TOTAL LEGAL DEFENSE FUND $200,000

Jayden is a 21 year old young woman in the Beginning of her life. Having survived the COVID pandemic Jayden was restarting college when she was charged with a crime she did not commit. Jayden is one of the most loving, caring and compassionate people we know. When her Dad needed help-Jayden showed up. When her Mom needed help-Jayden showed up. When her little brother needed help-jayden showed up.

Now Jayden needs your help. She did not commit this crime. She is innocent. She needs help raising her legal defense fund. Her lawyer’ name is

Eugene Hanrahan

We have a deadline of September 8 for the first $25,000.

Gene has tried over 70 murder trials and has graciously agreed to answer any questions from friends or family. Simply click on his name - it’s a hyperlink- and feel free to call or email him.

As argued in her recent bail motion by Gene. . .

MEMORANDUM OF POINTS AND AUTHORITIES I. INTRODUCTION

Jayden is a 21-year-old woman charged with conspiracy to commit murder and the murder of Nicholas N. (“Nick”) with the special circumstance of lying in wait. Her codefendants Noah Farmer (“Noah”) and Hailey Rangel (“Hailey”) are changed with the same counts while Noah is also charged with the personal use of a firearm and a strike allegation. The People have requested detention for all defendants. The defense moves for the court to set the least restrictive bond amount for Jayden under Penal Code § 1289.

II. STATEMENT OF FACTS

A. Jayden’s Background

Jayden has strong ties to the community since much of her immediate family,

including her parents, live in Southern California. She has lived in Southern California since she was three years old. She attended all local schools: Alderwood Elementary, San Juaquin Middle, and University High.

Her grandmother describes her as --

caring and giving and when sharing her thoughts she spoke with empathy and compassion for the needs of her [ill] mother not herself.... she has a way of picking up any need we might have and supporting us.... The Jayden I have always known is gentle, sensitive, caring for others and gives her love unconditionally.

Jayden is very close with her father in Irvine where she has worked as a waitress and as a commentator on her father’s online talk show “Real Talk.” Although Jayden was traumatized by [redacted] and a sexual assault when she was 15, the attached character letters and photographs attest to her character for peacefulness and her generosity of spirit. She has no criminal record.

B. The Shooting

According to the police reports, on August 3, 2023, in the early afternoon, Jayden arranged with Nick to meet him near hear house in Irvine in her father’s Mercedes so that her boyfriend Noah could rob Nicholas of fentanyl tablets due to Nick’s drug debt to Noah. Jayden stated the purpose of the encounter was to “scare (Nicholas) and for Noah to get his stuff.” Jayden sat with Nick in her father’s car for a few minutes when Hailey drove Noah to her location in a car which Noah exited and fatally shot Nick approximately four times at close range. Jayden then drove off with Noah back to her house where Noah checked Jayden to make sure that she had not also been shot. Jayden and Noah were arrested shortly thereafter.

When interviewed by police detectives, Jayden denied planning to kill Noah or knowing that Noah intended to kill Nicholas. Nevertheless, she told the detectives that she “was not going to make excuses and was going to take accountability for making a wrong decision.” Noah corroborated Jayden’s statement during his full confession to the police detectives. He stated that “the plan was never to kill Nick.... Jayden and Hailey did not want to murder Nick.”

Although Jayden has no criminal record, Noah has a prior robbery conviction from 2020 and a pending assault case. Hailey has an open criminal case.

Justice Cuellar wrote that “liberty is the norm, and detention prior to trial or without trial is the carefully limited exception.” In re Humphrey (2021) 11 Cal.5th 1135, 156 citing US v. Salerno (1987) 481 US 739, 755. An arrestee may not be held in custody pending trial unless the court has made an individualized determination that (1) the arrestee has the financial ability to pay, but nonetheless failed to pay, the amount of bail the court finds reasonably necessary to protect compelling government interests; or (2) detention is necessary to protect victim or public safety, or ensure the defendant's appearance, and there is clear and convincing evidence that no less restrictive alternative will reasonably vindicate those interests. Humprey at 156. Pretrial detention on victim and public safety grounds, subject to specific and reliable constitutional constraints, is a key element of our criminal justice system. Id. Conditioning such detention on the arrestee's financial resources, without ever assessing whether a defendant can meet those conditions or whether the state's interests could be met by less restrictive alternatives, is not.” Id. To detain a defendant, “a court must find by clear and convincing evidence that no condition short of detention could suffice and then ensure the detention or otherwise complies with statutory and constitutional requirements.” Id. at 143.

A person shall be released on bail by sufficient sureties except for a capital crime when “the facts are evident or the presumption great.” California Const., Art. I, § 12(a); Penal Code § 1270.5 (no bail for charged capital crimes when proof “is evident or the presumption thereof great”). This phrase means that It is not necessary that the evidence should be so convincing as to justify a verdict against the accused, but it is sufficient if it points to him [or her] and induces the belief that he [or she] may have committed the offense charged. In re Page (1927) 82 Cal.App. 576, 578.

Jayden is entitled to a hearing to decide whether the proof is “evident” or the presumption “great.” Clark v. Superior Court (1992) 11 Cal.App.4th 455, 457.

Here, the facts are not evident nor is the presumption great that Jayden committed murder. Jayden stated to the detectives that she did not intend to kill Nick. Noah corroborated her statement. Historically, the prosecution might have nonetheless filed murder charges against Jayden under a felony-murder theory since this theory only required that Jayden had the intent to commit the qualifying felony to convict her of murder. People v. Lopez (2023) 88 Cal.App.5th 566, 576. However, in 2018, Senate Bill 1437 narrowed the felony-murder doctrine. Participation in a qualifying felony in which a death occurs is no longer sufficient to justify liability for first degree murder. Instead, the defendant must have 1) actually killed, 2) intended to kill, or 3) been a major participant in the underlying felony and acted with reckless indifference to human life. Id. SB 1437 thus eliminated the natural and probable consequences doctrine for first and second-degree murder. Id. at 576. Malice shall no longer be imputed to a person solely based on her participation in a crime. Id.

As a result of SB 1437, Jayden should have been charged with robbery at the most. This court may instead set bail for Jayden by applying the guidelines for the setting of bail under Penal Code § 1275. Even with public safety as the primary consideration, she meets several of the criteria for a reduced bail such as the absence of a criminal history and strong work and family ties to the community.

Date: August 16, 2023

Eugene Hanrahan Counsel for Defendant

here is the process Jayden must now face as described by Gene:

Crim Pro 101

In general, representing a criminal defendant is about preparing for trial on one hand while negotiating for the best plea bargain with the other. It is Jayden's decision alone whether to accept or reject a plea bargain. I specialize in trials in general and murders in particular from when I was a prosecutor in LA County's Hardcore Gang Division.

Jayden's next hearing is the actual arraignment on the Complaint where Jayden is formally advised of the charges against her in open court. Since we just had a hearing on bail today, bail will not be an issue at Jayden's arraignment. She is entitled to a preliminary hearing within 10 court days (and other time limits) unless she waives these limits. Typically, in a case as serious as this, the preliminary hearing is continued until a reasonable time when all the defense attorneys announce ready. If I announce at the arraignment on the Complaint that I represent Jayden, then I must represent her through the preliminary hearing.

At the preliminary hearing, the prosecution presents their evidence before a judge that Jayden committed the charged crimes although their burden is proof is low, effectively probable cause. The rules of hearsay are relaxed, and virtually all police officers can testify to the statements they heard from witnesses. If the prosecution meets its burden of proof, the judge holds Jayden to answer on the charges and sets the case for her arraignment on the Information. The information usually just restates the charges listed in the complaint, and the Information lists the charges that will proceed to the trial. If I announce at the arraignment on the Information that I represent Jayden, then I must represent her through trial.

After the Information is filed, the defense usually files a motion to dismiss some or all of the charges listed in the Information (akin to a motion for summary judgement -- called a "995 motion") if the evidence presented at the preliminary hearing was insufficient. The defense can also file motions to suppress statements or other evidence at various times depending on tactical considerations. During this time, the prosecution will also decide whether to seek the death penalty. The defense will present evidence to the prosecution that Jayden should not receive the death penalty. As I have said, I think that it is unlikely that the prosecution will seek the death penalty for Jayden, but I cannot guarantee that.

The next step is a jury trial where, as the name suggests, each side presents its case, and the jury decides whether Jayden is guilty of any of the counts charged in the Information or lesser ones. If she is found not guilty of all charges, the case is over. If she is found guilty of murder with special circumstances (lying in wait) and the prosecution has elected to seek the death penalty, then case proceeds to the penalty phase where the same jury will decide whether Jayden receives the death penalty. If the jury decides that she should received the death penalty, then she will be sentenced accordingly although the current governor has issues a moratorium on the imposition of the death penalty. If she is found to be guilty of first degree murder with special circumstances and the prosecution does not seek the death penalty, then she will be sentenced to Life-without the possibility of parole (LWOP). If she is found to be guilty of a lesser crime, such as robbery, then she would be sentenced on that charge (max sentence 5 years prison).

The above procedures are a small sample of the infinite number of possible variations to this procedure and outcomes. It is also, in many ways, a worst-case scenario. It nevertheless explains the kind of trouble that Jayden is in with a DA who believes in the righteousness of her case.

100 percent less $10,000 already advanced by family will go directly to Gene for Jaydens defense.

Please help Jayden as she has helped so many others in her life. Help her clear her name.

Jayden’s family