Next Court Date — LAX Courthouse
No court date set — click to add
A structured, day-by-day execution plan for defeating the charges, replacing your attorney, and building your civil rights case against the City of Los Angeles.
Prepared For
Adam Joshua Rodriguez
Case Number
25ARCM00422
Critical Deadline
July 24, 2025
Weekly Focus
File the motion at the courthouse this week. Secure a new, competent criminal defense attorney who will aggressively fight for you.
Obtain certified dental and medical records documenting the chipped tooth and head trauma. This is the cornerstone of every legal claim.
Interview and hire a top-tier Los Angeles civil rights attorney. Use the pre-qualification questions and scripts in this planner.
Full-Focus Weekly Preview
This Week's Big 3
The three outcomes that matter most this week. Everything else is secondary.
Weekly Appointments
Schedule your key legal actions and appointments for each day this week.
Key Wins
What three things went well this week in your case?
Gratitude
What are you grateful for as you fight this case?
Weekly Reflection
What did you learn this week? What will you do differently to advance your case?
Weekly Progress Tracker
Day-by-Day Execution
Call dentist — schedule emergency appointment for chipped tooth
Request a formal written report specifically documenting 'blunt force trauma.' This language is critical for your civil lawsuit.
Call physician — document head trauma and shoulder bruising
Describe the head slam and shoulder shoves. Request photos be taken and included in your medical file.
Mail Evidence Preservation Demand to Westfield Century City Mall
Send via Certified Mail with Return Receipt to the Mall's Legal Department. Keep the tracking number and green card as proof.
Print and organize your Marsden Motion hearing folder
Tab 1: Communication log (all 6 ignored messages with dates). Tab 2: Receipts from restaurants and E. St. Laurent. Tab 3: Brady officer information.
Go to the Los Angeles Superior Court — Airport Courthouse
11701 S. La Cienega Blvd, Los Angeles, CA 90045. Bring two printed copies of the Marsden Motion and your hearing folder.
Hand the Marsden Motion to the courtroom clerk
Ask the clerk to file it and bring it to the judge's attention to schedule the closed-door hearing. Keep your stamped copy.
Practice your 2-minute Marsden hearing statement
Use the script provided in this planner. Be specific: name the dates, name the motions he failed to file, quote your text message.
Identify 5 top civil rights law firms in Los Angeles
Search for firms specializing in 42 U.S.C. § 1983, LAPD excessive force, and Monell claims. Target firms with jury trial experience, not just settlements.
Email the Civil Rights Attorney Outreach Letter to all 5 firms
Send in the morning. The letter highlights the Brady officer, the prior acquittal, the false police report, and the July 24th deadline.
Follow up by phone — use the Elevator Pitch Script
Call 4 hours after emailing. Reference the letter. Ask to speak with a managing partner. Use the pre-qualification questions at the consultation.
Mail LAPD Internal Affairs Complaint — send to both IAG and OIG
Mail to LAPD IAG (P.O. Box 30158, LA 90030) AND the Office of the Inspector General (350 S. Grand Ave, Suite 290). Certified Mail only.
Have your father write and sign his witness statement
He should describe what he observed that night — your condition, the officers' behavior, and the timeline. Sign and date it.
Review and prepare the Government Tort Claim for filing
Deadline: July 24, 2025. Fill in your personal information and have it ready to file the moment your civil rights attorney is retained.
Priority Action
The Marsden motion is your constitutional right under People v. Marsden (1970) 2 Cal.3d 118. It is your most urgent legal action. You do not need your current attorney's permission or assistance to file it.
Do NOT tell your current attorney
The Marsden hearing is designed to be confidential so you can speak freely to the judge about your attorney's failures. You are not required to notify him before filing.
Print two copies of the Marsden Motion
Bring both copies to the courthouse. The clerk keeps one and stamps the other as your filed copy. Also bring your evidence folder (texts, emails, receipts).
Go to the courthouse and hand it to the courtroom clerk
Ask the clerk to file your Marsden motion and bring it to the judge's attention to schedule the closed-door hearing. Keep your stamped copy.
At the hearing, speak directly and specifically to the judge
Name the dates, name the motions he failed to file, quote your text message. The more specific you are, the stronger your case.
Present your physical evidence
Hand the judge your printed communication log showing all 6 ignored messages (Dec 17, Dec 30, Jan 7, and three more), your receipts, and your dental records if available.
The Six Documented Grounds for Removal
📋 Marsden Hearing Script — Read This to the Judge
"Your Honor, I am requesting new counsel because there has been a complete breakdown in communication and my attorney is not actively defending me. I have six documented instances — on December 17th, December 30th, January 7th, and three additional times — where he ignored my written requests for a defense strategy. He has refused to provide me with the Body Worn Camera footage, claiming it's 'too large' or 'needs redaction,' which violates my rights under PC 1054.2. He has failed to subpoena the disciplinary file of a known Brady officer involved in my arrest. He has failed to send spoliation letters for the mall security footage. And most importantly, I provided him with receipts proving I was a paying customer, which defeats the intent element of the 602(k) charge, and he has refused to use them to move for a dismissal. I have the text messages and receipts right here. I cannot receive a fair trial with this attorney."
Civil Rights Representation
📞 Phone Elevator Pitch Script — Use This When You Call
"Hi, my name is Adam Rodriguez. I am calling regarding a high-value 42 U.S.C. § 1983 excessive force and false arrest case against the LAPD. I have a Government Claims Act deadline of July 24th and I need to move quickly. I have documentary evidence including receipts proving I was not trespassing, medical records of a chipped tooth from an unprovoked head slam, and the police report falsely claims the arrest was 'without incident.' Furthermore, I have a prior 2023 jury acquittal on identical charges establishing a Monell pattern, and a known Brady officer was involved. I sent an email earlier today with a detailed summary. Can I schedule a consultation with a managing partner?"
Question 01
"How many § 1983 excessive force cases have you taken to trial against the LAPD specifically?"
You want someone who litigates, not just settles early. If they cannot name specific LAPD cases, keep looking.
Question 02
"Given my prior 2023 acquittal on identical charges, what is your strategy for pursuing a Monell failure-to-discipline claim?"
If they do not know what Monell is, or cannot articulate a strategy, walk away immediately.
Question 03
"One of the arresting officers is on the Brady list. How will you leverage that in discovery and at trial?"
A Brady officer on the stand is a plaintiff's dream. Your attorney must know how to use this aggressively.
Question 04
"Are you prepared to advance all costs — dental experts, use-of-force experts, and video forensic analysts?"
A top contingency firm covers all upfront costs. If they ask you to pay for experts, find another firm.
Question 05
"My current public defender ignored six of my messages. What is your firm's policy on client communication?"
You need a firm with a clear communication protocol. Get a commitment in writing if possible.
Question 06
"The Government Claims Act deadline is July 24th. Can you file the tort claim against the City of Los Angeles before then?"
This is a hard deadline. If they cannot commit to meeting it, they are not the right attorney for this case.
Case Chronology
A complete chronological view of your case from the 2019 Chief of Police letter through the January 2025 incident to the critical deadlines ahead. Click any event for details. Print this page as an exhibit for your first civil rights attorney consultation.
CF No. 18-003063 — Chief's Letter
Jun 7, 2019 (Prior)
Chief of Police Michel R. Moore confirmed sustained finding of misconduct against Officer Limon (Serial No. 41257) for unlawful search during trespass detention. Discipline: admonishment only.
Chief of Police Michel R. Moore confirmed sustained finding of misconduct against Officer Limon (Serial No. 41257) for unlawful search during trespass detention. Discipline: admonishment only.
Pro Per Acquittal
2023 (Prior)
Adam Rodriguez appeared Pro Per and was acquitted on three counts of PC 148(a)(1) — the same charge filed again in 2025. Establishes pattern of pretextual enforcement.
Adam Rodriguez appeared Pro Per and was acquitted on three counts of PC 148(a)(1) — the same charge filed again in 2025. Establishes pattern of pretextual enforcement.
The Incident
Jan 24, 2025
Detained at Westfield Century City Mall during a private celebration for fiancee. Four LAPD officers used excessive force — head slammed into patrol vehicle, chipped tooth. Arrested on PC 148(a)(1), PC 243(b), PC 602(k).
Detained at Westfield Century City Mall during a private celebration for fiancee. Four LAPD officers used excessive force — head slammed into patrol vehicle, chipped tooth. Arrested on PC 148(a)(1), PC 243(b), PC 602(k).
Arraignment
Jan 25, 2025
Arraigned at LAX Courthouse, Los Angeles Superior Court. Alternate Public Defender assigned. Case No. 25ARCM00422.
Arraigned at LAX Courthouse, Los Angeles Superior Court. Alternate Public Defender assigned. Case No. 25ARCM00422.
Attorney Communication Failures
Feb – Mar 2025
Six documented written contacts to assigned APD ignored: Dec 17, Dec 30, Jan 7, and three additional attempts. No defense strategy communicated. No motions filed.
Six documented written contacts to assigned APD ignored: Dec 17, Dec 30, Jan 7, and three additional attempts. No defense strategy communicated. No motions filed.
Evidence Preservation Window
Mar 2025
Critical window to demand preservation of Westfield Century City CCTV footage and LAPD body-worn video from all four officers. Mall footage typically retained 30–90 days.
Critical window to demand preservation of Westfield Century City CCTV footage and LAPD body-worn video from all four officers. Mall footage typically retained 30–90 days.
LAPD Complaint Filed
Apr 2025
Formal misconduct complaint submitted to LAPD Internal Affairs Group documenting excessive force, false police report, and unlawful detention.
Formal misconduct complaint submitted to LAPD Internal Affairs Group documenting excessive force, false police report, and unlawful detention.
GOVERNMENT CLAIMS ACT DEADLINE
Jul 24, 2025
Absolute deadline to file Government Tort Claim against the City of Los Angeles under Gov. Code § 911.2. Missing this date permanently bars the civil rights lawsuit. If missed, file late claim petition under § 911.4 immediately.
Absolute deadline to file Government Tort Claim against the City of Los Angeles under Gov. Code § 911.2. Missing this date permanently bars the civil rights lawsuit. If missed, file late claim petition under § 911.4 immediately.
LAPD 'No Misconduct' Finding
Nov 2025
LAPD investigated its own officers and found 'no misconduct' — despite the chipped tooth and the police report stating 'without incident.' This finding is a strategic asset for the Monell ratification claim.
LAPD investigated its own officers and found 'no misconduct' — despite the chipped tooth and the police report stating 'without incident.' This finding is a strategic asset for the Monell ratification claim.
Federal Statute of Limitations
Jan 24, 2027
Two-year statute of limitations for filing the § 1983 federal civil rights complaint in the U.S. District Court, Central District of California.
Two-year statute of limitations for filing the § 1983 federal civil rights complaint in the U.S. District Court, Central District of California.
Attorney Consultation Exhibit: Print this timeline (Ctrl+P / Cmd+P) and bring it to your first civil rights attorney meeting. It provides a complete chronological overview of the case in a single page.
Master Timeline
Medical & Dental Documentation
See dentist and physician; obtain certified records
File Marsden Motion at Courthouse
Hand-deliver to courtroom clerk; request closed-door hearing
Evidence Preservation Demand — Westfield Mall
Send via Certified Mail to mall's legal department
LAPD Internal Affairs Complaint
Submit to both IAG and Office of Inspector General
Retain Civil Rights Attorney
Use outreach letter and pre-qualification questions
Father's Witness Statement
Written, signed, and dated account of the incident
Government Tort Claim — City of Los Angeles
File with LA City Clerk, 200 N. Spring St., Room 395
Reflection & Notes
Use this space to record attorney names, callback numbers, court dates, and key observations.
Strategic Asset
Key Fact
In late November 2025, the LAPD responded to your formal misconduct complaint by issuing a finding of "no misconduct" against the arresting officers. This finding does not hurt your case — it is a powerful strategic asset for the following four reasons.
Proves Administrative Exhaustion
Courts and civil rights attorneys want documented proof you used official channels first. Your complaint letter and the LAPD's response is exactly that — it removes any argument that you failed to exhaust remedies before filing suit.
Creates an Irreconcilable Conflict with Physical Evidence
The LAPD says 'no misconduct' — yet you have a chipped tooth and head trauma. These two facts cannot coexist. Your dental and medical records will force a jury to choose between the LAPD's self-serving finding and objective, certified physical evidence.
Establishes Monell Pattern-of-Covering-Up
Under Monell v. Department of Social Services (1978), the City can be sued for its custom of whitewashing misconduct complaints. The November 2025 'no misconduct' letter is direct evidence of that custom — even with your injury documented, they cleared their own officers.
Opens the Door to the OIG and Police Commission
The LAPD's internal finding is not final. You have the right to appeal to the Los Angeles Police Commission and the Office of the Inspector General — both independent of the LAPD chain of command. Filing both creates maximum pressure and additional paper trails.
How to Use This in Court
"Ladies and gentlemen of the jury, even after Mr. Rodriguez filed a formal complaint documenting that he was slammed into a patrol vehicle and suffered a chipped tooth, the LAPD investigated itself and found nothing wrong. This is not justice. This is a cover-up. And the City of Los Angeles must be held accountable."
— Closing argument narrative for the § 1983 civil trial
Next Action: File Your Appeal
Send your formal appeal letter via Certified Mail to both the LAPD Office of the Inspector General (100 W. First St., Suite 1010, LA 90012) and the Board of Police Commissioners (same address). The appeal template is included in the Documents section below.
Evidence Management
Case Strength Meter
7 of 12 evidence items collected · 0 files attached
Evidence Collected
0/0
3/3
0/2
0/2
1/2
3/3
0/0
Restaurant Receipt — Westfield Century City
Receipt from dining establishment proving lawful customer presence on Jan 24, 2025
E. St. Laurent Purchase Receipt
Receipt from luxury retailer proving shopping activity before arrest
Third Receipt — Westfield Century City
Additional receipt confirming lawful customer presence
Dental Records — Chipped Tooth
Certified dental records documenting blunt force trauma to tooth from head slam into patrol vehicle
Medical Records — Head Trauma & Shoulder Bruising
Physician documentation of head trauma and shoulder bruising from repeated shoves
LAPD Body-Worn Video (BWV)
BWV footage from Officers Crawford, Suleiman, Limon, and Tepos — critical for proving contradictory commands and force used
CF No. 18-003063 — Chief of Police Letter
Signed letter from Chief Moore confirming sustained finding of unlawful search against Officer Limon
LAPD 'No Misconduct' Finding Letter
November 2025 LAPD response to formal complaint — finding of no misconduct despite documented injury
Police Report — Incident Jan 24, 2025
Contains 8 documented fabrications including 'without incident' claim contradicted by chipped tooth
Westfield Century City Mall CCTV
Mall security footage — preservation demand sent. Critical for proving lawful presence and officer approach
2023 Acquittal Records — 3 Counts PC 148
Court records proving pro per acquittal on three counts of PC 148(a)(1) — same charge, same division
Fiancee Witness Statement
Written account from fiancee who was present during the arrest and witnessed the entire incident
Motion Management
Track every motion from drafting through ruling. Update the status as each motion progresses through the court system.
4
Drafting
2
Ready to File
0
Filed
0
Pending Ruling
0
Granted
0
Denied
Marsden Motion
Replace Alternate Public Defender — People v. Marsden (1970) 2 Cal.3d 118
Pitchess Motion
Compel disclosure of Officer Limon's personnel file — Evidence Code §§ 1043-1047
Brady/Giglio Demand
Compel DA to disclose impeachment material on Officer Limon — Brady v. Maryland (1963)
Motion to Suppress (PC § 1538.5)
Suppress evidence from unlawful detention — no reasonable suspicion for stop
Trombetta/Youngblood Motion
Failure to preserve exculpatory evidence — mall CCTV footage
Government Tort Claim
File with LA City Clerk — Government Code § 910 et seq.
Attorney Outreach Tracker
Track every firm you contact. Update the communication stage as you progress through outreach. You need to retain counsel before July 24, 2025.
Case Communications
Document every phone call, email, letter, and meeting related to your case. This creates an unimpeachable record for your civil rights attorney.
0
0
0
0
0
0
📋
No communications logged yet
Click "Log Communication" to start documenting your case interactions
Damages Documentation
Track every out-of-pocket expense related to your case. This feeds directly into your damages calculation for the § 1983 civil lawsuit.
Total Expenses
$0.00
Items Logged
0
With Receipts
0
Categories
0
Your Legal Arsenal
All motions and letters drafted for your case. Review each with a licensed California attorney before filing. Documents are listed in order of urgency.
Marsden Motion
URGENTReplace your Alternate Public Defender
Brady Motion
LEGALCompel disclosure of Brady officer's file
Motion to Suppress
LEGALPC § 1538.5 — unlawful detention
Government Tort Claim
DEADLINEFile by July 24, 2025 — City of Los Angeles
Evidence Preservation Demand
URGENTWestfield Century City Mall CCTV
LAPD IA Complaint
ADMINSubmit to IAG and OIG simultaneously
LAPD Finding Appeal Letter
NEWAppeal the November 2025 no-misconduct finding
Trombetta/Youngblood Motion
LEGALFailure to preserve evidence
Civil Rights Attorney Letter
CIVILOutreach letter for § 1983 counsel
Defense Strategy
STRATEGYFull criminal defense strategy memo
| Action | Deadline | Priority |
|---|---|---|
| File Government Tort Claim (or late petition under § 911.4) | July 24, 2025 | URGENT |
| Retain civil rights attorney | ASAP | URGENT |
| File Brady/Giglio demand to DA | Next court date | HIGH |
| File Pitchess Motion | 10 court days before hearing | HIGH |
| Demand BWV footage preservation | Immediate | HIGH |
| File Marsden Motion | Next court date | HIGH |
| Federal § 1983 complaint (statute of limitations) | January 24, 2027 | TRACK |