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Most likely to keep costs down, as Grand Theft Auto III had a lot of celebrity voice artists, like Frank Vincent and Debi Mazar. His role in Grand Theft Auto: San Andreas is also minor and there was no need to have him talk.

Claude Speed from Grand Theft Auto 2 also did not talk, although this is more than likely due to the limitations of the PlayStation, meaning they wouldn't put a voice in for the PC version either. He also doesn't speak during GTA 2: The Movie.