John Doe was charged with possession of a controlled substance for sale. Detectives obtained a search warrant and found drug paraphernalia on Doe. When officers approached, Doe was searched and officers found a large amount of cash, a cell phone, and loose change on his person. In Doe's hotel room, officers discovered numerous empty baggies with drug residue, a digital scale, drugs, and drug paraphernalia. In Doe's vehicle, officers found a laptop, scales with drug residue, and a safe containing cash and several bags of methamphetamine and heroin. The memorandum concludes there is overwhelming evidence that Doe is guilty of possession of a controlled substance for sale.

1. MEMORANDUM ALTERED FOR CONFIDENTIAL PURPOSES
TO: VICTOR
FROM: ISABELLA
RE: JOHN DOE (#1234)
COUNT 1 POSESSION FOR SALE OF A CONTROLLED SUBSTANCE HEALTH AND
SAFETY CODE 11378:
ISSUE- ON (DATE) DETECTIVE DOE OBTAINED A SEARCH WARRANT FOR JOHN
DOE. DETECTIVES FOUND DRUG PARAPHERNALIA. JOHN DOE PULLED INTO
PARKING SPACE AFTER OFFICERS PULLED BEHIND HIM AND ACTIVATED THEIR
FORWARD FACING RED LIGHTS. AFTER DOE WAS HANDCUFFED, DET. DOE BEGAN
SEARCHING DOE’S POCKETS. DETECTIVE DOE FOUND A LARGE AMOUNT OF
FOLDED US CURRENCY, SOME LOOSE CHANGE, AND A CELL PHONE.
RULE- HEALTH AND SAFETY CODE 11378 STATES AS OTHERWISE PROVIDED IN
ARTICLE 7 (COMMENCING WITH SECTION 4110) OF CHAPTER 9 OF DIVISION 2 OF
THE BUSINESS AND PROFESSIONS CODE, A PERSON WHO POSSESSES FOR SALE A
CONTROLLED SUBSTANCE THAT MEETS ANY OF THE FOLLOWING CRITERIA
SHALL BE PUNISHED BY IMPRISONMENT PURSUANT TO SUBDIVISION (H) OF
SECTION 1170 OF THE PENAL CODE
APPLICATION- ALL ELEMENTS REGARDING SUBSTANCE HEALTH AND SAFETY CODE
11378 ARE PROVEN. DOE KNEW OF ITS NATURE, AND THE AMOUNT WAS SUFFICIENT TO
BE USED FOR SALE OR CONSUMPTION AS A CONTROLLED SUBSTANCE. WHEN OFFICERS
CONDUCTED SEARCH, THEY FOUND…
ON HIS PERSON: $$$ CASH, LOOSE CHANGE, A CELL PHONE (RECEIVED NUMEROUS
TEXT MESSAGES AND CALLS DURING SEARCH)
HOTEL ROOM: NUMEROUS EMPTY BAGGIES W/NARCOTICS RESIDUE, AN EMPTY
DIGITAL SCALE BOX, SMALL BAGGIE CONTAINING CRYSTALLINE SUBSTANCE, SMALL
GLASS METHAMPHETAMINE PIPE, AN EMPTY SYRINGE, A SYRINGE CONTAINING
APPROX. 40CC’S OF DARK BROWN LIQUID
VEHICLE: LAPTOP (POSSIBLY USED AS A LEDGER), 2 WORKING MINI DIGITAL SCALES
WITH METHAMPHETAMINE AND HEROIN RESIDUE DIGITAL COMBINATION SAFE
CONTAINING 5 BAGS OF METHAMPHETAMINE (X GRAMS, X GRAMS, X GRAMS, X
GRAMS, X GRAMS), X GRAMS OF TAR HEROIN AND $$$$ CASH.
CONCLUSION- THERE IS AN OVERWHELMING AMOUNT OF EVIDENCE THAT
PROVES JOHN DOE GUILTY OF THIS COUNT. ALL ELEMENTS ARE PROVEN