kartal cooperated with the police and explained that he lent his car to a friend and that he (Kartal) did not commit the burglary.

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Table of Contents

CONTENTS


Directions for Determining Dates, Ages, and Applicable Law

Procedural and Factual History

      Introduction
      Pretrial Order
      Issues Raised
      Party and Witness Statements
      The Witnesses
      Plaintiff
      Defendant
      Expert Witness
      Party and Witness Depositions and/or Statements
      Exhibits and Documents
      Stipulations


The Facts
      Detailed Timeline of Significant Dates and Times
      Metropolitan News Article
      Department of Public Safety Field Report by Officer Oliver
      Voluntary Statement of Sarah Ramsey
      Statement of Rights, Acknowledgment and Waiver of Rights, and Statement of John Paul Kartal
      Statement of Rights, Acknowledgment and Waiver of Rights, and Statement of Edward M. Speare (Skippy)
      Lineup Witness Form by Sarah Ramsey
      Lineup Report by Officer Oliver
      Follow-Up Statement of Sarah Ramsey
      Supplemental Police Report by Officer Oliver


Pleadings
      Criminal Complaint
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Judge's Pretrial Order

Appendices
Appendix A: Directions

           Burden of Proof
           Order of Presentation and Rules of Evidence
           Suggested Time Schedules

Appendix B: Applicable Criminal Statutes

Appendix C: Joint Statement of the Case

Appendix D: Memo to Darrow County Attorney

Preliminary Legal and Strategic Analysis—State of Nita

Appendix E: Memo to Senior Public Defender

Preliminary Legal and Strategic Analysis—Defendant

Appendix F: Summary of Applicable Cases

Appendix G: Jury Instructions

Appendix H: Verdict Form

Appendix I: Plea Agreements
           Plea Agreement—General
           Plea Agreement—Stay of Imposition
           Plea Agreement—Stay of Execution
           Plea Agreement—Continuance for Dismissal/Deferral

Form 49A Criminal Judgment/Warrant of Commitment


Exhibits List


Exhibit 1: Diagram of Sarah Ramsey's house

(Witnesses: Sarah Ramsey, Officer Marty Oliver)


Exhibit 2: Photograph of chisel found inside Sarah Ramsey's house

(Witnesses: Sarah Ramsey, Officer Marty Oliver)


Exhibit 3: Photograph of baseball cap with Eelpout Logo from John Paul Kartal's place
of residence


(Witnesses: Sarah Ramsey, Officer Marty Oliver, John Paul Kartal)


Exhibit 4: Photograph of windbreaker from John Paul Kartal's place of residence

(Witnesses: Sarah Ramsey, Officer Marty Oliver, John Paul Kartal)


Exhibit 5: Photograph of Sarah Ramsey's jewelry box found in John Paul Kartal's car

(Witnesses: Sarah Ramsey, Officer Marty Oliver)


Exhibit 6: Photograph of Sarah Ramsey's jewelry box bottom with initials

(Witnesses: Sarah Ramsey, Officer Marty Oliver)


Exhibit 7: Diagram of John Paul Kartal's bedroom

(Witnesses: Officer Marty Oliver, John Paul Kartal)


Exhibit 8: Diagram of John Paul Kartal's car (dent and rust)

(Witnesses: Sarah Ramsey, Officer Marty Oliver, John Paul Kartal, Edward M.
Speare)


Exhibit 9: Diagram of John Paul Kartal's place of residence

(Witnesses: Officer Marty Oliver, John Paul Kartal, Edward M. Speare)


Exhibit 10: Voluntary Statement of Sarah Ramsey

(Witnesses: Officer Marty Oliver, Sarah Ramsey)


Exhibit 11: Statement of Rights, Acknowledgment and Waiver of Rights and Statement of
John Paul Kartal


(Witnesses: Officer Marty Oliver, John Paul Kartal)


Exhibit 12: Statement of Rights, Acknowledgment and Waiver of Rights and Statement of
Edward M. Speare (Skippy)


(Witnesses: Officer Marty Oliver, Edward M. Speare)


Exhibit 13: Lineup Witness Form by Sarah Ramsey

(Witnesses: Officer Marty Oliver, Sarah Ramsey)


Exhibit 14: Lineup Report by Officer Marty Oliver

(Witness: Officer Marty Oliver)


Exhibit 15: Follow-up Statement of Sarah Ramsey

(Witnesses: Officer Marty Oliver, Sarah Ramsey)


Exhibit 16: Supplemental Police Report by Officer Marty Oliver

(Witness: Officer Marty Oliver)

Learning Materials

Planning Guide and Checklist
           General
           Negotiation
           Mediation
           Discovery
           Motions/Oral Argument
           Trial (Court/Jury)

Learning Objectives
           Trial (Court/Jury)
           Depositions
           Negotiation
           Mediation
           Motions/Oral Argument
           Expert Witnesses