Whether the petitioner's Fourth Amendment rights were violated by a series of illegal searches and seizures that commenced as early as 2013, where alleged gang evidence was found in the apartment where the petitioner lived

No question identified. : TO THE HONORABLE CHIEF JUSTICE OF THE SUPREME COURT OF THE UNITED STATES, AND TO THE HONORABLE ASSOCIATE JUSTICES OF THE SUPREME COURT OF THE UNITED STATES: Pursuant to Rule 39 of the Rules of the Supreme Court of the United States, petitioner Brandon Aaron Thomas respectfully requests leave to file a petition for writ of certiorari in forma pauperis. The declaration in support of this motion is attached hereto. In light of the clear showing of indigency, as evidenced in the attached declaration, petitioner respectfully requests leave to proceed in forma pauperis in this court. Respectfilly submitted, Dated: September 28, 2021 7 UDLEY Attorney for Petitioner Brandon Aaron Thomas 2 DECLARATION IN SUPPORT OF MOTION TO PROCEED IN FORMA PAUPERIS ON PETITION FOR WRIT OF CERTIORARI (Rule 39 of the Rules of the Supreme Court ; of the United States) : J, Brandon Aaron Thomas, declare as follows: I am the petitioner named in the above-entitled case. My date of birth is November 30, 1992. On August 7, 2018, I was sentenced to life in prison without possibility of parole that was to be served consecutive to a 4 year sentence. I received the sentence of life in prison without possibility of parole as a result of a conviction of first degree premeditated murder with special circumstances. I received the 4 years for being convicted of the crime of assault with a firearm. I am currently housed at Salinas Valley State Prison in Soledad, Monterey County, California. Due to my sentence J have no parole release date. In support of my motion to proceed on a petition for writ of certiorari without being required to prepay fees, costs or give security therefor, I state that because of my poverty, I am unable to pay the costs of such a proceeding or to give security therefor. I further swear that in the state trial court in which my criminal case arose, I requested, and received, the appointment of counsel to represent me at no cost based upon the fact that I was without funds to defend the state trial court proceedings. This appointment of counsel was made pursuant to the provisions of section 27706 et seq. of the California Government 3 Code. A copy of the court minute order, dated April 8, 2015, reflecting this appointment of counsel] is attached hereto. I have continuously been in custody since on or about April 6, 2015. | Also, attached hereto is my financial declaration in support of my motion for leave to proceed in forma pauperis. I believe that based upon the issues raised in the petition for writ of certiorari ] am entitled to redress. | ; In brief, without in any way admitting guilt to any of the charges against me, the facts as presented at trial showed that my codefendant Jonah Namauu shot and killed one Sam Weinberg on the night of April 3, 2015, in the City of Santa Cruz. At the time of that \ shooting, codefendant Namauu was seated in the front passenger seat of a vehicle being driven by myself. When codefendant Namauu fired, what was only a single shot, that shot occurred when Sam Weinberg was a driver of a vehicle that was stopped at a traffic light at an intersection next to the vehicle containing myself and codefendant Namauu. At the time of that shooting the one and only passenger in Weinberg’s vehicle was one Michael Cook. The issues which I desire to present in the petition for writ of certiorari all relate (1) to a series of illegal searches and seizures that commenced as early as 2013, where I lived with family members at an apartment building in the City of Santa Cruz, California, during which searches and seizures alleged gang evidence was found in the apartment where I lived, 4 and (2) on one occasion during one of those searches and seizures I was found in the possession of a pistol in backpack that I was wearing while I was approaching on foot the apartment where I lived at a time when the police were searching that apartment in connection with an investigation of an attempted murder that th