deposition of: filiberto arroyo francis c. peterson, et al...

Deposition of:

Filiberto Arroyo

Case:

Francis C. Peterson, et al. v. Kevin Miranda, et al.2:11-CV-01919-LRH-RJJ

Date:

07/08/2013

Filiberto Arroyo Francis C. Peterson, et al. v. Kevin Miranda, et al.

702-476-4500 OASIS REPORTING SERVICES, LLC Page: 1

1 UNITED STATES DISTRICT COURT

2 FOR THE DISTRICT OF NEVADA

3 FRANCIS C. PETERSON, ) Case No.

4 individually, and LINDA ) 2:11-cv-01919-LRH-RJJ PETERSON, individually, )

5 and FRANCIS C. PETERSON ) and LINDA PETERSON on )

6 behalf of ANGELA ) PETERSON, deceased, )

7 ) Plaintiffs, )

8 ) vs. )

9 ) KEVIN MIRANDA, )

10 individually, et al., ) )

11 Defendants. ) ___________________________)

12 ) AND ANY AND ALL RELATED )

13 MATTERS. ) ___________________________)

14

15

16

17 DEPOSITION OF FILIBERTO ARROYO

18 Taken on Monday, July 8, 2013

19 By Videotape

20 At 9:06 a.m.

21 At 517 South Ninth Street

22 Las Vegas, Nevada

23

24 Reported by: William C. LaBorde, CCR 673, RPR, CRR

25 Job No. 6734



1 APPEARANCES:

2 For the Plaintiffs:

3 MARC P. COOK, ESQ. Bailus Cook & Kelesis, Ltd.

4 517 South Ninth Street Las Vegas, Nevada 89101

5

6 For the Defendants Clark County School District, Filiberto Arroyo, Brian Nebeker, Loren Johnson and

7 Armando Quintanilla:

8 KARA B. HENDRICKS, ESQ. Greenberg Traurig, LLP

9 3773 Howard Hughes Parkway Suite 400 North

10 Las Vegas, Nevada 89169

11 For the Defendants Tina Zuniga, Mark Robbins,

12 Cynthia Ruelas and Robert Morales:

13 MATTHEW W. PARK, ESQ. Lewis and Roca LLP

14 3993 Howard Hughes Parkway Suite 600


16 For the Defendants Kevin Miranda, Eric Miranda and

17 Chary Alvarado Miranda:

18 CHRISTOPHER M. KELLER, ESQ. Pyatt Silvestri

19 701 Bridger Avenue Suite 600


21 Also Present:

22 KENNETH LAURSEN

23 Certified Legal Video Specialist

24 FRANCIS C. PETERSON

25 LINDA PETERSON



1 I N D E X

2 WITNESS PAGE

3 FILIBERTO ARROYO

4 Examination by Mr. Cook 7

5 Examination by Mr. Park 265

6 Examination by Mr. Keller 270


8 Examination by Mr. Keller 280

9 Examination by Mr. Park 280


11

12

13

14 E X H I B I T S

15 NUMBER DESCRIPTION MARKED

16 1 "School officials defend actions 29 in probe of porn allegations,"

17 Posted January 21, 2011

18 2 Clark County School District 30 Organizational Chart

19 3 Photographs, Sixth Supplement 64

20 Numbers 85, 87, 90, 91, 119, 129, 122 and 94

21 4 April 30, 2008 Highlights of the 93

22 Week, CCSD000227

23 5 July 30, 2008 Highlights of the 100 Week, CCSD000219

24 6 February 5, 2010 Highlights of the 106

25 Week, CCSD000172




2 7 February 17, 2010 Highlights of 109 the Week, CCSD000174

3 8 January 21, 2011 Highlights of 115

4 the Week, CCSD000155

5 9 August 4, 2011 Highlights of the 117 Week

6 10 September 30, 2009 Department 119

7 Administrative Notice AN-017-10, PETERSON00705

8 11 January 7, 2010 Interoffice 120

9 Memorandum, Wamsley to Quintanilla, CCSD000143

10 12 11-29-09 Concern Report, 151

11 CCSD000125-130

12 13 March 9, 2011 Memorandum, Aldays 160 to Thomas, PETERSON00736

13 14 7-18-11 Concern Report, 167

14 CCSD 000047-048

15 15 August 10, 2011 Department 170 Administrative Notice AN 007-12

16 16 January 7, 2013 Life & Style 172

17 Weekly Cover and DontServeTeens.gov Pages and We

18 Don't Serve Teens Web Site Printout

19 17 10/31/2011 Memorandum, Rainey to 174

20 Ketsaa, CCSD 000057

21 18 July 11, 2012 Department 177 Administrative Notice AN 002-13

22 19 Color Photograph 178

23 20 Color Photograph 179

24 21 Facebook Post By Mark Robbins 190

25




2 22 February 17, 2011 E-mail, Hoffman 222 to [email protected],

3 CCSD 000043-045

4 23 Undated Letter To Whom It May 238 Concern, 4 pages

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25



1 P R O C E E D I N G S

2 THE VIDEOGRAPHER: Today is Monday, July

3 8, 2013. The time is approximately 9:06, as

4 indicated on the video screen. The location is

5 offices of Bailus Cook & Kelesis, 517 South Ninth

6 Street, Las Vegas, Nevada 89101.

7 My name is Kenneth Laursen, Certified

8 Legal Video Specialist, Member Number 00037,

9 American Guild of Court Videographers, from the firm

10 Oasis Reporting Services, located at 2620 Regatta

11 Drive, Suite 102, Las Vegas, Nevada 89128. The

12 court reporter is William LaBorde from the firm

13 Oasis Reporting Services.

14 This is Case Number 2:11-cv-01919-LRH-RJJ

15 in U.S. District Court, District of Nevada. The

16 case is entitled Peterson, et al. v. Miranda, et al.

17 The deponent is Filiberto Arroyo. The videographed

18 deposition is requested by the plaintiff.

19 Counsel and all present will please

20 identify themselves for the record, and then the

21 court reporter will swear in the deponent.

22 MR. COOK: Marc Cook on behalf of the

23 Plaintiffs.

24 MR. KELLER: Chris Keller on behalf of

25 the Defendants Mirandas.



1 MR. PARK: Matt Park on behalf of

2 Morales, Zuniga, Robbins and Ruelas Defendants.

3 MS. HENDRICKS: Kara Hendricks appearing

4 on behalf of the Clark County School District,

5 Filiberto Arroyo, Loren Johnson, Brian Nebeker and

6 Armando Quintanilla.

7 (Witness sworn.)

8 FILIBERTO ARROYO,

9 having been first duly sworn, was

10 examined and testified as follows:

11 EXAMINATION

12 BY MR. COOK:

13 Q. Sir, as I said, my name is Marc Cook. I

14 represent the plaintiffs in this matter. I'm going

15 to ask you a series of questions, first one being

16 have you ever had your deposition taken before?

17 A. Yes.

18 Q. So you're familiar with the process?

19 A. Not to this extent, but in Florida.

20 Q. Okay. What were the circumstances in

21 Florida that you had your deposition taken?

22 A. Multiple times as a police officer

23 working down there on various criminal cases.

24 Q. Your deposition was taken in criminal

25 cases in Florida?



1 A. Yes, not me as the plaintiff, basically

2 in regards to cases that I was investigating before

3 going to trial.

4 Q. Approximately how many times were you

5 deposed in Florida?

6 A. Hundreds.

7 Q. And all those were in your capacity as a

8 police officer in a pending criminal matter?

9 A. Yes, sir.

10 Q. Is this your first video deposition? Is

11 that why you kind of pointed at the phone when you

12 said "not to this extent"?

13 A. Yes, sir.

14 Q. I said "phone." I meant camera. Okay.

15 Procedure's the same. I'm going to ask

16 you a series of questions. You need to answer

17 audibly. I'm going to try to make sure I let you

18 finish your answer before I fire off the next one,

19 and I'd like you to wait till I'm done asking the

20 question even if you know where I'm going to before

21 you answer my question. Is that fair?

22 A. Yes, sir.

23 Q. Are you on any medication or anything

24 that would prevent you from giving your best

25 testimony here today?



1 A. No, sir.

2 Q. Okay. Do you generally understand the

3 deposition process as far as you need to make sure

4 you understand my question; if not, you're free to

5 ask me to rephrase or repeat it or whatever you need

6 to make sure we're on the same track?

7 A. Yes, sir.

8 Q. Okay. You said hundreds of times; is

9 that correct?

10 A. Yes, sir.

11 Q. Have you ever had your deposition taken

12 in a civil case?

13 A. No, sir.

14 Q. Okay. Let's go through your work history

15 then. When was your first job in law enforcement?

16 A. In 1993 with the City of Miami Police

17 Department.

18 Q. Did you say "City of Miami Police

19 Department"?

20 A. Yes, sir.

21 Q. And how long were you there?

22 A. I was there till 1994.

23 Q. Did you have the same position for the

24 year that you were there?

25 A. No. I began work as a patrol officer.



1 Several years into the time in the department, I

2 became a detective with the Narcotics Unit, Robbery

3 Task Force and several other units within the same

4 organization.

5 Q. Okay. Give me the years you were there

6 again 'cause I wrote '93 to '94 and that --

7 A. '83 to '94.

8 Q. Okay. So you started as a patrolman.

9 Where did you go from patrolman?

10 A. I went straight into vice and narcotics

11 and then eventually into the actual Narcotics Unit.

12 Q. When you went from vice and narcotics,

13 was that a promotion from patrolman to some

14 officer-level status?

15 A. When I went from patrol to -- vice and

16 narcotics was within the patrol segment. It wasn't

17 an actual promotion. It was just a change of

18 assignment.

19 Q. And when was that?

20 A. Within three years of being in the

21 department.

22 Q. Okay. So at least by '86 you had that

23 position?

24 A. Correct, sir.

25 Q. What was the next position you held with



1 the Miami Police Department?

2 A. I was with the Miami Narcotics Unit or

3 the overall Street Crimes Unit for the duration of

4 my stay with the Miami Police Department.

5 Q. And did your rank ever change?

6 A. No. I was basically a detective.

7 Q. Is -- well, detective's higher than

8 patrolman; correct?

9 A. In the City of Miami, there's no actual

10 rank for detective.

11 Q. Okay.

12 A. Other than just a change of assignment.

13 Q. So at no point did you achieve a rank of

14 sergeant or lieutenant or anything like that. It's

15 just your duties changed?

16 A. Correct. Yes, sir.

17 Q. When did you leave the Miami Police

18 Department?

19 A. In 1994.

20 Q. And what were the circumstances? Why did

21 you leave?

22 A. By then, Miami had gotten to be a rather

23 rough place to raise a family. My father was also

24 retiring, and we had discovered he -- he was

25 terminally ill. We -- we relocated to the west



1 coast to care for him and help him run his business,

2 which is a -- was a family business.

3 Q. And what was that business?

4 A. A Laundromat.

5 Q. How long did you work at your father's

6 Laundromat?

7 A. We -- he passed away. It took us six,

8 seven months to sell the property. Not even a year.

9 Q. Okay. You moved in '94 to where on the

10 west coast?

11 A. Palm Harbor.

12 Q. And where is that?

13 A. Pinellas County, close to Tampa.

14 Q. And how long were you working at the

15 Laundromat?

16 A. Roughly about a year during that period

17 of time.

18 Q. And during that year period of time, was

19 your dad alive?

20 A. He passed away within six months of us

21 going over to care for him.

22 Q. So in '94, you leave your job with the

23 Miami Police Department. You go to the west coast

24 of Florida --

25 A. Uh-huh.



1 Q. -- and to help your dad, and after about

2 six months he passes; --

3 A. Yes, sir.

4 Q. -- is that correct?

5 A. Yes, sir.

6 Q. Okay. And then what are you doing with

7 the Laundromat at that point?

8 A. We're just basically running the -- oh,

9 during the period?

10 Q. No, no, after your dad passed away.

11 A. Basically just run the -- the property.

12 Q. And you keep saying "we." Who's the

13 "we"?

14 A. My wife, my mom.

15 Q. And how long are you at the Laundromat?

16 Did you say a year?

17 A. Roughly about a year, yeah, uh-huh.

18 Q. Where'd you go after that?

19 A. Three-quarters of the way into the

20 Laundromat, I went to work for Wackenhut Security

21 out of the Tampa office. Once the sale of the

22 Laundromat facilitated, I continued with Wackenhut

23 for another year.

24 Q. So you worked at the laundry -- I mean,

25 at Wackenhut for about a year, year and a half?



1 A. Uh-huh, roughly.

2 Q. And does that take us to roughly

3 somewhere in '95, '96?

4 A. Yes.

5 Q. Now let me back up a bit. You -- you

6 mentioned your wife. What's your wife's name?

7 A. Iliana, I-l-i-a-n-a, Arroyo.

8 Q. And how long have you been married to

9 her?

10 A. It will be 29 years in November.

11 Q. And do you have any kids?

12 A. I have two boys.

13 Q. What is the year of their birth?

14 A. One was born in '91. The other one was

15 born in '85.

16 Q. What's the one born in '91, what's his

17 name?

18 A. '91 is Alex, Eric Alexander Arroyo.

19 Q. And the one born in '85, the older one?

20 A. Phil Michael Arroyo.

21 Q. All right. So I'm in '95, '96, and I've

22 got you so far going from Miami Police Department to

23 a Laundromat to Wackenhut; correct?

24 A. Correct, yes, sir.

25 Q. Were there any reasons that you left the



1 Miami Police Department besides your father's

2 illness and relocating your family?

3 A. No. It was a family decision.

4 Q. Were you ever disciplined while you were

5 with the Miami Police Department?

6 A. A couple times.

7 Q. For what and when?

8 A. I was disciplined as a patrol officer

9 within the first year of working in the department.

10 When you complete an accident report, at least back

11 then at that time, you had to turn it in at the end

12 of the day. I failed to turn in an accident report.

13 I apparently had left it inside the glove

14 compartment of the vehicle. I discovered it when I

15 returned -- when I returned three days later from my

16 three days off. We worked four tens.

17 At that point I went and handed it in to

18 the administrative accident investigation sergeant,

19 and he wrote me up for having turned it in past the

20 24 hours.

21 Q. Did you think that was fair?

22 A. Not necessarily, but I was in -- I was

23 not in compliance.

24 Q. And you said a couple of times. Does

25 that mean two?



1 A. That was one incident. Another incident,

2 I was involved in a -- an arrest and the firearm I

3 was carrying had been off -- basically we have to

4 require our firearms to be within departmental

5 certification. We have to shoot with a firearm at

6 least once a year so we can carry it. The firearm I

7 happened to be carrying that particular day was past

8 certification by five days.

9 Q. So they said it was an unauthorized

10 firearm?

11 A. I was carrying an unauthorized firearm,

12 yeah.

13 Q. And was that in the arrest of Alfred Lee?

14 A. Yes, sir.

15 Q. And was the only discipline you received

16 in that arrest for carrying an unauthorized firearm?

17 A. Yes, sir.

18 Q. And did Mr. Lee sue the Miami Police

19 Department?

20 A. Yes, he did.

21 Q. And do you know how that case ended up?

22 A. I believe the City settled.

23 Q. Do you recall how much?

24 A. No.

25 Q. Did you have to pay anything out of your



1 own pocket for that settlement?

2 A. No.

3 Q. Were you named as a party in that?

4 A. At first.

5 Q. Were you deposed in that case?

6 A. No.

7 Q. Any other discipline while you were with

8 the Miami Police Department?

9 A. Not that I remember.

10 Q. And that incident with Alfred Lee is not

11 what led to your leaving the Police Department in

12 '94?

13 A. No, not at all.

14 Q. When was the incident, the arrest with

15 Alfred Lee?

16 A. I don't remember the exact time.

17 Q. Do you remember when it was in relation

18 to when you left?

19 A. It was a year or two before that, several

20 years before that actually. By the time I had left,

21 he had already been arrested for other issues that

22 he'd become involved in.

23 Q. By the time you left, how long was that

24 in relation to the settlement?

25 A. A couple years.



1 Q. Of the settlement?

2 A. I think.

3 Q. I'm not talking about the arrest. He was

4 arrested. You were involved in the arrest; correct?

5 A. Correct.

6 Q. He filed a civil rights suit; correct?

7 A. Correct.

8 Q. He didn't file that within the first year

9 of the arrest, did he?

10 A. I don't remember. I'll be very sincere

11 with you.

12 Q. All right. When he settled, that was --

13 do you recall how long in relation to the arrest?

14 A. I think he settled within a year or so if

15 I'm not mistaken.

16 Q. And is that a year following the

17 complaint or a year from the arrest?

18 A. I think it's from the arrest, yeah.

19 Q. And from that year from the arrest, in

20 relation to that -- I mean, I'm sorry. Strike that.

21 From the time of the settlement till the

22 time you left the Miami-Dade Police Department --

23 A. That was several years.

24 Q. All right. So we're in 19 -- oh, any

25 other disciplines with Miami Police Department we



1 haven't talked about?

2 A. Not that I remember, no.

3 Q. Any issues while you were with Wackenhut?

4 A. No.

5 Q. No discipline?

6 A. No, sir.

7 Q. Where did you go from Wackenhut?

8 A. We relocated to West Palm Beach and I

9 continued working from Wack- -- with Wackenhut out

10 of the West Palm Beach off- -- actually the Palm

11 Beach Gardens office.

12 Q. So how long total were you with

13 Wackenhut?

14 A. About five years.

15 Q. After you left Wackenhut, where did you

16 go?

17 A. I joined the School District Police

18 Department in Palm Beach.

19 Q. Had you applied for any police positions

20 since you had left the Miami Police Department in

21 '94 up until this point in time when you were hired

22 at the School District Police Department?

23 A. No.

24 Q. And then specifically what was the name

25 of the department you were hired at?



1 A. Palm Beach County School District Police

2 Department.

3 Q. And that was sometime in '96; correct?

4 A. No. I was hired in 2000, February of

5 2000 to be exact.

6 Q. Okay. And what position were you hired

7 in?

8 A. As a police officer.

9 Q. When did you leave the Palm Bounty --

10 Palm Beach County School District Police Department?

11 A. In 2005.

12 Q. Did you have the same rank when you left?

13 A. No. I left as a lieutenant.

14 Q. When did you achieve the rank of

15 lieutenant?

16 A. Several years earlier, halfway through my

17 stay there.

18 Q. So sometime around 2002, 2003?

19 A. Somewhere around there. 2003. It was

20 right after I -- I made Officer of the Year.

21 Q. Did you go from officer to lieutenant?

22 A. Lieutenant, yes.

23 Q. You skipped sergeant?

24 A. Yeah. There is no -- at that time there

25 weren't sergeants' positions for that particular



1 police department.

2 Q. Any disciplines while you were with the

3 Palm Beach County School District Police Department?

4 A. No, just commendations and awards.

5 Q. You said you were Officer of the Year?

6 A. I was Officer of the Month, Officer of

7 the Year. I took the community service award,

8 several others I'm very proud of.

9 Q. When did you -- or strike that.

10 The reason you left Palm Valley -- Palm

11 Beach County Police Department was to come work at

12 the Clark County School District Police Department;

13 is that correct?

14 A. Yes, sir.

15 Q. Was there any other reason for leaving

16 the Palm Beach County School District Police

17 Department?

18 A. No, sir.

19 Well, relocating. My wife and I, we had

20 already gone through three hurricanes and we wanted

21 to get out of Florida.

22 Q. Did you know anybody in the Clark County

23 School District Police Department that prompted you

24 to apply here?

25 A. At the time that I applied, no. It was



1 shortly there afterwards I discovered that the chief

2 of police, Hector Garcia, was the chief of police.

3 I had worked with him in West Palm Beach.

4 Q. Did you apply to any other school

5 districts?

6 A. No.

7 Q. So it was just by happenstance that the

8 one other school district in the country you applied

9 to had a chief of police that you worked for in West

10 Palm -- in West Palm Beach; is that correct?

11 A. Yes, sir.

12 Q. And then when you came out here in 2003,

13 what was your position?

14 A. I came out here in 2005, and I came as

15 captain.

16 Q. Oh, I'm sorry. I'm on the wrong column.

17 Okay.

18 You came out here in 2005?

19 A. August of 2005 as captain. That's the

20 position I had applied for.

21 Q. How did you know about the position? Did

22 you see it posted somewhere?

23 A. It was on-line.

24 Q. Okay. So you came here as a captain;

25 correct?



1 A. I was hired as a captain, yes, sir.

2 Q. How long were you a captain?

3 A. Roughly two, two and a half years.

4 Q. And then from that captain position, you

5 got the opening for chief of police; is that

6 correct?

7 A. The opening, the chief left and went back

8 to Florida, and I put in for the position and I was

9 1 of 65 candidates nationwide.

10 Q. Do you know why he left?

11 A. He went back to -- returned to his -- he

12 was in the process of getting his doctoral year.

13 Q. So your understanding is the reason he

14 left is because he was in the process of getting his

15 doctoral degree?

16 A. That's basically the information that

17 came out. I never spoke to him as to what were the

18 actual particulars.

19 Q. Okay. That's the information that came

20 out from who?

21 A. The notice that went out when he stepped

22 down, the District memorandum.

23 Q. Okay. The only two position -- strike

24 that.

25 Are the only two positions you've held



1 with the Clark County School District Police

2 Department captain and chief?

3 A. Yes, sir.

4 Q. Have you received any discipline in any

5 of those positions?

6 A. No, sir.

7 Q. If we total up the amount of time that

8 you've been in law enforcement, so we've got to take

9 out the Laundromat and the Wackenhut, how long have

10 you been in law enforcement?

11 A. 12 years with the City of Miami, 5 with

12 Palm Beach, and it was a total of 8 with Clark

13 County.

14 Q. So 25 years?

15 A. Yes, sir.

16 Q. And what was the reason for you leaving

17 your position with the Clark County School District?

18 A. Basically the superintendent and I could

19 not positively work together at that point in time.

20 Q. Why not?

21 A. Based on our interaction in the short

22 time that I worked for him, it came -- I came to the

23 conclusion that he had come to the District with a

24 business plan and it did not include me or any other

25 member of the cabinet which he chose to somehow work



1 around or eliminate while I was present.

2 Q. So is it your position that when

3 Superintendent Jones came to the Clark County School

4 District he came with a business plan that included

5 a program where you would no longer be compatible

6 with?

7 A. Correct.

8 MS. HENDRICKS: Objection, misstates

9 testimony.

10 A. Yeah.

11 BY MR. COOK:

12 Q. I'm sorry? Did you say, "Correct"?

13 A. Excuse me?

14 Q. Did you say, "Correct"?

15 A. No.

16 Q. What did you say?

17 A. I started to say, "Yes."

18 MS. HENDRICKS: Sorry, I threw you off.

19 THE WITNESS: No, don't worry.

20 MS. HENDRICKS: If you'll just pause a

21 little bit between your questions, it will give me a

22 chance to object.

23 THE WITNESS: Okay.

24 BY MR. COOK:

25 Q. Let's try it again because I'm not sure



1 what your answer is, so let me see if I can reword

2 it a little bit.

3 Is it your position that Superintendent

4 Jones when he came here as superintendent of the

5 Clark County School District Police Department, he

6 had a business plan in mind that you would not fit

7 into?

8 A. No.

9 Q. Then I don't understand why you're saying

10 you left.

11 A. Basically I don't believe he had that

12 plan in mind when he arrived. As we proceeded to

13 work together, myself reporting to him directly, we

14 started having certain issues, differences, and I

15 believe that's how that developed.

16 Q. What were the issues and differences you

17 were having with him?

18 A. His lack of understanding the concept of

19 supervising a law enforcement agency.

20 Q. Okay. What did he do that gave you the

21 impression he did not understand how to supervise a

22 law enforcement agency?

23 A. Trying to become involved in certain

24 cases, that he should not do the criminal aspects of

25 the cases and so forth.



1 Q. Okay. What were those cases?

2 A. They're personnel issues. I can't

3 discuss them.

4 Q. I'm sorry?

5 A. They're personnel issues. I can't

6 discuss them.

7 Q. Well, you said involved in certain police

8 cases. Now you're saying personnel, so help --

9 A. Well --

10 Q. Let me finish the question.

11 So help me out here. I want to

12 distinguish. I want to make sure we're clear --

13 A. Okay, sure.

14 Q. -- if what you're saying he was involving

15 himself in is personnel issues over Police

16 Department employees or police work issues. Let's

17 start there and then see where it follows up to.

18 A. Okay. Basically administrators working

19 for the District that he supervised possibly

20 involved in criminal activity.

21 Q. Okay. I don't understand what that

22 means. Are you telling me that you believed there

23 were administrators working for the School District

24 that were involved in criminal activity or that he

25 believed it?



1 A. We would --

2 MS. HENDRICKS: Objection as to form. Go

3 ahead and answer the best you can.

4 THE WITNESS: Okay. Administrators that

5 were under criminal investigation where he may have

6 attempted to acquire more information than he should

7 have been privy to.

8 BY MR. COOK:

9 Q. So is it your position then that

10 Superintendent Jones was asking questions about

11 investigations that the School District Police

12 Department was handling that you didn't think was

13 appropriate for him to ask?

14 A. Correct.

15 Q. Okay. And so earlier when you said you

16 couldn't see eye to eye and -- and he was involving

17 himself in some things that led you to believe he

18 didn't know how to run a police department, is that

19 what you were talking about?

20 A. Yes, sir.


22 testimony.

23 BY MR. COOK:

24 Q. That is what you were talking about?

25 A. Yes, sir.



1 Q. Specifically what was he doing that you

2 thought was inappropriate?

3 A. Trying to find out exactly what

4 procedures we were involved in into the criminal

5 investigation of a particular case.

6 Q. And what case is it?

7 A. It's a personnel matter.

8 Q. Nobody's instructing you not to answer.

9 What case was it?

10 A. I can't remember the name of the

11 individual. He worked out of the accounting

12 department. It had to do with a sexual interaction

13 over the Internet.

14 Q. So the private, confidential case you

15 couldn't talk about, is it this one that was in the

16 newspaper?

17 MR. COOK: Can we get that marked.

18 (Exhibit 1 was marked for

19 identification.)

20 THE WITNESS: Yes, it is the case.

21 BY MR. COOK:

22 Q. All right. So the confidential personnel

23 matter that you couldn't tell me about, that guy's

24 name is in the paper here, Darren Boyett?

25 A. Boyett, correct.



1 MS. HENDRICKS: All right. And, Marc,

2 this is the point where I'm going to instruct him

3 not to answer any details of an investigation that

4 he did related to this individual.

5 MR. COOK: I haven't asked anything yet.

6 MS. HENDRICKS: Well, I'm just giving you

7 a heads-up.

8 BY MR. COOK:

9 Q. So is it your position then that the

10 reason or the way you knew you and Jones wouldn't

11 get along was because he was asking you too many

12 questions about the Boyett case that you didn't

13 think was appropriate for him to know?


15 prior testimony. You can go ahead and answer.

16 THE WITNESS: Okay. That was not the

17 only reason, but yes, that was one of the reasons.

18 BY MR. COOK:

19 Q. Okay. What is your understanding as to

20 what -- strike that.


22 identification.)

23 MR. COOK: I don't have enough of these.

24 MR. PARK: That's all right.

25 MR. COOK: During one of the breaks, I'll



1 run some if we need them.

2 BY MR. COOK:

3 Q. I'm going to represent to you, sir, I

4 printed this out sometime earlier in the case just

5 before the deposition of Superintendent Jones.

6 A. Uh-huh.

7 Q. I have no idea why the font on the bottom

8 looks like it's in a different language, but this

9 was produced and ideally that would have had the

10 Bates stamp number on it.

11 Does this at least at the time of 2011

12 represent the structure of the levels of authority

13 of the Clark County School District?

14 A. I'm familiar with where we stood as far

15 as the chain of command. I'm not a hundred percent

16 sure of the rest of these.

17 Q. Okay. So while -- while you cannot

18 attest to whether student support services goes to

19 any particular area, you know the part that says,

20 "POLICE SERVICES" is correctly identified; is that

21 correct?

22 A. Yes, sir.

23 Q. And this shows police services is under

24 the superintendent, who is under the Board of School

25 Trustees; correct?



1 A. Yes, sir.

2 Q. Was that your understanding when you were

3 chief of police?

4 A. Yes, sir.

5 Q. Okay. With that understanding then, is

6 there certain things you understood that you still

7 were not allowed to disclose to the superintendent?

8 A. I don't understand the question.

9 Q. Was there information regarding

10 investigations or anything that you were permitted

11 to exclude reporting to the superintendent?

12 A. That was my understanding.

13 Q. Where do you get that understanding?

14 A. I only worked for Mr. Jones for a certain

15 amount of months prior and after I came back from

16 the Police Academy. The years I worked for Walt

17 Rulffes, he made it a point as superintendent to not

18 get involved in any aspect of our responsibilities

19 when it came to criminal investigations or any type

20 of investigations involving his administrators.

21 Q. The entire time you were the chief of

22 police, you understood that your supervisor was the

23 superintendent, though; correct?

24 A. Correct, sir.

25 Q. Okay. Where is it identified, can you



1 show me any particular paper, any set of orders, any

2 set of policy or regulations that says that there is

3 certain information you are permitted to not report

4 to the superintendent?

5 A. No.

6 Q. So your sole basis for that position is

7 that the prior superintendent appeared to work a

8 little differently with you than Jones did?

9 A. Correct, sir.

10 Q. Now, staying with regard to the case of

11 Boyett, you said that Jones had asked questions

12 beyond, I guess, what you believed you should be

13 telling him. Is that fair?

14 A. Yes, sir.

15 Q. Did you discuss with him this policy

16 that, "It's an investigation. It's ongoing, and

17 here's the reasons why I don't think I have to tell

18 you"?

19 A. Yes, sir.

20 Q. He disagreed?

21 A. Yes, sir.

22 Q. What are the policy reasons as to why you

23 would not want to tell your superintendent about a

24 particular investigation?

25 A. If he is part of the investigation, he



1 can be subpoenaed to testify and have to attend

2 court in such a case.

3 Q. So the sole reason you would not tell the

4 superintendent or is this just one of the reasons?

5 A. It's just one, one of the main reasons,

6 yes.

7 Q. Okay. What are the other reasons?

8 A. For him to actually start directing us as

9 to how to conduct the investigation.

10 Q. You didn't want to tell the

11 superintendent because you did not want the

12 superintendent to tell you how to conduct the

13 investigation.


15 testimony.

16 MR. COOK: You got to let me finish the

17 question.

18 BY MR. COOK:

19 Q. Is that correct?

20 A. Basically what it was, for him to involve

21 himself in directing our investigation, he had no

22 criminal or law enforcement background and/or

23 experience in such matters.

24 Q. Do you believe there is a difference in

25 having to follow a directive from a supervisor if



1 the supervisor knows what they're talking about

2 versus whether they don't know what they're talking

3 about?

4 MS. HENDRICKS: Objection as to form.

5 Answer if you can.

6 A. I don't believe so.

7 BY MR. COOK:

8 Q. So if your supervisor tells you something

9 and -- and they're -- if -- if while you were a

10 patrol officer in Miami and you've got a supervisor

11 who's great at his job and he knows how to tell you

12 to handle things and he gives you a directive that

13 you think is perfect, first he's your supervisor and

14 second you like the advice so you're likely to

15 follow it; is that correct?

16 A. If I believe --

17 MR. PARK: Objection, form.

18 MS. HENDRICKS: Join.

19 A. If the information being provided is

20 lawful and correct and within policy.

21 BY MR. COOK:

22 Q. Okay. Now, if your supervisor is an

23 idiot and doesn't know how to conduct a traffic stop

24 even but is telling you how to do your job and he's

25 still your supervisor and it is lawful and within



1 policy, you still have to follow it; is that

2 correct?


4 A. I would bring it to his attention, as I

5 did the superintendent, but I would be following his

6 directive.

7 BY MR. COOK:

8 Q. Okay. So there's no -- nothing you can

9 point to that says the superintendent asking you for

10 more information on any particular investigation is

11 unlawful; correct?

12 A. Correct.

13 Q. And there's nothing that you can point to

14 about a superintendent asking you for more

15 information that violates any policy you're aware

16 of; correct?

17 A. Correct.

18 Q. So you told him those concerns, but then

19 ultimately did you tell him the information he

20 wanted to know?

21 A. Yes, sir.

22 Q. Okay. But it was that type of request

23 for information that led you to believe that you

24 didn't want to work with this guy?

25 A. That was one of the aspects.



1 Q. Okay. What are the other aspects?

2 A. We were also having issues in negotiation

3 regarding my -- my contract.

4 Q. Any other issues?

5 A. No.

6 Q. Okay. Before we get to the contract

7 aspects, I want to stay in this area that we were

8 talking about that you didn't like or weren't

9 comfortable with -- I don't know what the right word

10 you want to use is -- of the way he would request

11 more information regarding investigations.

12 Did that involve other cases aside from

13 Boyett?

14 A. That's the one that stands out. I can't

15 remember anything else.

16 Q. Okay. And you don't remember anything

17 about this case falling into that category; is that

18 correct?

19 A. Correct.

20 Q. So the only case in which you believe

21 Superintendent Jones was asking questions that you

22 did not believe he was entitled to answers to was

23 the Boyett case?


25 A. Correct.



1 BY MR. COOK:

2 Q. And then what were your contract issues

3 that you believe led to your separation?

4 A. One of the issues were basically the

5 at-will segment of the contract.

6 Q. You did not want the at-will segment?

7 A. Correct.

8 Q. Are you aware of whether any other chief

9 of police had a contract that did not have the

10 at-will clause?

11 A. That's what was told to me by the EMR

12 representative, Mr. Goldman.

13 Q. And who did you come to understand had a

14 contract that didn't have an at-will clause?

15 A. No, they did have, that they -- they did.

16 Q. Right. Okay. Then let me ask it again.

17 At the time you said that that at-will

18 clause was an issue because you didn't want one.

19 Wasn't it your understanding that every chief of

20 police that you are aware of had that in their

21 contract with CCSDPD?

22 A. I -- I understand the previous chief of

23 police had an at-will contract. I had been working

24 without an at-will contract for three and a half

25 years.



1 Q. Say that again.

2 A. My contract was not at will. I had been

3 working under that status for three and a half

4 years.

5 Q. Okay. So you did not have at will and

6 they were asking to put an at will in there?

7 A. Correct, sir.

8 Q. I understand now.

9 Any other contract issues that led to

10 your separation?

11 A. No. That was basically it.

12 Q. Okay. When you conveyed to the

13 superintendent that you didn't think he had a right

14 to know these things and that's because, "One, you

15 could be subpoenaed; and second, you've never been a

16 cop. You don't know how to run an investigation,"

17 what did he respond with?


19 A. Well, I didn't exactly put it to him that

20 way, but --

21 BY MR. COOK:

22 Q. I -- I hope not, but substantively that's

23 what you told him?

24 A. Correct, sir.

25 Q. Okay. What was his response?



1 A. That he was the superintendent and I

2 reported to him.

3 Q. And did the superintendent give you any

4 different reasons as to why you were going to have a

5 separation from the School District?

6 A. Well, the separation, I basically

7 separated from the School District.

8 Q. Structurally how did that come about?

9 Wasn't there a period where you were suspended?

10 A. I was reassigned to his office September

11 something. I don't remember the exact date.

12 Q. When you were reassigned to his office,

13 were you still coming into work every day?

14 A. No, no.

15 Q. You weren't coming into work at all?

16 A. I was basically free to do what I needed

17 to do at whatever given time.

18 Q. What were your job duties when you were

19 assigned to his office?

20 A. Absolutely nothing.

21 Q. So how long was it that you were assigned

22 to his office and getting paid with absolutely

23 nothing to do?

24 A. Till February 25th, my last day with the

25 department, or with the District actually.



1 Q. So four, five months, somewhere in there?

2 A. Uh-huh.

3 Q. Is that a yes, sir?

4 A. Yes, sir.

5 Q. Was the reason for that reassignment what

6 we've been talking about or were the reasons for the

7 reassignment different from the ultimate reasons for

8 separation?

9 A. We had -- that was with the separation

10 issue. We had reached a point where we weren't

11 budging or they weren't budging; the School District

12 and I wasn't. I didn't feel comfortable at that

13 particular point to continue on.

14 Q. So then after the separation, how did

15 the -- I'm sorry.

16 After that reassignment, the separation,

17 that's four, five months later. What discussion

18 happened prior to that occurring?


20 Q. You get reassigned where you're at his

21 office?

22 A. Uh-huh.

23 Q. And we talked about two reasons why you

24 believe led to -- strike that.

25 Let me ask you this first: The two



1 reasons we've been talking about, the contract

2 aspects and the manner in which he was going to be a

3 supervisor and request information that you were

4 uncomfortable giving him, were those the two reasons

5 that led to your reassignment or your separation or

6 both?

7 A. Both.

8 Q. Okay. After the reassignment, did you

9 have those discussions with him again from the point

10 of reassignment to the point of actual separation?

11 A. We met several times to discuss the --

12 the reassignment and eventually the separation.

13 Q. Was there any substance to those

14 conversations that we haven't talked about?

15 A. I don't understand.

16 Q. Each of those subsequent conversations,

17 were they about the same thing, the contract issues

18 and the, "You're asking for information I don't

19 think you should be getting as superintendent,

20 particularly with regard to Boyett"?

21 A. Correct, yes.

22 Q. Those were the conversations each of the

23 times?

24 A. Basically it was whether I was going to

25 stay or go. That was no longer the topic of



1 discussion. We were now discussing whether I was

2 going to stay working for him or not.

3 Q. Okay. So those subsequent conversations

4 were, "Sir, knowing that you are only getting

5 something that says 'at will' in it and knowing I

6 need to know about this investigation on Boyett, are

7 you going to stay or are you going to go?"


9 BY MR. COOK:

10 Q. Is that in form and sub- -- or

11 substance --

12 A. To some degree, yes, sir.

13 Q. What part did I miss? You said "to some

14 degree."

15 A. Basically it's a trust issue. By then he

16 did not believe he could trust in me to lead the

17 department, and I did not have trust in him to be my

18 immediate supervisor.

19 Q. And --

20 A. Which -- yeah.

21 Q. And how did that trust issue come about

22 from reassignment to termination?

23 A. The things -- the way things were handled

24 in other areas, particularly with the case in

25 question.



1 Q. Okay. And what did you two talk about

2 that one of you was uncomfortable with the way

3 things were handled in relation to this case?

4 A. From the onset shortly after the first

5 story broke and I gave a statement to Mr. Knapp, I

6 was not allowed to discuss this, give a press

7 conference or deliver any information of any kind.

8 Q. Well, your first statement to Mr. Knapp

9 was essentially that; correct?

10 A. That was the first statement and it was

11 supervised by the PIO office at the District.

12 Q. So at what point was -- was Jones at any

13 point unhappy with that statement you gave?

14 A. No. He was not unhappy that I'm aware

15 of.

16 Q. Okay. So then when you talk about a loss

17 of confidence in relation to this case, when did

18 that begin and what was it about?


20 A. As the news media stories began to roll

21 out with intensity, he started having issues as to

22 the truth behind the news stories and the incidents

23 involving the case itself.

24 BY MR. COOK:

25 Q. How many times did you talk to Jones



1 about this case?

2 A. Several times.

3 Q. More than twice?

4 A. Oh, yes.

5 Q. More than five times?

6 A. Possibly, yes.

7 Q. More than ten times?

8 A. No, I don't think more than ten times.

9 Q. Best estimate then would be between five

10 and ten. Is that fair?

11 A. That's pretty close, yes, sir.

12 Q. When did those conversations begin?

13 A. Oh, the first one began shortly after

14 the -- the -- the George Knapp story.

15 Q. There's been a bunch of them.

16 A. The -- the first one that came out I

17 believe came out at the end of July, the first

18 story, which actually had my statement in it if I'm

19 not mistaken.

20 Q. So the statement on or around Miranda's

21 sentencing, does that sound right?

22 A. It was -- I believe -- I believe I gave

23 him my comment July 21st and his story came out July

24 26th or something like that.

25 Q. Of 2011?



1 A. Yes, sir.

2 Q. Okay. So you started having discussions

3 with Superintendent Jones about the Peterson case

4 after that story?

5 A. Correct.

6 Q. What were those conversations?

7 A. We discussed the situation at hand. He

8 asked me as to the particular steps I had taken upon

9 being informed of the situation.

10 Q. Approximately -- I know you said it was

11 five to ten conversations -- when after that July

12 story broke, July of 2011, was your first

13 conversation with him, within 30 days?

14 A. Within a week or so 'cause right -- right

15 at that point is when we elected to meet with Doug

16 Gillespie so he could review the case that the

17 investigators had conducted.

18 Q. So your first conversation with Jones was

19 also with Jones and Gillespie?

20 A. No. My first conversation with Jones was

21 shortly after the story with George Knapp.

22 Q. Okay. Then explain to me why you

23 mentioned the sheriff's name.

24 A. Because when the original incident was

25 brought to our attention the Monday after the



1 incident, I directed the current chief, Ketsaa, who

2 at the time was the captain over the administrative

3 division or department, to contact Metro and inform

4 Metro of the information we had received regarding

5 our employees having attended a party. And Ketsaa

6 contacted Metro -- if I'm not mistaken, it was

7 Detective Chavez -- and provided them with the

8 information.

9 Q. Your first conversation with Jones was

10 about a week after the July 2011 story?

11 A. Something around that time, yes.

12 Q. Was that in person or on the phone; do

13 you recall?

14 A. In person.

15 Q. Where?

16 A. In his office.

17 Q. What did you two discuss?

18 A. Basically the steps that I had taken

19 regarding the case. When the original case

20 occurred, Jones wasn't superintendent. That was

21 Mr. Rulffes.

22 Q. Right.

23 A. I briefed him on the steps we had taken,

24 which primarily were, as I stated, we -- Captain

25 Ketsaa at the time notified Metro, informed them of



1 the information, and Metro took the information, the

2 names in question, to investigate the criminal

3 action and that the allegations being presented by

4 the media weren't correct as to a cover-up and we

5 could contact Doug Gillespie, the sheriff, meet with

6 him; I can introduce him to the superintendent --

7 they had not met -- and at that point request for

8 him to have his investigators review the case one

9 more time.

10 Q. That was your first conversation with

11 him?

12 A. Yes, sir.

13 Q. Okay. And when you said "the

14 information," "we gave them the information," what

15 specifically in- -- what specific information did

16 you have Ketsaa --

17 A. That -- I'm sorry, keep going.

18 Q. -- give -- give Metro or whoever you had

19 there?

20 A. That Monday morning Sergeant Brian

21 Nebeker provided us with information that there had

22 been a party that weekend and several of our

23 dispatchers had attended. Several of them had

24 already come forth, and he had a list of names at

25 that particular time.



1 That information was passed on to the

2 detective by Captain Ketsaa.

3 Q. Any other information you had on that

4 Monday?

5 A. No. That's -- that's basically it.

6 Q. And when you said several dispatchers

7 came forth, who were those dispatchers?

8 A. I believe it was Wamsley, the owner of

9 the home; Gamboa; and I believe Armando Quintanilla.

10 Those are the names that stick to my head for some

11 reason.

12 Q. Okay. And it's your belief that Wamsley

13 came forward?

14 A. I remember seeing a memorandum that she

15 had written informing the department of the fact

16 that she had had a party.

17 Q. Let me ask this again just so I

18 understand.

19 On the Monday after the party, you had

20 said several dispatchers had come forward. What I'm

21 trying to find out is: Who were the dispatchers

22 that came forward that you are aware of by that

23 Monday after the party?

24 A. The names that I do remember specifically

25 were Gamboa and Quintanilla.



1 Q. So the Monday after the party, nobody

2 besides --

3 A. Those were --

4 Q. -- Gamboa and Quintanilla do you recall

5 coming forward?

6 A. Those were the names that I remember

7 being mentioned.

8 Q. Do you recall what information either of

9 those two came forward with?

10 A. No.

11 Q. Okay. So going now back to July 2011,

12 maybe the beginning of August 2011 when you're

13 talking to Jones this first time in person and you

14 tell him, "We turned over information to Metro,"

15 what specifically is the information you're telling

16 him you turned over to Metro?

17 A. The names that were provided to us that

18 Monday morning for them to follow up on the

19 investigation.

20 Q. Did you tell him, "We got some names that

21 Monday morning and we gave them to Metro," or did

22 you give him actual names that you gave over to

23 Metro?

24 A. I believe I specifically told him we had

25 acquired several names, never mentioned who the



1 employees were, and that they were basically given

2 to the detective being -- via a phone call by

3 Captain Ketsaa.

4 Q. Okay. What else did you do -- what else

5 did you tell Jones about during that July meeting?

6 A. Basically that the allegations being

7 presented weren't correct. At no time had we

8 attempted any type of cover-up.

9 Q. Do you know what Ketsaa told Chavez?

10 A. No, sir.

11 Q. So you're relying that the information he

12 gave you was accurate, "he" being Ketsaa?

13 A. After he spoke to Chavez?

14 Q. Right.


16 Q. Okay. What did Ketsaa tell you happened

17 with his conversation with Chavez?

18 A. That Chavez took the information down and

19 he would follow up on the names. I believe there's

20 also a folder, a file, that was put together by

21 Captain Ketsaa, which had the -- the individuals'

22 names.

23 This was word of mouth. I never actually

24 saw the folder.

25 Q. Who told you Ketsaa put together a file?



1 A. He did.

2 Q. And what was in the file?

3 A. The names of the infor- -- of the

4 individuals that we had been provided with that

5 morning.

6 Q. Is it your understanding that Ketsaa was

7 giving the file to Chavez?

8 A. No. He actually put together the file

9 for his record. He's the captain over the

10 administrative division. He chose to do that.

11 Q. What was your next meeting with Jones?

12 A. When we structured the meeting with

13 Sheriff Gillespie.

14 Q. Okay. So there was a second meeting

15 where you and Gillespie met with Jones?

16 A. The second meeting. First meeting with

17 myself and the superintendent; the second meeting

18 with Gillespie, superintendent and myself.

19 Q. Would it surprise you that Superintendent

20 Jones doesn't recall that meeting during his

21 deposition?

22 A. Now you understand why I no longer work

23 for him.

24 Q. How long was that meeting?

25 A. 35, 40 minutes if I had to guess.



1 Q. What was discussed during that meeting?

2 A. It was held at the Cleveland Clinic

3 across from the -- the County office, the brain

4 clinic.

5 Q. Why there?

6 A. The superintendent was having a workshop

7 where all his -- all his administrative staff and --

8 and District directors were to be part of, including

9 myself. It was an all-day affair. He chose to have

10 the meeting first thing in the morning before

11 attending the workshop.

12 I met Sheriff Gillespie in the courtyard

13 for a few minutes prior to going upstairs and

14 introducing him to the superintendent.

15 Q. What did you and Gillespie talk about

16 before you went up and talked to the superintendent?

17 A. Basically he wanted to know what was the

18 gist of the meeting. I explained to him it was not

19 only to meet the superintendent but also we were

20 going to be requesting if he could have his

21 detectives review the initial case due to all the

22 stories that had been coming out in the papers.

23 On a personal note, I also asked him that

24 after the information I had presented Mr. Knapp,

25 Mr. Knapp still wanted to have some more information



1 or interaction with me, and I asked for his personal

2 opinion on whether I should or not contact him.

3 Q. And what did Gillespie tell you?

4 A. He said it wouldn't hurt, and then I

5 agreed with him. Unfortunately when I asked the

6 superintendent, I was not allowed to discuss the

7 point with everyone or give a press conference or

8 anything thereof.

9 MR. PARK: Marc, when you get to a good

10 point, can I have just a two-minute break?

11 MR. COOK: Yeah. Let me finish up with

12 this conversation with -- and then we can do that.

13 BY MR. COOK:

14 Q. Now, you go upstairs and you have the

15 meeting with Jones. What is discussed?

16 A. Basically the same thing I had just

17 covered with Gillespie, the fact that -- you know, I

18 introduced him to the superintendent. We brought up

19 the case and that the information that we had

20 presented to his detectives and if he could open

21 some type of review to verify where the

22 investigation had led because from the moment that I

23 handed -- or, should I say, Captain Ketsaa contacted

24 the detective regarding the information, a year and

25 a half had passed and Metro never came back to us



1 giving us any more particulars or any specifics as

2 to the case, whether it should be followed through

3 with a personnel matter or not or -- or further

4 criminal activity.

5 Q. I've got two conversations you've had

6 with Jones, one with Gillespie and one with not,

7 since the story, and one of the things I recall from

8 the story -- and I don't know if you do, and if you

9 don't know, let me know -- was not just dispatchers,

10 but that there were police officers drinking with

11 this kid at the party. Do you recall that being in

12 the story?

13 A. I remember that story being there.

14 Q. Okay. What you've told me so far then

15 that you conveyed to Jones was information about

16 dispatchers that had come forward?

17 A. Correct.

18 Q. Do you view Quintanilla as a dispatcher

19 or a police officer or something --

20 A. He's a --

21 Q. -- in between?

22 A. He's a dispatch super- -- he was a

23 dispatch supervisor at the time.

24 Q. Okay. Is Jones not asking about the

25 allegations of police officers drinking?



1 A. Well, I made it clear during the

2 conversation when I brought all the details forth

3 that at no time were we ever informed by anyone via

4 complaint or otherwise that police officers had been

5 doing or participating in the actions in the news

6 story.

7 Q. When is this second meeting, the one at

8 the Cleveland Clinic?

9 A. It was somewhere in August. The reason I

10 remember it specifically, it was off site at the

11 Cleveland Clinic and it was during the workshop, but

12 I can't remember the exact time.

13 Q. Do you recall the news story about Penny

14 Higgins saying, "I saw officers drinking with this

15 kid, Miranda"?

16 A. Correct. I remember that.

17 Q. Was it before that news story that you

18 met this time with Superintendent Jones and

19 Gillespie or after?

20 A. I believe it was before that, but I'm not

21 a hundred percent sure.

22 Q. Well, if it was after, you wouldn't have

23 been able to tell Superintendent Jones --

24 Superintendent Jones that you haven't heard of any

25 officers drinking with Miranda; right?



1 A. Well, nothing was brought to our

2 attention in a formal complaint or -- or in an

3 actual documentation other than what was handed down

4 via the media, correct.

5 Q. Okay. But if you're telling somebody you

6 know something or haven't been informed something,

7 are you restricting it to what you've received in

8 writing?


10 Q. If you're telling Superintendent Jones

11 what you do or don't know or telling Sheriff

12 Gillespie what you do or don't know about this case

13 as of July and August 2011 when these meetings

14 occur, are you limiting the information you tell

15 them to just based on documents you have reviewed?

16 A. Oh, no, based on the overall story,

17 correct.

18 Q. Okay. So when you say that you told

19 Jones, "We don't have any information about cops

20 drinking or participating with kids," are you

21 telling me you just discounted Higgins' story or

22 Higgins' story wasn't something you had heard yet --

23 MS. HENDRICKS: Objection.

24 BY MR. COOK:

25 Q. -- or something else?




2 A. Yeah, I don't believe I had -- that story

3 had come out yet.

4 BY MR. COOK:

5 Q. Okay. Anything else about that second

6 meeting we haven't discussed?

7 A. No. I think that pretty much covered the

8 majority of it. The -- the -- Gillespie informed us

9 that he would contact his investigators but not to

10 expect quick action at any given time. It would

11 take a while to put together a squad or something of

12 that nature.

13 Q. Do you recall anything else about that

14 meeting we haven't discussed?

15 A. That's the one things that come to mind.

16 MR. COOK: Okay. Let's take a couple

17 minutes.

18 THE VIDEOGRAPHER: Please stand by. This

19 concludes disk number one in the videographed

20 deposition of Filiberto Arroyo. The approximate

21 time, as indicated on the video screen, 10:06.

22 We're now off the record.

23 (Recess taken.)

24 THE VIDEOGRAPHER: We're back on the

25 record. This is the beginning of disk number two in



1 today's videographed deposition of Filiberto Arroyo.

2 The approximate time, as indicated on the video

3 screen, 10:17.

4 BY MR. COOK:

5 Q. Sir, we went through two of the meetings.

6 When's the next meeting you recall?

7 MS. HENDRICKS: Meetings with --

8 MR. COOK: Strike that. Sorry.

9 BY MR. COOK:

10 Q. I've got you mentioned that there was

11 five to ten meetings with Superintendent Jones and

12 you. So far we've talked about a July meeting and a

13 August meeting that you believe was the beginning

14 part of August.

15 A. Okay.

16 Q. When is the next meeting you recall with

17 Superintendent Jones?

18 A. The easiest way for me to base it, we

19 would have a cabinet meeting almost every two weeks

20 on average. I usually talked to him right before,

21 during or after the cabinet meeting, in between

22 those days.

23 Q. Okay. So you talked to him every two

24 weeks --

25 A. On average, yes, sir.



1 Q. -- about this case or in general?

2 A. Oh, in general, yeah, and, you know,

3 certain aspects of the -- the situation would come

4 up, whether it was the most recent media story or --

5 or what actions are being addressed within the

6 department, so forth and so on.

7 Q. What's the next conversation you recall

8 with Jones after the ones we discussed?

9 A. If I had to calculate, probably within a

10 week or two.

11 Q. If your belief that the conversation we

12 just finished discussing before the break occurred

13 before the Higgins story is correct, is it fair to

14 say your next conversation would have come about

15 with something along the lines of, "I thought you

16 said no cops were drinking. This woman says she saw

17 cops drinking"? Did anything like that in form or

18 substance come up with Jones?


20 A. I specifically shared with him the fact

21 that, as far as I was aware, other than the stories

22 regarding the -- the allegations in the newspaper,

23 we had not been made any formal notification of such

24 things. I remember that coming up in one of the

25 conversations.



1 BY MR. COOK:

2 Q. When was it you first heard what you

3 believe was information on the potential of a police

4 officer drinking at this party with Miranda that was

5 significant enough to give you concern that it might

6 be true, if ever?


8 A. Shortly after the story came out, I

9 discussed it with the superintendent, and based on

10 the -- the particular story -- again, I don't

11 remember the actual story, how it was worded -- I

12 believe that the story itself was made up by certain

13 individuals within the department for other reasons.

14 BY MR. COOK:

15 Q. You believe the story from Knapp was made

16 up by individuals in the department for other

17 reasons?

18 A. Correct, sir.

19 Q. And when did you come to this belief?

20 A. Shortly after the story aired.

21 Q. What about that story made you think it

22 was coming from your department?

23 A. When the incident occurred, again we --

24 we made the notifications to Metro since they were

25 conducting the criminal investigation, and then for



1 a period of over a year and a half nothing was

2 mentioned, nothing was brought up, nothing else was

3 presented per se.

4 In February shortly after notifications

5 went out that two individuals were being promoted

6 from within the department as well as I was going to

7 be leaving for a three-month period, the rumors

8 started to roll within the organization.

9 Q. And that's February of when?

10 A. The end of February. I'm not --

11 Q. What year?

12 A. Oh, '11, 2011.

13 Q. Prior to February 2011 then -- strike

14 that. I want to get back to that. Let me change

15 subjects, and we're going to get back to this in a

16 bit.

17 During the time that you were a police

18 officer, 25 years, have you ever had to make a

19 traffic stop?

20 A. Yes, sir.

21 Q. That's what you were doing for at least

22 the better part of the first year; correct?

23 A. As -- in Miami as a police officer?

24 Q. Right.

25 A. Yeah, on occasion, yes, sir.



1 Q. And when you started at West Palm Beach,

2 you were also a patrol officer; correct?

3 A. Yes, sir.

4 Q. And that was part of your general duties

5 as a patrol officer?

6 A. Uh-huh.

7 Q. Is that a yes, sir?

8 A. Yes, sir. I'm sorry.

9 Q. Did you have any DUI arrests?

10 A. With Miami, never with the School

11 District.

12 Q. Is it fair to say that .152, in your

13 experience, is pretty drunk?

14 A. Yes, sir.

15 Q. Noticeable?

16 A. Yes, sir.

17 MR. PARK: Objection, form. Sorry.

18 BY MR. COOK:

19 Q. Would you expect -- while you were chief

20 of police at Clark County School District, would you

21 expect your officers if they were talking to a minor

22 who had .152 in their system from drinking Jack

23 Daniel's among potentially other beverages, would

24 you expect them to be able to tell they were talking

25 to a drunk kid?



1 A. I would --


3 MR. PARK: Objection, form, foundation.


5 A. I would hope so, yes, sir.

6 BY MR. COOK:

7 Q. Did you ever while you were acting as a

8 patrol officer, frankly any capacity in your 25

9 years as an officer, come upon an accident scene?

10 A. Yes, sir.

11 MR. COOK: These are the same package of

12 photos. Okay.

13 MR. PARK: Car photos?

14 MR. COOK: Yeah.


16 identification.)

17 BY MR. COOK:

18 Q. I'd like you to take a look through

19 those, please, sir.

20 Ever see an interior crush like that in

21 one of the accidents you rolled up on?

22 A. Yes, sir.

23 Q. Pretty significant impact?

24 A. Extremely.

25 Q. Are you, through your experience in



1 looking at these photos and being at other accident

2 scenes, be able to tell me how fast you think this

3 car was going, and I'll even give you a wide range

4 to estimate as you need?

5 A. From my experience, at least 60 miles an

6 hour.

7 Q. Do you understand why these people are

8 upset?

9 A. Yeah, I understand totally, sincerely.

10 Q. I want to talk to you about police duties

11 generally. If a police officer witnesses a crime,

12 Clark County School District police officer under

13 you as chief of police witnesses a crime, what's

14 your expectation?

15 A. Well, it would have to be depending on

16 the circumstances, the totality of the situation, if

17 it's a misdemeanor, if it's a violent act, a

18 category -- a Class A, Class B, whether they're on

19 duty, off duty, that type of scenario.

20 Q. If your officers are witnessing a crime,

21 does it matter whether they're on duty or off duty?

22 A. It depends on the circumstances. If

23 they're on duty, by law, they have to act as the

24 capacity that their chosen professional allows them.

25 If they're off duty, it depends on the circumstances



1 whether it rises to the level or not.

2 Q. Do you have any particular policy you can

3 point me to for that or is that just what you

4 believe?

5 A. No, that's -- no, there's nothing

6 written. That's basically it.

7 Q. Okay.

8 A. You have the legal obligation, the moral

9 obligation. That's --

10 Q. If one of your police officers is at a

11 party and he's sitting at a table and he's having a

12 beer with a kid who's having an alcoholic drink and

13 that kid's under 21 years old, what do you want your

14 officer to do?


16 A. If indeed that individual is a minor, as

17 a citizen and as an individual working for a law

18 enforcement agency, notify the owner of the home and

19 make arrangements to make sure the situation's

20 addressed.

21 BY MR. COOK:

22 Q. Is he done there?

23 A. Excuse me?

24 Q. Is he done there? Is the officer done

25 there?



1 A. If --

2 MR. PARK: Same objection.


4 BY MR. COOK:

5 Q. You said "notify the owner."

6 A. Yeah.

7 Q. We still have a kid who's drinking.

8 A. Uh-huh.

9 Q. What do you want him to do to make sure

10 this guy doesn't get into a car and kill somebody?

11 A. By all means --


13 A. And I'll clarify what I stated. Do what

14 he -- what has to be done in regards to making sure

15 that the kid or juvenile is not allowed to drive off

16 that property, keys confiscated, parents notified,

17 so forth and so on.

18 BY MR. COOK:

19 Q. And that doesn't matter whether he's off

20 duty or on duty; correct?

21 A. Well, it does matter. As a -- as a

22 on-duty officer, you're -- you're within the law.

23 You basically are obligated to take action. If

24 you're off duty, you may, but again it goes to the

25 moral aptitude.



1 Q. Okay. I -- I'm -- I want to separate the

2 moral obligation.

3 A. Okay.

4 Q. I want to talk about a police officer.

5 If a police officer sees a minor drinking in front

6 of him at a party, he's almost 1 -- .152 -- let me

7 start that again 'cause I think it looks like

8 "1.152."

9 You've got an officer at a party. He is

10 drinking across the table from a minor who's

11 drinking. This minor is approaching a .152. What

12 do you want your officer to do? What are his

13 duties?

14 A. Exactly what --


16 MS. HENDRICKS: Join. Go ahead.

17 A. Exactly what I just said. Basically

18 notify the owner of the home, make sure the

19 individual is not allowed to drive off property,

20 notify the parent and furthermore call the local

21 agency to report and respond to the location.

22 BY MR. COOK:

23 Q. If that officer is watching this kid play

24 beer pong with dispatchers, what do you want him to

25 do?




2 MR. PARK: And foundation.

3 BY MR. COOK:

4 Q. And I --

5 MR. PARK: Join.

6 BY MR. COOK:

7 Q. And I don't mean morally. I mean as a

8 cop.

9 A. If the young man -- if the individual's a

10 minor and it is obvious he is intoxicated and he's

11 been given or being allowed to acquire alcoholic

12 beverages, take the same action.

13 Q. As we sit here today, do you believe if

14 you were still chief of police -- strike that.

15 At what point in time in this case do you

16 believe there was enough information to suggest an

17 officer was drinking with a minor that would allow

18 you to direct some type of investigation of that

19 matter at the Clark County School District Police

20 Department?


22 MR. PARK: Join.

23 A. Basically once we were aware and we gave

24 the information to the Metropolitan Police

25 Department to conduct a criminal investigation, we'd



1 be dependent on their investigation to provide us

2 with the information. If indeed there's sustained

3 evidence or probable cause to follow through with

4 one of our officers or several of our officers, at

5 that point it would have been addressed at that

6 point.

7 Again, the criminal aspect would have

8 been handled by Metro.

9 BY MR. COOK:

10 Q. How about the investigation by you of

11 your agency for having a concern that cops are

12 drinking with minors?

13 A. Once Metro would have -- basically once

14 Metro would have completed their investigation,

15 which would have produced information that indeed

16 our officers or officers were involved in that type

17 of behavior, at that point we would have proceeded

18 with our Internal Affairs investigation. Is that

19 what you're referring to?

20 Q. Do you only need information from Metro?

21 What if it comes from another source?

22 A. Even if it comes from another source,

23 under the circumstances we still have to wait for

24 the criminal case to follow through.

25 Q. You don't do -- I'm just trying to get



1 the right terminology here.

2 You don't do joint investigations with

3 Henderson Police Department?

4 A. We've done joint investigations with --

5 Q. Okay.

6 A. -- Henderson Police Department.

7 Q. All right. So let me ask you again then.

8 At what point in time in this case, if

9 ever, did you believe you had enough information

10 that a police officer may have been drinking with a

11 minor that you or the Clark County School District

12 Police Department should have done some type of

13 investigation of members of the Clark County School

14 District Police Department?

15 A. When the stories proceeded to come out

16 involving Ms. Higgins, if I'm not mistaken, Metro

17 was investigating and interviewing the individual.

18 At that point we would have, again, waited for Metro

19 to conclude with their case before opening up a

20 personnel Internal Affairs case.

21 Q. Do you know when that investigation

22 concluded, if ever?

23 A. No.

24 Q. You were no longer in that position at

25 that time?



1 A. I don't know.

2 Q. Okay. When did you first hear about this

3 lawsuit?

4 A. I'm not exactly sure.

5 Q. What is your understanding as to what the

6 allegations in this lawsuit are?

7 A. Basically that employees of the Clark

8 County School District and School District Police

9 Department provided alcoholic beverages to the

10 individual, who went off and was involved in the

11 fatality, and that furthermore I along with my

12 command staff knew about it and obstructed the

13 information.

14 Q. At any time prior to the lawsuit being

15 filed, were you concerned that a lawsuit might be

16 filed?

17 A. I wasn't concerned, no.

18 Q. Are you paying for your attorneys' fees

19 in this case?

20 A. No.

21 Q. Who is?

22 A. The School District.

23 Q. When did you first hear that there was a

24 party at Rebecca Wamsley's house, before or after

25 the party?



1 A. That Monday morning.

2 Q. The Monday morning after the party?

3 A. Correct.

4 Q. Did you see a flier at any point in time?

5 A. No, sir.

6 Q. Have you ever seen a flier?

7 A. In one of the meetings with the

8 superintendent, he actually showed me a flier.

9 Q. Would you be surprised then that he told

10 me he had never seen a flier till I presented it to

11 him at his depo?

12 A. That wouldn't surprise me.

13 Q. Why would that not surprise you?

14 A. Again, it's one of the reasons I lost

15 confidence in the individual.

16 Q. And is that because you perceived as him

17 having a really bad memory, being too busy or being

18 untruthful or some combination of the three?


20 A. The third. And I believe furthermore

21 when he showed me the document -- oh, what's -- his

22 then chief of staff, Craig Kadlub, was present. It

23 was in his office.

24 Furthermore, just to add another piece,

25 our -- our building is very sterile. It's basically



1 an office building. There is no areas in the

2 building in the corridors to hang fliers or

3 notifications. The only bulletin board is in the

4 café or the employees' cafeteria, and the

5 documentation hanging or being pinned onto the board

6 is authorized through the chief's office. Whether

7 it's workmen's comp information or other type of

8 documentation, it all has to go through the chief's

9 office, be approved and then pinned on that board.

10 BY MR. COOK:

11 Q. So there shouldn't be anything in --

12 posted in that dispatch area or that mail area

13 around it without approval from your office?

14 A. Correct, sir.

15 Q. I'm going to read you from page 16 of

16 Superintendent Jones's deposition.

17 A. Uh-huh.

18 Q. "The last part of this exhibit is the

19 party flier. Have you ever seen that before?"

20 His answer: "I have not seen it."

21 That surprises you?

22 A. Yes, sir.

23 Q. I'll just give you a little more info

24 here. His deposition was taken July 19th, 2012,

25 which was after your separation; correct?



1 A. Yes, sir.

2 Q. So the meeting you're talking about where

3 he had the flier and you discussed the flier was

4 prior to that date?

5 A. Oh, yes, sir.

6 Q. So the first time you're saying you saw

7 the flier was at his office?

8 A. Correct.

9 Q. Did you hear about there being a flier at

10 any point in time prior to seeing it in his office?

11 A. No.

12 Q. You didn't hear about it in that July

13 2011 news report?

14 A. Well, I stand corrected. Yeah, it was in

15 the -- in the actual media story, but as far as

16 being firsthand information from someone, no.

17 Q. When you say "as far as being firsthand

18 information from somebody, no," I -- leads me to try

19 and get a clarification --

20 A. Okay.

21 Q. -- here. Okay?

22 Are you basically saying, "I forgot about

23 that, yeah," or is there a distinction you're making

24 in seeing something on the news versus seeing

25 something from an individual you're across the table



1 with?

2 A. No, I -- the first time I saw it was when

3 he provided it to me.

4 Q. Yeah. I'm trying to deal with the second

5 part of your answer where you --

6 A. Okay.

7 Q. -- said, "I stand corrected. That was on

8 the news. This was the first time somebody handed

9 it to me."

10 I've asked you a ton of questions so far

11 and at no point have I said "on the news" or "handed

12 to you."

13 A. Okay, okay.

14 Q. And I want to know if I got to go back

15 and ask you everything --

16 A. No.

17 Q. -- with that distinction or if you're

18 just saying, "Yeah, I forgot about that."

19 A. No, no, no.

20 Q. Which is it? You just forgot about the

21 news report two weeks earlier?

22 A. Correct, sir.

23 Q. Okay.

24 A. Yes.

25 Q. So you don't see a flier. Posting a



1 flier would have been against regs?

2 A. Yes, sir.

3 Q. And would it also have been against

4 policy to have created the flier on the Clark County

5 School District computer system?

6 A. Yes, sir.

7 Q. So you didn't know anything about a flier

8 until it was on that news story with I think they

9 even highlighted "and of course beer pong"?

10 A. Yes. Correct, yes.

11 Q. Okay. And you don't hear anything about

12 the party until that following Monday morning; is

13 that right?

14 A. Yes, sir.

15 Q. Who did you hear from?

16 A. It was Sergeant Nebeker at the time.

17 He's the one that provided us the information.

18 Q. Who's "us"?

19 A. Myself and Captain Ketsaa.

20 Q. And how did that happen, phone call --

21 A. That morning --

22 Q. -- in person?

23 A. I'm sorry.

24 That morning when I reported to work,

25 Nebeker came to us and let us know that there had



1 been a party and then the accident and some of our

2 employees had been at the party.

3 Q. Where was that, your office, Ketsaa's

4 office, or you just happened to be together?

5 A. I think we were just together. It could

6 have been in the EOC room, which is just adjacent to

7 my office but in the -- the main area of the

8 administrative division.

9 Q. Does Nebeker tell you anything else other

10 than, "There was a party. Some of our employees

11 were there, and there was a DUI accident

12 afterwards"?

13 A. Well, no, the whole -- the whole

14 information.

15 Q. Okay. Then tell me --

16 A. I'm sorry. Basically that -- basically

17 that there had been a party and there had been a

18 death that evening and that the individual who had

19 been involved in the -- in that -- causing that

20 accident had left that party or had been at the

21 party, something of that nature, picking up his

22 girlfriend.

23 And -- and at that point he had two

24 individuals -- I believe it was the names I

25 mentioned -- at which time I informed him to direct



1 himself to Captain Ketsaa, give him all the

2 information and then have Captain Ketsaa contact

3 Metro.

4 Q. So at that point in time, who did you

5 have an understanding was at the party?

6 A. Just of the two names I mentioned.

7 Q. Which were which two?

8 A. Gamboa and Quintanilla.

9 Q. Okay.

10 A. And their prospective others, their --

11 their husband and wife. Quintanilla's wife and, I

12 think, son I understand was there and then Gamboa's

13 husband, or maybe I have it reversed. I'm not sure.

14 Q. Did you know whose house it was at at

15 that time?

16 A. No, not at first, no.

17 Q. Okay. So at that point you don't even

18 know it's at a dispatcher's house?

19 A. Well, I knew it was at a dispatcher's

20 house, but I didn't know who, what dispatcher's

21 house it was.

22 Q. So the morning after the party -- sorry.

23 The Monday after the party, you are aware

24 that a party occurred, at least two dispatchers were

25 there, and somebody who was at the party caused a



1 death?

2 A. Correct.

3 Q. Is there any other information you're

4 aware of on that Monday after the party?

5 A. No, sir.

6 Q. And there's nothing else Nebeker conveyed

7 to you at that time?

8 A. No, sir.

9 Q. And the only two people at that time

10 you're aware of were at the party are Quintanilla

11 and Gamboa?

12 A. Gamboa, yes, sir.

13 Q. And do you have any indication as to why

14 this is being brought to your attention then?

15 A. Because they were employees and Metro was

16 handling the investigation, and in order to, well,

17 fulfill our obligation to Metro's investigation, we

18 were passing on all the information we had at the

19 time.

20 Q. Okay. So to fulfill your obligation to

21 Metro, what information generally do you have to

22 pass on?

23 A. Whatever we have in front of us, in which

24 case we gave them all the information we had.

25 Captain Ketsaa gave them all the information we had.



1 Q. Is it your obligation when you do that to

2 give them the names of everybody who you believe was

3 at the party?

4 A. The information that we had, yeah, all

5 information that we had regarding who was at the

6 party or who had attended the party. That's --

7 that's the information.

8 Q. Are you aware of whether Nebeker at that

9 time knew of other people that attended the party

10 and didn't tell you or maybe you don't recall the

11 names, or those are the only two you know that he

12 knew?

13 A. Those --


15 A. Those are the two names that come to

16 mind.

17 BY MR. COOK:

18 Q. What is the next thing you do in relation

19 to this party or the next time you hear about this

20 party or Angela's death?

21 A. It was a year and a half later.

22 Q. So from that date to a year and a half

23 later, you don't hear anything?

24 A. Correct.

25 Q. Now, you know you've got dispatchers at



1 this party and you thought it was significant enough

2 to tell Metro about it; correct?

3 A. Correct.

4 Q. When is it -- as I recall you saying

5 earlier, what you do is you wait till Metro's done

6 with their investigation before you do any

7 investigation you need to do; correct?

8 A. Correct.

9 Q. Okay. So when is Metro done with their

10 investigation of this accident so you can start

11 taking a look at the two people you knew were at the

12 party?

13 A. They never came back to us.

14 Q. Okay. Well, surely after the guy -- did

15 you know at some point the guy was convicted or pled

16 guilty, I should say?

17 A. Correct, yes.

18 Q. Okay. So at that point if all you know

19 is "We've got two dispatchers that were at a party.

20 This guy's got a DUI conviction," do you start your

21 investigation to see what these two people's

22 involvement was at that time?

23 A. Well, that's when -- when I asked the

24 superintendent that we should talk to Gillespie to

25 get --



1 Q. I thought that wasn't until after the

2 news report.

3 A. It was the news report. When was he

4 actually convicted?

5 Q. Well, he pled out, but let me back up

6 then.

7 Okay. So you give the info to Metro?

8 A. Correct.

9 Q. You're then assuming they're doing some

10 type of investigation?

11 A. Correct.

12 Q. Do you ever contact them to try and find

13 out what happened with the investigation or whether

14 it has been concluded?

15 A. I did not.

16 Q. Who -- is anybody from your office

17 supposed to follow up on that?

18 A. It would have been Captain Ketsaa.

19 Q. Okay. Do you know if he ever did that?

20 A. I don't know.

21 Q. I don't know what kind of boss you are as

22 far as some people micromanage, some people let

23 people go. Is that the type of thing you would

24 typically ask him or do you just expect that he'll

25 follow up and let you know?



1 A. I would expect him to follow up.

2 Q. Did he ever let you know?

3 A. No.

4 Q. Okay. Because that is his duty and you

5 expect him to do it, by not telling you, did you

6 just assume that that was handled and there was no

7 issue?

8 A. Yeah.


10 A. Yes, sir.

11 BY MR. COOK:

12 Q. All right. And then the next thing you

13 hear about this party isn't till a year and a half

14 later on the news report; is that correct?

15 A. Correct.

16 Q. Okay. So from December 2009 till July

17 2011, you hear nothing about Angela Peterson,

18 Rebecca Wamsley's party or even anybody else that

19 might have been at that party?

20 A. No, sir.

21 Q. No, sir, you didn't know; or --

22 A. No, sir, I did not hear.

23 Q. Okay. It was a bad question.

24 So the day before this news report, as

25 far as you know, there was a -- there was two



1 dispatchers at a party in November 2009 where

2 somebody left the party and killed somebody, and you

3 know nothing else the day before that news report;

4 is that correct, sir?

5 A. Yes, sir.

6 Q. Okay. Now once you find out through the

7 news, did you take any steps other than give the

8 information to Gillespie and then you separate

9 before you find out how that was resolved?

10 A. No.

11 Q. Let me ask it again 'cause I keep asking

12 these double-negative questions. Sorry.

13 After you find out, you give information

14 over to Gillespie and your expectation is that Metro

15 is going to conduct an investigation; is that

16 correct?

17 A. Yes, sir. Follow through, yes, sir.

18 Q. At the time you are assigned to

19 Superintendent Jones's office in October, you have

20 not heard any feedback on any investigation from

21 Metro; is that correct?

22 A. Correct.

23 Q. And you at that point forward don't have

24 any authority at the School District Police

25 Department to conduct any investigation?



1 A. Correct. Captain Ketsaa took over as

2 acting chief.

3 Q. If in December 2009 you had heard Penny

4 Higgins' story, the one you heard not till August

5 2011, that she saw police officers actively drinking

6 with this kid, making alcohol available to this kid

7 and dispatchers doing the same -- first, do you

8 recall that that was a fair synopsis of what her

9 story was in that August 2011?

10 A. Yes, sir.


12 A. Yes, sir. I think so.

13 BY MR. COOK:

14 Q. Okay. If you had heard that information

15 in December 2009, what would you have done?

16 A. Basically informed through channels of

17 course, again through my chain of command, the

18 Metropolitan Police Department so they can follow

19 through and include that in their investigation.

20 Q. Who decides whether there's going to --

21 while you were chief at Clark County School District

22 Police Department, who decides whether there is

23 going to be an Internal Affairs investigation at

24 your office?

25 A. Well, the buck stops with me.



1 Q. And I appreciate that, but then what is

2 the practice? Is -- is -- I mean, are you making

3 every call in every one or does --

4 A. No.

5 Q. -- somebody have some level of authority

6 below you?

7 A. Basically the Internal Affairs

8 investigator, Detective Loren Johnson, reported to

9 Captain Ketsaa, and it was handled at that level. I

10 was basically brought in to make the final

11 determinations with any disciplinary action.

12 Q. So if there's going to be an Internal

13 Affairs action, the -- the normal course would be

14 you would know about it. It would be handled

15 through Ketsaa unless you were at the action-taking

16 stage?

17 A. I don't understand "the action taking."

18 Q. You said, "Unless there's going to

19 take -- we're going to take some action that I know

20 about."

21 A. Not action; the determination. When the

22 totality of the case has been investigated,

23 discipline has to be delivered. That's when I would

24 come into play.

25 Q. Okay. So the standard Internal Affairs



1 investigation while you were chief over there, the

2 determination as to whether there is investigation

3 was Ketsaa's?

4 A. Yes, sir, unless I found or was made

5 aware of specifics where I would direct him

6 otherwise.

7 Q. Okay. So the decision to do an Internal

8 Affairs investigation was Ketsaa's unless you were

9 separately specifically given some information that

10 led you to want to direct an Internal Affairs

11 investigation?

12 A. Correct, sir.

13 Q. And then you would not become involved

14 until there was the discipline stage; is that

15 correct?

16 A. Correct.

17 Q. Now, was there a different process if

18 we're talking about a dispatcher employee as opposed

19 to a Metro officer?

20 A. Metro officer?

21 Q. I'm sorry. Let me try that again.

22 A. Oh.

23 Q. Would there be a different procedure if

24 it was a dispatcher employee as opposed to a School

25 District police officer?



1 A. Yes, sir.

2 Q. What is the difference in those two?

3 A. It would -- the internal investigation

4 would be handled through the School District.

5 Q. Does it initiate through Metro -- through

6 your Police Department office?

7 A. Basically the information can come

8 through our office or directly to the District. The

9 department is the Employee-Management Relations,

10 EMR.

11 Q. If in December 2009 Ketsaa and/or Johnson

12 had information that a dispatcher was drinking and

13 playing beer pong with a minor at a party and then

14 the minor left and killed somebody, what should they

15 do with that information?

16 A. Well, if Metro at the time was

17 investigating it, bring that information toward --

18 to Metro so they could follow through with their

19 investigation.

20 Q. Can they send it to EM- -- the Employee

21 Relations?

22 A. Employee-Man- -- yes, correct. One --

23 Q. Sorry. Is it EMR?

24 A. It's EMR, yes.

25 Q. Okay.



1 A. Employee-Management Relations, sir.

2 Q. So they should send it to EMR and to

3 Metro?

4 A. Well, send it to Metro, and then based on

5 Metro's direction, at their given direction, forward

6 it to EMR.

7 Q. So they're not allowed to forward it to

8 EMR until Metro says so?

9 A. Once they finish their criminal

10 investigation.

11 Q. Is there any written policy I can look to

12 to show that Clark County School District can't do

13 an Internal Affairs investigation or a EMR

14 investigation until they get Metro's okay?

15 A. It was basically common practice.

16 Q. Who started that practice?

17 A. It was there before I got there, sir.

18 Q. Okay. So it's -- it's the longstanding

19 policy of the Clark County School District Police

20 Department --

21 A. Uh-huh.

22 Q. -- that they are not going to do an

23 Internal Affairs investigation or an EMR

24 investigation on any case where Metro has any

25 information until they get the go-ahead from Metro?



1 A. Well, it's not so much Metro. If a law

2 enforcement agency's conducting a criminal

3 investigation, the criminal investigation goes

4 first. Once that's completed, then the follow-up

5 would be the Internal Affairs investigation. That

6 was -- that was the practice.

7 Q. Can't Internal Affairs investigate

8 criminal activity?

9 A. Not our department.

10 Q. Your Internal Affairs Department does not

11 conduct criminal investigations of Clark County

12 School District police officers?

13 A. No, sir. Once we are made aware of a

14 criminal technicality, we bring in either the

15 Metropolitan Police Department or the State of

16 Nevada.

17 Q. So what are the guys in your Internal

18 Affairs Department working on?

19 A. Basically when they work is Internal

20 Affairs cases within the department, policy issues,

21 and then there was also a -- two officers assigned

22 to EMR. Whenever they had employees committing

23 crimes, our -- our detectives would assist the EMR

24 investigators with the District regarding the

25 criminal investigation side of it.



1 Q. Okay. And if the cop -- if you have a

2 cop who's doing something criminally, you turn that

3 investigation over to another agency. You don't do

4 a criminal investigation of him yourself?

5 A. We would pass that on to Metro, yes, sir,

6 or the State of Nevada.

7 Q. Would you be surprised that Joe Barris,

8 who was in Internal Affairs, investigated crimes by

9 Clark County School District police officers while

10 he was in Internal Affairs?

11 A. It would surprise me.

12 Q. All right. Did you have any other

13 conversations with Gillespie about the Wamsley party

14 or Angela Peterson or anything about this case

15 besides that one meeting before you walked up to

16 Jones's office at the Cleveland Clinic? Or I

17 shouldn't say "Jones's office," but the office Jones

18 was at at the Cleveland Clinic.

19 A. No, sir.

20 Q. So that's the one conversation you've had

21 with Sheriff Gillespie about this --

22 A. Uh-huh.

23 Q. -- case? Is that --

24 A. Yes. I'm sorry.

25 Q. Have you ever talked to the FBI about



1 this case?

2 A. No.

3 Q. Have you ever talked to any other agency

4 about this case?

5 A. No, sir.


7 identification.)

8 BY MR. COOK:

9 Q. Sir, were you the one who started doing

10 the Highlights of the Week at the Clark County

11 School District Police Department?

12 A. Yes, sir.

13 Q. What made you come up with this idea?

14 A. Just a notification to the -- to the

15 command staff and to the members of the department,

16 something that I'd seen other departments do.

17 Q. Hadn't been done at the School District

18 before you, though; right?

19 A. No, sir.

20 Q. Take a look at the middle of this one

21 under "A MESSAGE FROM LIEUTENANT YORK." There's

22 another fresh paragraph. "On Sunday April 27th,

23 while off duty Dispatcher Zeddies observed a

24 possible suspect in the Hickey ES Robbery that had

25 been stopped by LVMPD. She stopped at the scene and



1 provided the information to LVMPD." Could you read

2 that paragraph to yourself, sir.

3 A. Sure.

4 Uh-huh.

5 Q. First, do you recall this incident?

6 A. Based on the information.

7 Q. You didn't recall it when you got into

8 the room, but now that you've read it, you recall it

9 a little better?

10 A. Somewhat, yes.

11 Q. Did you know who Dispatcher Zeddies was

12 before you had written this up?

13 A. I didn't write it. It was written by

14 someone else.

15 Q. Is this the first time you've read this

16 in the Highlight of the Week?

17 A. No. I've -- I read it before it went

18 out, yeah.

19 Q. Okay. When we look at this Highlight of

20 the Week, it says, "A MESSAGE FROM CHIEF ARROYO."

21 Is that your contribution to it personally?

22 A. The -- yeah, the top portion of it.

23 Q. And then the rest is messages from other

24 people?

25 A. Yes, sir.



1 Q. So you didn't type up the message from

2 Cap- -- or direct to have typed up the message from

3 Ketsaa or York or Young; correct?

4 A. Correct.

5 Q. But you did review the whole thing before

6 it went out?

7 A. Yes, sir.

8 Q. And is that generally your practice with

9 all of these?

10 A. Correct. The -- during the -- we have

11 a -- we had a weekly staff meeting, the staff

12 command, and prior to the highlight going out, the

13 captains, lieutenants, they each put in a certain

14 segment or -- or depending on the situation that's

15 going on type of information.

16 Q. And with regard to your part in each of

17 these, do you type your part out or do you direct

18 somebody to type it? How does your contribution go?

19 A. Mine usually I would type up myself. On

20 occasion I would get information from either my

21 executive assistant or my secretary put something

22 together for me.

23 Q. And who does the Quotes of the Week?

24 A. Most of those were my -- my executive

25 assistant, Warren Hull. I actually participated in



1 some, but he -- for the most part he would review

2 and put the quotes in.

3 Q. Do you know who Dispatcher Zeddies is

4 separate and apart from this?

5 A. If I see her, unless you point her out, I

6 may not recognize her.

7 Q. Did she do what she's supposed to do as

8 an off-duty dispatcher here?

9 A. Well, it's not what she's supposed to do.

10 She acted -- she acted on her own accord and brought

11 about some very positive actions.

12 Q. So this was a commendation. She went

13 even beyond the typical --

14 A. She was -- she was off duty basically and

15 she took it upon herself to take action, yeah.

16 Q. And she wasn't witnessing a crime being

17 committed, but she thought she recognized somebody

18 she drove by. That's what you gather from this;

19 correct?

20 A. Yes, sir.

21 Q. During your time as chief, did you have

22 pilot programs with Metro and Henderson law

23 enforcement to try and coexist a little better?

24 A. When I -- well, not exactly the coexist a

25 little better. When I took over the department, we



1 were in the process of conducting a pilot program

2 with the Henderson Police Department. Just at the

3 time I took over, there was a change of supervision

4 with Henderson PD. Jutta Chambers became the chief,

5 and we were able to discuss the points of the pilot

6 program for that particular year and had came to the

7 conclusion we could modify the program and eliminate

8 the -- the process that had been put into place by

9 our predecessors.

10 That's the one in particular that I

11 participated in.

12 Q. You're not aware of a pilot program with

13 Las Vegas Metropolitan Police Department?

14 A. You have to clarify what type of a pilot

15 program that would be. We had several programs that

16 we worked with Metro on, antiviolence initiatives

17 and anti-gang initiatives and stuff like that.

18 Q. All with Metro?

19 A. Yeah, with Metro, yes, sir.

20 Q. Okay. And what did those include? In

21 other words, if you're doing something where you're

22 collaborating with Metro, is there joint

23 investigations or you break up details separately?

24 How do you do it with them?

25 A. Basically the one that comes to mind is



1 the -- the antiviolence initiatives, which took

2 place in a certain -- certain high schools were --

3 and middle schools were targeted based on violence

4 in the area, calls for service, and then the

5 particular sergeants in the area along with the

6 lieutenant would work with the Metropolitan Police

7 Department supervisors involved in that segment of

8 the initiative.

9 Basically they put together the stats,

10 documented the -- the charts, and they would receive

11 input from our officers. It was more of a

12 statistical deployment where by acquiring the stats

13 of our schools per se Metro would be able to

14 reinforce areas where we may not have enough

15 officers based on the incidents occurring. Like if

16 after school a particular middle school was having

17 issues as the kids were walking home, they were

18 getting jumped by other students or -- or drug sales

19 and so forth, they would -- based on this

20 information presented by our officers and by our

21 sergeants, they would be able to change their

22 practices and -- and be in those areas, that type of

23 initiative.

24 Q. If there's a bust of a kid outside the

25 school for selling drugs or beating up another kid,



1 who does the investigation?

2 A. Depending on the circumstances, how far

3 from the school the individual was and whether

4 Metro, which in most cases would pass back on to

5 the -- the School District Police Department.

6 Q. If a student's on his way home from

7 school, is he in Clark County School District

8 jurisdiction still?

9 A. He's in -- well, he's in Metropolitan

10 Police jurisdiction.

11 Q. Can you do investigation of a fight on

12 the way home from school while they're walking home

13 from school regardless of the distance of the

14 school?

15 A. We -- if I remember correctly, by the

16 State law, we're responsible to supervise them on

17 their way home. As far as actually conduct an

18 investigation, we could open up an investigation,

19 notify Metro or Henderson or North Las Vegas, at

20 which time it would be their prerogative whether

21 they want to continue it or -- or -- or keep it in

22 the same perspective with the officer who initiated

23 it.

24 Q. If Clark County School District stops a

25 drug buy or a fight from two kids walking home from



1 school, do they have to get permission from Metro or

2 North -- North Las Vegas or Henderson to do the

3 investigation?

4 A. No, not necessarily. That's not how we

5 interpreted it, no.

6 Q. Okay.

7 MR. COOK: I think I overadjusted the

8 air. I'm just going to walk out there.

9 MS. HENDRICKS: Sounds good.

10 THE WITNESS: Can I go to the rest room?

11 MR. COOK: Why don't we take five

12 minutes.

13 THE VIDEOGRAPHER: Stand by, please.

14 We're going off the record at the approximate time

15 as indicated on the video screen, 11:07.

16 (Recess taken.)


18 identification.)


20 record at the approximate time as indicated on the

21 video screen, 11:11.

22 BY MR. COOK:

23 Q. Sir, I'm going to have Exhibit 5.

24 Perfect. If you could take a look at this.

25 Where it says, "A MESSAGE FROM CHIEF



1 ARROYO," this is something you prepared?

2 A. Yes, sir.

3 Q. July 30th, 2008 is the issue we're

4 talking about here, and it says, "The majority of

5 these cases" -- I'm in the middle of your first

6 paragraph -- "stories fueled by recent events and

7 proceedings, are either misinterpreted or totally

8 forged out of someone's necessity for professional

9 or personal survival."

10 What was going on there?

11 A. One of the things that happened when I

12 took over the department, the department for many

13 years had been beaten down by internal strife, and

14 the biggest thing that was presented to me and I was

15 able to observe while captain is the fact that the

16 officers believed they did not get any respect, they

17 didn't have authority. And -- and -- and I can't

18 remember the specifics of that particular time and

19 date, but I went back to the initial speech that I

20 had written and presented to the department

21 basically for motivation, motivation and

22 spiritual-type guidance.

23 We had -- we've always had to this day

24 people stirring up false accounts of incidents and

25 trying to undermine the actual direction of the



1 Police Department. It's -- it's common to many

2 police departments, but I had never seen it to the

3 extent that it had been in the -- ingrained in the

4 culture in our -- in our School District Police

5 Department.

6 Q. And what was ingrained in the culture was

7 people making up stories?

8 A. Yes, sir. Yeah, to basically undermine

9 the authority of certain individuals. People,

10 they've been working together for many, many, many

11 years, and for whatever reason that's how they took

12 it upon with the rumor mill, and it -- to this day

13 it goes on.

14 Q. What was this particular rumor?

15 A. For the love of me, I can't remember. I

16 had to address -- almost every speech that I

17 presented at the beginning of every school year, I

18 had to address the innuendos, the -- the -- the

19 rumors. They were as ridiculous as -- as "the sky

20 is blue."

21 Q. How did you as chief come to know whether

22 something was just rumors swirling around or whether

23 there was any factual support for it?

24 A. Well, at first it was rather complicated

25 'cause whenever it came to my office it was



1 secondhand information of course or through the

2 union. I had established -- one of the things I

3 wanted to do again was establish a good rapport with

4 the union members, the union presidents. That's

5 something that never existed before.

6 I would meet regularly with the union

7 president once a month and his vice president and

8 his cabinet, and -- and working with them, they

9 would present, "Well, this is the rumor mill,"

10 everything from the contract, the fact that -- I

11 could go on forever, I mean, situations that came up

12 as to they were working towards a contract with the

13 then Superintendent Rulffes and that members of our

14 command staff was passing on illicit information to

15 the board to try and diminish their stance in their

16 contractual agreements.

17 And it was just on and on, those types of

18 scenarios, and that's how these -- these types of

19 motivational tidbits basically came to be.

20 Q. How did you differentiate between rumor?

21 Something led you at least to believe that what you

22 were talking about here was rumor and not truthful;

23 correct?

24 A. Excuse me. Yes, sir.

25 Q. Okay. What did you do personally as



1 chief to try and figure out if something that came

2 to you secondhand had factual support or was a

3 rumor?

4 A. I would meet with the individuals

5 involved to try to address the situation firsthand

6 if I could. Sometimes we couldn't even get to the

7 bottom of the rumors, rumors that were at times

8 outlandish to the point where, for example, that the

9 FBI at one point had come into our Police Department

10 headquarters and bugged the entire building, in

11 particular the union. The union had their own

12 office in our building, that the -- the building had

13 been bugged along with the union office, that type

14 of scenario.

15 Q. Okay. So you get that information. What

16 do you do to make sure it's -- how do you address

17 it? First, how do you find out if it's a rumor or a

18 fact?

19 A. Well, if the FBI went into our building

20 and bugged the building, right from the get-go

21 someone would know. I would know. It would not

22 just happen overnight with the authority and the --

23 the capabilities that we have.

24 Second, we would bring in the union

25 president and the members involved and where they



1 got the information, and most of the time it would

2 go, it would lead nowhere. I mean, that was an

3 example of one.

4 Q. When you say "it would lead nowhere," you

5 would ask this guy and he would say, "I heard it

6 from that guy," and you'd ask that guy, who heard it

7 from somebody else?

8 A. And eventually it would just dissipate,

9 and we also -- we actually conducted -- we actually

10 conducted a screening of the actual office and we

11 changed the locks for them. I mean, that was just

12 one example.

13 Q. Okay. Is that typically what the kind of

14 thing you would do to rule out something factually

15 before you would disseminate that, "It is a rumor;

16 it's not true"?

17 A. We would, yeah, definitely, would go

18 through the process, yes.

19 Q. Okay. And then this particular one --

20 I'm in the fourth paragraph -- "Because I have

21 chosen not to give credence to the many fairytales

22 currently streaming through our organization, you

23 will not be hearing of justifications from my

24 office. I will say that you can continue to count

25 on the same undivided and unconditional support I



1 have dedicated myself to offering you since I swore

2 to uphold the Constitution of the State of Nevada

3 three years ago, when I first became a member of

4 this organization."

5 You don't recall the specifics that led

6 you to write this paragraph?

7 A. No.

8 Q. You wrote this paragraph, though?

9 A. Oh, yes, I wrote the paragraph.

10 Q. But you wouldn't write a paragraph like

11 this unless you did make sure that the fairy tales

12 currently streaming through the organization were in

13 fact not true?

14 A. Correct.


16 BY MR. COOK:

17 Q. And the quote at the bottom, that was one

18 that you pulled?

19 A. No. No. That's --

20 Q. Do you know where that quote came from?

21 A. Probably from Warren Hull, my exec, yeah.

22 Q. But you read it before it went out?

23 A. Yes, sir. Yes, I did.


25 identification.)



1 BY MR. COOK:

2 Q. Is this a Highlight of the Week that you

3 prepared?

4 A. No.

5 Q. Do you know who repaired -- do you know

6 who prepared either section of this?

7 A. It was most probably finalized by Warren

8 Hull.

9 Q. And when you have a highlight that is not

10 prepared by you, do you direct what topic you want

11 discussed?

12 A. Not -- not always. It didn't happen that

13 way. Depending on the circumstances, if I was out

14 of town or basically tied up in some other

15 circumstances, they would acquire information from

16 within.

17 In this case, the -- the command staff

18 was not involved, so there's no tidbits or segments

19 from them. I remember the main substance had to do

20 with we had an issue where the union president,

21 Phil Gil- --

22 Q. Gervasi.

23 A. -- Gervasi had -- had come in and

24 informed us, me in particular, in briefing or

25 passing actually that several of our officers had



1 been posting in -- unproper things on the -- on

2 their Facebook accounts, so if I remember correctly,

3 I think we sent out a memorandum through CALEA, if

4 I'm not mistaken, standards, and this was the piece

5 that was taken from the -- and posted so officers

6 would regain whatever structure they had within

7 their Facebook accounts.

8 Q. So you had heard that there was an issue

9 with inappropriate Facebooks and directed this type

10 of thing to end up in the Highlights of the Week?

11 A. Yeah. This was the reinforcement besides

12 the steps that were taken by Captain Ketsaa and then

13 the -- the accreditation manager regarding the

14 policies.

15 Q. What specifics about Facebook issues did

16 you hear on or before February 5th, 2010 that led

17 you to direct somebody to include this in Highlights

18 of the Week?

19 A. They were utilizing -- officers working

20 on a day-to-day basis had taken supposably pictures

21 of themselves or other officers in the -- in their

22 daily actions and were posting it on their Facebook

23 accounts, you know, representing the department,

24 uniform, badge, that kind of stuff.

25 Q. Do you do Facebook at all?



1 A. No, sir.

2 Q. Do you have any idea if they go through

3 and identify themselves other than in pictures on

4 Facebook?

5 A. I'm sorry?

6 Q. Do you know how people identify

7 themselves other than through pictures on Facebook?

8 A. I wouldn't know, sir.

9 Q. Were you provided with any specific

10 pictures or incidences that led you to have this

11 Highlight of the Week go out in addition to the

12 memo?

13 A. No.


15 identification.)

16 BY MR. COOK:

17 Q. Sir, you've been handed Exhibit 7. Where

18 it says, "A MESSAGE FROM THE CHIEF," is this

19 something that you then prepared?

20 A. Yes.

21 Q. What was it that you're discussing that

22 you were going to share that took place that prior

23 week?

24 A. The situation with -- with the two

25 subordinates?



1 Q. Right.

2 A. Basically two of our police officers were

3 involved in a personnel matter with a District

4 administrator at a school site, and that was handled

5 a certain way. And within days, the rumor mill

6 started passing information, passing on everything

7 from that the officers were going to be arrested.

8 It became a full-blown just debacle as far as the

9 allegations that were going to be done with the

10 officers or lack of action or too much action, that

11 the department had either backed the District

12 employee or had failed to back the District

13 employee.

14 And it was brought to my attention by

15 Phil Gervasi that these individuals, these two

16 officers, were having issues as to whether they

17 could fully do their duty during the course of their

18 day. They were actually becoming rather hesitant,

19 and I physically met with both of them, reassured

20 them of what steps were going to be addressed again.

21 They were at no time being looked at for anything.

22 It was all the rumor mill.

23 Q. What is it they actually did as opposed

24 to what the rumors were saying they were doing?

25 A. It's not what they did. It's what the



1 administration had done in lieu of their actions and

2 what the administration and the School District was

3 going to do in lieu of their actions.

4 Q. I'm trying to get an understanding as to

5 what the reality was of the situation as opposed to

6 the rumor of the situation.

7 A. Basically there was a situation between

8 two officers and an administrator during a football

9 game and there was supposably interaction between

10 one of the two officers and -- and the -- the

11 administrator, which in this case was a coach for

12 the school, regarding a violation, a trespass

13 violation, and supposably the officer acted in a way

14 or the case was handled administratively rather than

15 criminally at the site, and that became a full blown

16 that he was ordered not to make an arrest, that if

17 he did make an arrest he was going to go -- he was

18 going to be himself under investigation, and it just

19 snowballed from there --

20 Q. All right.

21 A. -- if that makes any sense.

22 Q. I'm having trouble --

23 A. Okay.

24 Q. -- following you 'cause everything is

25 pronouns and "interaction" can mean anything from



1 fighting to politely talking a mile apart on a

2 telephone.

3 A. Okay.

4 Q. Okay. So what I'm trying to get to is

5 I'm trying -- as I said, you're talking about the

6 rumor mills in this place were constant and you had

7 to deal with it on a regular basis, and here is an

8 example sufficient enough that you shared it to

9 everybody in the department through the Highlights

10 of the Week, so it doesn't appear to be anything

11 that was hidden.

12 What happened with two officers and a

13 coach? Let's start with the reality of what you

14 understood happened and then I'll get to the rumor,

15 and then I'm going to ask you how'd you figure out

16 that this is what happened as opposed to what the

17 rumor was?

18 MS. HENDRICKS: If -- if I may, Marc, I

19 think part of the difficulty will be maybe that

20 we're dealing with some personnel issues, so if we

21 can do Officer X, Officer Y so that you can get some

22 specifics, too --

23 MR. COOK: Well --

24 MS. HENDRICKS: -- without invading

25 anybody's personal information.



1 MR. COOK: First, it's in a Highlight of

2 the Week. It's not personal information.

3 MS. HENDRICKS: Well, but you're

4 asking --

5 MR. COOK: Second -- second --

6 MS. HENDRICKS: -- for more details

7 beyond that.

8 MR. COOK: Second, I don't care if he

9 calls them Bob or Jerry.

10 MS. HENDRICKS: Okay.

11 MR. COOK: I'm just trying to figure out

12 facts.

13 MS. HENDRICKS: And I'm trying to help

14 you have a way that we can do that.

15 So if you can just assign them a name

16 that's not their real name and give -- give some --

17 some general information that you feel is

18 comfortable.

19 BY MR. COOK:

20 Q. Sir, do you understand the information --

21 A. I understand. It's just -- it's just

22 rather --

23 Q. I just want to get the information.

24 A. During a football game, it is common

25 practice or actually District policy that everyone



1 coming on property has to go through a metal

2 detector, and this particular administrator had

3 several students who were either part of his group,

4 team or otherwise bypass the metal detector. He and

5 one of the two officers became confrontational.

6 Eventually the principal became involved and the

7 students were allowed to go in or stay in actually,

8 and the -- there was a supervisor on scene, a

9 sergeant, if I'm not mistaken, who was privy to all

10 the information.

11 After the incident, one of the officers

12 supposably made a comment that he would file an

13 arrest charge on the administrator at a later date.

14 It was brought to my attention by the union that

15 the -- the word on the street was that we had told

16 those officers that if they were to file any

17 documentation on the administrator we would do an

18 Internal Affairs complaint on them and charge them

19 for false information, so on, so on.

20 And then that got out of -- it went back

21 to the administrator side, and then they came -- I

22 had an administrator call me wanting to find out if

23 it's true that we were going to arrest their coach,

24 in which case if they did they would be going to the

25 media and all this other stuff that had nothing to



1 do with the actual incident.

2 So I met with both the officers and the

3 coach and made sure that they were well aware of

4 what was not going to happen and -- and in fact that

5 the situation had been taken care of as -- as

6 appropriately and passively as the District allowed.

7 Q. And when you say "confrontational," do

8 you mean physically confrontational or verbally?

9 A. Oh, verbal. It was verbal, yeah. It was

10 a discord.

11 Q. And how did you come to the conclusion

12 that what you just told me factually happened was in

13 fact what factually happened?

14 A. I met with the sergeant who responded to

15 the scene.

16 Q. You personally met with him?

17 A. Oh, yeah. I met with him, yes.

18 (Discussion off the

19 stenographic record.)


21 identification.)

22 BY MR. COOK:

23 Q. Did you prepare this, sir?

24 A. Yes, sir.

25 Q. And what was going on around this time?



1 A. I believe it was an article that was

2 released by the newspaper, but I'm not a hundred

3 percent sure.

4 Q. Do you recall what the article was about?

5 A. I remember one in particular that had to

6 do with allegations presented, presenting us to have

7 a hundred rifles and some other outlandish

8 allegations which had never been confirmed by --

9 or -- by the reporter, and -- and I believe that was

10 the essence of it. It was a Journal article if I'm

11 not mistaken.

12 Q. A Journal --

13 A. JR, JR. The RJ.

14 Q. Did you do the quote?

15 A. No. That was Warren. If I remember

16 correctly, he's the one that dealt with the reporter

17 firsthand, and --

18 Q. Did you review this before it went out?

19 A. Yes, sir.

20 Q. What portion of this was done by Warren

21 and which by you?

22 A. Oh, I had the entire memo. He basically

23 did the -- the Quote of the Week.

24 Q. Do you know who Aleister Crowley is?

25 A. I don't remember now.



1 Q. You said you don't remember or you don't

2 know? I didn't --

3 A. No. If he mentioned it to me, I don't

4 remember. I have no idea.

5 Q. Who researched the Code of Ethics and

6 Canons of Journalism for this?

7 A. He did.

8 Q. And he just told it to you and then

9 you --

10 A. He provided --

11 Q. -- prepared the note?

12 A. Well, he basically put notes together.

13 Q. And then you turned it into a cohesive

14 story?

15 A. To some degree, yes, sir.

16 Q. And you think that one was about the --

17 the guns issue; is that right?

18 A. That's the one that comes to mind. I may

19 be incorrect, but that's the one that stands out.


21 identification.)

22 BY MR. COOK:

23 Q. Did you prepare the portion of this that

24 says, "A MESSAGE FROM CHIEF ARROYO"?

25 A. Yes, sir.



1 Q. What are you talking about here in the

2 third paragraph?

3 A. Rumors that the FBI had come in and taken

4 out computer terminals from our dispatch center,

5 that Metropolitan Police Department had come in and

6 arrested Detective Loren Johnson for some fraud or

7 something, that Lieutenant Morales at the time and

8 Nebeker had been suspended and they were going to be

9 terminated. I meant, it went on forever. It was

10 just --

11 Q. And that was an internal rumor at the --

12 A. They were --

13 Q. -- School District?

14 A. -- just rumors, yeah.

15 Q. So the fact that this is about a week and

16 a half after the story broke on Angela Peterson,

17 this has nothing to do with Angela Peterson?

18 A. Correct, sir.

19 Q. And who did the quote?

20 A. That was me, yeah.

21 Q. And what does it mean?

22 A. Same thing. The more we bicker, the more

23 we undermine each other, the more the department was

24 going to go down. That was the direction.

25 Q. You wanted them to stick together?



1 A. Excuse me?

2 Q. Stick together?

3 A. Well, it's not stick together, but

4 maintain the directives, maintain the reason we're

5 there, for the kids, for the staff, for -- you know,

6 unfortunately all this undermining took away from

7 what our responsibility has always been, to take

8 care of the students and the kids and everything

9 else.

10 Q. Did you write this third paragraph again

11 or you just copied it from the other one?

12 A. It was probably just copied over. It

13 appears to be that way, yeah.


15 identification.)

16 BY MR. COOK:

17 Q. This came from your office, sir?

18 A. Yes, sir.

19 Q. And basically this was a change in logo?

20 A. Uh-huh.

21 Q. Is that a yes?

22 A. Oh, yes. I'm sorry. Yes.

23 Q. Why? What prompted you to change the

24 logo?

25 A. We changed the badge.



1 Q. What prompted that?

2 A. Well, for all the time that we had been a

3 School District Police Department, we had used

4 the -- the star emblem, and in order to show

5 definition from the other -- from Metro actually, we

6 chose as a morale booster to switch over to an

7 individual badge rather than a shield -- or a star.

8 I'm sorry.

9 MR. COOK: Let me have that marked next.

10 THE WITNESS: We kept the essence of the

11 star within the shield, but --


13 information.)

14 BY MR. COOK:

15 Q. Is -- is this the difference? I'm still

16 going to ask you about 10. I just wanted to see if

17 this helps you with the difference in the logo. Is

18 that -- are we looking at the old logo on the

19 Exhibit --

20 THE REPORTER: 11.

21 BY MR. COOK:

22 Q. -- 11?

23 A. Yeah, that's the old logo, yes.

24 Q. And Exhibit 10 has the one you changed it

25 to; is that correct?



1 A. Correct.

2 Q. Okay. Form-wise how does this work then

3 when we're looking at Exhibit 10? You just put

4 the -- do all the forms change and it's just when

5 everything's printed out it goes with the new one

6 now, or what happens?


8 Q. Well, how's everybody going to use this

9 logo? Does it go into the computer system so --

10 A. Yeah, there was a memorandum and -- and

11 it was structured within the actual confines of the

12 system, yes.

13 Q. So now if I go to print out -- if -- if

14 you're going to print out your next department

15 administrative notice --

16 A. Right.

17 Q. -- and so you pull up something for that,

18 you type out what the new notice is, it

19 automatically has the new emblem on it; is that

20 correct?

21 A. Well, the -- the emblem, the actual

22 template has to be sent out to the different

23 departments, whether it's Communications, Detective

24 Bureau, and so forth.

25 Q. So you don't do that, but this was



1 directing that to happen?

2 A. Yeah, that's basically it.

3 Q. Are you aware of whether that happened?

4 A. Well, as far as I was aware, yeah.

5 Q. Okay. Exhibit 11, which is in front of

6 you now, have you seen this before?

7 A. Yes. This is the -- the memo I mentioned

8 earlier I had seen.

9 Q. And is this the first memo you had seen?


11 BY MR. COOK:

12 Q. Exhibit 11, regarding the Wamsley party

13 and Angela's death?

14 A. This is the -- the only actual memo that

15 I have seen regarding an employee.

16 Q. Okay. And where is, if at all, your

17 signature on this page or your initials?

18 A. If it is, it may be the one at the

19 bottom.

20 Q. December 17th, 2010?

21 A. That's what it appears to be, yes.

22 Q. Do you have any idea why there would have

23 been a ten-month gap from when the signature above

24 you occurred till when you signed it?

25 MS. HENDRICKS: I'll just object as to



1 form. He said he wasn't certain that was his

2 signature on the bottom line.

3 BY MR. COOK:

4 Q. All right. Let's do it this way: Strike

5 that question.

6 A. Okay.

7 Q. You see Rebecca Wamsley signs this

8 document; correct?

9 A. Correct.

10 Q. Then the next line is, "Approved,

11 Disapproved, Acknowledged, Recommended."

12 "Acknowledged" is checked. It is dated 1/11/10, and

13 I believe that is Armando Quintanilla's signature.

14 Do you recognize that as such?

15 A. I -- I'll have to take it for granted.

16 Yeah, it's -- it's --

17 Q. He testified it was his.

18 A. Okay. Yeah.

19 Q. What does "Acknowledged" mean as opposed

20 to "Approved," "Disapproved"?

21 A. That it's been made aware.

22 Q. Okay. If Armando Quintanilla is signing

23 off "Acknowledged" on this and he knows any of the

24 information above it is incorrect, should he

25 disapprove it and send it back to Wamsley?



1 A. I would think so, yes, if he has that

2 knowledge, yes.

3 Q. And then it looks like a month later

4 because "Acknowledged" is also checked on the next

5 line on 2/12/10, does that appear to be

6 Mr. Nebeker's signature?

7 A. I think so, yes.

8 Q. Same thing, if he knows information and

9 this is not true, he should disapprove it; is that

10 correct?

11 A. Send it back.

12 Q. Disapprove and send it back to Wamsley to

13 redo it?

14 A. Yeah, if this is correct, yes.

15 Q. Okay. And then four days later, it looks

16 like, with another "Acknowledged" checked, 2/16/10,

17 with another signature. Do you know whose signature

18 that is?

19 A. The 2/16/10?

20 Q. Yes.

21 A. I can't make it out.

22 Q. Do you know in the chain of command in

23 your office at that time whose signature it should

24 be?

25 A. It would be -- it would be Captain



1 Ketsaa.

2 Q. Same thing, if he knows it's not true, he

3 should not check "Acknowledged"; he should check

4 "Disapproved." Is that correct?

5 A. Correct.

6 Q. Now, it looks like -- go ahead.

7 A. In a standard memorandum where the

8 individual is making a statement, such as this case,

9 the sup- -- it's basically an acknowledgment that

10 the document's going up the chain of command. It's

11 not that the supervisor -- if it had something to do

12 with a responsibility, a duty that the individual

13 knows for a fact, supervisor, that is incorrect, at

14 that point you send it back.

15 In this case this is a statement made by

16 an individual, so it would be acknowledged all the

17 way through.

18 Q. Okay. Well, then if -- if the individual

19 is making a false statement and you're not supposed

20 to disapprove it and send it back, should you at

21 least tell the supervisor you're sending it up the

22 chain of command to that, "Hey, this says 'X.' I

23 happen to know 'X' plus 'Y' plus 'Z' happened"? Or

24 is that not Quintanilla, Nebeker and Ketsaa's

25 responsibility if they know somebody's sending



1 something false that is eventually going to end up

2 with your signature on it?


4 A. Yeah, I don't understand the question.

5 I'm sorry.

6 BY MR. COOK:

7 Q. If any of the three signatures before

8 yours --

9 A. Uh-huh.

10 Q. -- in reading this statement they know

11 something in it is a lie or at least a lie by

12 omission, do they just let that happen and go up to

13 you and you think this is what happened, or do they

14 have to either do "Disapprove" so Wamsley rewrites

15 it or give you an additional memo that says, "This

16 is what Wamsley's thing says. I have information

17 that 'X,' 'Y' and 'Z' also happened"?

18 MS. HENDRICKS: Objection as to form and

19 foundation.

20 A. If this is a written statement by the

21 individual, they are to send it up the chain of

22 command and just put down "Acknowledge." They're

23 not to tell the person what to write or how to write

24 it or how to correct it.

25 \\\



1 BY MR. COOK:

2 Q. Do they separately notify you what you're

3 getting is incomplete --

4 A. I --

5 Q. -- or inaccurate?

6 A. I would think that would be their

7 prerogative as the -- the member of that

8 organization in chain of command to let me know,

9 yes.

10 Q. You're the chief.

11 A. Correct.

12 Q. Is that what you want them to do or not?

13 A. I would definitely want them to do that,

14 yeah.

15 Q. When you got this, did you get it with

16 any accompanying statement clarifying what is

17 accurate and what is not in it?

18 A. No.


20 He -- again, he has not verified that's his

21 signature. He's not certain that he received this.

22 BY MR. COOK:

23 Q. Okay. You don't recognize if that's your

24 own signature?

25 A. I'm not sure. I'll be very sincere.



1 Q. Do you recall reading this?

2 A. Briefly, yes.

3 Q. Do you recall reading it approximately a

4 year after the accident?

5 A. I don't remember when I exactly read it.

6 I remember it going through my -- my hand.

7 Q. If you read this a year after the

8 accident, earlier when you said from December 2009

9 until July 2011 you hadn't heard anything, that

10 would not be accurate; correct?

11 A. Correct.

12 Q. And did you do anything to verify whether

13 any of these statements were true?

14 A. No. Basically from what I remember, I

15 would have forwarded it to Captain Ketsaa to notify

16 Metro.

17 Q. This one you had also sent to Metro?

18 A. I would have, yes, correct.

19 Q. Do you recall doing that?

20 A. If Captain Ketsaa delivered it.

21 Q. Do you recall doing that with Exhibit 11,

22 having Ketsaa bring it to Metro?

23 A. I don't recall exactly.

24 Q. Do you recall when you got this?

25 A. Not exactly, no.



1 Q. You said "not exactly." Any range?

2 A. I'm not sure, no.

3 Q. Do you recall if you got this before the

4 news story came out?

5 A. I may have gotten it before the news

6 story came out.

7 Q. Did you read it?

8 A. Again, I went over it briefly.

9 Q. Did it match up with the information you

10 had at that time?

11 A. It was more information than I had at

12 that time.

13 MR. COOK: Okay. We're at a good place

14 to stop 'cause we're running out of tape, so why

15 don't we take a lunch break, and as soon as you guys

16 are back we'll get going.

17 THE VIDEOGRAPHER: This is the end of

18 disk number two in today's videographed deposition

19 of Filiberto Arroyo. The approximate time, as

20 indicated on the video screen, 11:51. We are now

21 off the record.

22 (Luncheon recess taken.)

23 \\\

24 \\\

25 \\\



1 AFTERNOON SESSION


3 record. This is the beginning of disk number three

4 in today's videographed deposition of Filiberto

5 Arroyo. The approximate time, as indicated on the

6 video screen, 1302.

7 BY MR. COOK:

8 Q. Sir, after the lunch break, same process,

9 still asking some questions. Do you have any

10 clarifications from this morning's session?

11 A. No, sir.

12 Q. During Superintendent Jones's deposition,

13 he testified that he had a single meeting with

14 Gillespie and it was just him and Gillespie, and

15 while they met for a period of time and spoke about

16 an FBI investigation regarding excessive force and a

17 couple other issues, they only spoke of Angela

18 Peterson for approximately five minutes and it was

19 only the two of them and you weren't there.

20 Your recollection is different, I

21 believe?

22 A. I was never involved in a conversation

23 with Gillespie or the superintendent where the FBI

24 was mentioned or anything of that matter.

25 Q. So the entirety of the conversation you



1 spoke of with Gillespie and Jones at the Cleveland

2 Clinic --

3 A. Correct.

4 Q. -- lasted approximately how long?

5 A. 35, 40 minutes. It was just before

6 the -- the workshop began.

7 Q. And the conversation regarding that

8 meeting was other than introductions exclusively

9 about the Angela Peterson case; correct?

10 A. Correct.

11 Q. So it's your testimony then that --

12 strike that.

13 It looks like he forgot about or lied

14 about a 40-minute meeting. Is that your

15 understanding --

16 MS. HENDRICKS: Objection, move to

17 strike.

18 BY MR. COOK:

19 Q. Is that your understanding if my

20 representation to you of his testimony is correct?


22 foundation.

23 A. He --

24 MR. PARK: Join.

25 A. Correct.



1 BY MR. COOK:

2 Q. Thank you.

3 Now, during that conversation, did

4 Sheriff Gillespie say he was going to open a file on

5 this, or what was he going to do?

6 A. He was going to notify his command staff

7 to contact the investigator, and they were going to

8 put together or were in the process of putting

9 together a squad, individuals, I believe two

10 detectives, to review all the pertinent information.

11 Q. Okay. And do you know what happened with

12 that?

13 A. No, sir.

14 Q. Superintendent Jones also testified that

15 his communications office issued a statement. I

16 believe it went to the media, but he issued a

17 statement that said, "Anybody who comes forward with

18 truthful information about this incident will not be

19 punished for the truthful statements themselves."

20 Do you recall that?

21 A. I remember something of that nature, yes,

22 sir.

23 Q. Do you recall approximately when that

24 came out?

25 A. Uh-uh, no, I don't.



1 Q. Did you have any conversations with him

2 about that in any of your meetings with him?

3 A. No.

4 Q. When you recall that coming out, is there

5 a reason you didn't include that, for instance, in

6 your Highlights of the Week to make sure everybody

7 related knew about that?

8 A. No.

9 Q. How did you disseminate that information

10 from the superintendent to your officers and

11 dispatchers?

12 A. What information was that?

13 Q. That Superintendent Jones would not

14 punish anybody for providing truthful testimony.

15 A. I did not.

16 Q. Why not?

17 A. It -- it went out from the

18 superintendent.

19 Q. Did it go out from the super- -- I know

20 it went to the news. Did it go from the

21 superintendent directly to your department?

22 A. No.

23 Q. So how would anybody in your department

24 know that?

25 A. They found out through the media, through



1 the notification that was released.

2 Q. So if they weren't watching the news

3 reports, they wouldn't know the superintendent said

4 that; is that --

5 A. Correct.


7 foundation.

8 A. That's how I found out.

9 BY MR. COOK:

10 Q. Okay. We talked earlier about when

11 there's rumors there's certain steps you take to

12 make sure in fact it's a rumor as opposed to a fact;

13 correct?

14 A. Uh-huh.

15 Q. Is that a yes, sir? And finish your

16 drink. I'm not rushing you.

17 A. Yes, sir. I'm sorry.

18 Q. Okay. Karma. Now I need one.

19 Isn't it true that the people most likely

20 to know about the party at least from the

21 dispatchers and police officers who were potentially

22 there would have been the dispatchers and police

23 officers themselves?


25 foundation.



1 MR. PARK: Join.

2 A. Correct.

3 BY MR. COOK:

4 Q. If you wanted to ascertain whether this

5 was rumor or fact then, why is it you didn't get the

6 information to the people who had the information to

7 say, "Look, if you're coming forward truthfully,

8 we're not going to go after you"?



11 BY MR. COOK:

12 Q. The superintendent says -- strike that.

13 Can we agree that the superintendent

14 advised that, "Coming forward with truthful

15 testimony, we will not punish you for providing

16 truthful testimony"?

17 A. Correct.

18 Q. Can we agree that that happened after the

19 news story broke in July of 2011?

20 A. Possibly, yes, sir.

21 Q. Possibly. You're not sure. He might

22 have said it beforehand?

23 A. I'm not sure -- I'll be very sincere --

24 when he said it.

25 Q. Okay. Well, you told me you didn't hear



1 anything about the party from December '09 to --

2 A. Oh, up until then, yes, yeah.

3 Q. So then it would have had to have been

4 after?

5 A. After that, correct, yes.

6 Q. So after July 2011 when the story breaks,

7 Jones releases this statement that, "If you provide

8 truthful testimony, nobody's going to go after you"?

9 A. Uh-huh.

10 Q. Is that right?

11 A. Correct. Okay.

12 Q. From that time when the story broke

13 forward, how long were you still chief of police in

14 not just title, in not just title, but duties?

15 A. Till September.

16 Q. Three months, two months?

17 A. Yes, in the middle of September.

18 Q. What did you do in those two to three

19 months to try and find out if the allegations in the

20 news were true?

21 A. I didn't do anything.

22 Q. And you also didn't let those officers

23 and dispatchers know separately from your office

24 what Superintendent Jones had talked about about

25 testifying truthfully and "We're not going to punish



1 you"; correct?

2 A. Correct.

3 Q. Do you think that would have been helpful

4 to get some of them to come forward with truthful

5 testimony?

6 A. My understanding, the superintendent went

7 out and contacted these individuals via the media,

8 which is the direction he wanted to take.

9 Q. Is it your belief as you sit here today

10 that the officers and dispatchers all heard about

11 that statement through watching the media?

12 A. I was under -- I would be under the

13 impression that, yes, that's exactly it.

14 Q. And why are you under that impression?

15 A. Because the -- the stories were

16 continuously sent out, and the superintendent by

17 coming out through the media sent it out to the

18 whole -- I mean, everybody, the whole county saw

19 that.

20 Q. Did this appear to be something that was

21 talked about pretty loudly and regularly in the

22 School District Police Department after the stories

23 came out?


25 A. It was being talked about. It was being



1 talked about throughout the entire county.

2 BY MR. COOK:

3 Q. Including your Police Department?

4 A. I would assume, yes, definitely.

5 Q. And including the dispatch center at the

6 department?

7 A. I would assume.

8 Q. Okay. You're assuming on both, which

9 means you have no idea if anybody knew about

10 Superintendent Jones's statement; is that true?

11 A. Correct.

12 THE VIDEOGRAPHER: I need to adjust the

13 witness's microphone, Counselor. Pardon me.

14 Thank you.

15 BY MR. COOK:

16 Q. During Superintendent Jones's deposition,

17 I asked why there was a separation, and he said he

18 wanted to go in a different direction. I'm going to

19 read to you from the bottom of page 40 through the

20 top of 41 of his deposition. I asked him, "Why did

21 you want to go in a different direction?"

22 And I'm going to read you his answer

23 starting on line 1 of page 41. "Over a period of

24 time, there were things that -- policy, procedures I

25 think that had gotten laxed, and the other piece,



1 that I think when a superintendent or a police chief

2 public confidence makes a big difference and I felt

3 like -- I did not feel like the public or in some

4 cases the trustees continued to have confidence."

5 I asked him, "Why did you think the

6 public did not continue to have confidence in him?"

7 He said, "I would just say stories of

8 negative fashion running through the press."

9 I said, "Such as?"

10 His answer: "One would be associated

11 with this case. Another was FBI pieces. There was

12 just things about tickets, whether the police were

13 going above their jurisdiction passed by the

14 legislation and giving tickets outside of a range of

15 the school zone, just procedural things that

16 appeared to be getting too laxed."

17 Did you know that that was his position

18 as to why there was a separation till I just read it

19 to you?

20 A. The third section regarding the tickets

21 never came up. The other segments regarding policy

22 and procedures, we did -- we basically had a

23 difference of opinion.

24 Q. Okay. And he didn't say "difference of

25 opinion." He said "policies and procedures I think



1 that had gotten laxed." Did he talk to you about

2 any policy or procedure you had that had gotten lax?

3 A. No.

4 Q. Did he talk to you about any policy or

5 procedure he had disagreed with other than your

6 disagreement with him as to how you had to report on

7 certain investigations?

8 A. No.

9 Q. So the only policy and procedure you

10 understood that you and him did not see eye to eye

11 on was you reporting to him on certain types of

12 investigations?

13 A. Correct.

14 Q. And help me out then. What types of

15 investigations was it involved that you were talking

16 about? We talked about the computer case; correct?

17 A. Correct, yes.

18 Q. Anything besides that computer porn Utah

19 issue?

20 A. No.

21 Q. Okay. What were you investigating with

22 regard to that Utah computer porn case?

23 A. I -- basically I or the department or --

24 Q. Your department that you were chief of.

25 A. It was an administrator working in the --



1 the main office that supposably engaged in

2 interaction with an individual who was posing as a

3 juvenile.

4 Q. And in this story it says that you had

5 turned the case over to the District Attorney. Is

6 that accurate?

7 A. Detective West went and met with a

8 District Attorney or Assistant District Attorney,

9 presented him the case, and the individual basically

10 informed Dennis, or Dennis West per se, that there

11 wasn't sufficient evidence at that particular time.

12 Q. And Dennis West did what at this time in

13 the School District Police Department?

14 A. In regards to the investi- --

15 Q. Sorry. Let me -- let me ask you in

16 English.

17 Was he an Internal Affairs cop for Clark

18 County School District Police Department?

19 A. No, he wasn't.

20 Q. Okay. What department with the School

21 District Police Department was he in?

22 A. He was a -- he was a sergeant over

23 investigations.

24 Q. Okay. A sergeant over investigations,

25 and he was investigating Boyett's activities as to



1 whether they were criminal or not?

2 A. Correct.

3 Q. And were you aware of whether any other

4 agency was investigating Boyett's actions as to

5 whether they were criminal or not?

6 A. How it came to be is we had a ICE agent

7 present Captain Ketsaa with the information that I

8 just described regarding the individual being on the

9 Internet and so forth.

10 Q. What's a ICE agent?

11 A. I don't know. You would have to ask

12 Captain Ketsaa.

13 Q. Okay.

14 A. And we came in as -- in order to assist

15 the ICE agent regarding this case.

16 Q. And then your investigator turned this

17 matter over to determine whether the DA would

18 prosecute?

19 A. Correct. He met with the Assistant

20 District Attorney.

21 Q. Now, when I talked to you this morning

22 about the incident involving Angela Peterson, you

23 made a comment to the extent that you think some

24 people had made it up because you didn't hear

25 anything about it from Angela's death until the



1 story in July 2011; correct?


3 testimony.

4 A. I don't understand the --

5 BY MR. COOK:

6 Q. Okay. When we were talking about rumors

7 and innuendos --

8 A. Okay.

9 Q. -- and I talked, I mentioned this case, I

10 believe what you said was that you thought the

11 anonymous letter and things to that effect were

12 something that happened because somebody was upset,

13 two individuals were upset about pro- -- or strike

14 that.

15 There were promotions in February 2011

16 that prompted individuals -- you may not have said

17 two -- to be upset and that led to these rumors that

18 led to the news story. Did I get that right?


20 Q. Okay. Who was promoted in 2011 that you

21 think upset other people that led to rumors and

22 innuendos that led to this news story?

23 A. Lieutenant Brian Nebeker and Lieutenant

24 Roberto Morales.

25 Q. And who do you believe that upset that



1 led to rumors that led to this news story?

2 A. The individuals that failed to be

3 promoted along with that group.

4 Q. Which were who?

5 A. Multiple members of the -- of the

6 sergeant staff.

7 Q. Okay. You believe it was sergeants that

8 didn't get that promotion?

9 A. Correct.

10 Q. Okay. And who were those sergeants?

11 A. Basically we had one, for example, who

12 went to complain to the superintendent is Erik

13 Aldays.

14 Q. Okay. And who besides Aldays?

15 A. I know there were pretty much -- I can't

16 think of her name, a female sergeant. I can't think

17 of --

18 Q. Belinda Brown?

19 A. No. Belinda Brown was an officer. That

20 was another situation.

21 God, I can't think of her name for the

22 love of me. She was the only female sergeant we had

23 at the time.

24 Q. Okay. So --

25 A. And -- and then by -- in creating those



1 positions, other sergeants were promoted from a

2 regular line of officers, and the officers that

3 weren't promoted to sergeants, there were several

4 that were rather disgruntled, one in particular Mike

5 Thomas.

6 Q. Okay. So the people that you believe

7 were disgruntled and therefore started rumors that

8 led to this July story were Sergeant Aldays, the

9 female sergeant whose name you can't recall;

10 correct?

11 A. Uh-huh.

12 Q. Is that a yes?

13 A. Yes.

14 Q. And Officer Thomas?

15 A. Correct.

16 Q. Anybody else?

17 A. Not off the top of my head.

18 Q. Well, I mean, this seems like it was a

19 pretty serious event in the recent history of the

20 School District Police Department.

21 A. Well, again, it's based on my assumption.

22 Nothing of this is concrete.

23 Q. Now, do you still have Exhibit 11 in

24 front of you?

25 A. Uh-huh.



1 Q. This was subsequent to December 2009 and

2 prior to July 2011 as to all of the signatures

3 regardless of their names; correct?

4 A. Correct. That's what the dates state.

5 Q. Okay. What is a GO 303 (3-5), Code of

6 Conduct?

7 A. I don't remember.

8 Q. Do you know if dispatchers and/or

9 officers have to report whether they are the subject

10 of a criminal investigation?

11 A. Police officers I know do.

12 Q. Do you know if dispatchers have to?

13 A. No, I'm not sure.

14 Q. If they're -- if a police officer or

15 dispatcher is subject to a civil suit, do you know

16 if they have to report it?

17 A. If I remember correctly, I think there

18 was something regarding not a civil suit but a -- a

19 bankruptcy, I think.

20 Q. And you don't know about a civil suit one

21 way or the other?


23 Q. All right. Second paragraph of this

24 interoffice memo says, "On November 28, 2009, I

25 hosted a Thanksgiving dinner at my home at 1032 Alan



1 Shepard Street in Las Vegas."

2 It was your testimony this morning that

3 you did not know Wamsley hosted a party until July

4 2011; correct?


6 prior testimony.

7 MR. COOK: I hope not. He's nodding.

8 BY MR. COOK:


10 A. I'm sorry?


12 A. Correct.

13 Q. Okay. So in all likelihood then, this is

14 either not your signature November 17th, 2010 or you

15 signed it without reading it or you dated it wrong.

16 Is that fair?

17 A. I -- I agree with that.

18 Q. Okay. There's -- there's no other -- I

19 mean, if there's an option I left out --

20 A. No, no, no. I --

21 Q. Are you in the habit of approving memos

22 without reading them?

23 A. I've done that in the past.

24 Q. When you do that, do you look at anything

25 related to the subject matter or is it just because



1 somebody else signed it you figure you'll sign it

2 and go?

3 A. In -- in many cases based on the

4 information, it's on the signatures. If it's

5 concurrent, I just go with the actual signature.

6 Q. Okay. Is that typically what happens ten

7 months after the event too? In other words, the

8 signature above the fourth line is February 2010 and

9 the signature on the fourth line is December 2010.

10 A. I'm not sure. I'll be very sincere.

11 Q. The beginning middle of the second line

12 of the second paragraph, "One of the guests that I

13 invited, invited her daughter and 18 year old Kevin

14 Miranda to the dinner." At what point in time

15 before sitting here today did you find out that that

16 other guest was Tina Zuniga?

17 MR. PARK: Objection, foundation.


19 BY MR. COOK:

20 Q. Do you know if I just made up Tina

21 Zuniga's name? Do you know if that was the

22 individual, the other guest she references?

23 A. I -- I remember reading the stories, but

24 I don't know.

25 Q. "At some point later in the evening or



1 early the next morning, the uninvited guest, Kevin

2 Miranda, caused a fatal accident and was arrested

3 for DUI." If you found out later that Rebecca

4 Wamsley stated to her insurance carrier and in her

5 deposition that Miranda was not uninvited, would you

6 have a problem being lied to in a memo like this?

7 A. It's not that I would --

8 MR. KELLER: Objection.

9 A. -- have a problem because of the

10 circumstances surrounding it. It would be handled

11 administratively. As I stated earlier, passed it on

12 to Metro for their investigation.

13 BY MR. COOK:

14 Q. So if somebody lies to you in a memo,

15 that's not something you handle. You turn that over

16 to Metro?


18 MR. PARK: Join.

19 MR. KELLER: Join.

20 A. That's a self -- I mean, that's a

21 voluntary statement that she presented from looking

22 at the actual document, and -- and -- and

23 realist- -- and if she is indeed lying, as obviously

24 we now know the document states, it would have just

25 been another piece of information to pass on to the



1 investigation.

2 BY MR. COOK:

3 Q. And I appreciate that, but is what you're

4 telling me if one of your -- one of the people you

5 supervised as chief of police lies to you but

6 they're volunteering the information when they're

7 lying, you can't take any action?


9 A. If the -- if I take action, I'm

10 interfering with an ongoing investigation. Again,

11 the information would have been passed on to the

12 case officer.

13 BY MR. COOK:

14 Q. Did you know whether there was an ongoing

15 investigation in December of 2010?

16 A. No.

17 Q. Did you do anything to find out if there

18 was an ongoing investigation December 2010?

19 A. No, not that I remember.

20 MR. COOK: I know, you guys, most of

21 these depos, same exhibits. I can keep handing them

22 out or you can bring them with you day to day.

23 MR. PARK: Yeah, whatever you want. I

24 mean, it's nice to have it here, but whatever, same

25 difference.



1 MR. COOK: I'll have them if you want

2 them.


4 identification.)

5 BY MR. COOK:

6 Q. Sir, you've been handed Exhibit 12. Have

7 you seen any of these pages before?

8 A. No, I've never seen this.

9 Q. Does that include the entirety of the

10 exhibit? There's -- there's two pages at the tail

11 end, CCSD000129 and 130.

12 A. Concern Report.

13 No. No.

14 Q. What is the --

15 A. I'm not -- I'm not familiar with this

16 document at all.

17 Q. What is the purpose of a Concern Report?

18 A. A Concern Report is to establish cause to

19 initiate an Internal Affairs investigation if need

20 be.

21 Q. Are you aware of whether this form was

22 turned in to anybody?

23 A. Not that I'm aware of.

24 Q. If the information in the "BRIEF DETAILS

25 OF CONCERN" paragraphs is true and correct, should



1 an Internal Affairs investigation have been opened

2 if it was properly turned in?

3 A. If this would have been properly turned

4 in, it would have been given a number, assigned an

5 Internal Affairs number, and a case would have been

6 opened, and at that point the information would have

7 been forwarded to Metro.

8 Q. What do you mean "it would have been

9 given a number"?

10 A. It would have been given a number, in

11 other words, initiating an act- -- open an actual

12 investigation, given a number, assign a number, a

13 departmental tracking number for all Internal

14 Affairs cases.

15 Q. Now, do you see the person reporting this

16 is listed as Armando Quintanilla, top left?


18 Q. In the "BRIEF DETAILS OF CONCERN," do you

19 see anywhere in this document where Quintanilla says

20 he was at the party?

21 A. No, not in this segment and again not in

22 this segment either.

23 Q. If he was at the party, shouldn't that be

24 included in "BRIEF DETAILS OF CONCERN"?

25 A. That would --




2 foundation.

3 A. That would have been the proper protocol

4 to take, yes, sir.

5 BY MR. COOK:

6 Q. And he doesn't list himself as a witness

7 to the event. He lists Andrea Gamboa; correct?

8 A. Correct, sir.

9 Q. Is there any information in this "BRIEF

10 DETAILS OF CONCERN" section that you did not know

11 prior to the July news story going out in July 2011?

12 MR. PARK: Objection, form.

13 THE WITNESS: Excuse me.


15 BY MR. COOK:

16 Q. Did you understand my question, sir?

17 A. Not exactly. I was going to ask you if

18 you can --

19 Q. Okay. My recollection is what you knew

20 December 2009 is Gamboa and Quintanilla are at a

21 party. Miranda at some point is there, gets in an

22 accident and kills somebody.

23 A. Correct.

24 Q. And you don't hear anything about it

25 again until you watch the news in July of 2011?



1 A. Correct.

2 Q. Okay. This Exhibit 12 says on November

3 29th Quintanilla received a call from Andrea Gamboa.

4 You knew that; right? Strike that.

5 You knew that Andrea and him were at a

6 party?

7 A. Well, I did know that based on the

8 information, yes, sir.

9 Q. Okay. This says, "On November 29, 2009,

10 I received a call from" Andrea "stating that Tina's

11 daughter and boyfriend were in a bad accident and

12 that a girl was killed (in" the "other vehicle), and

13 they arrested Tina's daughters boyfriend."

14 You didn't know until you watched the

15 news in July 2011 that Tina Zuniga, dispatcher at

16 Clark County School District's daughter was in the

17 vehicle with the guy that killed Angela?

18 A. Correct.

19 Q. And you didn't even know Tina Zuniga was

20 there; correct?

21 A. Correct.

22 Q. "She," being Andrea, "said' he was at the

23 dinner party that Rebecca Wamsley hosted" on "that

24 night . . . ." Andrea "said . . . Roberto Morales

25 and Ron Sufana later arrived at the party."



1 You didn't know that till even after the

2 July 2009 [sic] news story?

3 A. For some time, yes, sir.

4 Q. Okay. Andrea advised she left at

5 approximately -- help me. What's that, 10:00 at

6 night, 2200 hours?

7 A. 2200 hours is 10:00 at night.

8 Q. Okay. Did you know that?

9 A. No.

10 Q. Okay. Did you know that at any -- did

11 you know when Andrea Gamboa left at any time until

12 you just read it?

13 A. No, not at all whatsoever.

14 Q. Next paragraph, on November 2009, Tina

15 Zuniga called Quintanilla and said that she needed

16 to take time off because her daughter was in an

17 accident with her boyfriend and there was a

18 fatality. When did you find out about that, if

19 ever?

20 A. Now.

21 Q. Just now?

22 A. Correct, sir.

23 Q. Okay. "Others that were . . . from our

24 department (that I knew)," this is what Quintanilla

25 has listed next, and he lists Mark Robbins. When



1 did you find out Mark Robbins was at the party?

2 A. Way down the line.

3 Q. News story in July or sometime

4 afterwards?

5 A. Sometime around that, yeah.

6 Q. Cynthia Ruelas, when did you know she was

7 at the party?

8 A. Well, I'm assuming -- I assumed that if

9 Robbins was there he was going to be there with his

10 wife. Ruelas is his -- was his wife or is his wife.

11 Q. Is, but were they married in November

12 2009?

13 A. They were together as far as I know.

14 Q. Okay.

15 A. Yeah.

16 Q. So you didn't know either one of them

17 were there until after the news story?

18 A. Correct, yeah.

19 Q. But you would assume if one was there the

20 other was there?

21 A. Yes, sir.

22 Q. I'll ask longer questions when you're

23 drinking.

24 A. I'm sorry.

25 Q. No problem.



1 When did you first find out Penny Higgins

2 was at the party?

3 A. Till the stories came out or statements,

4 I guess.

5 Q. How about Dispatcher Carrie Williams?

6 A. Same thing.

7 Q. How about Tina Zuniga? I think I already

8 asked you.

9 A. Yeah. Yeah, you did.

10 Q. Okay. Did you find out that in October

11 2007 Rebecca Wamsley's insurance company settled her

12 claim with regard to the accident that killed Angela

13 Peterson?

14 A. In 2007?

15 Q. October 2010.

16 A. Oh, I'm sorry. I learned of that

17 situation shortly before I left the department

18 through Phil Gervasi.

19 Q. Does knowing that in October 2010 Rebecca

20 Wamsley settled the case based on Miranda drinking

21 at a party at her house and that in November of 2009

22 Quintanilla filled out a Concern Report with the

23 information we just went over and that Rebecca

24 Wamsley's January 7th, 2010 memorandum discusses the

25 same party, does that change your opinion at all as



1 to whether this information was made up in February

2 of 2011?


4 foundation, misstates prior testimony regarding when

5 this document was created. Go ahead.

6 MR. PARK: Join.

7 MR. KELLER: Join.

8 A. Could you reestablish the question.

9 BY MR. COOK:

10 Q. Yeah. Let me -- let me ask you a little

11 better.

12 When we were talking immediately after

13 the break, I attempted to summarize some of your

14 earlier testimony from the morning and I think I got

15 it in a manner acceptable to you, which is November

16 2009 you find out that Gamboa and Quintanilla are at

17 a party. Miranda's there, leaves, DUI --

18 A. Uh-huh.

19 Q. -- kills Angela Peterson.

20 A. Right.

21 Q. You don't hear anything else until July

22 2011, but there was promotions in February 2011 that

23 you believe led people to make up a story; correct?

24 A. I won't say led, but initiated people.

25 Q. Okay. With that correction, my statement



1 was correct?

2 A. Yes, sir.

3 Q. All right. Now, getting additional

4 information that from your testimony you didn't

5 know, which would be Rebecca Wamsley settling in

6 October of 2010, Rebecca Wamsley submitting a

7 statement dated January 7th, 2009 [sic], Armando

8 Quintanilla writing a statement dated 11/29/09

9 noting that he reported information to Sergeant

10 Nebeker on November 30th, 2009, does that

11 information change your opinion as to whether

12 somebody made up this story in response to not

13 getting a promotion or not?

14 A. I never said made up the story, but I

15 understand where you're headed.

16 Q. Okay.

17 A. I understand. No, it -- based on the

18 information presented, obviously that situation

19 happened in a certain way.

20 Q. Okay. So does this new information

21 change your mind as to how that story that

22 ultimately got released to the news came about?

23 A. Correct.

24 MR. KELLER: Object to form.

25 MR. PARK: Join.



1 BY MR. COOK:

2 Q. And you -- you clarified my statement

3 when I said "made up the story." Help me out then.

4 What is it you think they did in response to not

5 getting the promotions -- strike that. Let me try

6 it again.

7 When you testified this morning that you

8 thought they in response to not getting promotions

9 and other people getting them in February 2011 did

10 something that led to the news stories that got

11 released in July 2011, it -- you said it wasn't made

12 up the story. What is it you think they did then?

13 A. I think it -- it -- it -- it fueled them.

14 It gave them the fire in their belly to take the

15 next step.

16 Q. Okay. Do you think there's any

17 information they made up then since you made that

18 correction or just it was their motivation?


20 I'm not sure what you're even asking.

21 MR. COOK: All right. Let me just move

22 on. I can get back to that once I get a little

23 more.


25 identification.)



1 MR. PARK: Marc, you gave me an extra.

2 MR. COOK: Thank you.

3 BY MR. COOK:

4 Q. Have you seen this before?

5 A. Yes.

6 Q. What led -- strike that.

7 What happened here that led you to give

8 this direction to Sergeant Aldays?


10 foundation.

11 MR. COOK: All right.

12 BY MR. COOK:

13 Q. Does this -- does this memorandum

14 accurately reflect what you told Officer Aldays to

15 convey to Officer Thomas?

16 A. It was through the chain of command, but

17 he was to deliver that memorandum.

18 Q. And is the memorandum's content accurate?

19 A. Correct.

20 Q. What happened that led you to direct this

21 memo to go to Mike Thomas?

22 A. Shortly after a sergeant's promotion

23 where Sergeant Thomas was not promoted, he began

24 texting me and in a fashion that I perceived to be

25 him attempting to coerce a sergeant's position from



1 me as chief of police.

2 Q. And what specifically did he do that you

3 believed was an attempt to coerce you into doing

4 that?

5 A. I don't remember the exact text. I

6 actually had downloaded it. An Internal Affairs

7 case was initiated, and I handed it over to Ketsaa

8 and -- Captain Ketsaa and to Detective Loren Johnson

9 to follow.

10 After the texting, he -- he also would

11 call me on my department number and also he began

12 sending E-mails through chain of command to

13 different individuals in my command staff without

14 the proper protocol, which is what led to him

15 finally receiving this.

16 Q. At some point in time, did you have him

17 investigated for extortion? Does that sound

18 familiar?

19 A. Extortion? I basically handed the

20 information to Loren Johnson to follow through as a

21 policy violation, not necessarily a criminal

22 extortion case.

23 Q. You said "not necessarily." Does that

24 mean --

25 A. I know what I basically directed Captain



1 Ketsaa and Loren Johnson to do.

2 Q. So if they on behalf of Clark County

3 School District alleged that you were concerned

4 about being extorted, is that not accurately what

5 your concern was with Mike Thomas?

6 A. The initial -- the initial concept, yes,

7 sir.

8 Q. At any point in time, were you concerned

9 that Mike Thomas was ex- -- attempting to extort

10 you?

11 MS. HENDRICKS: You know, I'm going to

12 have to stop the question here. Mike Thomas has

13 filed a lawsuit now naming Mr. Arroyo personally and

14 the School District, and if you have questions

15 related to this case, that's fine, but into Mike

16 Thomas's personnel issues, which are now the subject

17 of his own lawsuit, I'm instructing him not to

18 answer.

19 MR. COOK: You're instructing him not to

20 answer when it is his position that the motivation

21 for this story was that he didn't get a promotion

22 and I'm asking about the interactions related to

23 that?

24 MS. HENDRICKS: You're -- you're asking

25 about Mike Thomas's personnel issues.



1 MR. COOK: I -- I absolutely am because

2 he's one of the guys that your witness just said was

3 part of the motivation as to why he came up with the

4 story.

5 MS. HENDRICKS: If you have specific

6 documents in this case, that's fine, but Mike Thomas

7 has made new allegations in a new -- a new civil

8 proceeding, and that's not what's before us now.

9 MR. COOK: I'm not -- I don't care about

10 his proceeding. I care about my proceeding.

11 MS. HENDRICKS: If you --

12 MR. COOK: My questions are geared to

13 this, and if you're going to instruct him not to

14 answer, he's going to have to come back again and do

15 it.

16 MS. HENDRICKS: If it's geared to this

17 case, he can answer, but if you're getting into Mike

18 Thomas's personnel issues, then that's where I have

19 to draw the line.

20 MR. COOK: I haven't seen Mike Thomas's

21 case. I don't know what his allegations are, and I

22 don't care what his allegations are. I care what my

23 allegations are and --

24 MS. HENDRICKS: And you can ask him --

25 MR. COOK: -- I care what your defenses



1 are.

2 MS. HENDRICKS: And I understand that,

3 and you can ask him relevant to this case, but I

4 don't want to get into Mike Thomas's employment

5 issues in total because Mike has filed a new

6 complaint, and if we have to go to the magistrate on

7 it, we can go to the magistrate on it.

8 MR. COOK: Can you read back my last

9 question, please.

10 (The following record was

11 read by the court reporter:

12 "Question: At any point in

13 time, were you concerned

14 that Mike Thomas was ex- --

15 attempting to extort you?")

16 MR. COOK: You're going to instruct him

17 not to answer that?

18 MS. HENDRICKS: You -- I thought -- I

19 thought you were going beyond that.

20 You can answer that question.

21 A. My understanding of what Mike was trying

22 to do is pressure me into making him a sergeant

23 based on his past history and all the attempts he

24 had attempted in the past regarding becoming a

25 sergeant.



1 MR. COOK: Can you read the question

2 again.

3 BY MR. COOK:

4 Q. Sir, I appreciate that and that's a

5 clarification, but it's not an answer to the

6 question.

7 A. Okay.

8 Q. I'm trying to find -- sorry. I'll just

9 ask it again.

10 Is it your position that you believe Mike

11 Thomas was trying to extort you?

12 A. No. I expected him to coerce me into

13 getting that position.

14 Q. And what is your distinction between

15 trying to coerce you and trying to extort from you?

16 A. Well, it never got to that level. I

17 never gave him the opportunity.

18 Q. Do you have Exhibit 10 in front of you

19 still, sir?

20 THE WITNESS: Thank you. Okay.

21 BY MR. COOK:

22 Q. And Exhibit 11 if you could. That's the

23 one where it had the different badge.

24 A. Uh-huh.

25 Q. Do you have any understanding as to why



1 Exhibit 11 doesn't have the badge that was supposed

2 to have been on the memos as of 2009 when it was

3 supposedly written in 2010?

4 A. I can only presume the individual who

5 used that form elected to use that particular form.

6 Q. Okay. So it wasn't changed at the

7 computer level, to your knowledge, or it was?

8 A. As far as I know, the -- once we switched

9 over to the new emblem, it went out and everyone was

10 directed to fulfill the documentation utilizing the

11 new form.

12 Q. So then how would somebody have been able

13 to use the old one?

14 A. If they still had their old template,

15 they use it.


17 identification.)

18 BY MR. COOK:

19 Q. Did you ever see this document before?

20 A. Doesn't look familiar.

21 Q. It says, "CONCERN TAKEN BY Detective

22 Purcell." Who's Detective Purcell?

23 A. Detective Purcell came into the unit

24 towards the end of my time on the department.

25 Q. Okay. Who's Detective Purcell? I



1 mean --

2 A. Internal Affairs investigator.

3 Q. All right. When he takes a Concern

4 Report, I think you said earlier when we were

5 talking about the other Concern Report, this is

6 what's used to start an Internal Affairs

7 investigation; correct?

8 A. Correct.

9 Q. Okay. When he takes this, who does he

10 give it to to decide whether there's going to be an

11 investigation or not?

12 A. He -- at the time I think he was still in

13 training, it would have gone to Detective Loren

14 Johnson. If not, it would have gone straight to

15 Captain Ketsaa, who was over the department

16 administration.

17 Q. Who would make the call on whether an

18 Internal Affairs investigation of the facts in the

19 "BRIEF DETAILS OF CONCERN" paragraph should occur?

20 A. Basically the -- the detective and/or

21 the -- the captain by all means.

22 Q. And when you say "the detective," in this

23 instance since Purcell was new would the detective

24 have been him and/or Loren Johnson?

25 A. Correct.



1 Q. And the captain would have been Ketsaa?

2 A. Yes, sir.

3 Q. And this second paragraph in the details

4 references the payment from Wamsley's insurance to

5 the Peterson family. When I asked you about that

6 payment earlier, I think you said you hadn't heard

7 about it until after the lawsuit was filed; correct?

8 A. Correct.

9 Q. So you didn't see this document either?

10 A. No. And in addition, this document would

11 have been forwarded to EMR for them to conduct the

12 investigation on Ms. Wamsley.

13 Q. You said earlier that a Concern Report

14 gets a ID number, too, an Internal Affairs file

15 number; correct?

16 A. A concern number.

17 Q. Okay. Do you know if one was opened on

18 this?

19 A. It doesn't look like there's one on this

20 particular document. But again, being that the

21 individual was a civilian, the information would

22 have passed on to EMR for them to initiate the

23 actual investigation.

24 Q. Do you have any information that this

25 information was forwarded to EMR?



1 A. No, sir.

2 Q. Now, this happened before the story broke

3 or at least was in the news.

4 A. Uh-huh.

5 Q. Did you hear about this --

6 A. No, sir.

7 Q. -- this Concern Report or the allegations

8 in it?

9 A. No, sir.

10 Q. Something with the benefit of hindsight

11 you would have liked to have known about?

12 A. Yes, sir.

13 Q. What would you have done with it if you

14 were given this on July 18th, 2011?

15 A. Forward it to Metro and also forward it

16 to EMR, proper protocol.

17 Q. Did you start the P.A.R.C. Program,

18 P.A.R.C.?

19 A. I'm not -- right off the top, I'm not

20 sure.

21 Q. Let me get it for you.


23 identification.)

24 THE WITNESS: Yes, I remember this

25 program.



1 BY MR. COOK:

2 Q. What prompted you to start this program?

3 A. We have an officer named Mayer, Bob

4 Mayer, who had been working with -- he was part of

5 the community relations working with CALEA and --

6 our accreditation manager. A year earlier he had

7 contacted P.A.R.C. and established this, established

8 the process and the program, and it had taken all

9 his efforts to initiate it and bring it about, and

10 this was a memorandum basically detailing the

11 program that we were going to embark on.

12 Q. Who received this administrative notice?

13 A. This went out to the department I take

14 it.

15 Q. Does that mean all officers?

16 A. Yeah, to all sworn officers.

17 Q. Did it go out to dispatchers?

18 A. It would be logged in to the dispatch

19 department, yeah.

20 Q. When it's logged in to the dispatch

21 department, what does that mean? Where does it go?

22 A. That means it's accessed to -- by -- by

23 everyone at dispatch.

24 Q. Fair to say the effort to curtail

25 underage drinking and driving under the influence



1 would be important to a School District Police

2 Department?

3 A. Extremely.

4 MR. KELLER: Objection, form.

5 MR. PARK: Join.


7 identification.)

8 BY MR. COOK:

9 Q. Have you ever seen this before?

10 A. No, sir.

11 Q. How often do you go in the dispatch area?

12 A. It was on occasion. It was nothing

13 regular. Usually if we had an emergency where they

14 were piping the -- the cameras into the dispatch,

15 I -- and I happened to be in the office, I would go

16 in and become involved to the degree of a spectator

17 as the case was unfolding on TV.

18 Q. This starting with page 2 here, "The

19 legal drinking age is 21, Thanks for NOT providing

20 alcohol to teens, DontServeTeens.gov," anything

21 about that that's offensive to you to have in the

22 Police Department?

23 A. Offensive, no.

24 MR. PARK: Marc, just a clarification, is

25 this the actual size of the magazine or is this



1 blown up just for exhibit purposes?

2 MR. COOK: You provided it to me, Kara.

3 I don't know.

4 MR. PARK: Do you know? Sorry. I was

5 just wondering --

6 MS. HENDRICKS: I have no idea.

7 MR. PARK: -- this part, was that like a

8 page in the magazine or was that a corner; do you

9 know?

10 MS. HENDRICKS: I believe it's a page,

11 but I do not know that personally.

12 MR. PARK: Okay. Thanks. Sorry about

13 that.

14 BY MR. COOK:

15 Q. Flip over to the next page. Anything you

16 would find offensive being in the dispatch area?

17 A. No.

18 Q. I mean, this document has got policies

19 you -- you want and encourage; correct?

20 A. Correct.

21 Q. Any idea why one of your dispatchers

22 would be disciplined for leaving this in the

23 dispatch area?


25 foundation.



1 BY MR. COOK:

2 Q. After --

3 MR. PARK: Join.

4 BY MR. COOK:

5 Q. -- you left.

6 A. No.


8 identification.)

9 THE WITNESS: Thank you.

10 BY MR. COOK:

11 Q. I'm assuming you hadn't seen this

12 document before; --

13 A. No.

14 Q. -- correct?

15 Any of the content in this document

16 information you had heard before?

17 A. No.

18 Q. Do you know who Vincent Glaviano is?

19 A. Yes.

20 Q. Who is he?

21 A. He's an employee that we -- a police

22 officer that we terminated for having been involved

23 in a vehicular accident similar to the ones that

24 took the lives of two Metro police officers in

25 previous cases. He was running his vehicle at a



1 high rate of speed with the lights and sirens on

2 without authorization, T-boned a car and almost

3 killed the family.

4 Q. And what?

5 A. Almost killed the family in the vehicle.

6 Prior to that, he had other discipline

7 that led to his termination.

8 Q. This fourth paragraph talking about

9 Robbins being looked at for lying in his interview

10 about drinking with kids because Penny Higgins had

11 pictures of him doing so, do you recall hearing

12 about that?

13 A. No.

14 Q. What interview are you aware of took

15 place with Robbins and anybody regarding the Wamsley

16 party as of October 2011 when you were chief?


18 foundation.

19 MR. PARK: Join.

20 A. None.

21 BY MR. COOK:

22 Q. The last paragraph here says, ". . .

23 Glaviano said that Arroyo had contacted Robbins via

24 phone to ask what he had said to the Detectives and

25 he could tell him because he was not going to return



1 to Clark County School District Police Department."

2 A. Never happened.

3 Q. How many times have you talked to Robbins

4 since your position was changed in October 2011?

5 A. Once.

6 Q. When was that?

7 A. Just as the court case began to progress,

8 he contacted me. Actually, right after I finished

9 conversing with him for four minutes regarding what

10 attorney was going to represent who, I contacted my

11 attorney, who informed me not to have any more

12 contact with him.

13 Q. So from October 2011 to as we sit here

14 today, you have had one conversation with Mark

15 Robbins?

16 A. Correct.

17 Q. And what was the content of that

18 conversation?

19 A. Basically he wanted to let me know that

20 he was under the impression that they were going to

21 give separate attorneys so we would not be able to

22 interact or go forward with anything, and I

23 basically informed him that I would contact my

24 attorney and verify and to thank me for the

25 information -- or thank him for the information.




2 identification.)

3 BY MR. COOK:

4 Q. Have you ever received this memo or any

5 of the information contained in it?

6 A. No.

7 Q. When you left Clark County School

8 District Police Department, did you leave all your

9 files there?

10 A. Correct.

11 Q. Just took your personal belongings?

12 A. Yes.

13 Q. Did you have any personal E-mails or

14 documents or writings related to this case?

15 A. No. Whatever was there is -- was left in

16 the computer.

17 Q. What are you of -- what are you aware of

18 that you had with regard to the Peterson case that

19 was left at the computer when you left?

20 A. Nothing in particular.

21 Q. That you had generated.

22 A. Oh, nothing.

23 Q. By the way, did you get to keep your

24 firearm when you left or did you --

25 A. No. Everything was turned in. And --



1 and during my departure, I had two -- I had -- I had

2 an officer, a sergeant and an administrator next to

3 me as I packed and removed my items to verify that I

4 did not take anything inappropriate with me.

5 Q. Was that when you were getting your

6 change in position and reporting to Supervisor Jones

7 or was that when you --

8 A. Oh, no. Oh, I'm sorry.

9 Q. -- or was that when you had left?

10 A. When I left, yeah.

11 Q. I asked you about your gun. It reminded

12 me of this. Is this -- let me get it marked.

13 Sorry.


15 identification.)

16 MR. COOK: Thank you.

17 BY MR. COOK:

18 Q. Is that your gun or at least a picture of

19 your model gun?

20 A. It was assigned to me for a certain

21 amount of time.

22 Q. Okay. Right.

23 A. Yes. Yeah, yeah.

24 Q. That looks like your gun is what I'm

25 asking you.



1 A. Well, my actual -- I was assigned a

2 handgun. This was an additional firearm that I had,

3 yes.

4 Q. That looks like the additional firearm

5 that you had that you left with you?

6 A. Yeah, I left it with the department.

7 Q. Okay. What model is that?

8 A. That's a 9-millimeter Beretta.

9 Q. I'm assuming since you left it that it

10 was a Clark County School District gun.

11 A. Correct.

12 Q. Would therefore only be authorized to be

13 used by Clark County School District police

14 personnel?

15 A. Correct.

16 MR. COOK: I thought I had more, guys.


18 identification.)

19 BY MR. COOK:

20 Q. Do you recognize that individual? If

21 you'll notice, that's a blowup of your gun.

22 A. I don't recognize the individual.

23 Q. Do you have any idea why a high-school

24 student named Spencer Ketsaa would be shooting your

25 gun?



1 A. No, none whatsoever.

2 Q. I received testimony from, I believe it

3 was, Lieutenant Burgess that conveyed through a

4 third party that you believed you were fired because

5 Ketsaa undermined you, Ketsaa and Nebeker undermined

6 you, and that's what led to your termination. Do

7 you recall telling anybody that information?

8 A. No.

9 Can I ask you a question?

10 Q. Sure.

11 A. When was this dated?

12 Q. After you left. I got it off his

13 Facebook account.

14 A. Wow.

15 Q. I believe within the last -- well,

16 certainly within the last three weeks.

17 A. Really?

18 Q. Yes. I don't know when it was taken.

19 Are you aware of how old Spencer Ketsaa is?

20 A. I know he's not an adult. That's for

21 sure. Yeah, I know -- well --

22 Q. It listed him as being a student at Green

23 Valley High School, I believe. Does that sound

24 right?

25 A. He's in high school. Yeah, yeah, very



1 much.

2 Q. All right. If you were chief of police,

3 would you let your minor kid go out and shoot your

4 CCSDPD gun?

5 A. No one is supposed to have control of

6 your firearm or firearms, specifically if they're

7 issued to you by the organization you work for,

8 whether you're a chief or a police officer, all the

9 way through.

10 Q. Police departments take their guns pretty

11 seriously?

12 A. Extremely.

13 Q. You told me you got disciplined this

14 morning for having an unauthorized gun because it

15 had expired for five days?

16 A. Correct.

17 Q. Okay. If you were chief of police and

18 you saw a picture of your captain letting his son

19 shoot a CCSD-issued weapon, what would you do?


21 foundation.

22 A. Obviously it would be an Internal Affairs

23 investigation to verify the information in question.

24 This could be up to a terminal -- terminal -- not

25 terminal. Term- -- term- --



1 BY MR. COOK:

2 Q. Terminable?

3 A. Thank you. Case.

4 Q. Lieutenant Burgess testi- --

5 A. Ah?

6 Q. Yes.

7 A. I just thought of something, and again

8 not to distort the facts or the information

9 presented, I believe in conversation with Ketsaa --

10 and not to be defending the circumstances -- he may

11 have his own similar firearm.

12 Q. I don't work for the Police Department.

13 I'm not going to start investigating Ketsaa.

14 A. I understand. I understand. I just

15 wanted -- it just came to me and I felt like for

16 whatever reason.

17 Q. We will let Metro and/or CCSD take care

18 of that whole serial number issue; right?

19 A. Completely. That's exactly it.

20 Q. Lieutenant Burgess testified that Robbins

21 told him that you were displeased with the command

22 staff and that people beneath him led to his -- his,

23 being your, demise. Do you recall telling Robbins

24 that?

25 A. No.



1 Q. Do you recall feeling that Johnson and

2 Ketsaa went over your head and went to the School

3 Board and that led to your demise?

4 A. No.

5 Q. Were you aware that Johnson and Ketsaa

6 went to the School Board?

7 A. No.

8 Q. You said you didn't recall earlier what

9 GO 303 was. I -- I think we've got testimony on it,

10 but do you generally understand that there is a

11 requirement under the CCSDPD general orders that

12 reports are to be complete and not false?

13 A. Correct, yes.

14 Q. And that is an outstanding order for any

15 report that anybody under you would fill out?

16 A. Yes, sir.

17 Q. And it would also be a requirement for

18 any report you as chief filled out?

19 A. Correct.

20 Q. We talked about off duty versus on duty

21 earlier. Is it accurate, your accurate

22 understanding of the duties, that an off-duty arrest

23 can be made if there is an immediate need to prevent

24 a crime or apprehend a suspect?

25 A. Correct.




2 BY MR. COOK:

3 Q. Here it is.

4 Earlier today we talked about a flier

5 that you had seen during the meeting with

6 Superintendent Jones, and I just want to make sure

7 we're talking about the same document. This is

8 PETERSON00791. I'm not going to mark it. I'm going

9 to get to the anonymous letter, which has it in it

10 anyway.

11 A. Yes.

12 THE VIDEOGRAPHER: Counselor, did you

13 wish me to take a picture of that?

14 MR. COOK: No, no, no. I just didn't

15 know if I flipped over your document.

16 THE VIDEOGRAPHER: Oh, okay.

17 MR. COOK: I mean speaker.

18 BY MR. COOK:

19 Q. What type of information do you need to

20 have to open up an Internal Affairs investigation?

21 A. Basically the type of concern you

22 presented earlier.

23 Q. But if instead of a Concern Report I gave

24 you a photograph like that, would that be enough for

25 you to open up investigation?



1 A. Under the circumstances, yes, that

2 picture would.

3 Q. Is there a specific form then that needs

4 to be filled out for an Internal Affairs

5 investigation to begin or do you just have to have

6 some information that would reasonably lead somebody

7 to think it was worth doing the investigation?

8 A. Well, usually we would have a phone call,

9 a person contacting the -- the office and then

10 filling out the Concern Report that -- or at least

11 the actual format that you presented earlier.

12 Q. If I just anonymously mailed you a

13 picture of somebody shooting your gun that shouldn't

14 be shooting your gun, would that be enough to start

15 an Internal Affairs investigation?

16 A. Well, in this case --


18 foundation.

19 A. In this case, a picture's worth a

20 thousand words.

21 BY MR. COOK:

22 Q. Okay. So even if it's anonymous, if it's

23 significant enough, that's enough for you to go on?

24 A. Correct.

25 Q. Who makes the call on whether it's



1 significant enough on a day-to-day basis? Is that a

2 Loren Johnson?

3 A. If it goes to the Internal Affairs

4 Department, it would be Loren Johnson, who then

5 brings it to a captain, or the captain over the

6 Internal Affairs Division makes the call.

7 Q. Okay.

8 A. If --

9 Q. If it's -- if it's something obvious to

10 Loren Johnson, can he say, "Yep, I'm opening it up,"

11 or does he still have to go to his captain, in this

12 case Ketsaa, and say, "Do I open it up or not?"

13 A. No, he can. He can actually open it up

14 on his own.

15 Q. He can make some calls, and is it his

16 discretion as to gray area as to whether he's going

17 to ask his captain?

18 A. Yes.

19 Q. And then if it's gray area for the

20 captain, can he ask the chief?

21 A. Yes, they can come to me.

22 Q. And that was the protocol you had in

23 place while you were chief?

24 A. Correct.

25 Q. Okay. Do you need a break? I see you --



1 A. I need to go to the bathroom. I've been

2 drinking too much water.

3 Q. I understand.

4 MR. COOK: Why don't we go take five

5 minutes.

6 THE VIDEOGRAPHER: We're going off the

7 record. Pardon me, Counselor. I have 20 minutes

8 remaining. Shall I change disks?

9 MR. COOK: Please.

10 THE VIDEOGRAPHER: This is the end of

11 disk number three in today's videographed deposition

12 of Filiberto Arroyo. The approximate time, as

13 indicated on the video screen, 1413 hours. We're

14 off the record.

15 (Recess taken.)


17 record. This is the beginning of disk number four



20 video screen, 1422 hours.

21 BY MR. COOK:

22 Q. Did you direct anybody in your department

23 to talk to Rebecca Wamsley and see what happened at

24 that party?

25 A. No.



1 Q. Did you direct anybody or you yourself

2 talk to Penny Higgins at any point in time to see

3 what happened at that party?

4 A. No, sir.

5 Q. If I ask you that question about

6 everybody that was at the party, is your answer

7 still a no?

8 A. Correct.

9 Q. Quintanilla, I think you testified this

10 morning, came forward and provided information that

11 an accident happened at the party that him and

12 Andrea Gamboa or at least Andrea Gamboa was there;

13 correct?

14 A. Based on that document that you presented

15 you mean?

16 Q. No, no, no, no. The Monday after the

17 party, you said you had found out that Andrea Gamboa

18 and Armando Quintanilla were at the party. Some guy

19 goes there, leaves and kills somebody. You didn't

20 know it was Angela Peterson, but you knew about

21 that, and you didn't know anything else; right?

22 A. Correct. Brian Nebeker informed us of

23 the -- yeah.

24 Q. Did anybody at CCSD follow up with the

25 two you said came forward, Quintanilla or Gamboa, to



1 find out what happened?

2 A. No, at least not to my knowledge.

3 Q. And certainly not at your direction?

4 A. Correct.

5 Q. I think I asked you this earlier, and if

6 so, I apologize, but if a dispatcher believes they

7 are going to be criminally charged with something,

8 do they have a duty to disclose that information to

9 the School District Police Department?

10 A. I am not sure. I know police officers

11 do, but being that they're School District

12 employees, I think there's a -- there's a policy.

13 It has to be a certain type of crime, but again I'm

14 not sure.

15 Q. So if Rebecca Wamsley says that she

16 attained counsel because she was concerned she was

17 going to be charged criminally for the alcohol

18 consumption by the driver --

19 A. Right.

20 Q. -- is that something -- when you said

21 it's got to be a specific type of crime, is that

22 something you think falls in the category that they

23 have to tell you about or not?

24 A. I believe --




1 A. I believe it would be a felony, Class B

2 or A, and it would be to notify the School District,

3 but again I'm not sure.

4 BY MR. COOK:

5 Q. We talked after the last break about the

6 fact that you thought there was a couple people that

7 were disgruntled, the female sergeant, Mike Thomas

8 and Erik Aldays, that led them to take certain acts

9 to, I guess, further their reporting that led to the

10 July story in 2011. Do you recall that?

11 A. Yes, I remember.

12 Q. When, if ever, did you come to the

13 conclusion that it was one or all three of those

14 people involved in bringing this story about?

15 A. It wasn't till after I left the

16 department.

17 Q. So then at the time the story came out in

18 July 2011, you didn't know who factually was

19 behind -- behind the allegations?

20 A. Correct.


22 identification.)

23 BY MR. COOK:

24 Q. This is another reason why you're glad

25 you don't have Facebook; right?



1 A. Tell me about it.

2 Q. If somebody at the School District,

3 whether it's another cop or anybody who's Facebook

4 friends with Mark Robbins, sends this to the

5 department, what policy-wise should the department

6 be doing about that?


8 foundation.

9 MR. PARK: Join.

10 BY MR. COOK:

11 Q. While you were chief.


13 A. One of the things we were in the process

14 of passing or attempting to pass was a policy that

15 would restrict these types of antics and more on

16 Facebook. Because we're part of a school district,

17 not an independent law enforcement agency, the --

18 the policy did not appear and died before -- as I

19 was leaving.

20 In regards to this type of scenario, this

21 would be ample information to provide to the

22 department regarding an internal investigation.

23 BY MR. COOK:

24 Q. And then it would get assigned one of

25 those IA numbers and a file would be opened?



1 A. Correct. The -- the issue at hand would

2 be whether we would have leverage to follow through

3 with it because if it's not -- the School District

4 Police policies fall under the School District

5 policies. If there -- if a policy in the District

6 does not exist, we cannot enforce our own policy

7 unless authorized through the Legal Department.

8 And that's one of the issues we always

9 had, but this --

10 Q. Right. But that's a little bit ahead of

11 it. You're talking about enforcement, which means

12 you did an investigation and now you find something?

13 A. Correct, to the -- yes.

14 Q. And you don't know what you would find

15 merely from this paper?

16 A. No. You would definitely have to go in

17 and -- and -- yes.

18 Q. Right. But the point is, though, that

19 paper would be enough for you to start an

20 investigation?

21 A. Definitely.


23 BY MR. COOK:

24 Q. Do you know what the MPS Quality Control

25 Program was at Clark County School District Police



1 Department while you were chief?

2 A. The Management Progress System. It was a

3 program the School District adhered to under

4 Superintendent Rulffes', I guess, tenure, and

5 basically it was to create standards within the

6 District, within all the departments, set to the ISO

7 9000, and the -- the District, if I'm not mistaken,

8 while I was there had to review the process and be

9 audited every two years for the four years I was

10 there.

11 Q. As part of that Quality Control Program,

12 did there come a time where they were having

13 meetings to try and discuss problems with the

14 department and a way to manage through them without,

15 I guess, that whole rumor mill process?

16 A. Actually, what -- what the process is

17 inten- -- each department, whether it was facilities

18 or risk management, had to present an employee or an

19 administrator to represent the -- the actual

20 department. In our case, it was Detective Tracy

21 Byrd, who was also the accreditation manager.

22 And working with -- I forgot his name --

23 the gentleman who's second in command over the MPS

24 for the audit system, he would literally have to go

25 department by department and to fit the criteria and



1 to meet the guidelines of the audit interview and

2 assess every department within the School District.

3 Q. And what was Tracy Byrd's day-to-day

4 function in that regard at --

5 A. She rep- -- she -- I'm sorry.

6 She represented us within the MPS

7 process.

8 Q. You mentioned Sergeant Aldays earlier.

9 A. Uh-huh.

10 Q. How much interaction did you have with

11 Sergeant Aldays?

12 A. Very little to none.

13 Q. What led you to believe he was

14 disgruntled with not getting any promotion?

15 A. He went to the superintendent. He met

16 with the superintendent, him and -- for the love of

17 me, I can't remember her name, the other female

18 sergeant. They met with the superintendent and they

19 wanted to share with him that they were upset of the

20 process and -- and how the process went about, that

21 they were not clearly allowed to follow through to

22 the interview process, I think, portion of the

23 candidacy.

24 Q. By the way, at the time -- well, who

25 makes the ultimate decision on who got those



1 lieutenant positions when --

2 A. Who --

3 Q. -- Nebeker and --

4 A. -- selected them? I'm sorry.

5 Q. When Nebeker and Morales got their

6 lieutenant positions, who was the one that made the

7 ultimate decision okaying, "Yes, you're getting the

8 lieutenant spot"?

9 A. That was easy. It was me. They were the

10 only two that passed. It's an internal

11 administrative process within the School District,

12 not with the Police Department.

13 Q. If they pass, do they automatically get

14 it, or if they pass and you don't think they can do

15 it, do you have to give them the spot?

16 A. They pass, then they are automat- --

17 well, I can always eliminate the -- the two

18 positions and then go off or continue without the --

19 the positions. We had three openings. I believe 13

20 people put in.

21 The process, again it's through the

22 School District. Interview process is administered

23 by the administrative division of hiring within the

24 HR department, and -- and from whoever passes the --

25 the initial interview process -- actually the --



1 the -- actually let me revert back.

2 It's -- it's based on qualifications and

3 based on education. Whoever clears that segment of

4 the process goes into the interview, and then

5 whoever passes the interview. By the time it was

6 all said and done, I had three openings and only two

7 bodies.

8 Q. And who decides -- there -- isn't there

9 oral interviews that you're not on; correct?

10 A. Correct.

11 Q. Okay. How do you -- how do you figure

12 out if these guys are playing favorites or not

13 during that process?

14 A. What guys? The -- the five individuals,

15 basically what it is is the HR department selects

16 directors from throughout the District and they

17 actually sit in. They're the -- they make up the

18 panel.

19 Then we have a representative from our

20 department who's basically there for reference. His

21 or her input does not count. For captain, it would

22 be me, only I always passed on the requirement to

23 the chief of staff of the superintendent not to show

24 favoritism. In the case of the lieutenants' oral

25 board, it was Captain Ketsaa who sat in.



1 But the individuals who are actually part

2 of the board, they -- they present -- they actually

3 present the questions and they, you know, categorize

4 each candidate based on the qualifications, and then

5 that information goes to HR. HR determines based on

6 their criteria who passed and who didn't. And then

7 they send the information to my office.

8 Oh, and one more step I forgot. Once I

9 make -- because actually what I do is I make

10 recommendations. I send it to the superintendent.

11 He has to sign off on it.

12 Q. Now, is the superintendent involved in

13 the process other than just signing off at the end?

14 A. Correct. If he decides that the

15 positions shouldn't be filled or he may have some

16 personal knowledge of the individuals, he could

17 always make his own determination.

18 Q. Okay. Did you have any disagreements or

19 negative interactions with Aldays other than he was

20 upset that he didn't get the lieutenant spot?

21 A. Yes, I've never had any issues with Erik.

22 Q. Overall did you think he was a good

23 sergeant?

24 A. Yes.

25 Q. Why is it he didn't get the lieutenant



1 spot?

2 A. He didn't make the qualification round.

3 Q. I understand that, but which of those

4 stages?

5 A. My -- he never made it to the interview.

6 Q. Okay.

7 A. I think, if I'm not mistaken, either only

8 three or four of all the candidates -- I think they

9 were all sergeants except for one individual who was

10 a sergeant -- I mean, an officer. Only four made it

11 to the -- to the interview process.

12 Q. Now, Nebeker, did he have any

13 requirements for his position that included getting

14 any kind of degree at UNLV or accumulating a certain

15 amount of classes before he got his promotion?

16 A. No.

17 Q. Do you recall an instance that Arroy- --

18 I mean, that Aldays brought up to you regarding

19 Nebeker taking his vehicle to school while on duty

20 at U- -- to school, being UNLV?

21 A. No, he never mentioned that to me.

22 Q. You don't recall that at all?

23 A. He never came to me to discuss that, but

24 I -- I am aware of -- of Brian going to school one

25 night in his car.



1 Q. In his CCSD car?

2 A. In his CCSD car, correct.

3 Q. Is that appropriate?

4 A. Yes. He was on call that particular

5 evening and he needed to complete his one class, and

6 I gave him the authorization.

7 Q. And are you aware of him doing -- Nebeker

8 doing that on any other occasion other than the one

9 time?


11 Q. Did Aldays ever meet with you and go over

12 just some general problems and concerns he had about

13 the department?

14 A. On occasion I would meet with the

15 sergeants, have them all at a particular location

16 throughout the city and try and assess as much as we

17 could based on our interaction at these meetings

18 what we could do better, how could we proceed,

19 different areas of the department.

20 Q. Do you remember him doing that with you

21 in May 2011?

22 A. May have.

23 Q. Do you recall the topic of that

24 conversation?

25 A. I partic- -- I participated in most of



1 the sergeants' meetings we had either as a sit-in or

2 actually orchestrated the meeting.

3 Q. Did you go to Atlanta for a technology

4 award while you were at CCSD?

5 A. Yes, we did.

6 Q. What was the technology award? I can't

7 get anybody to help me out with that.

8 A. We -- when I first took over the Police

9 Department, actually when I first got to the Police

10 Department, the records department was basically

11 paper. If you had -- this was in 2005 when the --

12 if you had to initiate a report, everything was

13 manual, on paper, and they were so backed up it

14 would take anywhere from five to six months to

15 actually get a report back.

16 One of the things we implemented besides

17 the dispatch section -- actually, one of the things

18 we did, we actually were in the basement of Bridger

19 before I got here for -- for 12 years. The dispatch

20 center was over at the Flamingo area, and one of the

21 things we did, we needed to come up to speed to

22 current times to be able to facilitate the needs of

23 the community and everybody else, so we went from

24 paperless to a computer automated CAD system, a

25 computer-aided dispatch system, which was linked



1 into our records management. Where we went from

2 multiple months before getting a report or even

3 handwritten, everything went electrical, on

4 computers. You could initiate case numbers, send

5 them to dispatch and so forth.

6 Along with that, we also established a

7 program through the Channel 10, which is partly

8 owned by the School District, which was connected to

9 all the computer laptops in the vehicles to send

10 information to the vehicles if and when need, if and

11 when an emergency were to occur.

12 And based on that technology advancement,

13 the -- the International Chiefs Association

14 presented us with an award for technology. I think

15 it was 2010 if I'm not mistaken.

16 We were the first School District Police

17 Department ever to acquire it.

18 Q. Do you know Lieutenant Burgess?

19 A. Yes, sir.

20 Q. Did you have any issues or disagreements

21 with him?

22 A. No.

23 Q. He's not one of the people that you think

24 from February of 2011 was disgruntled and therefore

25 led to letting information out that led to the July



1 2011 story; correct?


3 A. Correct.

4 BY MR. COOK:

5 Q. Do you think Lieutenant Burgess is

6 trustworthy as a cop?

7 A. Oh, lieutenant, I didn't even know he was

8 promoted. When I left, he was a sergeant.

9 Q. Do you know if Sergeant/now Lieutenant

10 Burgess during your time as his chief was a good

11 cop?

12 A. Yes, he was.

13 Q. Honest, straightforward guy?

14 A. Correct.

15 Q. And if he during his deposition made

16 certain statements that Robbins told him, would you

17 tend to believe Lieutenant Burgess was telling the

18 truth?

19 A. Yes.

20 Q. I asked Lieutenant Burgess when he was

21 talking about a conversation he was having with

22 Officer Robbins, I said, "Okay. Anything else he

23 said about the party?

24 "Answer: He said that, he said that he

25 thought it was covered up."



1 I asked him, "And did he elaborate when

2 he said it's been covered up?"

3 This is Burgess talking about Robbins'

4 conversation with him. "He just told me, he told me

5 that he's the only one that stays in contact with

6 Arroyo. And so he talks to Arroyo, I don't know how

7 often he said, but more than one or two times, and

8 then that's when he just said, he's like, 'It was a

9 cover-up,' and that's when he went into the Ken

10 Young tearing down the flyers."

11 First, did Robbins try and stay in

12 contact with you after you left?

13 A. No, other than that one conversation we

14 had there.

15 Q. In conveying this conversation to you, it

16 appears to me that your position is the substance of

17 what I'm telling you is not true. In other words,

18 it's your position that you didn't keep in contact

19 with Robbins, you didn't cover anything up and you

20 didn't have Ken Young tear down fliers; correct?

21 A. Correct, sir.

22 Q. If I tell you that's what Burgess told me

23 in his deposition, who do -- who do you think is

24 making this up, Robbins or Burgess?

25 MR. KELLER: Foundation.



1 MR. PARK: Join.

2 A. Robbins.

3 BY MR. COOK:

4 Q. And why is it you think Robbins would

5 make up something like this?

6 A. Because I know I did not have that

7 conversation with him.

8 Q. Yet you believe in the truth and veracity

9 of Burgess?

10 A. Correct.

11 Q. Okay. Do you know Officer Joe Thomas --

12 I'm sorry, Joe Barris?

13 A. Yes.

14 Q. Did you have any disagreements or issues

15 with him?

16 A. When we first met, he was a little bit

17 antagonistic while he was a -- in a good sense. Let

18 me rephrase that.

19 He was part of the union and he was very

20 open-minded, and at first we clashed at times and as

21 time progressed we were able to establish a working

22 relationship.

23 Q. Do you recall what positions he had under

24 you -- or strike that.

25 Do you recall what positions he had with



1 the School District when you were chief?

2 A. He was a police officer. He did a short

3 time as an Internal Affairs investigator. It didn't

4 work out. He went back to patrol, and then we -- we

5 expanded the -- the property room detail, the

6 warehousing of the property and evidence rooms. He

7 put in and he became an officer, one of the two

8 officers in the property room, evidence room detail.

9 Q. And between Internal Affairs and going

10 out to be an officer, do you recall him working for

11 the EMR, being that liaison?

12 A. Something of that nature, yes.

13 Q. Okay.

14 A. He was working with Detective Johnson at

15 the time.

16 Q. And do you believe he competently

17 performed his duties in the short period of time he

18 was in Internal Affairs?

19 A. I -- I'm assuming. I never really

20 supervised anything specifically he did.

21 Q. Did you get any reports that he wasn't

22 doing anything appropriately?

23 A. No, no.

24 Q. How about when he was with EMR, did he

25 seem to do things appropriately?



1 A. As far as I know. I don't know.

2 Q. You certainly did not get any complaints

3 about him?

4 A. No, I never. No, no, no, none

5 whatsoever.

6 Q. Did you have an executive meeting where

7 you told officers, including Barris, not to worry

8 about the things in the rumor mill and that things

9 were being taken care of and that a lot of what is

10 being said and put out in the media is not true with

11 regard to the Peterson case?

12 A. No, not in regards to the Peterson case,

13 no.

14 Q. His estimate was that was in the August

15 4th, 2011 meeting, so it was after the first story

16 broke but before Penny Higgins' story.

17 A. What type of a meeting was it?

18 Q. I believe he said executive, but I'm

19 having a little trouble finding the beginning of it.

20 We -- much like this, I talked to him for a long

21 time.

22 Yeah, he didn't tell me. [As read] "I

23 attended all, most, but not all, but most union

24 meetings." He thinks it was a union meeting, but he

25 is not certain.



1 A. Could it have been -- he -- for a while

2 he was part of the -- the Steering Committee. We

3 had a Steering Committee composed of 20, 25 officers

4 from throughout the department, and they would meet,

5 I think, once a month in the department. And at

6 times I would -- I basically sat in to hear the

7 interaction and so forth. It was administered by

8 the -- by the accreditation manager, Tracy Byrd.

9 Q. Okay. Well, at any meeting, do you

10 recall telling the members there that, "All this

11 stuff is going to go away. It's not a problem" --

12 and I lost my place -- or something to that general

13 substantive effect, "The rumors were not true. This

14 is all going away"?

15 A. Well, I was constantly having to deal

16 with the rumors and innuendos and so forth in

17 general.

18 Q. Okay. Do you understand I'm specifically

19 talking about the Peterson case?

20 A. No, no. I never spoke directly to any

21 group of people or any specific number of people

22 regarding any issues having to do with the

23 Petersons.

24 Q. So at no time did you talk about the

25 rumor mill and "This is all going to go away" in



1 relation to Angela Peterson's death or --

2 A. No.

3 Q. -- the Wamsley party?

4 A. No.

5 Q. Okay. My statement is correct?

6 A. Correct.

7 Q. Okay. Do you know Penny Higgins?

8 A. No. No.

9 Q. Before the August interview, did you know

10 she was a dispatcher?

11 A. Not really.

12 Q. Fair to say you didn't at least yourself

13 then have any issues or disagreements with her?

14 A. No, none whatsoever.

15 Q. Okay. After you heard her testimony --

16 strike that.

17 After you heard her statement in the news

18 interview in August 2011, what was your reaction to

19 her statements?

20 A. I was surprised.

21 Q. Why were you surprised?

22 A. That in case if she knew all this had

23 happened why didn't she make it a point to come out

24 sooner.

25 Q. Did you have a similar reaction as to her



1 suggestions that police officers were drinking with

2 kids?

3 A. Yeah, the whole concept, yes.

4 Q. Fair to say it's your position that your

5 cops should not be drinking with minors?

6 A. Of course not. That's not even -- by all

7 means.

8 Q. Do you recall an incident with Sergeant,

9 now Lieutenant Morales at the Gold Coast, a

10 Christmas party in December of 2009 where he at

11 least got grabbed by security at the Gold Coast for

12 domestic violence and the police were called?

13 A. I remember that.


15 A. Yes, I remember something to that effect.

16 BY MR. COOK:

17 Q. What do you recall from that?

18 A. I received a call from Lieutenant Young,

19 who had responded to the location. The allegation

20 was that Morales and his wife had become part of a

21 domestic violence situation. Metropolitan Police

22 responded. They have a unit specifically dealing

23 with domestic violence. They met with both

24 individuals. They pulled the tape of the incident

25 from the casino.



1 I called actually three phone calls, one

2 from Lieutenant Young letting me know he had arrived

3 to assess the situation and Metro was handling the

4 whole thing. The second one was to let me know that

5 they were reviewing the document that -- the

6 documented video and so forth, and then last that

7 Metro had seen that the wife was inebriated, the

8 allegations were not substantive and they were

9 releasing him or -- but releasing both of them

10 actually.

11 Q. They were releasing both because she was

12 inebriated or because the tape didn't show anything,

13 or you don't know?

14 A. Because the tape didn't show anything

15 and -- and that she was basically inebriated.

16 Q. And who conveyed this to you,

17 Lieutenant --

18 A. Lieutenant Young.

19 Q. Okay. And you were not at the party I

20 take it?

21 A. I'm trying to remember. I only went

22 to -- this was the one in 2010; correct?

23 Q. 2009, right after Angela's death.

24 A. Yes, okay. Basically, as chief of

25 police, I went to the first three Christmas parties



1 sponsored by the union. I would come in, basically

2 say "hellos" with my wife, say a couple of words and

3 then leave. The last Christmas party I did not

4 attend.

5 Q. So this one you did attend, though?

6 A. Yes, I did, yes.

7 Q. But you had left before this incident

8 happened?

9 A. Yes, yes.

10 Q. Where were you when you got the call?

11 A. Home.

12 Q. Do you recall at the union meeting, I

13 think it was, in December 2009 Mike Thomas

14 approaching you to tell you about the Wamsley party?

15 A. No.

16 Q. Do you recall Mike Thomas approaching you

17 at all at a meeting in 2009 and talking to you about

18 the Wamsley party --

19 A. No.

20 Q. -- and Angela's death?

21 A. No.

22 Q. Do you recall giving Nick Fetcho a

23 message to tell Mike Thomas not to Google you

24 anymore and if you want to know something about you

25 to ask you?



1 A. Oh, I remember that incident, yes.

2 Q. Tell me about that incident.

3 A. For some reason he was under the

4 impression that I had delivered a message through

5 Nick Fetcho regarding him Googling me. That's all I

6 know.

7 Q. Oh, you're saying you didn't tell Nick

8 Fetcho that?

9 A. Oh, no, no. Yeah, I did not tell him,

10 no.

11 Q. Are you aware of whether Mike Thomas was

12 Googling you?

13 A. No.

14 Q. So how is it you hear about that?

15 A. How did I hear about --

16 Q. How did you hear that there was some

17 rumor that Mike [sic] Fetcho told Mike Thomas to

18 stop Googling you?

19 A. Mike Thomas came up to me and said, "I'm

20 not Googling you." I go, "I have no idea what

21 you're talking about." And that's how that derived.

22 Q. Did you have any involvement with regard

23 to any investigation or anything related to Angela's

24 death or the Wamsley party other than directing

25 Ketsaa as you did at the very beginning after that



1 November meeting?

2 A. Correct.

3 Q. That was the only contact?

4 A. Yes, sir.

5 Q. And that was your only involvement?

6 A. Correct, sir.

7 Q. Until post news story and your meeting

8 with Gillespie and Jones?

9 A. Correct.

10 Q. Did you and Ketsaa see eye to eye on

11 these policy issues as to how to handle the Boyett

12 matter?

13 A. Not necessarily, no.

14 Q. What was different?

15 A. I was not comfortable with the way the

16 Boyett investigation came to be in our hands from

17 the ICE investigator to the School District. I

18 believe that was -- that could have been handled

19 much better.

20 Q. And then to the extent that

21 Superintendent Jones wanted to involve himself in

22 that investigation or the direction of that

23 investigation, did you and Ketsaa agree that that is

24 not a good idea for him to be involved?




1 A. No, it had nothing to do with Captain

2 Ketsaa.

3 BY MR. COOK:

4 Q. No, no. I understand it --

5 A. I'm sorry.

6 Q. -- didn't. I'm just trying to find out

7 if you and Ketsaa were of the same mind-set that

8 maybe the superintendent shouldn't be involved in

9 that type of police work.

10 A. Oh, I don't know. That would have to be

11 up to him. I'm not sure.

12 Q. So --

13 A. It was never brought to my attention.

14 Q. You and Ketsaa never had that general

15 discussion about, "Look, I got Jones wanting to know

16 these details like he's going to run an

17 investigation. What do you think?"

18 A. Well, actually, I'll go one step further.

19 Ketsaa had had -- did not want us having any direct

20 involvement with the School District.

21 Q. Did he convey that to you specifically

22 with regard to the Boyett issue or just a more

23 general matter?

24 A. No, in general. He did not believe we

25 should not only not interact with or have indirect



1 interaction with the School District, we should be

2 an independent body, but obviously being a

3 department which is part of a large organization,

4 you just can't. You know, it's like -- it's like

5 Florida cutting out of the rest of the United

6 States. It doesn't work.

7 Q. Were you surprised then that Ketsaa ended

8 up being chief of police?

9 A. Kinda sorta, yeah.

10 Q. Why else were you surprised besides this

11 policy issue?

12 A. Because everything he pretty much stood

13 for, I guess, he had to show during the candidacy

14 that he was for in order to acquire the job, I'm

15 assuming.

16 Q. Explain what you said. I'm not quite

17 sure I understand you, sir.

18 A. Being that he -- there's -- there were

19 different obvious reasons he did not particularly

20 care for direct interaction with the -- the

21 District, in order to be selected in that position,

22 obviously he would have had to do a complete 360 and

23 abide by everything the superintendent asked of him;

24 hence, all the changes that occurred after I left.

25 Q. What changes were they?



1 A. Everything from the Steering Committee

2 being dissolved, the process following to become

3 certified with a national certification. That

4 became a moot point. More direct involvement with

5 Metro over the department and -- and so on and so

6 forth.

7 Q. Now you believe there's more direct

8 involvement with Metro over the department than when

9 you were there?

10 A. Correct, yes.

11 Q. And why do you say that? What -- what

12 specifics can you point to?

13 A. When you see all the initiatives out,

14 they are primarily run by Metro and the School

15 District Police is secondary.

16 Q. I asked you about Burgess and Robbins and

17 their conversation. Glaviano had said that Robbins

18 contacted him via phone to ask what you had said to

19 the detective. You remember from that --

20 A. Uh-huh.

21 Q. -- E-mail?

22 Same question: As you sit here today, do

23 you believe Glaviano when he says, "That's what

24 Robbins told me," or do you think Glaviano's making

25 it up and not Robbins somehow?



1 A. Based on the previous information

2 regarding Robbins and Burgess and other statements

3 by Robbins and knowing and having been well aware of

4 Glaviano, I wouldn't trust either one of them with

5 that answer.

6 Q. When I asked Quintanilla what he believes

7 could have been done or should have been done

8 differently in his depo, he said, "I told my

9 superiors. They knew about it, everything that I

10 knew. I would not condone anything like that, and

11 none of that's going to help bring anything back now

12 that -- and I just hope that this will bring some

13 light to you at least to say, 'Well, you know what?

14 At least at that part, at that level something was

15 done. It wasn't just nothing.'"

16 And he then complains that he was kept

17 out of things. I shouldn't say "complains." He

18 says he was kept out of things.

19 Do you agree with that testimony?

20 A. I never had any direct involvement in

21 anything regarding his information. If he shared

22 that information up his chain of command, it would

23 have gone to Sergeant Nebeker and then to Captain

24 Ketsaa. As far as I know, he did not provide me any

25 information.



1 Q. And if he did convey it to somebody above

2 him, it didn't get to you?

3 A. Correct.

4 MS. HENDRICKS: Can you adjust the air

5 again?

6 MR. COOK: I'm sorry?

7 MS. HENDRICKS: Can we adjust the air

8 conditioning again?

9 MR. COOK: Yeah. Do you want to take a

10 five-minute one?

11 MS. HENDRICKS: Sure.

12 MR. PARK: Sure.

13 THE VIDEOGRAPHER: Stand by, please.

14 We're going off the record at the -- at the

15 approximate time as indicated on the video screen,

16 1503.

17 (Recess taken.)


19 record at the approximate time as indicated on the

20 video screen, 1511 hours.

21 BY MR. COOK:

22 Q. Sir, any changes or corrections or

23 additions from any prior testimony today?

24 A. No, sir.

25 Q. Okay. Anything you did with regard to



1 the Wamsley party or Angela's death or any

2 investigation or conversation with anyone regarding

3 those that wasn't done in your capacity as chief of

4 the police?

5 A. No, sir.

6 Q. I'm going to read to you one of the

7 affirmative defenses in the answer to complaint that

8 you have filed in this case, and I've got a couple

9 questions for you about it.

10 Your third affirmative defense that you

11 have filed in this case is called contribution, and

12 it says, "CCSD Defendants allege that the damage

13 suffered by plaintiffs, if any, was the direct and

14 proximate result of the negligence of parties,

15 persons, corporations and/or entities other than

16 CCSD Defendants and that the liability of CCSD

17 Defendants, if any, is limited in direct proportion

18 to the percentage of fault actually attributable to

19 the CCSD Defendants."

20 And as I hope you're aware, you're one of

21 the CCSD Defendants. Do you understand that, sir?

22 A. Yes, sir.

23 Q. Okay. What other party, person,

24 corporation and/or entity are you aware of I should

25 have named in this lawsuit I didn't?



1 A. As far as I know, this is -- I don't know

2 anybody else.

3 Q. Okay. Your fourth affirmative defense

4 says, "The CCSD Defendants are informed and believe

5 and allege that the plaintiffs have engaged in

6 conduct, acts, deeds, activities and/or omissions

7 sufficient to constitute a waiver of any alleged

8 breach of duty, negligence, act, omission or any

9 other conduct, if any, as set forth in plaintiffs'

10 second amended complaint. Plaintiffs' claims are

11 also barred by the doctrine of laches and estoppel."

12 Sir, what acts do you believe Angela

13 Peterson or her parents engaged in that in any way

14 limit her ability to sue as a result of her death?

15 A. None that I'm aware of.

16 Q. They didn't do anything wrong, did they?

17 A. Correct, yes.

18 Q. Hundred percent victims; correct?

19 A. Yes, sir.

20 Q. All right. Your next affirmative

21 defense, number 5, is acts of third parties. "CCSD

22 Defendants are informed and believe and on that

23 basis allege that the damages sustained by

24 plaintiffs, if any, were caused by the acts of third

25 parties who were not agents, servants or employees



1 of CCSD Defendants and who were not acting on behalf

2 of CCSD in any manner or form, and as such CCSD

3 Defendants are not liable in any way to plaintiff."

4 Again, what third parties do you believe

5 made any acts that I didn't include in this lawsuit?

6 A. No one that I'm aware of.

7 Q. Okay. Your seventh affirmative defense

8 says, "CCSD Defendants allege that plaintiffs have

9 failed to join a party or parties necessary and

10 indispensable to this action." Are you aware of

11 anybody I didn't name that is necessary or

12 indispensable to this action?

13 A. I'm not aware.

14 Q. The next one is number 9,

15 intervening/superseding cause. "Plaintiffs are

16 barred from asserting any claim against CCSD

17 Defendants because the alleged damages were the

18 result of an intervening and superseding cause."

19 Are you aware of any intervening or superseding

20 cause?


22 Q. 11, attorneys' fees, "CCSD Defendants

23 have incurred attorneys' fees and costs in the

24 defense of this action and is entitled to full

25 reimbursement thereof." I believe you testified



1 earlier today that you haven't paid anything in

2 attorneys' fees; correct?

3 A. Correct. Yes, sir.

4 Q. Next one, failure to mitigate,

5 "Plaintiffs have failed to mitigate their damages."

6 Do you know generally what mitigating your damages

7 are?

8 A. No, not exactly.

9 Q. Taking some affirmative action to limit

10 your damages so they're not so bad. Do you

11 understand that?

12 A. Not exactly, no.

13 Q. Okay. Are you aware of anything Angela

14 did or failed to do, I should say, that as a result

15 her damages should be limited?

16 A. No.

17 Q. Are you aware of anything her parents did

18 that should any way limit their damages?

19 A. No, sir.


21 identification.)

22 THE WITNESS: Thank you.

23 MR. COOK: 22?

24 THE REPORTER: (Nodding head.)

25 \\\



1 BY MR. COOK:

2 Q. Have you seen any of these pages before?

3 A. Yes, sir.

4 Q. When?

5 A. Last week when I met with Kara and --

6 MS. HENDRICKS: That's it.

7 THE WITNESS: Yeah.

8 BY MR. COOK:

9 Q. Well, I mean, I don't want to know the

10 conversation, but if you saw it any other occasion,

11 I --

12 A. No. That was -- that's where I was

13 headed. That's --

14 Q. So in February of 2011, five and a

15 half -- strike that -- five and a half months before

16 this story broke --

17 A. Yes, sir.

18 Q. -- this letter was sent by Bill Hoffman

19 to [email protected]. Do you see that?

20 A. Yes, sir.

21 Q. When is the first time you knew about

22 that?

23 A. When I met with my attorney last week.

24 Q. Who's Bill Hoffman?

25 A. Bill Hoffman was the legal counsel for



1 the School District at the time I was there.

2 Q. How was your relationship with him at

3 that time?

4 A. It was okay.

5 Q. Are you surprised he didn't give this to

6 you?

7 A. I -- yeah, very much so.

8 Q. If you'll take a look at page 2, it's

9 directed to Superintendent Jones; correct?

10 A. Yes.

11 Q. Now, when we talked earlier a couple

12 different times about you believing the impetus for

13 people getting kind of a fire lit under them to

14 pursue this story was not getting promotions and you

15 told me it was the female sergeant and Aldays and

16 Thomas, Jones had this before mid-February 2011;

17 correct?

18 A. Yes.

19 Q. Okay. So does that change your opinion

20 as to the impetus for why this matter was pushed

21 forward?

22 A. Yes.

23 Q. And do you know who prepared this?

24 A. The?

25 Q. Sorry. Page 2 and 3 of this Exhibit 22.



1 A. My understanding was Mr. Glaviano.

2 Q. When you answered your question earlier

3 today where I asked you who did you think would be

4 more likely to tell the truth, Glaviano or Robbins,

5 is part of what you took into account when you

6 answered with regard to Glaviano is this letter?

7 A. As well, yes, also.

8 Q. Glaviano was not one of the people you

9 mentioned with an issue in February of 2011;

10 correct?

11 A. Correct.

12 Q. If the superintendent would have provided

13 you with this letter in February of 2011, what would

14 you have done?

15 A. Well, there's certain segments of it that

16 would have been necessarily forwarded to Metro and

17 other aspects review and try and establish where the

18 information came from. I know that there was a

19 policy in place in the District while Walt Rulffes

20 was there not to follow up on anonymous type of

21 letters per se. This, even though it's anonymous,

22 it has enough information in it to establish some

23 type of direction.

24 Q. So this also would have been the basis

25 for opening an Internal Affairs file?



1 A. And --


3 A. Yes, correct.

4 BY MR. COOK:

5 Q. And this letter begins, "In light of" --

6 "In light of the recent media reports concerning

7 CCSD employee Boyette this week," which I'm assuming

8 is the January 21st, 2011 news report that we

9 already went over this morning --

10 A. Uh-huh.

11 Q. -- at least it's correct in the time

12 frame anyway -- "I wanted to forward to you another

13 problem with the CCSD police administration." Do

14 you see that?

15 A. Where?

16 Q. I just read you the first sentence.

17 A. I'm sorry, I'm sorry.

18 Q. First two sentences.

19 A. I -- I was ahead of you.

20 Q. "In light of the recent media reports

21 concerning CCSD employee Boyette this week" --

22 A. Uh-huh.

23 Q. -- "I wanted to forward . . . you another

24 problem with the CCSD police administration. I

25 would like to say that I appreciate" your -- "you



1 letter and your promise to 'investigate fully' the

2 Boyette investigation." Do you see that?

3 A. Am I reading -- I don't know where.

4 Q. I'm reading on Bates stamp page 44, which

5 is the second page of Exhibit 22, the first

6 paragraph.

7 A. Oh, okay. Oh, I'm way ahead. That's

8 why. Okay.

9 Yeah.

10 Q. Okay. So is it fair to say time frame

11 that this letter was written -- based on the time

12 frame of the news reports, it appears it was written

13 sometime late January 2011?

14 A. Yeah, I --


16 BY MR. COOK:

17 Q. And do you recall Superintendent Jones

18 with regard to the Boyett matter saying that they

19 would investigate fully?

20 A. I don't remember him saying anything to

21 that matter.

22 Q. Okay. Second paragraph, "With that in

23 mind there have been investigations conducted by the

24 CCSD Police, before your arrival of course, that

25 have been inadequate, not-investigated or just plain



1 covered up to avoid CCSD embarrassment and the

2 involvement of CCSD police officers."

3 Had you heard that allegation with regard

4 to any other matters as of February 2011?

5 A. No.

6 Q. Next paragraph, "In November . . . 2009,

7 UNLV Honor student Angela Nichole Peterson was

8 killed in a DUI traffic accident" at "Flamingo and

9 Rainbow."

10 A. Uh-huh.

11 Q. This so far, you knew that paragraph,

12 that sentence, to be true at this point?

13 A. Correct, yes.

14 Q. Okay. "The driver who killed Peterson,

15 Kevin Miranda admittedly was drunk according to many

16 media reports." When you heard about this story in

17 that Monday, did you put it together that it was

18 this Kevin Miranda that was in the news that next

19 day --


21 BY MR. COOK:

22 Q. -- or that prior day?


24 MR. PARK: And foundation.

25 A. Yes, sir.



1 BY MR. COOK:

2 Q. So you knew this sentence was true too;

3 correct?

4 A. Yes, sir.

5 Q. "What was not reported in the media was

6 that Miranda's passenger was a 16 year old female

7 who was the daughter of a Clark County School

8 District Police Dispatcher, Zuniga." Well, that

9 statement is true because you -- because it wasn't

10 reported in the media at that time; correct?


12 A. Yes.

13 BY MR. COOK:

14 Q. Okay. And you didn't find out that it

15 was Marisa Zuniga that was the female passenger of

16 Miranda's at the time of the accident until when?

17 A. Way later --

18 Q. The --

19 A. -- after the story started to break.

20 Q. So after July's story in 2011?

21 A. Yes.

22 Q. Correct?

23 A. Yes.

24 Q. So that's about five months after -- it's

25 more than five months after this was forwarded to



1 the sheriff; correct?

2 A. Yes.

3 Q. "A holiday party thrown by the dispatcher

4 Wamsley, was attended by numerous other police

5 dispatchers, several CCSD police officers and a

6 police Sergeant Morales." In February of 2011, you

7 did not know that information; correct?

8 A. Correct.

9 Q. As you sit here today, you understand

10 that that information is true, though; correct?

11 A. Correct.

12 Q. "One dispatcher present at the party,

13 Zuniga also had her daughter and daughter's

14 boyfriend (Miranda) present." Same thing, you

15 didn't know that was true in February 2011, but as

16 you sit here today you know it's true?

17 A. Yes, sir.

18 Q. "The problem arises out of the

19 investigation conducted by L. Johnson, who happens

20 to be friends with Sgt. Morales." First, do you

21 know if Loren Johnson and Sergeant Morales are

22 friends?

23 A. Yes, I -- at least they were when I

24 was -- while I was still there.

25 Q. Next sentence, "Several party attendees



1 specifically Dispatcher Penny Higgins told me

2 personally that she observed Sgt. Morales, drinking

3 and playing Beer Pong with Miranda." Did you know

4 that in February 2011?

5 A. No.


7 BY MR. COOK:

8 Q. As you sit here today, do you know

9 whether that's true?

10 A. No.

11 Q. Have you heard testimony to that effect,

12 though? Are you aware of testimony to that effect?


14 A. No.

15 BY MR. COOK:

16 Q. Okay. "Higgins, uncomfortable with the

17 situation at the party left after a short period of

18 time as she was uncomfortable with several teens in

19 attendance drinking alcohol." You did not know that

20 in February 2011; correct?

21 A. Correct, sir.

22 Q. Have you heard her statements to that

23 effect subsequently?


25 MR. PARK: Join.



1 A. Well, other than was in the media.

2 BY MR. COOK:

3 Q. Right. In that August 2011 media report,

4 she said essentially the same thing; correct?

5 A. Correct, yes.

6 Q. Do you have any reason to dispute that

7 statement by her?

8 A. I have no reason to dispute that

9 statement.

10 Q. The next paragraph, "During the Internal

11 Investigation conducted by L. Johnson he was advised

12 by Morales that he (Morales) never observed Miranda

13 Drinking." Do you know whether that's true or not?

14 A. There was no investigation conducted by

15 Johnson or anyone else in Internal Affairs.

16 Q. And you know that for a fact or you're

17 just saying, "There was none I was aware of"?

18 A. None that I was aware of, yeah.

19 Q. Okay. If we've had testimony that Loren

20 Johnson was pulling out people who were at the party

21 to bring them to their office and talk about it, do

22 you have any information to dispute that?

23 MS. HENDRICKS: Objection as to

24 foundation.

25 MR. PARK: And form. Join.



1 A. I would not be privy to that, but again,

2 there was no investigation, as far as I know, and

3 that should not have occurred.

4 BY MR. COOK:

5 Q. If there was no investigation, Loren

6 Johnson should not have been pulling dispatchers out

7 of the dispatch area to talk about events at the

8 party?

9 A. Correct.


11 A. Correct.

12 Q. Okay. I believe your testimony earlier

13 was that if the police, Metro, is investigating

14 something you can't. Is that right or am I

15 overstating that?

16 A. Correct, yes.

17 Q. Okay. So if Metro -- if -- if CCSD

18 Police Department knows Metro is investigating and

19 is separately doing an investigation to get together

20 a story, is that, in your view, interfering with the

21 Metro investigation?


23 foundation.

24 MR. PARK: Join.

25 A. Yes.



1 BY MR. COOK:

2 Q. The next sentence there says, "Not any

3 other dispatcher who was questioned admitted seeing

4 any underage person drinking at the party." As you

5 sit here, you don't think Loren Johnson talked to

6 anybody, so you don't have any information on that

7 sentence?

8 A. Correct.

9 Q. Okay. Next paragraph, "I have also been

10 told that before the internal investigation,

11 Sgt. Morales had met with the other party attendees

12 and openly discussed the 'situation' in an attempt

13 to cover up the truth of the events." You are not

14 aware that that happened?

15 A. Correct.

16 Q. If it did happen, you would agree that

17 that would be interfering with the Metro

18 investigation?

19 A. Correct.

20 Q. And you would agree that it would be

21 inappropriate conduct to occur with a CCSD police

22 sergeant?

23 A. Yes, sir.

24 Q. "Sgt. Morales advised" that "the group

25 needed to get their stories straight." Obviously



1 that would be illegal; correct?

2 A. That's correct.



5 A. Yes.

6 BY MR. COOK:

7 Q. "One party attendee (Higgins) advised

8 Sgt. Morales that if" he "asked she was not going to

9 lie and would tell what she had seen during the

10 party." You don't know whether that happened;

11 correct?

12 A. Correct.

13 Q. But rather than getting their stories

14 straight, it would be your preference and your

15 direction even that they would tell the truth?

16 A. Correct.

17 Q. "Ironically Higgins was NEVER questioned

18 by L. Johnson or by Las Vegas Metro Police." Do you

19 know whether that's true?

20 A. I have no idea.

21 Q. "I am sure Las Vegas Metro police only

22 used information given to them by L. Johnson or

23 Arroyo." You didn't give them any information?

24 A. No. It was through -- the information

25 that we received from Nebeker to Ketsaa to Detective



1 Chavez.

2 Q. And do you know who the -- do you know

3 that Ketsaa was the contact with Chavez other than

4 Johnson?

5 A. No, it was Ketsaa.

6 Q. Okay.

7 A. It wasn't Johnson as far as I'm aware.

8 Q. Okay. The next sentence says, "Please

9 keep in mind I am not privy to the specifics of the

10 investigation but what I do know is that

11 Sgt. Morales and L. Johnson are friends."

12 If an Internal Affairs officer has to

13 investigate somebody who's a friend, aren't they

14 supposed to give it to -- I understand you're saying

15 an investigation didn't happen, but if -- if Johnson

16 had to investigate Morales for something and they're

17 friends, shouldn't it be somebody in Internal

18 Affairs other than Johnson?

19 A. If there's an investigation, we can bring

20 in -- and one of the reasons we brought in Purcell

21 towards the end of my stay with the department, we

22 only had enough manpower for a long period of time

23 just for one individual, being Detective Johnson.

24 Once we were able to come up to speed, we started to

25 bring in extra officers.



1 But that would be the proper thing. It

2 doesn't mean that it would automatically happen. It

3 depends on staffing. And then the fact that the

4 department, a lot of these individuals have been in

5 the department such a long time, they were pretty

6 much all acquaintances with each other.

7 Q. So there would be instances where you

8 would have a friend investigating a friend because

9 you didn't have anybody else to do it?

10 A. In some cases.


12 MR. PARK: Join.

13 BY MR. COOK:

14 Q. Let me go on to the second page, the

15 second sentence. "It is a fact Sgt. Morales"

16 died -- geez.

17 "It is a fact Sgt. Morales lied during

18 questioning and Higgins who knew the truth and made

19 it known to Morales was NEVER questioned in the

20 investigation." Do you know if any of that is true

21 or not?

22 A. No.

23 Q. The next sentence talks about Morales

24 being promoted. He was promoted; correct?

25 A. Yes, sir.




2 identification.)

3 MR. PARK: This has your writing on it.

4 MR. COOK: No. It's just the old exhibit

5 number.

6 BY MR. COOK:

7 Q. I had talked to you earlier in the

8 deposition about with regard to Wamsley if she had

9 lied to you in a statement what you would do. If

10 somebody being interviewed by Metro in relation to

11 this investigation, if they lied to the police and

12 the School District had information to demonstrate

13 that they were lying, would you have an obligation

14 to give it to Metro?

15 A. Yes. That's --

16 Q. And you can't put your head in the sand

17 and pretend you don't see it?

18 A. Correct.

19 Q. I believe you have Exhibit 23 in front of

20 you. Have you taken a look through this?

21 A. Yes, somewhat. I didn't go all through

22 it.

23 Q. Have you seen this letter before?

24 A. It looks familiar. Yes, it does.

25 Q. Do you recall whether or not this was one



1 of the letters posted on Channel 8 when the story

2 first broke in July 2011?

3 A. I think it could have been.

4 Q. And do you recall the flier attached

5 being the same flier that was posted?

6 A. Yeah, I see the flier.

7 Q. I'm going to go to the front page of

8 Exhibit 23.

9 A. Uh-huh.

10 Q. Start with paragraph three, "But the real

11 tragedy is what happened after this incident and the

12 cover-up by the Clark County School District Police

13 Chief Phil Arroyo." So right out front as soon as

14 this story breaks it's about you; right?


16 Q. And at this time are you aware that

17 Robbins had already told Burgess that you were

18 involved in a cover-up?

19 A. No.

20 MR. PARK: Objection, foundation, form.


22 BY MR. COOK:

23 Q. The next paragraph, "Kevin Miranda had

24 been at a private home of a CCSD School Police

25 Dispatcher named Rebecca Wamsley . . . ." It gives



1 the address.

2 A. Uh-huh.

3 Q. It says, "This was a party involving

4 Police Dispatchers, Police Officers and others." Do

5 you see that?

6 A. Yes.

7 Q. Okay. And it's your position again that

8 you didn't know anybody there other than Quintanilla

9 and Gamboa until after the story broke?

10 A. Correct.

11 Q. How come it seems like I've got two

12 anonymous letters, I've got statements from Zuniga

13 and Gamboa to the police, I've got a written

14 statement of concern 303 from Wamsley, a statement

15 written out by Quintanilla that all have a full list

16 of people? How come you were the one that didn't

17 know anybody other than these two? I mean, were you

18 intentionally trying to separate yourself from this?


20 foundation.

21 A. No.

22 BY MR. COOK:

23 Q. I mean, do you understand what I'm

24 saying?

25 A. I understand what you're saying, but I am



1 telling you straight out.

2 Q. You're the guy in charge. How's

3 everybody know that cops were there except you?


5 foundation.

6 A. I'm telling you I did not know cops were

7 there.

8 BY MR. COOK:

9 Q. What would you have done in November if

10 you knew cops were there?

11 A. It would have taken a totally different

12 scenar- -- if I would have been informed of the

13 situation, I would have been more direct overseeing

14 the case that Metro was involved in through the

15 notification of Captain Ketsaa.

16 Q. Did you ask anybody, "It's just these two

17 guys? We don't have anybody else from our

18 department in trouble?"

19 A. No.

20 Q. "We don't have anybody else from our

21 department there?" You didn't ask?

22 A. No.

23 Q. Do you know if anybody asked?

24 A. No.

25 Q. You didn't ask whose house the party was



1 at?

2 A. No.

3 Q. Paragraph six, "Kevin drank with School

4 Police Sergeant Roberto Morales at the party and

5 other members of the School Police department."

6 Have you ever heard that before besides in this

7 letter and I think the prior letter?


9 MR. COOK: What's your foundation

10 objection?

11 MR. PARK: You said has -- has he ever

12 heard it? Is that what you --

13 MR. COOK: Has he ever heard it before.

14 MR. PARK: Oh, heard it.

15 A. Through the -- the stories in the media

16 and so forth.

17 BY MR. COOK:

18 Q. Okay. So you have heard that Morales was

19 at the party drinking with Kevin Miranda through

20 Exhibit 22 and 23 and the media reports only; is

21 that correct?

22 A. Correct.

23 Q. At any point in time when you heard them,

24 did you contact Roberto Morales and go, "Hey, is

25 this true?"



1 A. No.

2 Q. Remember at the morning session of the

3 deposition when we were talking about, "Well, if

4 there's a rumor, what I do is I bring in the guys

5 that are involved in the rumor so I can find out if

6 this is true or not"?

7 A. Uh-huh.

8 Q. We had a dead girl. Why didn't you do it

9 here?

10 A. 'Cause Metro was investigating the

11 criminal case, I was not about to interfere and

12 start asking my own questions to individuals who may

13 have been involved.

14 Q. So you didn't ask Morales ever -- as you

15 sit here today, you've never asked this guy, "Were

16 you at this party drinking with this kid?"

17 A. No.

18 Q. So because Metro is doing an

19 investigation, you may have an officer who's now

20 promoted to lieutenant who you don't know whether he

21 was drinking with a kid or not and you don't care

22 because you don't want to interfere with Metro's

23 investigation that you didn't even know if or when

24 it ended; is that correct?




1 foundation.

2 A. I didn't say I didn't care. The facts

3 remain if I would have gone in and started asking

4 all these individuals whether they were there or

5 not, now I am intoxicating the investigation that

6 Metro is involved in. And then --

7 BY MR. COOK:

8 Q. So if -- if -- if I'm a bad employee at

9 CCSD, I should do something criminal because while

10 the investigation is going on you're never going to

11 be able to talk to me about it? I mean, is -- that

12 can't be the structure, is it?

13 A. That --


15 foundation.

16 MR. PARK: Join.

17 A. That is the structure.

18 BY MR. COOK:

19 Q. Okay. And who set that structure up?

20 A. It's been in place since before I ever

21 got there.

22 Q. And is there a written policy you can

23 direct me to that says that's the way you handle it?

24 A. When there's a criminal investigation,

25 the criminal investigation goes first and --



1 Q. Okay. Is there a written policy you can

2 direct me to?

3 A. There is no -- there is no written

4 policy. It's a con- -- it's a practice.

5 Q. When's the first time you heard fliers of

6 this party were allegedly distributed around the

7 police station?

8 A. Again through the stories.

9 Q. So in paragraph eight where it says,

10 "Arroyo immediately ordered . . . all of the flyers"

11 to "be removed, collected and destroyed," you would

12 dispute that statement?

13 A. That's a lie.

14 Q. The next paragraph, "Chief Arroyo ordered

15 Sgt. Brian Nebeker to make it very clear that none

16 of the dispatchers that worked under his command

17 were to talk about, discuss or even bring up the

18 fact that there" was -- "even was a party."

19 A. That was a lie also.

20 Q. So even though it's your position that

21 nobody was allowed to talk about it because it would

22 be interfering with an investigation, you never told

23 anybody, "Don't talk about it because you'd be

24 interfering in an investigation"?

25 A. No.




2 BY MR. COOK:

3 Q. So if the dispatchers wanted to talk

4 about the party amongst themselves, that would have

5 been fine in your view?

6 A. No. If they would have discussed it and

7 it would have been brought up to our attention, at

8 that time we have to take disciplinary action.

9 Q. Why would you have taken disciplinary

10 action?

11 A. Well, disciplinary action in the sense of

12 having to correct their actions.

13 Q. Okay. But what was wrong with their

14 actions in talking about it?

15 A. Because they're all being -- they're all

16 part of an investi- -- ongoing investigation.

17 Q. Did you turn all of their names over to

18 Metro to conduct an investigation?

19 A. I -- only whatever Captain Ketsaa turned

20 over to Metro.

21 Q. Which you believe was just Gamboa and

22 Quintanilla?

23 A. Those are the names that I remember.

24 Q. Okay. So if Wamsley and Zuniga and

25 Higgins are talking about the party, do you have a



1 problem with that?

2 A. If any- -- anyone at the party or

3 pertain -- participated in the party were discussing

4 the party, yes, that would be an issue.

5 Q. But you did not direct anybody to tell

6 them not to talk about it?

7 A. No. I didn't tell anybody not to talk

8 about it.

9 Q. How are they supposed to know it's part

10 of an investigation and don't talk about it if

11 nobody tells them?

12 A. Well, again, that would fall under the

13 investigation that Metro -- Metro was conducting.

14 Q. How would Wamsley, Higgins, Zuniga and

15 Ruelas know that they could not talk about the party

16 if nobody told them they could not talk about the

17 party?

18 A. I don't under- -- I don't know to tell

19 you the truth.

20 Q. Okay. Did you direct Ketsaa to tell the

21 dispatchers that you had turned their names and/or

22 information over to Metro?

23 A. No.

24 Q. Then they don't know their names have

25 been turned over to Metro. They don't know if



1 anybody even knows about their names, and in fact

2 you didn't know about their names?

3 A. Right.

4 Q. Yet they would be disciplined for talking

5 about the party; is that correct?

6 A. Correct.

7 Q. And you never spoke to Hoffman or anybody

8 in the Legal Department about this party; correct?

9 A. Correct.

10 Q. What was the promotion Loren Johnson got?

11 A. He didn't.

12 Q. He didn't get an administrative

13 investigator position with an increase of salary?

14 A. No. He was lined up for that position

15 when the story broke, and then the Board of Trustees

16 decided to close the position and not promote him

17 based on the stories in the newspaper.

18 Q. What was the basis of creating that

19 position to begin with? In other words -- well,

20 strike that.

21 Let me ask it this way: The position

22 that was open that he was going to get that you had

23 said closed down, was the criteria for that position

24 specifically tailored for Loren Johnson?

25 A. No.



1 Q. Are you aware of anybody else besides

2 Loren Johnson who was qualified to apply for that

3 position?

4 A. There were several people that applied if

5 I'm not mistaken.

6 Q. Okay. Was there anybody besides Loren

7 Johnson that met the qualifications for that

8 position?

9 A. Oh, yes, several people.

10 Q. Who?

11 A. Any of the sergeants that were there in

12 the department met the qualifications, just -- just

13 to begin with that.

14 Q. Did you ever tell any employee of the

15 Clark County School District Police Department not

16 to talk or cooperate or communicate about the

17 Peterson investigation or the Wamsley party to any

18 third party?

19 A. No.

20 Q. Did you ever direct anyone to destroy

21 documents related to this case?

22 A. No, sir.

23 Q. If Robbins and Morales were at this party

24 and this kid gets in this vehicle and drives away

25 and kills somebody and Morales and Robbins were



1 drinking at the same table with this kid, did they

2 have an obligation to report that?

3 A. I believe if they know that he is a minor

4 and/or even as an adult if the individual is

5 impaired, morally they should have, yes, taken

6 action.

7 Q. Did you have to bring Robbins in to talk

8 to you at any time out of concern because he was

9 having a meltdown?

10 A. I had to bring in Robbins and Ruelas.

11 Ruelas, his -- his counterpart.

12 Q. When was that?

13 A. Shortly before I left the department.

14 Q. And what was the concern there? Why'd

15 you bring them in?

16 A. Basically they had been at a party and it

17 had gotten back to me through the union that they

18 had been in a verbal confrontation, so my biggest

19 worry was that her being a dispatcher and him being

20 a police officer on the same channel would impede

21 the proper practices of their responsibilities, so I

22 brought them both in and discussed it with them.

23 Q. What specifically do you mean when they

24 were having a confrontation or -- or whatever it

25 was?



1 A. Apparently leaving a party that they had

2 attended with other officers, they entered into a

3 verbal argument, and it got back to me through the

4 union, Phil Gervasi to be exact.

5 Q. So Gervasi tells you Robinson [sic] and

6 Ruelas were yelling at each other when they were

7 leaving a party, and based on that you brought them

8 in to talk to them about it to make sure everything

9 would be good from a work standpoint?

10 A. Correct.

11 Q. Did you ever bring in any of the

12 dispatchers to talk about them on some of the

13 dysfunction I've heard about in the dispatch

14 department?

15 A. No.

16 Q. When you received the document, the 303

17 report, from Rebecca Wamsley, did you ask anybody to

18 turn over those additional names to Metro for their

19 investigation?

20 A. What 303?

21 Q. If you'll hand them to me, I'll find it

22 in your exhibits pretty quickly.

23 Exhibit 11.

24 A. I don't remember. I'll be very sincere.

25 Q. Who decided whose names then got turned



1 over to Metro?

2 A. The information that Nebeker provided

3 Ketsaa and I, whatever information he had at the

4 time Ketsaa provided to them.

5 Q. And did you understand that they told you

6 all the information they had?

7 A. No.

8 Q. So you don't know if they were giving you

9 part of it, all of it or some piecemeal version of

10 the story?

11 A. When I directed Ketsaa to pass on the

12 information to Metro, I was under the impression

13 that he would give them all the information we had.

14 Q. Right. But did you understand that you

15 had been given all the information he had?

16 A. At that particular time first thing in

17 the morning, yes, sir.

18 Q. And did you understand, was it clear that

19 your instruction to Ketsaa was, "Whatever

20 information you have, turn it over to Metro," or was

21 it less clear where Ketsaa might have thought, "The

22 information I have right now I turn over, but if I

23 get anything new, I get to keep it"?

24 A. No. I made it very clear, "Any

25 information that we can provide Metro, we're here to



1 assist them."

2 Q. And then you never talked to Ketsaa about

3 it again until after the story broke; correct?

4 A. Pretty much, yes, sir.

5 Q. And what were the circumstances that you

6 and Ketsaa talked about it again?

7 A. In passing in the office from what I

8 remember.

9 Q. That's it, just in passing?

10 A. Correct.

11 Q. Did you ever pull Loren Johnson in and

12 say, "Hey, this letter says about as much about you

13 as about me. Is it true?"

14 A. I remember him mentioning something, but

15 we didn't get into the details of it.

16 Q. Did you ever speak to Captain Goodwin

17 about the DUI case?

18 A. No.

19 Q. As you sit here today, do you know if

20 Robert Morales was in uniform while he was at that

21 party?

22 A. No.

23 Q. Do you know if he was on call?

24 A. No.

25 Q. Do you know if he drove a police vehicle



1 there?

2 A. No.

3 Q. Would any of those things been

4 appropriate to end up with a drink in your hand at a

5 party?

6 A. Not at all.

7 MR. COOK: We got just a couple minutes

8 left on tape. It's a good time to take a break.

9 THE VIDEOGRAPHER: This concludes disk

10 number four in today's videographed deposition of

11 Filiberto Arroyo. The approximate time, as

12 indicated on the video screen, 1557 hours. We are

13 off the record.

14 (Recess taken.)


16 record. This is the beginning of disk number five



19 video screen, 1607.

20 BY MR. COOK:

21 Q. Sir, I've just got some follow-up, so I'm

22 going to kind of be all over the place.

23 A. Okay.

24 Q. Not that I haven't already been, but a

25 little more so.



1 Penny Higgins, her interview to the news

2 in August 2011 that was aired, if she was still a

3 dispatcher at the time that was aired and you were

4 still chief of police, you would have then

5 disciplined her for giving that interview because

6 there was a police investigation pending; is that

7 correct?

8 MS. HENDRICKS: Objection as to form,

9 misstates prior testimony.

10 A. I would have basically notified Metro of

11 the information she was providing and notified EMR

12 regarding the statement that she provided. It would

13 be up to the District to handle that.

14 BY MR. COOK:

15 Q. And what would you have notified EMR

16 with, what specific information or what specific

17 request?

18 A. The specific information that she had --

19 you know, she had basically given that information

20 to the media.

21 Q. During a police investigation?

22 A. Correct.

23 Q. And that you do not find that conduct

24 appropriate or acceptable or -- or something of that

25 nature?



1 A. Well, it's not that --


3 A. Correct. It's not that I don't find the

4 conduct a- -- it's part of a criminal investigation

5 and -- and in that point of view it needed to be

6 addressed as far as the -- the violation of the

7 confidential information she was providing.

8 BY MR. COOK:

9 Q. So is it your position that if there's a

10 criminal investigation going, there's sort of a gag

11 order in effect where your employees are not allowed

12 to talk to anybody about anything regarding that

13 matter?

14 A. There's not a gag order. I would notify

15 EMR, the proper -- the proper entity within the

16 District to address the issue with a civilian

17 employee.

18 Q. There's not a gag order, but you would

19 write then EMR to see if she could be disciplined or

20 would be disciplined for that?

21 A. It would be their -- their

22 responsibility. It would be their determination

23 based on their policy of their union contract as to

24 what needed to be addressed.

25 Q. Okay. But by sending it to EMR, you're



1 essentially asking them to act. If they do

2 something appropriate in the workplace, you don't

3 send everything they do every day to EMR; right?

4 A. Well, not to act, but basically to

5 evaluate the situation based on the employee,

6 responsibility, job description, contract and so

7 forth.

8 Q. Okay. If an employee is acting

9 appropriately, has a day at work where they do

10 everything, handle their calls right and do

11 everything right, you've got nothing to send to EMR;

12 correct?

13 A. Correct.

14 Q. It is only when they do something that

15 you believe is questionable in nature and needs to

16 be looked into that you send it to EMR; correct?

17 A. Correct, sir.

18 Q. And in the instance in the example of

19 Penny Higgins, that action would be talking to the

20 news media about the events of the party; correct?

21 A. Uh-huh, yes.

22 Q. You said you met with Dwight Jones. I

23 think we narrowed the estimate down to five to ten

24 times. We talked in detail about the first two, and

25 I believe your general testimony about the remaining



1 ones was it was substantively the same information;

2 is that correct?

3 A. Yes, sir.

4 Q. Okay. Give me a time frame of when the

5 balance of those conversations occurred through.


7 Q. Okay. I've got conversation one sometime

8 the end of July 2011.

9 A. Uh-huh.

10 Q. Conversation two sometime the beginning

11 of August 2011.

12 A. Okay.

13 Q. Conversations three through five or three

14 through ten occurred in what time frame?

15 A. Within weeks of each other. We would at

16 least see each other at least a minimum of once a

17 week for sure at the cabinet meetings. We also met

18 at a -- at a Starbucks one -- one afternoon. There

19 was several meetings over the course of time.

20 Q. The Starbucks, was it to specifically

21 talk about the Peterson death, the Wamsley party?

22 A. No.

23 Q. A number of items were discussed at that?

24 A. Excuse me?

25 Q. Were a number of items discussed at that



1 meeting?

2 A. We discussed, yes, several items.

3 Q. Okay. Among them was either the Wamsley

4 party or Angela's death?

5 A. No.

6 Q. Okay. So when you had testified earlier

7 that you had talked to him about five to ten times,

8 I take it then that was not limited to conversations

9 about Wamsley or Angela?

10 A. Correct.

11 Q. All right. How many times did you talk

12 to him about Wamsley and/or Angela besides the two

13 we have already discussed?

14 A. It may have come up another maybe three

15 more times during the course of our conversation in

16 passing.

17 Q. So those were short, in-passing

18 conversations?

19 A. Correct.

20 Q. Can you give me an example of one.

21 A. One of the scenarios, I was in his

22 office. One of the last stories had come out in the

23 media, and again I had asked him pertaining to the

24 specifics being mentioned in that particular article

25 if we could come up with a statement, if he would



1 allow me to come up and just, you know, present our

2 side, and again he stated no.

3 Q. Okay. I thought you testified earlier

4 that that was in the conversation while Gillespie

5 was there because you even asked Gillespie what he

6 thought about it before you went into the meeting,

7 so is that true?

8 A. I don't understand what you're saying.

9 Q. Okay. As I recall your testimony from

10 this morning, you had said before the meeting at the

11 Cleveland Clinic with Gillespie and Jones you asked

12 Gillespie what he thought about --

13 A. Uh-huh.

14 Q. -- you making a statement; correct?

15 A. Correct.

16 Q. What I'm trying to find out now is: Did

17 you then ask Jones on two separate occasions, "Can I

18 make a statement?" Or in spite of talking to

19 Gillespie about it at that time did you not ask him

20 at that time, just the later time?

21 A. No, I actually -- yeah, I actually asked

22 him on two separate occasions besides the time that

23 we met with Gillespie.

24 Q. Okay.

25 A. Yeah.



1 Q. And when was the last of these series of

2 conversations you had with Jones about Angela

3 Peterson and/or the Wamsley party and/or the

4 allegations of a cover-up?

5 A. I guess it was up until the time I

6 separated, around September I would assume.

7 Q. And you talked about this office being

8 filled with rumors. Did you not hear any of the

9 rumors about a cover-up until the story broke?

10 A. Correct.

11 Q. From the time the story broke alleg- --

12 yeah, alleging a cover-up to the time you first met

13 with Jones, a few days had passed. Did you take any

14 action in those few days to investigate the

15 cover-up?

16 A. No.

17 Q. Why not?

18 A. I found there was no reason to follow

19 through with that direction since they're implying

20 that I had been covering up the investigation, which

21 I wasn't.

22 Q. So therefore, you dismissed the

23 allegations of the anonymous letter in its entirety?

24 A. And I wanted to share the information

25 with Jones, yes.



1 Q. So you dismissed the allegations of the

2 letter in its entirety at that time?

3 A. Correct.

4 Q. Were you aware that Brian Nebeker for a

5 time had picked his son up from school in a

6 department vehicle?

7 A. No.

8 Q. Were you aware that Belinda Brown did it?

9 A. Yes.

10 Q. Belinda Brown was essentially terminated

11 for it; is that correct?

12 A. She was allowed to retire. She was not

13 terminated.

14 Q. She wouldn't have had to make the choice

15 as to being allowed to retire if she didn't get

16 caught picking up her kid in her company vehicle,

17 though; correct?

18 A. It was a little bit more complicated than

19 that. She was actually picking up the vehicle,

20 taking it home and not going off to her area of

21 patrol, and then she would take her one child to the

22 public school, come back home, take another nephew

23 or niece to a private school, so there was more than

24 just taking the kids to and from. And she was

25 allowed to retire.



1 Q. I talked to you earlier in the deposition

2 about whether Mike Thomas was trying to coerce

3 you --

4 A. Uh-huh.

5 Q. -- I believe was the phrase you used;

6 correct?

7 A. Yes.

8 Q. Okay. What time frame was it where he

9 was trying to somehow coerce you into becoming a

10 sergeant?

11 A. It was just before I left, if I'm not

12 mistaken, to the FBI Academy.

13 Q. And when did you go to the FBI Academy?

14 A. I left March 20th -- 29th. I'm sorry.

15 Q. Of 2011?

16 A. Yes. Yeah.

17 Q. What was he trying to coerce you with?

18 In other words, what he wants out of it is to become

19 a sergeant. What is he telling you, "If I'm not a

20 sergeant, this is what you should be concerned about

21 happening"?

22 A. It never went further than that. He

23 started calling my home, then text messaging me

24 letting me know that he -- as to why he should be a

25 sergeant, how he should have qualified to be a



1 sergeant. He wanted to talk to me in private, meet

2 someplace else, anywhere away from the station, that

3 kind of scenario.

4 Q. So he didn't actually at any point say,

5 "If you don't make me a sergeant, this is the

6 problem"?

7 A. Correct.

8 Q. He just basically nagged you about being

9 a sergeant and at some point you said, "Enough,"

10 and --

11 A. Correct.

12 Q. And no one ordered you, directed you or

13 implied to you to stay out of this investigation?

14 A. No.

15 Q. And you never ordered or implied or

16 suggested to anybody not to investigate?


18 Q. Under -- anybody under you, Ketsaa,

19 Johnson, any of the people that normally would have

20 investigated an Internal Affairs type of action.

21 A. Yes, I never gave the order to commit to

22 an investigation.

23 Q. As you sit here today, what is your

24 understanding as to what happened at that party at

25 Wamsley's house? I'm not talking about 2009. I'm



1 talking about -- not talking about when the story

2 first broke. As you sit here today, what's your

3 understanding as to what happened?



6 A. Based on the information that's been

7 presented over the course of this time, there was a

8 party and there was alcohol being served and this

9 young man acquired alcohol. Based on the other

10 statements from other people, that officers and

11 dispatchers were aware, and he was allowed to leave

12 the premises as is and was involved in a vehicular

13 accident, which took the life of Angela.

14 MR. COOK: Okay. I don't have anything

15 else. Thank you.

16 EXAMINATION

17 BY MR. PARK:

18 Q. I just have a few questions. My name's

19 Matt Park. I represent Robbins, Ruelas, Zuniga and

20 Morales defendants.

21 First off, you weren't at the Wamsley

22 party in 2009; correct?

23 A. No, sir.

24 Q. Okay. And have you ever had any

25 conversations with Tina Zuniga about the facts and



1 circumstances surrounding that party or this

2 lawsuit?

3 A. No, sir.

4 Q. Have you ever had any conversations with

5 Cynthia Ruelas concerning the facts and

6 circumstances surrounding that party or this

7 lawsuit?

8 A. No, sir.

9 Q. Okay. I believe you also testified

10 earlier today that you worked with Mark Robbins when

11 he was at the department. Is that correct?

12 A. Yes.

13 Q. What's your opinion of Robbins as a

14 police officer?

15 A. He was a fair police officer.

16 Q. Uh-huh. Did you find him to be a

17 truthful police officer while you were there?

18 A. I never found any reason not to believe

19 he wasn't.

20 Q. You had a discussion previously with

21 counsel about where he read Burgess's testimony

22 where Burgess had said that he had this conversation

23 with Robbins about an alleged cover-up. Do you

24 remember that?

25 A. Yes, sir.



1 Q. And I believe you said that you -- again,

2 don't let me misstate your testimony, but I believe

3 you said that you thought Burgess was telling the

4 truth if Robbins ever said he had that conversation

5 with you because the conversation never happened; is

6 that accurate?

7 A. Yes, sir.

8 Q. Okay. And while Robbins hasn't given

9 his -- his deposition testimony in this matter, if

10 Robbins agreed with you that the conversation never

11 happened, Robbins would be telling the truth;

12 correct?

13 A. Correct, sir.

14 Q. And Burgess would be lying?

15 A. Correct.

16 Q. Okay. I want to talk to you a little bit

17 about the Facebook post -- I'm not sure what exhibit

18 it is -- from Robbins.

19 MS. HENDRICKS: I had all these all in

20 order. Exhibit 21.

21 MR. PARK: Thank you.

22 BY MR. PARK:

23 Q. You've never seen that before today;

24 correct?

25 A. Correct, sir.



1 Q. And you've never had any conversation

2 with Mark Robbins about that post?

3 A. No, sir.

4 Q. Is that right?

5 A. No, sir. That's correct, yeah.

6 Q. And I believe you testified earlier today

7 that if you saw this post you would be concerned and

8 would possibly refer it to Internal Affairs. Is

9 that accurate?

10 A. Well, we would look into it regarding the

11 actual content on the Facebook account.

12 Q. Okay.

13 A. Yeah.

14 Q. And one of the things you would do would

15 be to look up NRS 283.143; is that right?

16 A. Well, above other things, yes.

17 Q. And see what it says?

18 A. Correct.

19 Q. Okay. Do you even know if NRS 283.143 is

20 a real statute?

21 A. If I -- if I'm familiar with 283, I think

22 it has to do with the law enforcement capability.

23 Q. And but you don't know specifically

24 whether 283.143 is a real statute, is it?

25 A. No, I can't tell you right off the top.



1 Q. Okay. And if it were a made-up statute,

2 would that be reason to refer Mark Robbins to

3 Internal Affairs for this post?

4 A. No. It would be something -- that would

5 be one of the first things you have to assess --

6 Q. Right.

7 A. -- basically what the statute stands for.

8 Q. So if it were a made-up statute, if it

9 were in effect NRS kajillion bajillion and it were a

10 made-up NRS statute, there's no procedure that he's

11 violating by posting that; right?

12 A. Correct.

13 Q. And let's see. What about Sergeant

14 Morales, did you ever work with Sergeant Morales

15 while you were at the Police Department?

16 A. Yes, sir.

17 Q. What's your opinion of Sergeant Morales

18 as --

19 A. He was a good -- good police officer.

20 Q. I'm sorry?

21 A. He's a good police officer.

22 Q. He's a good police officer. Do you have

23 any reason to believe that he was ever untruthful

24 when he was performing his duties?

25 A. No, sir.



1 Q. I believe you learned during the course

2 of your deposition that he's now been promoted to

3 lieutenant.

4 A. Correct.

5 Q. Do you believe that based on your

6 experiences with -- with Sergeant Morales that he

7 would be capable of performing the duties of -- of a

8 lieutenant?

9 A. Very capable, yes, sir.

10 Q. Any concerns about his ability to fulfill

11 his duties as a police officer?

12 A. No, sir.

13 MR. PARK: I don't have anything else.

14 EXAMINATION

15 BY MR. KELLER:

16 Q. I just have a few follow-up questions.

17 Good afternoon, sir. My name is Chris Keller, and I

18 represent Kevin Miranda and --

19 THE VIDEOGRAPHER: Wait, hold it. Yeah,

20 go ahead and set the mike down.

21 MR. KELLER: Sorry.

22 BY MR. KELLER:

23 Q. I represent Kevin Miranda and his parents

24 in the lawsuit that you're a defendant. I have just

25 some general follow-up questions for you.



1 First of all, I'm just not sure I

2 understand your testimony. I want to be very clear

3 today.

4 Did Rebecca Wamsley have a duty as an

5 employee of the dispatch unit within your -- within

6 the Clark County School District not to have a party

7 where beer pong would be served?

8 A. Could you repeat the question. I'm

9 sorry.

10 Q. Did she have a duty not to have a party

11 where beer pong would be served?

12 A. No.

13 Q. Okay. Did she have a duty not to have

14 alcohol served at a party where minors were present?

15 A. Correct.

16 Q. Okay. And that duty, is it a moral duty,

17 in your eyes, or is this actually a duty that we can

18 look to somewhere, you can say, "This is her duty.

19 She violated Code XYZ of the School District Code of

20 Conduct or otherwise"?

21 A. No, she -- she basically had a duty.

22 She -- it's not a duty. I mean, it's her right to

23 have a party at her home and have beer pong

24 festivities at her home if that's the question.

25 Q. But are there any Codes of Conduct where



1 you can say to me, "Wamsley, when she had this party

2 and she allowed Kevin Miranda to drink or at least

3 alcohol to be served and for him to sneak it or

4 otherwise" -- I mean, you haven't heard his

5 testimony, but, "When she allowed this to take

6 place, she violated this Code of Conduct or this

7 rule or this whatever," so we can say, "Yes, she

8 violated a School District code or otherwise"?

9 A. No, we don't.

10 Q. So you're just speaking in moral terms?


12 Q. Now, what about Robbins? Robbins, if

13 he's there as a police officer, what code did he

14 violate by being at a party where a minor allegedly

15 snuck drinks or otherwise?

16 MR. COOK: Well, objection, misstatement

17 unless you want to take out "snuck."

18 MR. KELLER: You know, I -- how I

19 characterize it is snuck, and that's my

20 characterization. You're right.

21 BY MR. KELLER:

22 Q. Mr. Miranda testified in a certain

23 fashion that I interpreted to be sneak. He was

24 having drinks and trying to hide them, is what he

25 said, but I'm just saying he drank while he was at a



1 party with Mark Robbins allegedly there.

2 A. Okay.

3 Q. So what code did -- or conduct, morality

4 or otherwise did Mark Robbins violate as a police

5 officer, not the dispatchers, but the police

6 officers?

7 A. Oh, as a police officer, if you're aware

8 that -- that you have a minor that's actually

9 intoxicated or drinking from alcoholic beverages

10 that he's acquiring, he's impaired, he failed to

11 notify the proper authorities, failed to notify the

12 homeowner and try and prevent this individual from

13 leaving the home.

14 Q. I'm just trying to find out because

15 obviously his, you know, Kevin's, parents may be

16 interested to know that there's a code that Mark

17 Robbins violated when this allegedly occurred, and I

18 want to know where I can look to find this code.

19 A. It's basically -- it's basically moral

20 conduct.

21 Q. Okay. Is there a moral conduct code that

22 you can point me to and say --

23 A. It's -- it's a general moral conduct. It

24 doesn't specifically detail the specifics of what

25 you're pertaining to as a law enforcement officer.



1 Q. And does it affect your answer if -- if

2 Mr. Robbins was in his police uniform as opposed to

3 just a guest at someone else's party?

4 A. It would definitely take it to the next

5 level, yes, sir.

6 Q. Okay. And you don't know as we sit here

7 today whether he was or wasn't?

8 A. No, sir.

9 Q. But there isn't a code that I can look to

10 and say, "You know what? He violated a sworn duty

11 he had not to be present at a party where a minor

12 was drinking and allow that minor to leave while

13 drunk"?

14 A. There -- yeah, there's no actual written

15 verbatim code per se.

16 Q. The investigation of the accident of

17 Angela Peterson, whose responsibility was it?

18 A. It was handled by Metro.

19 Q. Okay. Let's just speak in hypothetical

20 terms. Let's start from the beginning and you did

21 receive more information than you've testified here

22 today that you received. What if you'd received

23 more information that other people were there at the

24 party who you didn't know about?

25 A. Uh-huh.



1 Q. Could you have started an investigation

2 given that Ms. Peterson was dead and Metro was

3 investigating?

4 A. We would have passed on the information

5 to Metro.

6 Q. Could you have started an Internal

7 Affairs investigation when there's a Metro

8 investigation currently pending?

9 A. Basically what we would have done is open

10 up a folder, given it a case number at Internal

11 Affairs, and then once Metro would have completed

12 their case, we would begin from there.

13 Q. What would you have done to, for example,

14 the person who held the party, Ms. Wamsley? Would

15 she have been disciplined for holding the party

16 where a minor consumed alcohol and then got in the

17 accident?

18 A. We would have passed on the information

19 to EMR. It would have been up to the District to

20 investigate.

21 Q. What about Robbins, who was present at a

22 party -- I'm sorry, Penny Higgins, who was present

23 at a party, watched a minor drink and actually may

24 have had -- seen him drink a beer from her cooler?

25 Would she have also faced possible disciplining for



1 those activities?

2 A. Yes, sir.

3 Q. And so that would have occurred after the

4 conclusion of the Metro investigation?

5 A. Yes, sir.

6 Q. And you wouldn't have done anything

7 before then?

8 A. No, sir.

9 Q. Do you make your investigations public?

10 Do you -- do you turn over your reports to the

11 victims of the families, for example, internal

12 investigation reports?

13 A. No. It's personnel matters.

14 Q. That's subject to the District -- excuse

15 me, the -- the Clark County School District's

16 protocols and such?


18 Q. And you yourself, you had no involvement

19 with tearing down fliers or ordering anyone to tear

20 down fliers?

21 A. No, sir.

22 Q. Do you know why you're sued in this

23 lawsuit?

24 A. Why?

25 Q. Yes.



1 A. Because the allegations presented that I

2 participated in these actions.

3 MR. KELLER: That's all the questions I

4 have.

5 MR. COOK: I've got some follow-ups.

6 EXAMINATION

7 BY MR. COOK:

8 Q. If Officer Robbins and Morales are

9 sitting across a table -- I think it was a card

10 table, is what they testified to, or some kind of a

11 folding table set up -- while Miranda testified that

12 he had Jack Daniel's mixed with Coke in his drink,

13 refilled it and came back to the table and drank,

14 went over to the beer pong table with his Jack

15 Daniel's, played beer pong with Tina Zuniga, who's a

16 dispatcher, Cynthia Ruelas, who's a dispatcher, and

17 Mark Robbins, who's a police officer, was standing

18 there filling up the cups, is that appropriate

19 police behavior in any manner?

20 A. No, sir.



23 MR. PARK: Objection, form, foundation, I

24 believe it misstates prior testimony.




1 MR. COOK: It's actually a hundred

2 percent of what the testimony is, and if you want,

3 I'll read it.

4 MR. KELLER: That wasn't Kevin Miranda's

5 testimony.

6 BY MR. COOK:

7 Q. Miranda's testimony so you understand,

8 sir, is, "I had mixed drinks. I had four shots of

9 Jack Daniel's and I had beer," and he had all three

10 and each separately. He gave about five different

11 versions of what he had, and the bottom line is he's

12 too drunk to remember what he had.

13 Would you expect your officer to be able

14 to recognize somebody who was that drunk sitting

15 across the table from them for hours?


17 MR. KELLER: Join.

18 MR. PARK: Mischaracterizes prior

19 testimony.


21 A. Based on their experience, they should be

22 able to recognize.

23 BY MR. COOK:

24 Q. And they shouldn't be participating in

25 the drinking by sitting across the table and



1 drinking with him, should they?



4 A. If they know for a fact he's a juvenile,

5 no.

6 BY MR. COOK:

7 Q. Well, how about the fact that Robbins had

8 met Miranda previously at Tina Zuniga's house with

9 Cynthia Ruelas, does that help you understand that

10 he knew who Miranda was prior to this party?


12 A. Yes, sir.

13 BY MR. COOK:

14 Q. Okay. And certainly he shouldn't be

15 participating in Miranda's drinking by watching him

16 play beer pong and filling up cups, should he?


18 A. Correct.

19 BY MR. COOK:

20 Q. Okay. And if you knew about any of that,

21 you would have handled this much differently?

22 A. Yes, sir.

23 MR. COOK: All right. I don't have

24 anything else for you. Thank you.

25 \\\



1 EXAMINATION

2 BY MR. KELLER:

3 Q. Just -- just to be clear, I just want

4 to -- and I don't mean to belabor this, but the

5 things that you would have done differently was open

6 a file and then do nothing until the Metro report

7 was finished; right? I mean, that's what I'm trying

8 to understand. What would you have done

9 differently?

10 A. Well, administratively I would have

11 opened the folder and passed on all the information

12 that was brought to my attention to Metro so they

13 can conduct their follow-through. Realistically I

14 believe Metro failed to do the proper follow-through

15 when they received the information that we provided

16 them.

17 MR. PARK: And I have a follow-up too.

18 MR. COOK: Go ahead, go ahead, go ahead.

19 EXAMINATION

20 BY MR. PARK:

21 Q. And when you were answering Mr. Cook's

22 questions about these hypotheticals about what had

23 happened, if there were these police officers

24 sitting at the same table with Miranda drinking,

25 you're basing your answers on the assumption that



1 they knew that Miranda was drinking alcohol at the

2 time; correct?

3 A. Correct, sir.

4 Q. Okay. And if they didn't know that

5 Miranda was drinking alcohol at the time, would you

6 have a different answer?

7 A. Most definitely.

8 Q. Yeah, because they wouldn't know what to

9 stop; correct?

10 A. Correct.

11 MR. PARK: Okay.

12 EXAMINATION

13 BY MR. COOK:

14 Q. All right. Minimally you would have made

15 sure Metro knew that you had somebody in your office

16 prepared to testify that Robbins was drinking with

17 him and Morales was drinking with him and Zuniga and

18 Ruelas and Robbins were playing beer pong with him;

19 correct?

20 A. Yes, sir.

21 MS. HENDRICKS: Objection as to form,

22 incomplete hypothetical.

23 MR. PARK: Join.

24 BY MR. COOK:

25 Q. Okay. So you don't have to know for a



1 fact. What you're saying when I asked if you would

2 handle it differently is if you had that information

3 you'd have made sure Metro had that information. I

4 think you also said you would have stayed more

5 actively involved to make sure they stayed up to

6 date?

7 A. Yes, sir.

8 Q. Okay. But the information you were given

9 was limited to -- from December 2009 to Janu- -- the

10 end of January 2011, the information you were

11 limited to was Andrea Gamboa and Armando Quintanilla

12 were at a party where a guy showed up, left and

13 killed a girl?

14 A. Correct.

15 Q. Okay. Knowing that that's all you knew,

16 you think you handled it appropriately?

17 A. At that particular time, yes, sir.

18 Q. You don't think Metro handled it

19 appropriately?

20 A. I believe they could have done a much

21 better job.

22 Q. Knowing all the information that came

23 out, though, and I -- and knowing you didn't know

24 it, who dropped the ball at the Clark County School

25 District Police Department then?




2 foundation.

3 A. In regards to?

4 BY MR. COOK:

5 Q. Well, I've got testimony that says

6 Miranda's drinking with Robbins and Morales for an

7 extended period of time at a table and he's playing

8 beer pong with Zuniga and Ruelas and Morales is

9 there -- I mean, Robbins is there, and by the way,

10 the only thing Miranda said he did to hide the fact

11 that he was drinking is he put it in a red Solo cup,

12 which by the way is the same cup everybody put their

13 drinks in, so he didn't do essentially anything to

14 hide his drinking.

15 MR. PARK: Objection, misstates prior

16 testimony, and I guess is there a question pending?

17 BY MR. COOK:

18 Q. Okay. With that information, who dropped

19 the ball at the School District that Metro didn't

20 find that out or somebody at the School District

21 didn't convey that allegation to them?


23 A. I don't -- I don't understand as far as

24 who dropped the ball.

25 \\\



1 BY MR. COOK:

2 Q. If George Knapp can find this stuff out,

3 what's going on at Clark County School District, if

4 I can find out what's going on, somebody at the

5 School District reasonably should have known if they

6 didn't stick their head in the sand. Is that fair?


8 A. It's to some degree.

9 BY MR. COOK:

10 Q. Okay. So if not you because you didn't

11 get the info, who's that guy?

12 A. Well, realistically the information that

13 came directly from the dispatchers through the chain

14 of command via the dispatch supervisor via the

15 sergeant and then to -- to Captain Ketsaa, who was

16 the intermediate with the Metropolitan Police

17 Department conducting the investigation.

18 Q. So that's the way it rolls all the way up

19 that chain to there; is that correct?

20 A. Correct.

21 MR. COOK: Okay. For now I don't have

22 anything else.

23 MR. PARK: I don't think I have anything

24 else.

25 MR. COOK: All right. Thank you, sir.



1 THE VIDEOGRAPHER: Please stand by. This

2 concludes today's videographed deposition of

3 Filiberto Arroyo, consisting of five disks. Master

4 disks will remain in the custody of Oasis Reporting

5 Services.

6 The approximate time, as indicated on the

7 video screen, 1638. We are now off the record.

8 (Deposition recessed at 4:38

9 p.m.)

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25



1 CERTIFICATE OF WITNESS

2 PAGE LINE CHANGE REASON

3 ____________________________________________________

4 ____________________________________________________

5 ____________________________________________________

6 ____________________________________________________

7 ____________________________________________________

8 ____________________________________________________

9 ____________________________________________________

10 ____________________________________________________

11 ____________________________________________________

12 ____________________________________________________

13 ____________________________________________________

14 ____________________________________________________

15 ____________________________________________________

16 ____________________________________________________

17 ____________________________________________________

18 ____________________________________________________

19 * * * * *

20 I, FILIBERTO ARROYO, witness herein, do hereby certify and declare under penalty of perjury

21 the within and foregoing transcription to be my deposition in said action; that I have read,

22 corrected and do hereby affix my signature to said deposition.

23

24 _________________________________ __________ FILIBERTO ARROYO

25 Witness Date



1 REPORTER'S CERTIFICATE

2 STATE OF NEVADA )

3 ) ss COUNTY OF CLARK )

4

5 I, William C. LaBorde, a duly certified court reporter licensed in and for the State of Nevada, do

6 hereby certify:

7 That I reported the taking of the deposition of the witness, FILIBERTO ARROYO, at the time and

8 place aforesaid;

9 That prior to being examined, the witness was by me duly sworn to testify to the truth, the whole

10 truth, and nothing but the truth;

11 That I thereafter transcribed my shorthand notes into typewriting and that the typewritten

12 transcript of said deposition is a complete, true and accurate record of testimony provided by the

13 witness at said time to the best of my ability.

14 I further certify (1) that I am not a relative, employee or independent contractor of

15 counsel of any of the parties; nor a relative, employee or independent contractor of the parties

16 involved in said action; nor a person financially interested in the action; nor do I have any other

17 relationship with any of the parties or with counsel of any of the parties involved in the action that

18 may reasonably cause my impartiality to be questioned; and (2) that transcript review pursuant

19 to FRCP 30(e) was requested.

20 IN WITNESS WHEREOF, I have hereunto set my hand in the County of Clark, State of Nevada, this

21 21st day of July 2013.

22

23 _____________________________________ William C. LaBorde, CCR 673, RPR, CRR

24

25

WORD INDEX

< , >, 155:24

< 0 >000043-045 5:3000047-048 4:14000057 4:2000037 6:8002-13 4:21007-12 4:1509 136:1 159:8

< 1 >1 3:16 23:9 29:18 68:6 123:12 138:23 287:141.152 68:810 4:5, 15, 18 119:14 120:16, 24 121:3 123:12 124:5, 16, 19 166:18 201:710:00 155:5, 710:06 58:2110:17 59:3100 3:23102 6:111032 146:25106 3:23109 4:211 4:7, 21 62:12 120:12, 20, 22 122:5, 12 123:12 128:21 145:23 159:8 166:22 167:1 221:22 251:2311:07 100:1511:11 100:2111:51 129:2011-29-09 4:9115 4:2117 4:5119 3:20 4:512 4:9 24:11 124:5 151:3, 6 154:2 200:19

120 4:7122 3:20129 3:2013 4:12 160:24 195:19130 151:111302 130:614 4:12 167:161413 187:131422 187:2015 4:15 170:221503 218:16151 4:91511 218:20152 63:12, 22 68:6,111557 254:1216 4:15 74:15 124:16, 19 172:6 229:6160 4:121607 254:191638 285:7167 4:1217 4:2, 18 5:2 174:7170 4:15172 4:15174 4:18177 4:21178 4:21179 4:2117th 122:20 147:1418 4:21 148:13 177:118th 170:1419 4:21 18:24 178:14190 4:211993 9:161994 9:22 11:1919th 74:24

< 2 >2 3:18 30:21 124:5, 16, 19 172:18 224:8, 25 287:182:11-cv-01919-LRH-RJJ 1:4 6:14

20 4:21 179:17 187:7 207:32000 20:4, 52002 20:182003 20:18, 19 22:122005 20:11 22:14,18, 19 200:112007 157:11, 142008 3:20, 23 101:32009 4:5 84:16 85:1 86:3, 15 89:11 128:8 146:1, 24 153:20 154:9 155:2, 14 156:12 157:21 158:16 159:7, 10 167:2 209:10 210:23 211:13, 17 228:6 264:25 265:22 282:92010 3:23 4:2, 7 108:16 122:20 147:14 148:8, 9 150:15, 18 157:15,19, 24 159:6 167:3 201:15 210:222011 3:17 4:2, 5,12, 15, 18 5:2 31:11 45:25 46:12 47:10 50:11, 12 57:13 62:12, 13 75:13 84:17 86:5, 9 128:9 135:19 136:6 143:1, 15, 20 146:2 147:4 153:11, 25 154:15 158:2, 22, 22 160:9,11 170:14 175:16 176:4, 13 190:10,18 199:21 201:24 202:1 206:15 208:18 223:14 224:16 225:9, 13 226:8 227:13 228:4 229:20 230:6, 15 231:4, 20 232:3 239:2

255:2 258:8, 11 263:15 282:102012 4:21 74:242013 1:18 4:15 6:3 287:2120th 263:1421 3:17 4:2, 21 66:13 172:19 190:21 267:2021st 45:23 226:8 287:2122 5:2 222:20, 23 224:25 227:5 242:202200 155:6, 7222 5:223 5:4 238:1, 19 239:8 242:20238 5:424 15:2025 24:14 62:18 64:8 207:325th 40:242620 6:10265 3:526th 45:24270 3:6277 3:727th 93:2228 146:24280 3:8, 9281 3:10283 268:21283.143 268:15, 19,2429 3:16 14:10 154:9 159:829th 154:3 263:14

< 3 >3 3:18 64:15 224:2530 3:18, 20, 23 4:5 46:13 287:19303 146:5 183:9 240:14 251:16, 2030th 101:3 159:1031 4:1835 52:25 131:53-5 146:5

360 215:223773 2:93993 2:14

< 4 >4 3:20 4:5 5:4 93:64:38 285:840 52:25 131:5 138:19400 2:940-minute 131:1441 138:20, 2344 227:44th 206:15

< 5 >5 3:23, 23 24:11 100:17, 23 220:21517 1:21 2:4 6:55th 108:16

< 6 >6 3:23 106:2460 65:5600 2:14, 1964 3:1865 23:9673 1:24 287:236734 1:25

< 7 >7 3:4 4:2, 7, 15 109:14, 17701 2:197-18-11 4:127th 157:24 159:7

< 8 >8 1:18 4:2 6:3 24:12 115:20 239:183 10:785 3:20 14:15, 1986 10:2287 3:2089101 2:4, 20 6:689128 6:1189169 2:10, 15

< 9 >

9 4:5, 12 117:20 221:149:06 1:20 6:390 3:209000 193:791 3:20 14:14, 16,1893 3:20 10:694 3:20 10:6, 7 12:9, 22 17:12 19:2195 14:3, 2196 14:3, 21 20:39-millimeter 179:8

< A >a.m 1:20abide 215:23ability 220:14 270:10 287:13able 56:23 63:24 65:2 97:5 98:13,21 101:15 167:12 176:21 200:22 204:21 236:24 244:11 278:13, 22Absolutely 40:20,22 164:1Academy 32:16 263:12, 13acceptable 158:15 255:24accessed 171:22accident 15:10, 12,18 64:9 65:1 78:1, 11, 20 82:10 128:4, 8 149:2 153:22 154:11 155:17 157:12 174:23 188:11 228:8 229:16 265:13 274:16 275:17accidents 64:21accompanying 127:16accord 96:10account 180:13 225:5 268:11accounting 29:11

accounts 101:24 108:2, 7, 23accreditation 108:13 171:6 193:21 207:8accumulating 198:14accurate 51:12 127:17 128:10 141:6 161:18 183:21, 21 267:6 268:9 287:12accurately 161:14 163:4achieve 11:13 20:14Acknowledge 126:22Acknowledged 123:11, 12, 19, 23 124:4, 16 125:3, 16acknowledgment 125:9acquaintances 237:6acquire 28:6 69:11 107:15 201:17 215:14acquired 50:25 265:9acquiring 98:12 273:10act 65:17, 23 152:11 220:8 257:1, 4acted 96:10, 10 111:13acting 64:7 86:2 221:1 257:8action 48:3 58:10 67:23 69:12 87:11, 13, 17, 19, 21 96:15 110:10, 10 150:7, 9 221:10, 12,24 222:9 246:8, 10,11 250:6 257:19 261:14 264:20 286:21 287:16, 16,17actions 3:16 56:5 60:5 96:11

108:22 111:1, 3 142:4 246:12, 14 277:2action-taking 87:15actively 86:5 282:5activities 141:25 220:6 276:1activity 27:20, 24 55:4 91:8acts 190:8 220:6,12, 21, 24 221:5actual 10:11, 17 11:9 23:18 42:10 50:22 57:3 61:11 75:15 101:25 105:10 115:1 121:11, 21 122:14 148:5 149:22 152:11 169:23 172:25 179:1 185:11 193:19 268:11 274:14add 73:24addition 109:11 169:10additional 126:15 159:3 179:2, 4 251:18additions 218:23address 102:16, 18 104:5, 16 240:1 256:16addressed 60:5 66:20 70:5 110:20 256:6, 24adhered 193:3adjacent 78:6adjust 138:12 218:4, 7administered 195:22 207:7administration 111:1, 2 168:16 226:13, 24Administrative 4:7,15, 21 15:18 47:2 52:10 53:7 78:8 121:15 171:12 195:11, 23 248:12



administratively 111:14 149:11 280:10administrator 110:4 111:8, 11 114:2, 13, 17, 21, 22 140:25 178:2 193:19administrators 27:18, 23 28:4 32:20admitted 234:3admittedly 228:15adult 180:20 250:4advancement 201:12advice 35:14advised 135:14 155:4 232:11 234:24 235:7affair 53:9Affairs 70:18 71:20 86:23 87:7,13, 25 88:8, 10 90:13, 23 91:5, 7,10, 18, 20 92:8, 10 114:18 141:17 151:19 152:1, 5, 14 162:6 168:2, 6, 18 169:14 181:22 184:20 185:4, 15 186:3, 6 205:3, 9,18 225:25 232:15 236:12, 18 264:20 268:8 269:3 275:7, 11affect 274:1affirmative 219:7,10 220:3, 20 221:7 222:9affix 286:22aforesaid 287:8AFTERNOON 130:1 258:18 270:17age 172:19agency 26:19, 22 66:18 68:21 70:11 92:3 93:3 142:4 191:17

agency's 91:2agent 142:6, 10, 15agents 220:25ago 106:3agree 135:13, 18 147:17 213:23 217:19 234:16, 20agreed 54:5 267:10agreements 103:16Ah 182:5ahead 28:3 30:15 68:16 125:6 158:5 192:10 226:19 227:7 270:20 280:18, 18,18air 100:8 218:4, 7aired 61:20 255:2,3al 1:10 6:16, 16Alan 146:25alcohol 86:6 172:20 189:17 231:19 265:8, 9 271:14 272:3 275:16 281:1, 5alcoholic 66:12 69:11 72:9 273:9Aldays 4:12 144:13, 14 145:8 161:8, 14 190:8 194:8, 11 197:19 198:18 199:11 224:15Aleister 116:24Alex 14:18Alexander 14:18Alfred 16:13 17:10, 15alive 12:19all-day 53:9alleg 261:11allegation 209:19 228:3 283:21allegations 48:3 51:6 55:25 60:22 72:6 110:9 116:6,8 136:19 164:7, 21,22, 23 170:7 190:19 210:8

261:4, 23 262:1 277:1allegations, 3:16allege 219:12 220:5, 23 221:8alleged 163:3 220:7 221:17 266:23allegedly 245:6 272:14 273:1, 17alleging 261:12allow 69:17 260:1 274:12allowed 32:7 44:6 54:6 67:15 68:19 69:11 90:7 114:7 115:6 194:21 245:21 256:11 262:12, 15, 25 265:11 272:2, 5allows 65:24Alvarado 2:17amended 220:10American 6:9amount 24:7 32:15 178:21 198:15ample 191:21AN-017-10 4:7Andrea 153:7 154:3, 5, 10, 22, 24 155:4, 11 188:12,12, 17 282:11ANGELA 1:6 84:17 92:14 118:16, 17 130:17 131:9 142:22 154:17 157:12 158:19 188:20 208:1 220:12 222:13 228:7 259:9, 12 261:2 265:13 274:17Angela's 81:20 122:13 142:25 210:23 211:20 212:23 219:1 259:4anonymous 143:11 184:9 185:22

225:20, 21 240:12 261:23anonymously 185:12answer 8:16, 18, 21 26:1 28:3 29:8 30:3, 15 35:5 74:20 76:5 138:22 139:10 163:18, 20 164:14,17 165:17, 20 166:5 188:6 202:24 217:5 219:7 274:1 281:6answered 225:2, 6answering 280:21answers 37:22 280:25antagonistic 204:17antics 191:15anti-gang 97:17antiviolence 97:16 98:1anybody 21:22 83:16 84:18 132:17 133:14, 23 138:9 145:16 151:22 175:15 180:7 183:15 187:22 188:1, 24 191:3 200:7 220:2 221:11 234:6 237:9 240:8, 17 241:16,17, 20, 23 245:23 247:5, 7 248:1, 7 249:1, 6 251:17 256:12 264:16, 18anybody's 112:25anymore 211:24anyway 184:10 226:12apart 96:4 112:1apologize 189:6apparently 15:13 251:1appear 112:10 124:5 137:20 191:18APPEARANCES 2:1



appeared 33:7 139:16appearing 7:3appears 119:13 122:21 203:16 227:12applied 19:19 21:25 22:8, 20 249:4apply 21:24 22:4 249:2appreciate 87:1 150:3 166:4 226:25apprehend 183:24approaching 68:11 211:14, 16appropriate 28:13 30:13 199:3 254:4 255:24 257:2 277:18appropriately 115:6 205:22, 25 257:9 282:16, 19approval 74:13approved 74:9 123:10Approved, 123:20approving 147:21approximate 58:20 59:2 100:14, 20 129:19 130:5 187:12, 19 218:15,19 254:11, 18 285:6approximately 6:3 8:4 46:10 128:3 130:18 131:4 132:23 155:5April 3:20 93:22aptitude 67:25area 31:19 37:7 74:12, 12 78:7 98:4, 5 172:11 173:16, 23 186:16,19 200:20 233:7 262:20areas 43:24 74:1 98:14, 22 199:19argument 251:3arises 230:18

Armando 2:7 7:6 49:9 123:13, 22 152:16 159:7 188:18 282:11arrangements 66:19arrest 16:2, 13, 16 17:14 18:3, 4, 9, 13,17, 18, 19 111:16,17 114:13, 23 183:22arrested 17:21 18:4 110:7 118:6 149:2 154:13arrests 63:9arrival 227:24arrived 26:12 154:25 210:2Arroy 198:17ARROYO 1:17 2:6 3:3 6:17 7:5,8 14:7, 18, 20 58:20 59:1 94:20 117:24 129:19 130:5 163:13 175:23 187:12, 19 203:6, 6 235:23 239:13 245:10, 14 254:11, 18 285:3 286:20, 24 287:7ARROYO, 101:1article 116:1, 4, 10 259:24ascertain 135:4aside 37:12asked 30:5 33:11 46:8 53:23 54:1,5 76:10 82:23 138:17, 20 139:5 157:8 169:5 178:11 189:5 202:20 203:1 215:23 216:16 217:6 225:3 235:8 241:23 243:15 259:23 260:5, 11, 21 282:1asking 8:19 28:10 30:11 36:9, 14 37:21 39:6 42:18 55:24 85:11

113:4 130:9 160:20 163:22, 24 178:25 243:12 244:3 257:1aspect 32:18 70:7aspects 26:24 36:25 37:1, 7 42:2 60:3 225:17asserting 221:16assess 194:2 199:16 210:3 269:5assign 113:15 152:12assigned 40:19, 21 85:18 91:21 152:4 178:20 179:1 191:24assignment 10:18 11:12assist 91:23 142:14 253:1assistant 95:21, 25 141:8 142:19associated 139:10Association 201:13assume 84:6 138:4, 7 156:19 261:6assumed 156:8assuming 83:9 138:8 156:8 174:11 179:9 205:19 215:15 226:7assumption 145:21 280:25Atlanta 200:3attached 239:4attained 189:16attempt 162:3 234:12attempted 28:6 51:8 158:13 165:24attempting 161:25 163:9 165:15 191:14attempts 165:23attend 34:1 211:4,

5attendance 231:19attended 47:5 48:23 81:6, 9 206:23 230:4 251:2attendee 235:7attendees 230:25 234:11attending 53:11attention 36:4 46:25 57:2 80:14 110:14 114:14 214:13 246:7 280:12attest 31:18Attorney 141:5, 8,8 142:20 176:10,11, 24 223:23attorneys 72:18 176:21 221:22, 23 222:2attributable 219:18at-will 38:5, 6, 10,14, 17, 23, 24audibly 8:17audit 193:24 194:1audited 193:9August 4:5, 15 22:19 50:12 56:9 57:13 59:13, 14 86:4, 9 206:14 208:9, 18 232:3 255:2 258:11authorities 273:11authority 31:12 85:24 87:5 101:17 102:9 104:22authorization 175:2 199:6authorized 74:6 179:12 192:7automat 195:16automated 200:24automatically 121:19 195:13 237:2available 86:6Avenue 2:19

average 59:20, 25avoid 228:1award 21:7 200:4,6 201:14awards 21:4aware 36:15 38:8,20 44:14 49:22 60:21 69:23 79:23 80:4, 10 81:8 88:5 91:13 97:12 115:3 122:3, 4 123:21 142:3 151:21, 23 175:14 177:17 180:19 183:5 198:24 199:7, 10 212:11 217:3 219:20, 24 220:15 221:6, 10, 13, 19, 21 222:13, 17 231:12 232:17, 18 234:14 236:7 239:16 249:1 262:4, 8 265:11 273:7

back 14:5 15:10 23:7, 11 32:15 50:11 54:25 58:24 62:14, 15 76:14 82:13 83:5 99:4 100:19 101:19 110:12 114:20 123:25 124:11, 12 125:14,20 129:16 130:2 160:22 164:14 165:8 187:16 196:1 200:15 205:4 217:11 218:18 250:17 251:3 254:15 262:22 277:13backed 110:11 200:13background 34:22bad 73:17 84:23 154:11 222:10 244:8

badge 108:24 119:25 120:7 166:23 167:1Bailus 2:3 6:5bajillion 269:9balance 258:5ball 282:24 283:19, 24bankruptcy 146:19barred 220:11 221:16Barris 92:7 204:12 206:7base 59:18Based 24:21 57:15, 16 61:9 90:4 94:6 98:3,15, 19 145:21 148:3 154:7 157:20 159:17 165:23 188:14 196:2, 3 197:4, 5 199:17 201:12 217:1 227:11 248:17 251:7 256:23 257:5 265:6, 9 270:5 278:21basement 200:18basically 8:1 11:6 13:8, 11 16:3 23:16 24:18 26:11 27:18 34:20 38:4 39:11 40:6, 16 42:24 43:15 47:18 49:5 51:1, 6 53:17 54:16 66:6 67:23 68:17 69:23 70:13 72:7 73:25 75:22 78:16, 16 86:16 87:7, 10 89:7 90:15 91:19 96:14 97:25 98:9 101:21 102:8 103:19 107:14 110:2 111:7 116:22 117:12 119:19 122:2 125:9 128:14 139:22 140:23

141:9 144:11 162:19, 25 168:20 171:10 176:19, 23 184:21 193:5 196:15, 20 200:10 207:6 210:15, 24 211:1 250:16 255:10, 19 257:4 264:8 269:7 271:21 273:19, 19 275:9basing 280:25basis 33:6 108:20 112:7 186:1 220:23 225:24 248:18Bates 31:10 227:4bathroom 187:1Beach 19:8, 10, 11,18 20:1, 10 21:3,11, 16 22:3, 10 24:12 63:1beaten 101:13beating 98:25becoming 110:18 165:24 263:9beer 66:12 68:24 77:9 89:13 231:3 271:7, 11, 23 275:24 277:14, 15 279:16 281:18 283:8beer, 278:9began 9:25 44:20 45:13 131:6 161:23 162:11 176:7beginning 50:12 58:25 59:13 102:17 130:3 148:11 187:17 206:19 212:25 254:16 258:10 274:20begins 226:5behalf 1:6 6:22,24 7:1, 4 163:2 221:1behavior 70:17 277:19belabor 280:4

belief 49:12 60:11 61:19 137:9believe 16:22 26:11, 15 28:17 34:24 35:6, 16 36:23 37:20, 22 38:3 41:24 43:16 45:17, 22, 22 49:8,9 50:24 51:19 56:20 58:2 59:13 61:3, 12, 15 66:4 69:13, 16 71:9 73:20 78:24 81:2 103:21 116:1, 9 123:13 130:21 132:9, 16 143:10,25 144:7 145:6 158:23 166:10 173:10 180:2, 15,23 182:9 189:24 190:1 194:13 195:19 202:17 204:8 205:16 206:18 213:18 214:24 216:7, 23 220:4, 12, 22 221:4,25 233:12 238:19 246:21 250:3 257:15, 25 263:5 266:9, 18 267:1, 2 268:6 269:23 270:1, 5 277:24 280:14 282:20believed 27:22, 25 33:12 101:16 162:3 180:4believes 189:6 217:6believing 224:12Belinda 144:18, 19 262:8, 10belly 160:14belongings 177:11beneath 182:22benefit 170:10Beretta 179:8best 8:24 28:3 45:9 287:13better 62:22 94:9 96:23, 25 158:11

199:18 213:19 282:21beverages 63:23 69:12 72:9 273:9beyond 33:12 96:13 113:7 165:19bicker 118:22big 139:2biggest 101:14 250:18Bill 223:18, 24, 25birth 14:13bit 14:5 25:21 26:2 62:16 192:10 204:16 262:18 267:16blown 111:15 173:1blowup 179:21blue 102:20Board 31:24 74:3,5, 9 103:15 183:3,6 196:25 197:2 248:15Bob 113:9 171:3bodies 196:7body 215:2booster 120:6born 14:14, 15, 16,19boss 83:21bottom 31:7 104:7 106:17 122:19 123:2 138:19 278:11Bounty 20:9Boyett 29:24, 25 30:12 33:11 37:13, 23 42:20 43:6 213:11, 16 214:22 227:18Boyette 226:7, 21 227:2Boyett's 141:25 142:4boyfriend 154:11,13 155:17 230:14boys 14:12brain 53:3breach 220:8

break 54:10 60:12 97:23 129:15 130:8 158:13 186:25 190:5 229:19 254:8breaks 30:25 136:6 239:14Brian 2:6 7:5 48:20 143:23 188:22 198:24 245:15 262:4Bridger 2:19 200:18BRIEF 151:24 152:18, 24 153:9 168:19briefed 47:23briefing 107:24Briefly 128:2 129:8bring 36:4 89:17 91:14 104:24 128:22 150:22 171:9 217:11, 12 232:21 236:19, 25 243:4 245:17 250:7, 10, 15 251:11bringing 190:14brings 186:5broke 44:5 46:12 118:16 135:19 136:12 170:2 206:16 223:16 239:2 240:9 248:15 253:3 261:9, 11 265:2brought 46:25 54:18 56:2 57:1 62:2 80:14 87:10 96:10 110:14 114:14 198:18 214:13 236:20 246:7 250:22 251:7 280:12Brown 144:18, 19 262:8, 10buck 86:25budging 41:11, 11bugged 104:10, 13,20

building 73:25 74:1, 2 104:10, 12,12, 19, 20bulletin 74:3bunch 45:15Bureau 121:24Burgess 180:3 182:4, 20 201:18 202:5, 10, 17, 20 203:3, 22, 24 204:9 216:16 217:2 239:17 266:22 267:3, 14Burgess's 266:21business 12:1, 2, 3 24:24 25:4 26:6bust 98:24busy 73:17buy 99:25bypass 114:4Byrd 193:21 207:8Byrd's 194:3

< C >cabinet 24:25 59:19, 21 103:8 258:17CAD 200:24café 74:4cafeteria 74:4calculate 60:9CALEA 108:3 171:5call 51:2 68:20 77:20 87:3 114:22 154:3, 10 162:11 168:17 185:8, 25 186:6 199:4 209:18 211:10 253:23called 155:15 209:12 210:1 219:11calling 263:23calls 98:4 113:9 186:15 210:1 257:10camera 8:14cameras 172:14candidacy 194:23

215:13candidate 197:4candidates 23:9 198:8Canons 117:6Cap 95:2capabilities 104:23capability 268:22capable 270:7, 9capacity 8:7 64:8 65:24 219:3captain 22:15, 19,24 23:1, 2, 4 24:2 47:2, 24 49:2 51:3, 21 52:9 54:23 77:19 79:1,2 80:25 83:18 86:1 87:9 101:15 108:12 124:25 128:15, 20 142:7,12 162:8, 25 168:15, 21 169:1 181:18 186:5, 5, 11,17, 20 196:21, 25 214:1 217:23 241:15 246:19 253:16 284:15captains 95:13Car 64:13 65:3 67:10 175:2 198:25 199:1, 2card 277:9care 12:1, 21 113:8 115:5 119:8 164:9, 10, 22,22, 25 182:17 206:9 215:20 243:21 244:2Carrie 157:5carrier 149:4carry 16:6carrying 16:3, 7,11, 16Case 1:2 6:14, 16 9:12 16:21 17:5 29:5, 6, 9, 14, 20 30:12 31:4 33:10 34:2 37:17, 20, 23 43:24 44:3, 17, 23 45:1 46:3, 16 47:19, 19 48:8



53:21 54:19 55:2 57:12 60:1 69:15 70:24 71:8, 19, 20 72:19 80:24 87:22 90:24 92:14, 23 93:1, 4 107:17 111:11, 14 114:24 125:8, 15 131:9 139:11 140:16, 22 141:5, 9 142:15 143:9 150:12 152:5 157:20 162:7, 22 163:15 164:6, 17,21 165:3 172:17 176:7 177:14, 18 182:3 185:16, 19 186:12 193:20 196:24 201:4 206:11, 12 207:19 208:22 219:8, 11 241:14 243:11 249:21 253:17 275:10, 12cases 7:23, 25 8:2 26:24, 25 27:1, 8 37:12 91:20 99:4 101:5 139:4 148:3 152:14 174:25 237:10casino 209:25categorize 197:3category 37:17 65:18 189:22caught 262:16cause 10:6 46:14 68:7 70:3 85:11 102:25 111:24 129:14 151:18 221:15, 18, 20 243:10 287:18caused 79:25 149:2 220:24causing 78:19CCR 1:24 287:23CCSD 4:14, 20 5:3 182:17 188:24 199:1, 2 200:4 219:12, 16,16, 19, 21 220:4, 21 221:1, 2, 2, 8, 16, 22

226:7, 13, 21, 24 227:24 228:1, 2 230:5 233:17 234:21 239:24 244:9CCSD000125-130 4:11CCSD000129 151:11CCSD000143 4:9CCSD000155 4:4CCSD000172 3:25CCSD000174 4:2CCSD000219 3:23CCSD000227 3:22CCSD-issued 181:19CCSDPD 38:21 181:4 183:11center 118:4 138:5 200:20certain 26:14, 23 27:7 32:6, 14 33:3 60:3 61:12 95:13 98:2, 2 102:9 110:5 123:1 127:21 134:11 140:7, 11 159:19 178:20 189:13 190:8 198:14 202:16 206:25 225:15 272:22certainly 180:16 189:3 206:2 279:14CERTIFICATE 286:1 287:1certification 16:5,8 216:3Certified 2:23 6:7 216:3 287:5certify 286:20 287:6, 14chain 31:15 86:17 124:22 125:10, 22 126:21 127:8 161:16 162:12 217:22 284:13, 19Chambers 97:4chance 25:22

change 10:17 11:5,12 62:14 97:3 98:21 119:19, 23 121:4 157:25 159:11, 21 178:6 187:8 224:19 286:2changed 11:15 105:11 119:25 120:24 167:6 176:4changes 215:24, 25 218:22Channel 201:7 239:1 250:20channels 86:16characterization 272:20characterize 272:19charge 114:13, 18 241:2charged 189:7, 17Chart 3:18charts 98:10Chary 2:17Chavez 47:7 51:9,13, 17, 18 52:7 236:1, 3check 125:3, 3checked 123:12 124:4, 16chief 22:1, 2, 9 23:5, 7 24:2 32:3,21 38:8, 19, 22 47:1 63:19 65:13 69:14 73:22 86:2,21 88:1 94:20 96:21 97:4 100:25 102:21 104:1 117:24 127:10 136:13 139:1 140:24 150:5 162:1 175:16 181:2, 8, 17 183:18 186:20, 23 191:11 193:1 196:23 202:10 205:1 210:24 215:8 219:3 239:13 245:14

255:4CHIEF, 109:18Chiefs 201:13chief's 74:6, 8child 262:21choice 262:14chose 24:25 52:10 53:9 120:6chosen 65:24 105:21Chris 6:24 270:17Christmas 209:10 210:25 211:3CHRISTOPHER 2:18circumstances 7:20 11:20 65:16, 22, 25 70:23 99:2 107:13, 15 149:10 182:10 185:1 253:5 266:1, 6citizen 66:17City 9:16, 18 11:9 16:22 24:11 199:16civil 9:12 18:6 146:15, 18, 20 164:7civilian 169:21 256:16claim 157:12 221:16claims 220:10clarification 75:19 166:5 172:24clarifications 130:10clarified 160:2clarify 67:13 97:14clarifying 127:16Clark 2:6 3:18 7:4 21:12, 22 24:1, 12, 17 25:3 26:5 31:13 63:20 65:12 69:19 71:11, 13 72:7 77:4 86:21 90:12,19 91:11 92:9 93:10 99:7, 24 141:17 154:16 163:2 176:1



177:7 179:10, 13 192:25 229:7 239:12 249:15 271:6 276:15 282:24 284:3 287:3, 20clashed 204:20Class 65:18, 18 190:1 199:5classes 198:15clause 38:10, 14, 18clear 27:12 56:1 245:15 252:18, 21,24 271:2 280:3clearly 194:21clears 196:3Cleveland 53:2 56:8, 11 92:16, 18 131:1 260:11Clinic 53:2, 4 56:8, 11 92:16, 18 131:2 260:11close 12:13 45:11 248:16closed 248:23coach 111:11 112:13 114:23 115:3coast 12:1, 10, 23 209:9, 11Code 117:5 146:5 271:19, 19 272:6, 8,13 273:3, 16, 18, 21 274:9, 15Codes 271:25coerce 161:25 162:3 166:12, 15 263:2, 9, 17coexist 96:23, 24cohesive 117:13Coke 277:12collaborating 97:22collected 245:11Color 4:21, 21column 22:16combination 73:18come 21:11 24:23 38:13 40:8 43:21 48:24 49:20 55:16 58:3, 15 60:3, 14, 18 61:19

64:9 71:15 81:15 87:24 89:7 93:13 102:21 104:9 107:23 115:11 118:3, 5 137:4 164:14 186:21 190:12 193:12 200:21 208:23 211:1 236:24 240:11, 16 259:14,22, 25 260:1 262:22comes 70:21, 22 97:25 117:18 132:17comfortable 37:9 41:12 113:18 213:15coming 40:13, 15 50:5 53:22 60:24 61:22 114:1 133:4 135:7, 14 137:17command 31:15 72:12 86:17 93:15 95:12 103:14 107:17 124:22 125:10, 22 126:22 127:8 132:6 161:16 162:12, 13 182:21 193:23 217:22 245:16 284:14commendation 96:12commendations 21:4comment 45:23 114:12 142:23commit 264:21committed 96:17Committee 207:2,3 216:1committing 91:22common 90:15 102:1 113:24communicate 249:16Communications 121:23 132:15

community 21:7 171:5 200:23comp 74:7company 157:11 262:16compartment 15:14compatible 25:5competently 205:16complain 144:12complains 217:16,17complaint 18:17 56:4 57:2 114:18 165:6 219:7 220:10complaints 206:2complete 15:10 183:12 199:5 215:22 287:12completed 70:14 91:4 275:11Completely 182:19compliance 15:23complicated 102:24 262:18composed 207:3computer 77:5 118:4 121:9 140:16, 18, 22 167:7 177:16, 19 200:24 201:9computer-aided 200:25computers 201:4con 245:4concept 26:18 163:6 209:3Concern 4:9, 12 5:4 61:5 70:11 151:12, 17, 18, 25 152:24 153:10 157:22 163:5 167:21 168:3, 5, 19 169:13, 16 170:7 184:21, 23 185:10 240:14 250:8, 14CONCERN, 152:18concerned 72:15,17 163:3, 8 165:13 189:16 263:20 268:7

concerning 226:6,21 266:5concerns 36:18 199:12 270:10conclude 71:19concluded 71:22 83:14concludes 58:19 254:9 285:2conclusion 24:23 97:7 115:11 190:13 276:4concrete 145:22concurrent 148:5conditioning 218:8condone 217:10conduct 34:9, 12 35:23 69:25 85:15, 25 91:11 99:17 146:6 169:11 220:6, 9 234:21 246:18 255:23 256:4 271:20, 25 272:6 273:3, 20, 21, 23 280:13conducted 46:17 105:9, 10 227:23 230:19 232:11, 14conducting 61:25 91:2 97:1 247:13 284:17conference 44:7 54:7confidence 44:17 73:15 139:2, 4, 6confidential 29:14,22 256:7confines 121:11confirmed 116:8confiscated 67:16confrontation 250:18, 24confrontational 114:5 115:8confrontational, 115:7connected 201:8consisting 285:3constant 112:6



constantly 207:15constitute 220:7Constitution 106:2consumed 275:16consumption 189:18contact 47:3 48:5 54:2 58:9 79:2 83:12 132:7 176:12, 23 203:5,12, 18 213:3 236:3 242:24contacted 47:6 54:23 137:7 171:7 175:23 176:8, 10 216:18contacting 185:9contained 177:5content 161:18 174:15 176:17 268:11continue 41:13 99:21 105:24 139:6 195:18continued 13:22 19:9 139:4continuously 137:16contract 37:3, 6 38:2, 5, 9, 14, 21, 23,24 39:2, 9 42:1, 17 103:10, 12 256:23 257:6contractor 287:14,15contractual 103:16contribution 94:21 95:18 219:11control 181:5 192:24 193:11conversation 46:13,18, 20 47:9 48:10 51:17 54:12 56:2 60:7, 11, 14 92:20 130:22, 25 131:7 132:3 176:14, 18 182:9 199:24 202:21 203:4, 13,15 204:7 216:17 219:2 223:10 258:7, 10 259:15

260:4 266:22 267:4, 5, 10 268:1conversations 42:14, 16, 22 43:3 45:12 46:6, 11 55:5 60:25 92:13 133:1 258:5, 13 259:8, 18 261:2 265:25 266:4conversing 176:9convey 161:15 214:21 218:1 283:21conveyed 39:12 55:15 80:6 180:3 210:16conveying 203:15convicted 82:15 83:4conviction, 82:20COOK 2:3, 3 3:4,7, 10 6:5, 22, 22 7:12, 13 25:11, 24 28:8, 23 29:17, 21 30:5, 8, 18, 23, 25 31:2 34:16, 18 35:7, 21 36:7 38:1 39:21 43:9 44:24 54:11, 13 57:24 58:4, 16 59:4, 8, 9 61:1, 14 63:18 64:6, 11, 14,17 66:21 67:4, 18 68:22 69:3, 6 70:9 74:10 81:17 84:11 86:13 93:8 100:7, 11, 22 106:16 107:1 109:16 112:23 113:1, 5, 8, 11, 19 115:22 117:22 119:16 120:9, 14,21 122:11 123:3 126:6 127:1, 22 129:13 130:7 131:18 132:1 134:9 135:3, 11 138:2, 15 143:5 147:7, 8 148:19 149:13 150:2, 13,20 151:1, 5 153:5,

15 158:9 160:1, 21 161:2, 3, 11, 12 163:19 164:1, 9, 12,20, 25 165:8, 16 166:1, 3, 21 167:18 171:1 172:8 173:2, 14 174:1, 4,10 175:21 177:3 178:16, 17 179:16,19 182:1 184:2, 14,17, 18 185:21 187:4, 9, 21 190:4,23 191:10, 23 192:23 202:4 204:3 209:16 214:3 218:6, 9, 21 222:23 223:1, 8 226:4 227:16 228:21 229:1, 13 231:7, 15 232:2 233:4 234:1 235:6 237:13 238:4, 6 239:22 240:22 241:8 242:9, 13, 17 244:7,18 246:2 254:7, 20 255:14 256:8 265:14 272:16 277:5, 7 278:1, 6,23 279:6, 13, 19, 23 280:18 281:13, 24 283:4, 17 284:1, 9,21, 25Cook's 280:21cooler 275:24cooperate 249:16cop 39:16 69:8 92:1, 2 141:17 191:3 202:6, 11copied 119:11, 12cops 57:19 60:16,17 70:11 209:5 241:3, 6, 10corner 173:8corporation 219:24corporations 219:15correct 9:9 10:24 11:8, 16 13:4 14:23, 24 18:4, 5, 6,7 20:3 21:13

22:10, 25 23:6 25:7, 12, 14 28:14 29:25 31:21, 25 32:23, 24 33:9 34:19 35:15, 20 36:2, 11, 12, 16, 17 37:18, 19, 25 38:7 39:7, 24 42:21 44:9 46:5 48:4 51:7, 15 55:17 56:16 57:4, 17 60:13 61:18 62:22 63:2 67:20 73:3 74:14, 25 75:8 76:22 77:10 80:2 81:24 82:2,3, 7, 8, 17 83:8, 11 84:14, 15 85:4, 16,21, 22 86:1 88:12,15, 16 89:22 95:3,4, 10 96:19 103:23 106:14 118:18 120:25 121:1, 20 123:8, 9 124:10, 14 125:4, 5 126:24 127:11 128:10, 11,18 131:3, 9, 10, 20,25 134:5, 13 135:2,17 136:5, 11 137:1,2 138:11 140:13,16, 17 142:2, 19 143:1, 19 144:9 145:10, 15 146:3, 4 147:4, 9, 11, 12 151:25 152:17 153:7, 8, 23 154:1,18, 20, 21 155:22 156:18 158:23 159:1, 23 161:19 168:7, 8, 25 169:7,8, 15 173:19, 20 174:14 176:16 177:10 179:11, 15 181:16 183:13, 19,25 185:24 186:24 188:8, 13, 22 189:4 190:20 192:1, 13 196:9, 10 197:14 199:2 202:1, 3, 14 203:20, 21 204:10 208:5, 6 210:22

213:2, 6, 9 216:10 218:3 220:17, 18 222:2, 3 224:9, 17 225:10, 11 226:3,11 228:13 229:3,10, 22 230:1, 7, 8,10, 11 231:20, 21 232:4, 5 233:9, 10,11, 16 234:8, 15, 19 235:1, 2, 11, 12, 16 237:24 238:18 239:15 240:10 242:21, 22 243:24 246:12 248:5, 6, 8,9 251:10 253:3, 10 255:7, 22 256:3 257:12, 13, 16, 17,20 258:2 259:10,19 260:14, 15 261:10 262:3, 11,17 263:6 264:7, 11 265:22 266:11 267:12, 13, 15, 24,25 268:5, 18 269:12 270:4 271:15 272:11 276:17 279:18 281:2, 3, 9, 10, 19 282:14 284:19, 20corrected 75:14 76:7 286:22correction 158:25 160:18corrections 218:22correctly 31:20 99:15 108:2 116:16 146:17corridors 74:2costs 221:23Counsel 6:19 189:16 223:25 266:21 287:15, 17Counselor 138:13 184:12 187:7count 105:24 196:21counterpart 250:11country 22:8County 2:6 3:18 7:4 12:13 20:1,10 21:3, 11, 12, 16,

22 24:1, 13, 17 25:3 26:5 31:13 53:3 63:20 65:12 69:19 71:11, 13 72:8 77:4 86:21 90:12, 19 91:11 92:9 93:10 99:7,24 137:18 138:1 141:18 154:16 163:2 176:1 177:7 179:10, 13 192:25 229:7 239:12 249:15 271:6 276:15 282:24 284:3 287:3, 20couple 15:6, 24 17:25 58:16 130:17 190:6 211:2 219:8 224:11 254:7course 77:9 86:17 87:13 103:1 110:17 209:6 227:24 258:19 259:15 265:7 270:1COURT 1:1 6:9,12, 15, 21 34:2 165:11 176:7 287:5courtyard 53:12Cover 4:17 203:19 234:13covered 54:17 58:7 202:25 203:2 228:1covering 261:20cover-up 48:4 51:8 239:12, 18 261:4, 9, 12, 15 266:23cover-up, 203:9Craig 73:22create 193:5created 77:4 158:5creating 144:25 248:18credence 105:21

crime 65:11, 13, 20 96:16 183:24 189:13, 21Crimes 11:3 91:23 92:8criminal 7:23, 24 8:8 26:24 27:20,24 28:5 29:4 32:19 34:22 48:2 55:4 61:25 69:25 70:7, 24 90:9 91:2, 3, 8, 11, 14, 25 92:4 142:1, 5 146:10 162:21 243:11 244:9, 24,25 256:4, 10criminally 92:2 111:15 189:7, 17criteria 193:25 197:6 248:23Crowley 116:24CRR 1:24 287:23crush 64:20culture 102:4, 6cup 283:11, 12cups 277:18 279:16current 47:1 200:22currently 105:22 106:12 275:8curtail 171:24custody 285:4cutting 215:5Cynthia 2:12 156:6 266:5 277:16 279:9

< D >DA 142:17dad 12:19 13:1, 10daily 108:22damage 219:12damages 220:23 221:17 222:5, 6, 10,15, 18Daniel's 63:23 277:12, 15 278:9Darren 29:24date 40:11 75:4 81:22 101:19

114:13 282:6 286:25dated 123:12 147:15 159:7, 8 180:11dates 146:4daughter 148:13 154:11, 16 155:16 229:7 230:13daughters 154:13daughter's 230:13day 15:12 16:7 40:13, 24 84:24 85:3 101:23 102:12 110:18 150:22, 22 228:19,22 257:3, 9 287:21days 15:15, 16 16:8 46:13 59:22 110:5 124:15 181:15 261:13, 14day-to-day 108:20 186:1 194:3dead 243:8 275:2deal 76:4 112:7 207:15dealing 112:20 209:22dealt 116:16death 78:18 80:1 81:20 122:13 142:25 208:1 210:23 211:20 212:24 219:1 220:14 258:21 259:4debacle 110:8deceased 1:6December 84:16 86:3, 15 89:11 122:20 128:8 136:1 146:1 148:9 150:15, 18 153:20 209:10 211:13 282:9decide 168:10decided 248:16 251:25decides 86:20, 22 196:8 197:14



decision 15:3 88:7 194:25 195:7declare 286:20dedicated 106:1deeds 220:6defend 3:16defendant 270:24Defendants 1:11 2:6, 10, 15 6:25 7:2 219:12, 16, 17,19, 21 220:4, 22 221:1, 3, 8, 17, 22 265:20defending 182:10defense 219:10 220:3, 21 221:7, 24defenses 164:25 219:7definitely 105:17 127:13 138:4 192:16, 21 274:4 281:7definition 120:5degree 23:15 43:12, 14 117:15 172:16 198:14 284:8deliver 44:7 161:17delivered 87:23 128:20 212:4demise 182:23 183:3demonstrate 238:12Dennis 141:10, 10,12Department 4:5,15, 21 9:17, 19 10:1, 21 11:1, 4, 18 12:23 14:22 15:1,5, 9 16:19 17:8, 11 18:22, 25 19:18, 20,22, 25 20:2, 10 21:1, 3, 11, 12, 17,23 24:2 26:5 27:16 28:12, 18 29:12 40:25 43:17 47:3 49:15 60:6 61:13, 16, 22 62:6 69:20, 25

71:3, 6, 12, 14 72:9 85:25 86:18, 22 89:6, 9 90:20 91:9, 10, 15, 18, 20 93:11, 15 96:25 97:2, 13 98:7 99:5 101:12, 12, 20 102:1, 5 104:9 108:23 110:11 112:9 118:5, 23 120:3 121:14 133:21, 23 137:22 138:3, 6 140:23, 24 141:13, 18, 20, 21 145:20 155:24 157:17 162:11 167:24 168:15 171:13, 19, 21 172:2, 22 176:1 177:8 179:6 182:12 186:4 187:22 189:9 190:16 191:5, 5, 22 192:7 193:1, 14, 17,20, 25, 25 194:2 195:12, 24 196:15,20 199:13, 19 200:9, 10, 10 201:17 207:4, 5 215:3 216:5, 8 233:18 236:21 237:4, 5 241:18, 21 242:5 248:8 249:12, 15 250:13 251:14 262:6 266:11 269:15 282:25 284:17departmental 16:4 152:13departments 93:16 102:2 121:23 181:10 193:6departure 178:1dependent 70:1depending 65:15 95:14 99:2 107:13depends 65:22, 25 237:3deployment 98:12depo 73:11 217:8

deponent 6:17, 21depos 150:21deposed 8:5 17:5DEPOSITION 1:17 6:18 7:16,21, 24 8:10 9:3, 11 31:5 52:21 58:20 59:1 74:16, 24 129:18 130:4, 12 138:16, 20 149:5 187:11, 18 202:15 203:23 238:8 243:3 254:10, 17 263:1 267:9 270:2 285:2, 8 286:21, 22 287:7,12derived 212:21described 142:8DESCRIPTION 3:15 4:1 5:1 257:6destroy 249:20destroyed, 245:11detail 205:5, 8 257:24 273:24detailing 171:10details 30:3 56:2 97:23 113:6 151:24 152:18, 24 153:10 168:19 169:3 214:16 253:15detective 10:2 11:6, 10 47:7 49:2 51:2 54:24 87:8 118:6 121:23 141:7 162:8 167:21, 22,23, 25 168:13, 20,23 193:20 205:14 216:19 235:25 236:23detective, 168:22detectives 53:21 54:20 91:23 132:10 175:24detective's 11:7detector 114:2, 4

determination 87:21 88:2 197:17 256:22determinations 87:11determine 142:17determines 197:5developed 26:15died 191:18 237:16difference 34:24 89:2 120:15, 17 139:2, 23, 24 150:25differences 26:14,16different 31:8 40:4 41:7 88:17,23 121:22 130:20 138:18, 21 162:13 166:23 199:19 213:14 215:19 224:12 241:11 278:10 281:6differentiate 103:20differently 33:8 217:8 279:21 280:5, 9 282:2difficulty 112:19diminish 103:15dinner 146:25 148:14 154:23direct 69:18 78:25 88:5, 10 95:2, 17 107:10 108:17 161:20 187:22 188:1 214:19 215:20 216:4, 7 217:20 219:13, 17 241:13 244:23 245:2 247:5, 20 249:20directed 47:1 108:9 162:25 167:10 224:9 252:11 264:12directing 34:8, 21 122:1 212:24direction 90:5, 5 101:25 118:24 137:8 138:18, 21



161:8 189:3 213:22 225:23 235:15 261:19directive 34:25 35:12 36:6directives 119:4directly 26:13 89:8 133:21 207:20 284:13directors 53:8 196:16disagreed 33:20 140:5disagreement 140:6disagreements 197:18 201:20 204:14 208:13disapprove 123:25 124:9, 12 125:20 126:14Disapproved 123:11, 20 125:4disciplinary 87:11 246:8, 9, 11discipline 16:15 17:7 19:5 24:4 87:23 88:14 175:6disciplined 15:4, 8 173:22 181:13 248:4 255:5 256:19, 20 275:15disciplines 18:25 21:2disciplining 275:25disclose 32:7 189:8discord 115:10discounted 57:21discovered 11:24 15:14 22:1discretion 186:16discuss 27:3, 6 33:15 42:11 44:6 47:17 54:6 97:5 193:13 198:23 245:17discussed 46:7 53:1 54:15 58:6,14 60:8 61:9 75:3 107:11 234:12 246:6

250:22 258:23, 25 259:2, 13discusses 157:24discussing 43:1 60:12 109:21 247:3discussion 41:17 43:1 115:18 214:15 266:20discussions 42:9 46:2disgruntled 145:4,7 190:7 194:14 201:24disk 58:19, 25 129:18 130:3 187:11, 17 254:9,16disks 187:8 285:3,4dismissed 261:22 262:1dispatch 55:22, 23 74:12 118:4 138:5 171:18, 20,23 172:11, 14 173:16, 23 200:17,19, 25 201:5 233:7 251:13 271:5 284:14dispatcher 55:18 88:18, 24 89:12 93:23 94:11 96:3,8 146:15 154:15 157:5 189:6 208:10 229:8 230:3, 12 231:1 234:3 239:25 250:19 255:3 277:16, 16dispatchers 48:23 49:6, 7, 20, 21 55:9,16 68:24 79:24 81:25 82:19 85:1 86:7 133:11 134:21, 22 136:23 137:10 146:8, 12 171:17 173:21 230:5 233:6 240:4 245:16 246:3 247:21

251:12 265:11 273:5 284:13dispatcher's 79:18,19, 20displeased 182:21dispute 232:6, 8,22 245:12disseminate 105:15 133:9dissipate 105:8dissolved 216:2distance 99:13distinction 75:23 76:17 166:14distinguish 27:12distort 182:8distributed 245:6DISTRICT 1:1, 2 2:6 3:18 6:15, 15 7:4 19:17, 22 20:1, 10 21:3, 12,16, 23 22:8 23:22 24:1, 17, 23 25:4 26:5 27:19, 23 28:11 31:13 40:5,7, 25 41:11 44:11 53:8 63:11, 20 65:12 69:19 71:11, 14 72:8, 8,22 77:5 85:24 86:21 88:25 89:4,8 90:12, 19 91:12,24 92:9 93:11, 17 99:5, 7, 24 102:4 110:3, 11, 12 111:2 113:25 115:6 118:13 120:3 137:22 141:5, 8, 8,13, 18, 21 142:20 145:20 163:3, 14 172:1 176:1 177:8 179:10, 13 189:9, 11 190:2 191:2, 16 192:3, 4,5, 25 193:3, 6, 7 194:2 195:11, 22 196:16 201:8, 16 205:1 213:17 214:20 215:1, 21 216:15 224:1 225:19 229:8

238:12 239:12 249:15 255:13 256:16 271:6, 19 272:8 275:19 276:14 282:25 283:19, 20 284:3, 5districts 22:5District's 154:16 276:15division 47:3 52:10 78:8 186:6 195:23doctoral 23:12, 15doctrine 220:11document 73:21 123:8 149:22, 24 151:16 152:19 158:5 167:19 169:9, 10, 20 173:18 174:12, 15 184:7, 15 188:14 210:5 251:16documentation 57:3 74:5, 8 114:17 167:10documented 98:10 210:6documents 57:15 164:6 177:14 249:21document's 125:10doing 13:6 29:1 56:5 62:21 83:9 86:7 92:2 93:9 97:21 110:24 128:19, 21 162:3 175:11 185:7 191:6 199:7, 8, 20 205:22 233:19 243:18domestic 209:12,21, 23

DontServeTeens.gov 4:17DontServeTeens.gov, 172:20double-negative 85:12Doug 46:15 48:5downloaded 162:6

drank 242:3 272:25 277:13draw 164:19drink 66:12 134:16 254:4 272:2 275:23, 24 277:12drinking 55:10, 25 56:14, 25 57:20 60:16, 17 61:4 63:22 67:7 68:5,10, 11 69:17 70:12 71:10 86:5 89:12 156:23 157:20 171:25 172:19 175:10 187:2 209:1, 5 231:2, 19 232:13 234:4 242:19 243:16, 21 250:1 273:9 274:12 278:25 279:1, 15 280:24 281:1, 5, 16, 17 283:6, 11, 14drinks 272:15, 24 278:8 283:13Drive 6:11 67:15 68:19driver 189:18 228:14drives 249:24driving 171:25dropped 282:24 283:18, 24drove 96:18 253:25drug 98:18 99:25drugs 98:25drunk 63:13, 25 228:15 274:13 278:12, 14due 53:21DUI 63:9 78:11 82:20 149:3 158:17 228:8 253:17duly 7:9 287:5, 9duration 11:3duties 11:15 40:18 63:4 65:10 68:13 136:14

183:22 205:17 269:24 270:7, 11duty 65:19, 19, 21,21, 23, 25 67:20, 20,24 84:4 93:23 96:14 110:17 125:12 183:20, 20 189:8 198:19 220:8 271:4, 10, 13,16, 16, 17, 18, 21, 22 274:10Dwight 257:22dysfunction 251:13

< E >earlier 20:16 28:15 31:4 76:21 82:5 122:8 128:8 134:10 149:11 158:14 168:4 169:6, 13 171:6 183:8, 21 184:4, 22 185:11 189:5 194:8 222:1 224:11 225:2 233:12 238:7 259:6 260:3 263:1 266:10 268:6early 149:1easiest 59:18easy 195:9education 196:3effect 143:11 207:13 209:15 231:11, 12, 23 256:11 269:9effort 171:24efforts 171:9eight 245:9either 50:8 91:14 95:20 101:7 107:6 110:11 114:3 126:14 147:14 152:22 156:16 169:9 198:7 200:1 217:4 259:3elaborate 203:1elected 46:15

167:5electrical 201:3eliminate 25:1 97:7 195:17else's 274:3EM 89:20E-mail 5:2 216:21E-mails 162:12 177:13embark 171:11embarrassment 228:1emblem 120:4 121:19, 21 167:9emergency 172:13 201:11employee 88:18, 24 89:20 110:12, 13 122:15 174:21 193:18 226:7, 21 244:8 249:14 256:17 257:5, 8 271:5 287:14, 15Employee-Man 89:22Employee-Management 89:9 90:1employees 27:16 47:5 51:1 72:7 74:4 78:2, 10 80:15 91:22 189:12 220:25 256:11employment 165:4EMR 38:11 89:10,23, 24 90:2, 6, 8, 13,23 91:22, 23 169:11, 22, 25 170:16 205:11, 24 255:11, 15 256:15,19, 25 257:3, 11, 16 275:19encourage 173:19ended 16:21 215:7 243:24enforce 192:6enforcement 9:15 24:8, 10 26:19, 22 34:22 66:18 91:2 96:23 191:17

192:11 268:22 273:25engaged 141:1 220:5, 13English 141:16Enough, 264:9entered 251:2entire 32:21 104:10 116:22 138:1entirety 130:25 151:9 261:23 262:2entities 219:15entitled 6:16 37:22 221:24entity 219:24 256:15EOC 78:6Eric 2:15 14:18Erik 144:12 190:8 197:21ES 93:24ESQ 2:3, 8, 13, 18essence 116:10 120:10essentially 44:9 232:4 257:1 262:10 283:13establish 103:3 151:18 204:21 225:17, 22established 103:2 171:7, 7 201:6estimate 45:9 65:4 206:14 257:23estoppel 220:11et 1:10 6:16, 16Ethics 117:5evaluate 257:5evening 78:18 148:25 199:5event 145:19 148:7 153:7events 101:6 233:7 234:13 257:20eventually 10:11 42:12 105:8 114:6 126:1

everybody 81:2 112:9 121:8 133:6 137:18 188:6 200:23 241:3 283:12everything's 121:5evidence 70:3 141:11 205:6, 8ex 163:9 165:14exact 17:16 20:5 40:11 56:12 162:5 251:4exactly 29:3 39:19 68:14, 17 72:4 96:24 128:5, 23, 25 129:1 137:13 153:17 182:19 222:8, 12Examination 3:4, 5,6, 7, 8, 9, 10 7:11 265:16 270:14 277:6 280:1, 19 281:12examined 7:10 287:9example 104:8 105:3, 12 112:8 144:11 257:18 259:20 275:13 276:11excessive 130:16exclude 32:11exclusively 131:8Excuse 25:13 66:23 103:24 119:1 153:13 258:24 276:14exec 106:21executive 95:21, 24 206:6, 18Exhibit 29:18 30:21 64:15 74:18 93:6 100:17, 23 106:24 109:14, 17 115:20 117:20 119:14 120:12, 19, 24 121:3 122:5, 12 128:21 145:23 151:3, 6, 10 154:2 160:24 166:18, 22

167:1, 16 170:22 172:6 173:1 174:7 177:1 178:14 179:17 190:21 222:20 224:25 227:5 238:1, 4, 19 239:8 242:20 251:23 267:17, 20exhibits 150:21 251:22exist 192:6existed 103:5expanded 205:5expect 58:10 63:19, 21, 24 83:24 84:1, 5 278:13expectation 65:14 85:14expected 166:12experience 34:23 63:13 64:25 65:5 278:21experiences 270:6expired 181:15explain 46:22 215:16explained 53:18extended 283:7extent 7:19 8:12 102:3 142:23 213:20extort 163:9 165:15 166:11, 15extorted 163:4extortion 162:17,19, 22extra 161:1 236:25Extremely 64:24 172:3 181:12eye 28:16, 16 140:10, 10 213:10,10eyes 271:17

< F >Facebook 4:21 108:2, 7, 15, 22, 25 109:4, 7 180:13 190:25 191:3, 16

267:17 268:11Facebooks 108:9faced 275:25facilitate 200:22facilitated 13:22facilities 193:17fact 49:15 54:17 60:20 101:15 103:10 104:18 106:13 115:4, 13 118:15 125:13 134:12, 12 135:5 190:6 232:16 237:3, 15, 17 245:18 248:1 279:4, 7 282:1 283:10facts 113:12 168:18 182:8 244:2 265:25 266:5factual 102:23 104:2factually 105:14 115:12, 13 190:18failed 15:12 110:12 144:2 221:9 222:5, 14 273:10, 11 280:14failure 222:4fair 8:21 15:21 33:13 45:10 60:13 63:12 86:8 147:16 171:24 208:12 209:4 227:10 266:15 284:6fairy 106:11fairytales 105:21fall 192:4 247:12falling 37:17falls 189:22false 101:24 114:19 125:19 126:1 183:12familiar 7:18 31:14 151:15 162:18 167:20 238:24 268:21families 276:11

family 11:23 12:2 15:2, 3 169:5 175:3, 5far 9:3 14:22 31:14 55:14 59:12 60:21 75:15, 17 76:10 83:22 84:25 99:2,17 110:8 122:4 156:13 167:8 206:1 217:24 220:1 228:11 233:2 236:7 256:6 283:23fashion 139:8 161:24 272:23fast 65:2fatal 149:2fatality 72:11 155:18father 11:23father's 12:5 15:1fault 219:18favorites 196:12favoritism 196:24FBI 92:25 104:9,19 118:3 130:16,23 139:11 263:12,13February 3:23 4:2 5:2 20:4 40:24 62:4, 9, 10,13 108:16 143:15 148:8 158:1, 22 160:9 201:24 223:14 225:9, 13 228:4 230:6, 15 231:4, 20feedback 85:20feel 41:12 113:17 139:3feeling 183:1fees 72:18 221:22,23 222:2felony 190:1felt 139:2 182:15female 144:16, 22 145:9 190:7 194:17 224:15 229:6, 15festivities 271:24



Fetcho 211:22 212:5, 8, 17fight 99:11, 25fighting 112:1figure 104:1 112:15 113:11 148:1 196:11file 18:8 51:20, 25 52:2, 7, 8 114:12,16 132:4 169:14 191:25 225:25 280:6filed 18:6 72:15,16 163:13 165:5 169:7 219:8, 11files 177:9FILIBERTO 1:17 2:6 3:3 6:17 7:5,8 58:20 59:1 129:19 130:4 187:12, 18 254:11,17 285:3 286:20,24 287:7fill 183:15filled 157:22 183:18 185:4 197:15 261:8filling 185:10 277:18 279:16final 87:10finalized 107:7finally 162:15financially 287:16find 29:3 49:21 83:12 85:6, 9, 13 104:17 114:22 136:19 148:15 150:17 155:18 156:1 157:1, 10 158:16 166:8 173:16 189:1 192:12, 14 214:6 229:14 243:5 251:21 255:23 256:3 260:16 266:16 273:14, 18 283:20 284:2, 4finding 206:19fine 163:15 164:6 246:5

finish 8:18 27:10 34:16 54:11 90:9 134:15finished 60:12 176:8 280:7fire 8:18 160:14 224:13firearm 16:2, 5, 6,10, 11, 16 177:24 179:2, 4 181:6 182:11firearms 16:4 181:6fired 180:4firm 6:9, 12first 7:9, 15 8:10 9:15 15:9 17:4 18:8 35:13 41:25 44:4, 8, 10 45:13,16, 17 46:12, 18, 20 47:9 48:10 50:13 52:16 53:10 61:2 62:22 72:2, 23 75:6 76:2, 8 79:16 86:7 91:4 94:5, 15 101:5 102:24 104:17 106:3 113:1 122:9 157:1 200:8, 9 201:16 203:11 204:16, 20 206:15 210:25 223:21 226:16, 18 227:5 230:20 239:2 244:25 245:5 252:16 257:24 261:12 265:2, 21 269:5 271:1firsthand 75:16, 17 104:5 116:17fit 26:6 193:25five 16:8 19:14 41:1, 17 45:5, 9 46:11 59:11 100:11 130:18 181:15 187:4 196:14 200:14 223:14, 15 229:24,25 254:16 257:23

258:13 259:7 278:10 285:3five-minute 218:10Flamingo 200:20 228:8flier 73:4, 6, 8, 10 74:19 75:3, 3, 7, 9 76:25 77:1, 4, 7 184:4 239:4, 5, 6fliers 74:2 203:20 245:5 276:19, 20Flip 173:15flipped 184:15Florida 7:19, 21,25 8:5 12:24 21:21 23:8 215:5flyers 203:10 245:10folder 51:20, 24 275:10 280:11folding 277:11follow 34:25 35:15 36:1 50:18 51:19 70:3, 24 83:17, 25 84:1 85:17 86:18 89:18 162:9, 20 188:24 192:2 194:21 225:20 261:18followed 55:2following 18:16 36:5 77:12 111:24 165:10 216:2follows 7:10 27:17follow-through 280:13, 14follow-up 91:4 254:21 270:16, 25 280:17follow-ups 277:5font 31:7football 111:8 113:24Force 10:3 130:16foregoing 286:21forever 103:11 118:9forged 101:8

forgot 75:22 76:18, 20 131:13 193:22 197:8form 28:2 35:4,17 36:3 37:24 39:18 43:8, 10 44:19 58:1 60:17,19 61:7 63:17 64:3 66:15 68:15 69:1, 21 73:19 81:14 84:9 86:11 106:15 122:10 123:1 126:3, 18 127:19 131:21 134:6, 24 135:9 137:24 149:17 150:8 151:21 153:1, 12 158:3 159:24 160:19 161:9 167:5, 5, 11 172:4 173:24 175:17 181:20 184:1 185:3, 17 191:7 192:22 202:2 209:14 213:25 221:2 226:2 228:23 229:11 231:6, 24 232:25 233:22 235:3 239:20 240:19 241:4 243:25 244:14 246:1 255:8 256:2 277:23 278:16 279:17 281:21 283:1, 22 284:7formal 57:2 60:23format 185:11forms 121:4Form-wise 121:2forth 26:25 48:24 49:7 56:2 60:6 67:17 98:19 121:24 142:9 201:5 207:7, 16 210:6 216:6 220:9 242:16 257:7forward 49:13, 20,22 50:5, 9 55:16

85:23 90:5, 7 132:17 135:7, 14 136:13 137:4 170:15, 15 176:22 188:10, 25 224:21 226:12, 23forwarded 128:15 152:7 169:11, 25 225:16 229:25found 88:4 133:25 134:8 149:3 188:17 261:18 266:18foundation 64:3 66:15 68:15 69:2 126:19 131:22 134:7, 25 148:17 153:2 158:4 161:10 173:25 175:18 181:21 185:18 189:25 191:8 192:22 203:25 209:14 228:24 231:6 232:24 233:23 235:3 239:20 240:20 241:5 242:8, 9 244:1, 15 265:4 277:23 278:16 279:11, 17 283:2four 15:16 41:1,17 124:15 176:9 187:17 193:9 198:8, 10 254:10 278:8fourth 105:20 148:8, 9 175:8 220:3frame 226:12 227:10, 12 258:4,14 263:8FRANCIS 1:2, 5 2:24frankly 64:8fraud 118:6FRCP 287:19free 9:4 40:16fresh 93:22friend 236:13 237:8, 8

friends 191:4 230:20, 22 236:11,17front 68:5 80:23 122:5 145:24 166:18 238:19 239:7, 13fueled 101:6 160:13fulfill 80:17, 20 167:10 270:10full 111:15 221:24 240:15full-blown 110:8fully 110:17 227:1,19function 194:4further 55:3 190:9 214:18 263:22 287:14furthermore 68:20 72:11 73:20, 24

< G >gag 256:10, 14, 18Gamboa 49:9, 25 50:4 79:8 80:11,12 153:7, 20 154:3 155:11 158:16 188:12, 12, 17, 25 240:9, 13 246:21 282:11Gamboa's 79:12game 111:9 113:24gap 122:23Garcia 22:2Gardens 19:11gather 96:18geared 164:12, 16geez 237:16general 60:1, 2 63:4 113:17 183:11 199:12 207:12, 17 214:14,23, 24 257:25 270:25 273:23generally 9:2 65:11 80:21 95:8 183:10 222:6generated 177:21gentleman 193:23

George 45:14 46:21 284:2Gervasi 107:22, 23 110:15 157:18 251:4, 5get-go 104:20getting 23:12, 14 40:22 42:19 43:4 98:18 127:3 139:16 159:3, 13 160:5, 8, 9 164:17 166:13 178:5 194:14 195:7 198:13 201:2 224:13, 14 235:13Gil 107:21Gillespie 46:16, 19 48:5 52:13, 15, 18 53:12, 15 54:3, 17 55:6 56:19 57:12 58:8 82:24 85:8,14 92:13, 21 130:14, 14, 23 131:1 132:4 213:8 260:4, 5, 11,12, 19, 23girl 154:12 243:8 282:13girlfriend 78:22gist 53:18Give 10:5 25:21 40:3 44:6 48:18,18 50:22 54:7 61:5 65:3 74:23 79:1 81:2 83:7 85:7, 13 105:21 113:16, 16 126:15 161:7 168:10 176:21 195:15 224:5 235:23 236:14 238:14 252:13 258:4 259:20given 40:17 51:1 58:10 69:11 88:9 90:5 152:4, 9, 10,12 170:14 235:22 252:15 255:19 267:8 275:2, 10 282:8gives 35:12 239:25

giving 8:24 30:6 42:4 52:7 55:1 139:14 211:22 252:8 255:5glad 190:24Glaviano 174:18 175:23 216:17, 23 217:4 225:1, 4, 6, 8Glaviano's 216:24glove 15:13go 9:14 10:9 12:23 13:18 19:7,16 20:21 28:2 30:15 42:25 43:7 54:14 68:16 74:8 76:14 83:23 95:18 100:10 103:11 105:2, 17 109:2, 11 111:17 114:1, 7 118:24 121:9, 13 125:6 126:12 133:19, 20 135:8 136:8 138:18, 21 146:5 148:2, 5 158:5 161:21 165:6, 7 171:17, 21 172:11,15 176:22 181:3 183:9 185:23 186:11 187:1, 4 192:16 193:24 195:18 199:11 200:3 207:11, 25 212:20 214:18 237:14 238:21 239:7 242:24 263:13 270:20 280:18, 18, 18go-ahead 90:25God 144:21goes 31:18 67:24 91:3 102:13 121:5 186:3 188:19 196:4 197:5 244:25going 7:14 8:3, 15,17, 20 12:21 14:22 30:2 31:3 40:4 42:2, 24 43:2, 7, 7 48:17 50:11 53:13, 20 62:6, 15

65:3 74:15 85:15 86:20, 23 87:12, 18,19 90:22 95:12, 15 100:8, 14, 23 101:10 109:22 110:7, 9, 20 111:3,17, 18 112:15 114:23, 24 115:4,25 118:8, 24 120:16 121:8, 14 125:10 126:1 128:6 129:16 132:4, 5, 6, 7 135:8 136:8, 25 138:18,22 139:13 153:11,17 156:9 163:11 164:13, 14 165:16,19 168:10 171:11 175:25 176:10, 20 182:13 184:8, 8 186:16 187:6 189:7, 17 198:24 205:9 207:11, 14,25 214:16 217:11 218:14 219:6 235:8 239:7 244:10, 10 248:22 254:22 256:10 262:20 284:3, 4Gold 209:9, 11Goldman 38:12good 54:9 100:9 103:3 129:13 197:22 202:10 204:17 213:24 251:9 254:8 269:19, 19, 21, 22 270:17Goodwin 253:16Google 211:23Googling 212:5, 12,18, 20gotten 11:22 129:5 138:25 140:1, 2 250:17grabbed 209:11granted 123:15gray 186:16, 19great 35:11Green 180:22Greenberg 2:8

group 114:3 144:3 207:21 234:24guess 33:12 52:25 157:4 190:9 193:4, 15 215:13 261:5 283:16guest 148:16, 22 149:1 274:3guests 148:12guidance 101:22guidelines 194:1Guild 6:9guilty 82:16gun 178:11, 18, 19,24 179:10, 21, 25 181:4, 14 185:13,14guns 117:17 181:10guy 36:24 67:10 82:14, 15 105:5, 6 154:17 188:18 202:13 241:2 243:15 282:12 284:11guy, 105:6guys 91:17 129:15 150:20 164:2 179:16 196:12, 14 241:17 243:4guy's 29:23 82:20

< H >habit 147:21half 13:25 23:3 38:24 39:3 54:25 62:1 81:21, 22 84:13 118:16 223:15, 15halfway 20:16hand 46:7 128:6 192:1 251:21 254:4 287:20handed 15:17 54:23 57:3 76:8,11 109:17 151:6 162:7, 19handgun 179:2handing 150:21

handle 35:12 149:15 213:11 244:23 255:13 257:10 282:2handled 43:23 44:3 70:8 84:6 87:9, 14 89:4 110:4 111:14 149:10 213:18 274:18 279:21 282:16, 18handling 28:12 80:16 210:3hands 213:16handwritten 201:3hang 74:2hanging 74:5happen 77:20 104:22 107:12 115:4 122:1 125:23 126:12 234:16 236:15 237:2happened 16:7 41:18 51:16 78:4 83:13 101:11 112:12, 14, 16 115:12, 13 122:3 125:23 126:13, 17 132:11 135:18 143:12 159:19 161:7, 20 170:2 172:15 176:2 187:23 188:3, 11 189:1 208:23 211:8 234:14 235:10 239:11 264:24 265:3 267:5, 11 280:23happening 263:21happens 121:6 148:6 230:19happenstance 22:7Harbor 12:11head 49:10 145:17 183:2 222:24 238:16 284:6headed 159:15 223:13

headquarters 104:10heads-up 30:7hear 72:2, 23 75:9,12 77:11, 15 81:19,23 84:13, 17, 22 108:16 135:25 142:24 153:24 158:21 170:5 207:6 212:14, 15,16 261:8heard 56:24 57:22 61:2 85:20 86:3,4, 14 105:5, 6 108:8 128:9 137:10 169:6 174:16 208:15, 17 228:3, 16 231:11,22 242:6, 12, 13, 14,18, 23 245:5 251:13 272:4hearing 105:23 175:11Hector 22:2he'd 17:22held 10:25 23:25 53:2 275:14he'll 83:24hellos 211:2help 12:1 13:1 27:8, 11 113:13 140:14 155:5 160:3 200:7 217:11 279:9helpful 137:3helps 120:17Henderson 71:3, 6 96:22 97:2, 4 99:19 100:2HENDRICKS 2:8 7:3, 3 25:8, 18, 20 28:2, 21 30:1, 6, 14 34:14 35:4, 18 36:3 37:24 39:18 43:8 44:19 57:23 58:1 59:7 60:19 61:7 64:2, 4 68:16 69:1, 21 73:19 81:14 84:9 86:11 100:9 106:15 112:18, 24

113:3, 6, 10, 13 122:10, 25 126:3,18 127:19 131:16,21 134:6, 24 135:9 137:24 143:2 147:5 149:17 150:8 153:1, 14 158:3 160:19 161:9 163:11, 24 164:5, 11, 16, 24 165:2, 18 173:6, 10,24 175:17 181:20 185:17 191:7 202:2 213:25 218:4, 7, 11 223:6 226:2 228:20, 23 229:11 232:23 233:22 235:4 237:11 239:21 240:19 241:4 243:25 244:14 246:1 255:8 256:2 265:5 267:19 277:21, 25 278:20 279:3 281:21 283:1, 22 284:7hereunto 287:20hesitant 110:18Hey 125:22 242:24 253:12Hickey 93:24hidden 112:11hide 272:24 283:10, 14Higgins 56:14 57:21, 22 60:13 71:16 86:4 157:1 175:10 188:2 206:16 208:7 231:1, 16 235:7, 17 237:18 246:25 247:14 255:1 257:19 275:22high 98:2 175:1 180:23, 25higher 11:7Highlight 94:16,19 95:12 107:2, 9 109:11 113:1highlighted 77:9

Highlights 3:20, 23,23 4:2, 2, 5 93:10 108:10, 17 112:9 133:6high-school 179:23hindsight 170:10hired 19:21, 25 20:4, 6 23:1hiring 195:23history 9:14 145:19 165:23Hoffman 5:2 223:18, 24, 25 248:7hold 270:19holding 275:15holiday 230:3home 49:9 66:18 68:18 98:17 99:6,12, 12, 17, 25 146:25 211:11 239:24 262:20, 22 263:23 271:23, 24 273:13homeowner 273:12Honest 202:13Honor 228:7hope 39:22 64:5 147:7 217:12 219:20hosted 146:25 147:3 154:23hour 65:6hours 15:20 155:6,7 187:13, 20 218:20 254:12 278:15house 72:24 79:14,18, 20, 21 157:21 241:25 264:25 279:8Howard 2:9, 14how'd 112:15how's 121:8 241:2HR 195:24 196:15 197:5, 5Hughes 2:9, 14Hull 95:25 106:21 107:8

hundred 31:15 56:21 116:2, 7 220:18 278:1Hundreds 8:6 9:8hurricanes 21:20hurt 54:4husband 79:11, 13hypothetical 274:19 281:22hypotheticals 280:22

IA 191:25ICE 142:6, 10, 15 213:17ID 169:14idea 31:7 93:13 109:2 117:4 122:22 138:9 173:6, 21 179:23 212:20 213:24 235:20ideally 31:9identification 29:19 30:22 64:16 93:7 100:18 106:25 109:15 115:21 117:21 119:15 151:4 160:25 167:17 170:23 172:7 174:8 177:2 178:15 179:18 190:22 222:21 238:2identified 31:20 32:25identify 6:20 109:3, 6idiot 35:23Iliana 14:7I-l-i-a-n-a 14:7ill 11:25illegal 235:1illicit 103:14illness 15:2immediate 43:18 183:23immediately

158:12 245:10impact 64:23impaired 250:5 273:10impartiality 287:18impede 250:20impetus 224:12, 20implemented 200:16implied 264:13, 15implying 261:19important 172:1impression 26:21 137:13, 14 176:20 212:4 252:12inaccurate 127:5inadequate 227:25inappropriate 29:2 108:9 178:4 234:21incidences 109:10incident 16:1, 1 17:10, 14 46:24 47:1 61:23 94:5 114:11 115:1 132:18 142:22 209:8, 24 211:7 212:1, 2 239:11incidents 44:22 98:15 101:24include 24:24 86:19 97:20 108:17 133:5 151:9 221:5included 25:4 152:24 198:13including 53:8 138:3, 5 206:7incomplete 127:3 281:22incorrect 117:19 123:24 125:13increase 248:13incurred 221:23independent 191:17 215:2 287:14, 15indicated 6:4 58:21 59:2 100:15, 20 129:20 130:5 187:13, 19



218:15, 19 254:12,18 285:6indication 80:13indirect 214:25indispensable 221:10, 12individual 29:11 30:4 66:16, 17 68:19 71:17 72:10 73:15 75:25 78:18 99:3 120:7 125:8, 12, 16,18 126:21 141:2, 9 142:8 148:22 167:4 169:21 179:20, 22 198:9 236:23 250:4 273:12individually 1:4, 4,10individuals 51:21 52:4 61:13, 16 62:5 78:24 102:9 104:4 110:15 132:9 137:7 143:13, 16 144:2 162:13 196:14 197:1, 16 209:24 237:4 243:12 244:4individual's 69:9inebriated 210:7,12, 15influence 171:25info 74:23 83:7 284:11infor 52:3inform 47:3information 23:16,19 28:6 32:9 33:3 35:19 36:10,15, 19, 23 37:11 42:3, 18 44:7 47:4, 8 48:1, 1, 15,21 49:1, 3 50:8, 14,15 51:11, 18 53:24,25 54:19, 24 55:15 57:14, 19 61:3 69:16, 24 70:2, 15,20 71:9 72:13 74:7 75:16, 18

77:17 78:14 79:2 80:3, 18, 21, 24, 25 81:4, 5, 7 85:8, 13 86:14 88:9 89:7,12, 15, 17 90:25 94:1, 6 95:15, 20 98:20 103:1, 14 104:15 105:1 107:15 110:6 112:25 113:2, 17,20, 23 114:10, 19 120:13 123:24 124:8 126:16 129:9, 11 132:10,18 133:9, 12 135:6,6 142:7 148:4 149:25 150:6, 11 151:24 152:6 153:9 154:8 157:23 158:1 159:4, 9, 11, 18, 20 160:17 162:20 169:21, 24, 25 174:16 176:25, 25 177:5 180:7 181:23 182:8 184:19 185:6 188:10 189:8 191:21 197:5, 7 201:10, 25 217:1,21, 22, 25 225:18,22 230:7, 10 232:22 234:6 235:22, 23, 24 238:12 247:22 252:2, 3, 6, 12, 13,15, 20, 22, 25 255:11, 16, 18, 19 256:7 258:1 261:24 265:6 274:21, 23 275:4,18 280:11, 15 282:2, 3, 8, 10, 22 283:18 284:12information, 48:14,14informed 46:9 47:25 56:3 57:6 58:8 78:25 86:16 107:24 141:10

176:11, 23 188:22 220:4, 22 241:12informing 49:15ingrained 102:3, 6initial 53:21 101:19 163:6, 6 195:25initials 122:17initiate 89:5 151:19 169:22 171:9 200:12 201:4initiated 99:22 158:24 162:7initiating 152:11initiative 98:8, 23initiatives 97:16,17 98:1 216:13innuendos 102:18 143:7, 22 207:16in-passing 259:17input 98:11 196:21inside 15:13instance 133:5 168:23 198:17 257:18instances 237:7instruct 30:2 164:13 165:16instructing 29:8 163:17, 19instruction 252:19insurance 149:4 157:11 169:4inten 193:17intensity 44:21intentionally 240:18interact 176:22 214:25interaction 24:21 29:12 54:1 111:9,25 141:2 194:10 199:17 207:7 215:1, 20interactions 163:22 197:19interested 273:16 287:16interfere 243:11, 22

interfering 150:10 233:20 234:17 245:22, 24interior 64:20intermediate 284:16Internal 70:18 71:20 86:23 87:7,12, 25 88:7, 10 89:3 90:13, 23 91:5, 7, 10, 17, 19 92:8, 10 101:13 114:18 118:11 141:17 151:19 152:1, 5, 13 162:6 168:2, 6, 18 169:14 181:22 184:20 185:4, 15 186:3, 6 191:22 195:10 205:3, 9, 18 225:25 232:10, 15 234:10 236:12, 17 264:20 268:8 269:3 275:6, 10 276:11International 201:13Internet 29:13 142:9Interoffice 4:7 146:24interpreted 100:5 272:23intervening 221:15,18, 19interview 175:9, 14 194:1, 22 195:22,25 196:4, 5 198:5,11 208:9, 18 255:1,5interviewed 238:10interviewing 71:17interviews 196:9intoxicated 69:10 273:9intoxicating 244:5introduce 48:6introduced 54:18introducing 53:14introductions 131:8invading 112:24

investi 141:14 246:16investigate 48:2 91:7 227:1, 19 236:13, 16 261:14 264:16 275:20investigated 87:22 92:8 162:17 264:20investigating 8:2 71:17 89:17 140:21 141:25 142:4 182:13 233:13, 18 237:8 243:10 275:3investigation 15:18 28:5 29:5 30:3 33:16, 24, 25 34:9,13, 21 36:10 43:6 50:19 54:22 61:25 69:18, 25 70:1, 10, 14, 18 71:13, 21 80:16, 17 82:6, 7, 10, 21 83:10, 13 85:15, 20,25 86:19, 23 88:1,2, 8, 11 89:3, 19 90:10, 13, 14, 23, 24 91:3, 3, 5, 25 92:3,4 99:1, 11, 18, 18 100:3 111:18 130:16 146:10 149:12 150:1, 10,15, 18 151:19 152:1, 12 168:7, 11,18 169:12, 23 181:23 184:20, 25 185:5, 7, 15 191:22 192:12, 20 212:23 213:16, 22, 23 214:17 219:2 227:2 230:19 232:11, 14 233:2, 5,19, 21 234:10, 18 236:10, 15, 19 237:20 238:11 243:19, 23 244:5,10, 24, 25 245:22,24 246:16, 18 247:10, 13 249:17 251:19 255:6, 21

256:4, 10 261:20 264:13, 22 274:16 275:1, 7, 8 276:4,12 284:17investigation, 39:16investigations 28:11 32:10, 19, 20 37:11 71:2, 4 91:11 97:23 140:7, 12, 15 141:23, 24 227:23 276:9investigator 87:8 132:7 142:16 168:2 205:3 213:17 248:13investigators 46:17 48:8 58:9 91:24invited 148:13, 13involve 34:20 37:12 213:21involved 16:2 17:22 18:4 26:23 27:7, 20, 24 29:4 32:18 70:16 72:10 78:19 88:13 98:7 104:5,25 107:18 110:3 114:6 130:22 140:15 172:16 174:22 190:14 197:12 213:24 214:8 239:18 241:14 243:5, 13 244:6 265:12 282:5 287:16, 17involvement 82:22 212:22 213:5 214:20 216:4, 8 217:20 228:2 276:18involving 27:14 28:16 32:20 44:23 71:16 142:22 240:3Ironically 235:17ISO 193:6issue 38:18 41:10 43:15, 21 84:7 101:3 107:20 108:8 117:17

140:19 182:18 192:1 214:22 215:11 225:9 247:4 256:16issued 132:15, 16 181:7issues 17:21 19:3 26:14, 16 27:2, 5,15, 16 37:2, 4 38:2,4 39:9 42:17 44:21 91:20 98:17 108:15 110:16 112:20 130:17 163:16, 25 164:18 165:5 192:8 197:21 201:20 204:14 207:22 208:13 213:11items 178:3 258:23, 25 259:2its 261:23 262:2

< J >Jack 63:22 277:12,14 278:9Janu 282:9January 3:17 4:2,7, 15 157:24 159:7 226:8 227:13 282:10Jerry 113:9Job 1:25 9:15 12:22 35:11, 24 40:18 215:14 257:6 282:21Joe 92:7 204:11,12Johnson 2:6 7:5 87:8 89:11 118:6 162:8, 20 163:1 168:14, 24 183:1, 5 186:2, 4, 10 205:14 230:19, 21 232:11,15, 20 233:6 234:5 235:18, 22 236:4, 7,11, 15, 18, 23 248:10, 24 249:2, 7 253:11 264:19Join 35:18 64:4 68:16 69:5, 22

131:24 135:1 149:18, 19 153:14 158:6, 7 159:25 172:5 174:3 175:19 191:9 204:1 221:9 231:25 232:25 233:24 235:4 237:12 239:21 244:16 265:5 277:25 278:17, 20 279:3 281:23joined 19:17joint 71:2, 4 97:22Jones 25:3 26:4 28:10 30:10 31:5 32:14 33:8, 11 37:21 44:12, 25 46:3, 18, 19, 20 47:9, 20 50:13 51:5 52:11, 15, 20 54:15 55:6, 15, 24 56:18, 23, 24 57:10,19 59:11, 17 60:8,18 92:17 131:1 132:14 133:13 136:7, 24 178:6 184:6 213:8, 21 214:15 224:9, 16 227:17 257:22 260:11, 17 261:2,13, 25Jones's 74:16 85:19 92:16, 17 130:12 138:10, 16Journal 116:10, 12Journalism 117:6JR 116:13, 13July 1:18 3:23 4:21 6:2 45:17,23, 23 46:11, 12 47:10 50:11 51:5 57:13 59:12 74:24 75:12 84:16 101:3 128:9 135:19 136:6 143:1 145:8 146:2 147:3 153:11, 11,25 154:15 155:2 156:3 158:21

160:11 170:14 190:10, 18 201:25 239:2 258:8 287:21July's 229:20jumped 98:18jurisdiction 99:8,10 139:13justifications 105:23Jutta 97:4juvenile 67:15 141:3 279:4

< K >Kadlub 73:22kajillion 269:9KARA 2:8 7:3 173:2 223:5Karma 134:18keep 13:12 48:17 85:11 99:21 150:21 177:23 203:18 236:9 252:23Kelesis 2:3 6:5KELLER 2:18 3:6, 8 6:24, 24 149:8, 19 158:7 159:24 172:4 184:1 203:25 227:15 231:24 270:15, 17, 21, 22 272:18, 21 277:3,22 278:4, 17 280:2Ken 203:9, 20KENNETH 2:20 6:7kept 120:10 217:16, 18Ketsaa 4:20 47:1,5, 25 48:16 49:2 51:3, 9, 12, 16, 21,25 52:6 54:23 77:19 79:1, 2 80:25 83:18 86:1 87:9, 15 89:11 95:3 108:12 125:1 128:15, 20,22 142:7, 12 162:7,8 163:1 168:15

169:1 179:24 180:5, 5, 19 182:9,13 183:2, 5 186:12 196:25 212:25 213:10, 23 214:2, 7,14, 19 215:7 217:24 235:25 236:3, 5 241:15 246:19 247:20 252:3, 4, 11, 19, 21 253:2, 6 264:18 284:15Ketsaa's 78:3 88:3, 8 125:24KEVIN 1:9 2:15 148:13 149:1 228:15, 18 239:23 242:3, 19 270:18,23 272:2 278:4Kevin's 273:15keys 67:16kid 55:11 56:15 63:25 66:12 67:7,15 68:23 86:6, 6 98:24, 25 181:3 243:16, 21 249:24 250:1 262:16kids 14:11 98:17 99:25 119:5, 8 175:10 209:2 262:24kid's 66:13kids, 57:20kill 67:10killed 85:2 89:14 154:12, 17 157:12 175:3, 5 228:8, 14 282:13kills 153:22 158:19 188:19 249:25kind 8:11 44:7 83:21 105:13 108:24 198:14 224:13 254:22 264:3 277:10Kinda 215:9Knapp 44:5, 8 45:14 46:21 53:24, 25 61:15 284:2

knew 30:10 72:12 79:19 81:9, 12 82:11 133:7 138:9 153:19 154:4, 5 155:24 188:20 208:22 217:9, 10 223:21 228:11 229:2 237:18 241:10 279:10, 20 281:1,15 282:15know 8:20 16:21 21:22 22:21 23:10 28:18 30:13 31:19 35:2,23 36:20 37:9 39:14, 16 43:6 46:10 51:9 53:17 54:17 55:8, 9, 9 57:6, 11, 12 60:2 71:21 72:1 76:14 77:7, 25 79:14, 18,20 81:11, 25 82:15,18 83:19, 20, 21, 25 84:2, 21, 25 85:3 87:14, 19 94:11 96:3 102:21 104:21, 21 106:20 107:5, 5 108:23 109:6, 8 116:24 117:2 119:5 124:17, 22 125:23,25 126:10 127:8 132:11 133:19, 24 134:3, 20 136:23 139:17 142:11 144:15 146:8, 11,12, 15, 20 147:3 148:20, 21, 24 149:24 150:14, 20 153:10 154:7, 14,19 155:1, 8, 10, 11 156:6, 13, 16 159:5 162:25 163:11 164:21 167:8 169:17 173:3, 4, 9,11 174:18 176:19 180:18, 20, 21 184:15 188:20, 21 189:10 190:18 192:14, 24 197:3

201:18 202:7, 9 203:6 204:6, 11 206:1, 1 208:7, 9 210:2, 4, 13 211:24 212:6 214:10, 15 215:4 217:13, 24 220:1, 1 222:6 223:9 224:23 225:18 227:3 230:7, 15, 16, 21 231:3, 8, 19 232:13,16 233:2 235:10,19 236:2, 2, 10 237:20 240:8, 17 241:3, 6, 23 243:20,23 247:9, 15, 18, 24,25 248:2 250:3 252:8 253:19, 23,25 255:19 260:1 263:24 268:19, 23 272:18 273:15, 16,18 274:6, 10, 24 276:22 279:4 281:4, 8, 25 282:23knowing 43:4, 5 157:19 217:3 282:15, 22, 23knowledge 124:2 167:7 189:2 197:16known 170:11 237:19 284:5knows 35:1, 11 123:23 124:8 125:2, 13 233:18 248:1

< L >LaBorde 1:24 6:12 287:5, 23laches 220:11lack 26:18 110:10language 31:8laptops 201:9large 215:3Las 1:22 2:4, 10,15, 20 6:6, 11 97:13 99:19 100:2 147:1 235:18, 21



lasted 131:4late 227:13Laundromat 12:4,6, 15 13:7, 15, 20,22 14:23 24:9laundry 13:24LAURSEN 2:20 6:7law 9:15 24:8, 10 26:19, 22 34:22 65:23 66:17 67:22 91:1 96:22 99:16 191:17 268:22 273:25lawful 35:20, 25lawsuit 72:3, 6, 14,15 163:13, 17 169:7 219:25 221:5 266:2, 7 270:24 276:23lax 140:2laxed 138:25 139:16 140:1lead 43:16 105:2,4 185:6leads 75:18learned 157:16 270:1leave 11:17, 21 12:22 20:9 177:8 211:3 265:11 274:12leaves 158:17 188:19leaving 17:11 21:15 24:16 62:7 173:22 191:19 251:1, 7 273:13led 17:11 28:17 36:23 38:3 39:9 41:24 42:5 54:22 88:10 103:21 106:5 108:16 109:10 143:17, 18,21, 22 144:1, 1 145:8 158:23, 24 160:10 161:6, 7, 20 162:14 175:7 180:6 182:22 183:3 190:8, 9 194:13 201:25, 25

Lee 16:13, 18 17:10, 15left 14:25 15:13 17:18, 20, 23 18:22 19:15, 20 20:12, 13 21:10 23:7, 10, 14 26:10 78:20 85:2 89:14 147:19 152:16 155:4, 11 157:17 174:5 177:7, 15, 19, 19, 24 178:9, 10 179:5, 6,9 180:12 190:15 202:8 203:12 211:7 215:24 231:17 250:13 254:8 263:11, 14 282:12Legal 2:23 6:8 66:8 172:19 192:7 223:25 248:8legislation 139:14Letter 5:4 143:11 184:9 223:18 225:6, 13 226:5 227:1, 11 238:23 242:7, 7 253:12 261:23 262:2letters 225:21 239:1 240:12letting 181:18 201:25 210:2 263:24level 66:1 87:5, 9 166:16 167:7 217:14 274:5levels 31:12leverage 192:2Lewis 2:13liability 219:16liable 221:3liaison 205:11licensed 287:5lie 126:11, 11 235:9 245:13, 19lied 131:13 149:6 237:17 238:9, 11lies 149:14 150:5lieu 111:1, 3

lieutenant 11:14 20:13, 15, 21, 22 93:21 98:6 118:7 143:23, 23 180:3 182:4, 20 195:1, 6,8 197:20, 25 201:18 202:5, 7, 9,17, 20 209:9, 18 210:2, 17, 18 243:20 270:3, 8lieutenants 95:13 196:24Life 4:15 265:13light 217:13 226:5,6, 20lights 175:1liked 170:11likelihood 147:13limit 220:14 222:9,18limited 219:17 222:15 259:8 282:9, 11limiting 57:14LINDA 1:4, 5 2:25line 123:2, 10 124:5 138:23 145:2 148:8, 9, 11 156:2 164:19 278:11 286:2lined 248:14lines 60:15linked 200:25list 48:24 153:6 240:15listed 152:16 155:25 180:22lists 153:7 155:25lit 224:13literally 193:24little 25:21 26:2 33:8 74:23 94:9 96:23, 25 158:10 160:22 192:10 194:12 204:16 206:19 254:25 262:18 267:16lives 174:24LLP 2:8, 13local 68:20located 6:10

location 6:4 68:21 199:15 209:19locks 105:11logged 171:18, 20logo 119:19, 24 120:17, 18, 23 121:9long 9:21 12:5, 14 13:15 14:8 17:23 18:13 19:12 23:2 24:9 40:21 52:24 131:4 136:13 206:20 236:22 237:5longer 25:5 42:25 52:22 71:24 156:22longstanding 90:18look 64:18 82:11 90:11 93:20 94:19 100:24 135:7 147:24 167:20 169:19 214:15 224:8 238:20 268:10, 15 271:18 273:18 274:9looked 110:21 175:9 257:16looking 65:1 120:18 121:3 149:21looks 31:8 68:7 124:3, 15 125:6 131:13 178:24 179:4 238:24Loren 2:6 7:5 87:8 118:6 162:8,20 163:1 168:13,24 186:2, 4, 10 230:21 232:19 233:5 234:5 248:10, 24 249:2, 6 253:11loss 44:16lost 73:14 207:12lot 206:9 237:4loudly 137:21love 102:15 144:22 194:16

lunch 129:15 130:8Luncheon 129:22LVMPD 93:25 94:1lying 149:23 150:7 175:9 238:13 267:14

< M >made-up 269:1, 8,10magazine 172:25 173:8magistrate 165:6, 7mail 74:12mailed 185:12main 34:5 78:7 107:19 141:1maintain 119:4, 4majority 58:8 101:4making 67:14 75:23 86:6 87:2 102:7 125:8, 19 165:22 203:24 216:24 260:14man 69:9 265:9manage 193:14Management 193:2, 18 201:1manager 108:13 171:6 193:21 207:8manner 42:2 158:15 221:2 277:19manpower 236:22manual 200:13MARC 2:3 6:22 7:13 30:1 54:9 112:18 161:1 172:24March 4:12 263:14Marisa 229:15Mark 2:10 4:21 155:25 156:1 176:14 184:8 191:4 266:10

268:2 269:2 273:1, 4, 16 277:17MARKED 3:15 4:1 5:1 29:17, 18 30:21 64:15 93:6 100:17 106:24 109:14 115:20 117:20 119:14 120:9, 12 151:3 160:24 167:16 170:22 172:6 174:7 177:1 178:12, 14 179:17 190:21 222:20 238:1married 14:8 156:11Master 285:3match 129:9Matt 7:1 265:19matter 7:14 8:8 29:7, 23 55:3 65:21 67:19, 21 69:19 110:3 130:24 142:17 147:25 213:12 214:23 224:20 227:18, 21 256:13 267:9MATTERS 1:13 34:23 228:4 276:13MATTHEW 2:13Mayer 171:3, 4me, 216:24mean 13:24 15:25 18:20 69:7, 7 87:2 103:11 105:2, 11 111:25 115:8 118:21 123:19 137:18 145:18 147:19 149:20 150:24 152:8 162:24 168:1 171:15, 21 173:18 184:17 188:15 198:10, 18 223:9 237:2 240:17, 23 244:11 250:23 271:22

272:4 280:4, 7 283:9means 27:22 67:11 138:9 168:21 171:22 192:11 209:7meant 8:14 118:9media 44:20 48:4 57:4 60:4 75:15 114:25 132:16 133:25 137:7, 11,17 206:10 226:6,20 228:16 229:5,10 232:1, 3 242:15,20 255:20 257:20 259:23medication 8:23meet 46:15 48:5 53:19 103:6 104:4 194:1 199:11, 14 207:4 264:1meeting 51:5 52:11, 12, 14, 16, 16,17, 20, 24 53:1, 10,18 54:15 56:7 58:6, 14 59:6, 12,13, 16, 19, 21 75:2 92:15 95:11 130:13 131:8, 14 184:5 200:2 206:6, 15, 17, 24 207:9 211:12, 17 213:1, 7 259:1 260:6, 10meetings 57:13 59:5, 7, 11 73:7 133:2 193:13 199:17 200:1 206:24 258:17, 19meltdown 250:9Member 6:8 24:25 106:3 127:7members 71:13 93:15 103:4, 13 104:25 144:5 207:10 242:5memo 109:12 116:22 122:7, 9, 14 126:15 146:24

149:6, 14 161:21 177:4Memorandum 4:9,12, 18 23:22 49:14 108:3 121:10 125:7 157:24 161:13, 17 171:10memorandum's 161:18memory 73:17memos 147:21 167:2mentioned 14:6 46:23 50:7, 25 59:10 62:2 78:25 79:6 117:3 122:7 130:24 143:9 194:8 198:21 225:9 259:24mentioning 253:14merely 192:15MESSAGE 93:21 94:20 95:1, 2 100:25 109:18 117:24 211:23 212:4messages 94:23messaging 263:23met 42:11 48:7 52:15 53:12 56:18 110:19 115:2, 14, 16, 17 130:15 141:7 142:19 194:15, 18 204:16 209:23 223:5, 23 234:11 249:7, 12 257:22 258:17 260:23 261:12 279:8metal 114:1, 4Metro 47:3, 4, 6,25 48:1, 18 50:16,23 54:25 61:24 70:8, 13, 14, 20 71:16, 18 79:3 80:15, 21 82:2, 9 83:7 85:14, 21 88:19, 20 89:5, 16,18 90:3, 4, 8, 24, 25 91:1 92:5 96:22 97:16, 18, 19, 22

98:13 99:4, 19 100:1 120:5 128:16, 17, 22 149:12, 16 152:7 170:15 174:24 182:17 210:3, 7 216:5, 8, 14 225:16 233:13, 17, 18, 21 234:17 235:18, 21 238:10, 14 241:14 243:10, 18 244:6 246:18, 20 247:13,13, 22, 25 251:18 252:1, 12, 25 255:10 274:18 275:2, 5, 7, 11 276:4 280:6, 12, 14 281:15 282:3, 18 283:19Metro, 50:14, 21 252:20Metropolitan 69:24 86:18 91:15 97:13 98:6 99:9 118:5 209:21 284:16Metro's 80:17 82:5 90:5, 14 243:22Miami 9:16, 18 11:1, 2, 4, 9, 17, 22 12:23 14:22 15:1,5 16:18 17:8 18:25 19:20 24:11 35:10 62:23 63:10Miami-Dade 18:22Michael 14:20micromanage 83:22microphone 138:13middle 93:20 98:3,16 101:5 136:17 148:11mid-February 224:16Mike 145:4 161:21 163:5, 9, 12,15, 25 164:6, 17, 20 165:4, 5, 14, 21 166:10 190:7

211:13, 16, 23 212:11, 17, 17, 19 263:2 270:20mile 112:1miles 65:5mill 102:12 110:5,22 193:15 206:8 207:25mill, 103:9mills 112:6mind 26:6, 12 58:15 81:16 97:25 117:18 159:21 227:23 236:9mind-set 214:7Mine 95:19Minimally 281:14minimum 258:16minor 63:21 66:16 68:5, 10, 11 69:10, 17 71:11 89:13, 14 181:3 250:3 272:14 273:8 274:11, 12 275:16, 23minors 70:12 209:5 271:14minutes 52:25 53:13 58:17 100:12 130:18 131:5 176:9 187:5, 7 254:7MIRANDA 1:9 2:15, 15, 17 6:16 56:15, 25 61:4 148:14 149:2, 5 153:21 157:20 228:15, 18 230:14 231:3 232:12 239:23 242:19 270:18, 23 272:2,22 277:11 279:8,10 280:24 281:1, 5 283:10Mirandas 6:25Miranda's 45:20 158:17 229:6, 16 278:4, 7 279:15 283:6

Mischaracterizes 278:18misdemeanor 65:17misinterpreted 101:7misstate 267:2misstatement 272:16misstates 25:8 28:21 30:14 34:14 143:2 147:5 158:4 255:9 277:24 283:15mistaken 18:15 45:19 47:6 71:16 108:4 114:9 116:11 193:7 198:7 201:15 249:5 263:12mitigate 222:4, 5mitigating 222:6mixed 277:12 278:8model 178:19 179:7modify 97:7mom 13:14moment 54:22Monday 1:18 6:2 46:25 48:20 49:4,19, 23 50:1, 18, 21 73:1, 2 77:12 79:23 80:4 188:16 228:17Month 21:6 103:7 124:3 207:5months 12:8, 20 13:2 32:15 41:1,17 136:16, 16, 19 148:7 200:14 201:2 223:15 229:24, 25moot 216:4moral 66:8 67:25 68:2 271:16 272:10 273:19, 21,23morale 120:6Morales 2:12 7:2 118:7 143:24

154:24 195:5 209:9, 20 230:6, 20,21 231:2 232:12,12 234:11, 24 235:8 236:11, 16 237:15, 17, 19, 23 242:4, 18, 24 243:14 249:23, 25 253:20 265:20 269:14, 14, 17 270:6 277:8 281:17 283:6, 8morality 273:3morally 69:7 250:5morning 48:20 50:18, 21 52:5 53:10 73:1, 2 77:12, 21, 24 79:22 142:21 147:2 149:1 158:14 160:7 181:14 188:10 226:9 243:2 252:17 260:10morning's 130:10motivation 101:21,21 160:18 163:20 164:3motivational 103:19mouth 51:23move 131:16 160:21moved 12:9MPS 192:24 193:23 194:6Multiple 7:22 144:5 201:2

< N >nagged 264:8name 6:7 7:13 14:6, 17 19:24 29:10, 24 46:23 113:15, 16 144:16,21 145:9 148:21 193:22 194:17 221:11 270:17

named 17:3 171:3 179:24 219:25 239:25names 48:2, 24 49:10, 24 50:6, 17,20, 22, 25 51:19, 22 52:3 78:24 79:6 81:2, 11, 15 146:3 246:17, 23 247:21,24 248:1, 2 251:18,25name's 265:18naming 163:13Narcotics 10:2, 10,11, 12, 16 11:2narrowed 257:23national 216:3nationwide 23:9nature 58:12 78:21 132:21 205:12 255:25 257:15Nebeker 2:6 7:5 48:21 77:16, 25 78:9 80:6 81:8 118:8 125:24 143:23 159:10 180:5 188:22 195:3, 5 198:12, 19 199:7 217:23 235:25 245:15 252:2 262:4Nebeker's 124:6necessarily 15:22 100:4 162:21, 23 213:13 225:16necessary 221:9, 11necessity 101:8need 8:16 9:3, 5 31:1 43:6 65:4 70:20 82:7 134:18 138:12 151:19 183:23 184:19 186:25 187:1 201:10needed 40:16 155:15 199:5 200:21 234:25 256:5, 24needs 185:3 200:22 257:15

negative 139:8 197:19negligence 219:14 220:8negotiation 37:2nephew 262:22NEVADA 1:2, 22 2:4, 10, 15, 20 6:6,11, 15 91:16 92:6 106:2 287:1, 5, 20never 23:17 39:15 50:25 51:23 54:25 63:10 73:10 82:13 102:2 103:5 116:8 130:22 139:21 151:8 159:14 166:16, 17 176:2 197:21 198:5, 21, 23 205:19 206:4 207:20 214:13, 14 217:20 232:12 235:17 237:19 243:15 244:10 245:22 248:7 253:2 263:22 264:15, 21 266:18 267:5, 10, 23 268:1new 121:5, 18, 19 159:20 164:7, 7, 7 165:5 167:9, 11 168:23 252:23news 44:20, 22 56:5, 13, 17 75:13,24 76:8, 11, 21 77:8 83:2, 3 84:14, 24 85:3, 7 129:4, 5 133:20 134:2 135:19 136:20 143:18, 22 144:1 153:11, 25 154:15 155:2 156:3, 17 159:22 160:10 170:3 208:17 213:7 226:8 227:12 228:18 255:1 257:20

newspaper 29:16 60:22 116:2 248:17nice 150:24Nichole 228:7Nick 211:22 212:5,7niece 262:23night 154:24 155:6, 7 198:25Ninth 1:21 2:4 6:5no, 75:18Nobody's 29:8 136:8nodding 147:7 222:24normal 87:13normally 264:19North 2:9 99:19 100:2, 2note 53:23 117:11notes 117:12 287:11nothing.' 217:15Notice 4:7, 15, 21 23:21 121:15, 18 171:12 179:21Noticeable 63:15notification 60:23 93:14 134:1 241:15notifications 61:24 62:4 74:3notified 47:25 67:16 255:10, 11,15notify 66:18 67:5 68:18, 20 99:19 127:2 128:15 132:6 190:2 256:14 273:11, 11noting 159:9not-investigated 227:25November 14:10 85:1 146:24 147:14 154:2, 9 155:14 156:11 157:21 158:15

159:10 213:1 228:6 241:9nowhere, 105:4NRS 268:15, 19 269:9, 10NUMBER 3:15 4:1 5:1 6:8, 14 31:10 58:19, 25 129:18 130:3 152:4, 5, 9, 10, 12,12, 13 162:11 169:14, 15, 16 182:18 187:11, 17 207:21 220:21 221:14 238:5 254:10, 16 258:23,25 275:10Numbers 3:20 191:25 201:4numerous 230:4

< O >Oasis 6:10, 13 285:4object 25:22 122:25 159:24 184:1 231:24Objection 25:8 28:2, 21 30:14 34:14 35:4, 17 36:3 37:24 39:18 43:8 44:19 57:23 58:1 60:19 61:7 63:17 64:2, 3 66:15 67:2, 12 68:15 69:1, 21 73:19 81:14 84:9 86:11 106:15 122:10 126:3, 18 127:19 131:16, 21 134:6, 24 135:9 137:24 143:2 147:5 148:17 149:8, 17 150:8 153:1, 12 158:3 160:19 161:9 172:4 173:24 175:17 181:20 185:17 189:25 191:7, 12 192:22 202:2 209:14



213:25 226:2 227:15 228:20, 23 229:11 231:6, 13 232:23 233:22 235:3 237:11 239:20 240:19 241:4 242:8, 10 243:25 244:14 246:1 255:8 256:2 265:4 272:16 277:21, 22,23 278:16 279:2,11, 17 281:21 283:1, 15, 22 284:7obligated 67:23obligation 66:8, 9 68:2 80:17, 20 81:1 238:13 250:2observe 101:15observed 93:23 231:2 232:12obstructed 72:12obvious 69:10 186:9 215:19obviously 149:23 159:18 181:22 215:2, 22 234:25 273:15occasion 62:25 95:20 172:12 199:8, 14 223:10occasions 260:17,22occur 57:14 168:19 201:11 234:21occurred 47:20 60:12 61:23 79:24 122:24 215:24 233:3 258:5, 14 273:17 276:3occurring 41:18 98:15October 85:19 157:10, 15, 19 159:6 175:16 176:4, 13off-duty 96:8 183:22

offensive 172:21,23 173:16offering 106:1office 13:21 19:11 40:10, 12, 19, 22 41:21 44:11 47:16 53:3 73:23 74:1, 6, 9, 13 75:7,10 78:3, 4, 7 83:16 85:19 86:24 89:6,8 92:16, 17 102:25 104:12, 13 105:10,24 119:17 124:23 132:15 136:23 141:1 172:15 185:9 197:7 232:21 253:7 259:22 261:7 281:15office, 92:17officer 7:22 8:8 9:25 15:8 20:8,20, 21 21:5, 6, 6 35:10 55:19 61:4 62:18, 23 63:2, 5 64:8, 9 65:11, 12 66:14, 24 67:22 68:4, 5, 9, 12, 23 69:17 71:10 88:19, 20, 25 99:22 111:13 112:21, 21 144:19 145:14 146:14 150:12 161:14, 15 171:3 174:22 178:2 181:8 198:10 202:22 204:11 205:2, 7, 10 236:12 243:19 250:20 266:14, 15, 17 269:19, 21, 22 270:11 272:13 273:5, 7, 25 277:8,17 278:13officer-level 10:14officers 55:10, 25 56:4, 14, 25 63:21 65:20 66:10 70:4,4, 16, 16 86:5 91:12, 21 92:9 98:11, 15, 20

101:16 107:25 108:5, 19, 21 110:2,7, 10, 16 111:8, 10 112:12 114:5, 11,16 115:2 133:10 134:21, 23 136:22 137:10 145:2, 2 146:9, 11 171:15,16 174:24 189:10 205:8 206:7 207:3 209:1 228:2 230:5 236:25 240:4 251:2 265:10 273:6 280:23offices 6:5officials 3:16oh 13:8 18:24 22:16 45:4, 13 57:16 60:2 62:12 73:21 75:5 88:22 106:9 115:9, 17 116:22 119:22 136:2 157:16 177:22 178:8, 8 184:16 197:8 202:7 212:1, 7, 9 214:10 227:7, 7 242:14 249:9 273:7Okay 7:20 8:14 9:2, 8, 14 10:5, 8,22 11:11 12:9 13:6 20:6 22:17,24 23:19, 23 25:23 26:20 27:1, 13, 18,21 28:4, 15 30:16,19 31:17 32:5, 25 34:7 35:22 36:8,22 37:1, 6, 16 38:16 39:5, 12, 25 42:8 43:3 44:1,16 46:2, 22 48:13 49:12 50:11 51:4,16 52:14 55:14, 24 57:5, 18 58:5, 16 59:15, 23 64:12 66:7 68:1, 3 71:5 72:2 75:20, 21 76:6, 13, 13, 23 77:11 78:15 79:9,

17 80:20 82:9, 14,18 83:7, 19 84:4,16, 23 85:6 86:14 87:25 88:7 89:25 90:14, 18 92:1 94:19 97:20 100:6 103:25 104:15 105:13, 19 111:23 112:3, 4 113:10 121:2 122:5, 16 123:6, 18,22 124:15 125:18 127:23 129:13 132:11 134:10, 18 135:25 136:11 138:8 139:24 140:21 141:20, 24 142:13 143:6, 8, 20 144:7, 10, 14, 24 145:6 146:5 147:13, 18 148:6 153:19 154:2, 9 155:4, 8, 10, 23 156:14 157:10 158:25 159:16, 20 160:16 166:7, 20 167:6, 25 168:9 169:17 173:12 178:22 179:7 181:17 184:16 185:22 186:7, 25 196:11 197:18 198:6 202:22 204:11 205:13 207:9, 18 208:5, 7,15 210:19, 24 218:25 219:23 220:3 221:7 222:13 224:4, 19 227:7, 8, 10, 22 228:14 229:14 231:16 232:19 233:12, 17 234:9 236:6, 8 240:7 242:18 244:19 245:1 246:13, 24 247:20 249:6 254:23 256:25 257:8 258:4, 7, 12 259:3, 6 260:3, 9,24 263:8 265:14,

24 266:9 267:8, 16 268:12, 19 269:1 271:13, 16 273:2,21 274:6, 19 279:14, 20 281:4,11, 25 282:8, 15 283:18 284:10, 21okaying 195:7old 66:13 120:18,23 148:13 167:13,14 180:19 229:6 238:4older 14:19omission 126:12 220:8omissions 220:6Once 13:21 16:6 69:23 70:13, 13 85:6 90:9 91:4,13 103:7 160:22 167:8 176:5 197:8 207:5 236:24 258:16 275:11on-duty 67:22ones 60:8 174:23 258:1ongoing 33:16 150:10, 14, 18 246:16on-line 22:23onset 44:4open 54:20 99:18 132:4 152:11 184:20, 25 186:12,13 248:22 275:9 280:5opened 152:1, 6 169:17 191:25 280:11opening 23:5, 7 71:19 186:10 225:25openings 195:19 196:6openly 234:12open-minded 204:20opinion 54:2 139:23, 25 157:25

159:11 224:19 266:13 269:17opportunity 166:17opposed 88:18, 24 110:23 111:5 112:16 123:19 134:12 274:2option 147:19oral 196:9, 24orchestrated 200:2order 80:16 120:4 142:14 183:14 215:14, 21 256:11,14, 18 264:21 267:20ordered 111:16 245:10, 14 264:12,15ordering 276:19orders 33:1 183:11organization 10:4 62:8 105:22 106:4, 12 127:8 181:7 215:3Organizational 3:18original 46:24 47:19outlandish 104:8 116:7outside 98:24 139:14outstanding 183:14overadjusted 100:7overall 11:3 57:16 197:22overnight 104:22overseeing 241:13overstating 233:15owned 201:8owner 49:8 66:18 67:5 68:18

P.A.R.C 170:17 171:7P.A.R.C. 170:18p.m 285:9package 64:11packed 178:3

PAGE 3:2 74:15 122:17 138:19, 23 172:18 173:8, 10,15 224:8, 25 227:4,5 237:14 239:7 286:2Pages 4:17 5:4 151:7, 10 223:2paid 40:22 222:1Palm 12:11 19:8,10, 10, 18 20:1, 9,10 21:3, 10, 10, 16 22:3, 10, 10 24:12 63:1panel 196:18paper 29:24 33:1 192:15, 19 200:11,13paperless 200:24papers 53:22paragraph 93:22 94:2 101:6 105:20 106:6, 8, 9,10 118:2 119:10 146:23 148:12 155:14 168:19 169:3 175:8, 22 227:6, 22 228:6, 11 232:10 234:9 239:10, 23 242:3 245:9, 14paragraphs 151:25Pardon 138:13 187:7parent 68:20parents 67:16 220:13 222:17 270:23 273:15PARK 2:13 3:5, 9 7:1, 1 30:24 35:17 54:9 63:17 64:3, 13 66:15 67:2, 12 68:15 69:2, 5, 22 131:24 135:1 148:17 149:18 150:23 153:12 158:6 159:25 161:1 172:5, 24 173:4, 7,12 174:3 175:19 189:25 191:9, 12

192:22 204:1 209:14 218:12 228:24 231:6, 13,25 232:25 233:24 235:3 237:12 238:3 239:20 242:8, 11, 14 244:16 265:4, 17,19 267:21, 22 270:13 277:23 278:16, 18 279:2,11, 17 280:17, 20 281:11, 23 283:15 284:23Parkway 2:9, 14part 31:19 33:25 43:13 53:8 59:14 62:22 63:4 74:18 76:5 95:16, 17 96:1 112:19 114:3 164:3 171:4 173:7 191:16 193:11 197:1 204:19 207:2 209:20 215:3 217:14 225:5 246:16 247:9 252:9 256:4partic 199:25participated 95:25 97:11 199:25 247:3 277:2participating 56:5 57:20 278:24 279:15particular 16:7 20:25 29:5 31:19 33:1, 24 36:10 41:13 46:8 48:25 61:10 66:2 97:6,10 98:5, 16 101:18 102:14 104:11 105:19 107:24 114:2 116:5 141:11 145:4 167:5 169:20 177:20 199:4, 15 252:16 259:24 282:17particularly 42:20 43:24 215:19



particulars 23:18 55:1parties 210:25 219:14 220:21, 25 221:4, 9 287:15, 15,17, 17partly 201:7party 17:3 47:5 48:22 49:16, 19, 23 50:1 55:11 61:4 66:11 68:6, 9 72:24, 25 73:2 74:19 77:12 78:1,2, 10, 17, 20, 21 79:5, 22, 23, 24, 25 80:4, 10 81:3, 6, 6,9, 19, 20 82:1, 12,19 84:13, 18, 19 85:1, 2 89:13 92:13 122:12 134:20 136:1 147:3 152:20, 23 153:21 154:6, 23,25 156:1, 7 157:2,21, 25 158:17 175:16 180:4 187:24 188:3, 6, 11,17, 18 202:23 208:3 209:10 210:19 211:3, 14,18 212:24 219:1,23 221:9 230:3, 12,25 231:17 232:20 233:8 234:4, 11 235:7, 10 240:3 241:25 242:4, 19 243:16 245:6, 18 246:4, 25 247:2, 3,4, 15, 17 248:5, 8 249:17, 18, 23 250:16 251:1, 7 253:21 254:5 257:20 258:21 259:4 261:3 264:24 265:8, 22 266:1, 6 271:6, 10,14, 23 272:1, 14 273:1 274:3, 11, 24 275:14, 15, 22, 23 279:10 282:12

pass 80:22 92:5 99:4 149:25 191:14 195:13, 14,16 252:11passed 12:7, 20 13:10 49:1 54:25 139:13 149:11 150:11 169:22 195:10 196:22 197:6 261:13 275:4, 18 280:11passenger 229:6, 15passes 13:2 195:24 196:5passing 80:18 103:14 107:25 110:6, 6 191:14 253:7, 9 259:16passively 115:6patrol 9:25 10:15,16 15:8 35:10 63:2, 5 64:8 205:4 262:21patrolman 10:8, 9,13 11:8pause 25:20pay 16:25paying 72:18payment 169:4, 6PD 97:4penalty 286:20pending 8:8 255:6 275:8 283:16Penny 56:13 86:3 157:1 175:10 188:2 206:16 208:7 231:1 255:1 257:19 275:22people 65:7 80:9 81:9 82:11 83:22,22, 23 94:24 101:24 102:7, 9 109:6 134:19 135:6 142:24 143:21 145:6 150:4 158:23, 24 160:9 182:22 190:6, 14 195:20 201:23 207:21, 21 224:13 225:8

232:20 240:16 249:4, 9 264:19 265:10 274:23people's 82:21perceived 73:16 161:24percent 31:15 56:21 116:3 220:18 278:2percentage 219:18perfect 35:13 100:24performed 205:17performing 269:24 270:7period 12:16, 18 13:9 40:9 62:1, 7 130:15 138:23 205:17 231:17 236:22 283:7perjury 286:20permission 100:1permitted 32:10 33:3person 47:12, 14 50:13 77:22 126:23 152:15 185:9 219:23 234:4 275:14 287:16personal 53:23 54:1 101:9 112:25 113:2 177:11, 13 197:16personally 94:21 103:25 115:16 163:13 173:11 231:2personnel 27:2, 5,8, 15 29:7, 22 55:3 71:20 110:3 112:20 163:16, 25 164:18 179:14 276:13persons 219:15perspective 99:22pertain 247:3pertaining 259:23 273:25pertinent 132:10

PETERSON 1:2, 4,5, 5, 6 2:24, 25 6:16 46:3 84:17 92:14 118:16, 17 130:18 131:9 142:22 157:13 158:19 169:5 177:18 188:20 206:11, 12 207:19 220:13 228:7, 14 249:17 258:21 261:3 274:17 275:2PETERSON00705 4:7PETERSON00736 4:12PETERSON00791 184:8Petersons 207:23Peterson's 208:1Phil 14:20 107:21 110:15 157:18 239:13 251:4phone 8:11, 14 47:12 51:2 77:20 175:24 185:8 210:1 216:18Photograph 4:21,21 184:24Photographs 3:18photos 64:12, 13 65:1phrase 263:5physically 110:19 115:8picked 262:5picking 78:21 262:16, 19picture 178:18 181:18 184:13 185:2, 13pictures 108:20 109:3, 7, 10 175:11picture's 185:19piece 73:24 108:4 138:25 149:25piecemeal 252:9pieces 139:11pilot 96:22 97:1, 5,



12, 14Pinellas 12:13pinned 74:5, 9PIO 44:11piping 172:14place 11:23 97:8 98:2 109:22 112:6 129:13 175:15 186:23 207:12 225:19 244:20 254:22 272:6 287:8plain 227:25plaintiff 6:18 8:1 221:3Plaintiffs 1:7 2:2 6:23 7:14 219:13 220:5, 9, 10, 24 221:8, 15 222:5plan 24:24 25:4 26:6, 12play 68:23 87:24 279:16played 277:15playing 89:13 196:12 231:3 281:18 283:7please 6:19 58:18 64:19 100:13 165:9 187:9 218:13 236:8 285:1pled 82:15 83:5plus 125:23, 23pocket 17:1point 11:13 13:7 15:17 19:21 24:19 30:2 32:17 36:9, 13 41:10, 13 42:9, 10 44:12, 13 46:15 48:7 54:7,10 66:3 69:15 70:5, 6, 17 71:8, 18 73:4 75:10 76:11 78:23 79:4, 17 82:15, 18 85:23 96:5 104:8, 9 125:14 148:14, 25 152:6 153:21 162:16 163:8 165:12 188:2

192:18 208:23 216:4, 12 228:12 242:23 256:5 264:4, 9 273:22pointed 8:11points 97:5police 7:22 8:8 9:16, 18 11:1, 4, 17 12:23 14:22 15:1,5 16:18 17:8, 11 18:22, 25 19:17, 19,20, 22 20:1, 8, 10 21:1, 3, 11, 12, 16,23 22:2, 2, 9 23:5 24:1 26:5 27:7,15, 16 28:11, 18 31:20, 23 32:3, 16,22 38:9, 20, 23 55:10, 19, 25 56:4 61:3 62:17, 23 63:20 65:10, 11, 12,13 66:10 68:4, 5 69:14, 19, 24 71:3,6, 10, 12, 14 72:8 85:24 86:5, 18, 22 88:25 89:6 90:19 91:12, 15 92:9 93:11 97:2, 13 98:6 99:5, 10 102:1, 2, 4 104:9 110:2 118:5 120:3 134:21, 22 136:13 137:22 138:3 139:1, 12 141:13, 18, 21 145:20 146:11, 14 150:5 162:1 172:1, 22 174:21,24 176:1 177:8 179:13 181:2, 8, 10,17 182:12 189:9,10 192:4, 25 195:12 200:8, 9 201:16 205:2 209:1, 12, 21 210:25 214:9 215:8 216:15 219:4 226:13, 24 227:24 228:2 229:8 230:4, 5, 6 233:13, 18 234:21

235:18, 21 238:11 239:12, 24 240:4, 4,13 242:4, 5 245:7 249:15 250:20 253:25 255:4, 6, 21 266:14, 15, 17 269:15, 19, 21, 22 270:11 272:13 273:4, 5, 7 274:2 277:17, 19 280:23 282:25 284:16policies 108:14 139:25 173:18 192:4, 5policy 33:2, 15, 22 35:20 36:1, 15 66:2 77:4 90:11,19 91:20 113:25 138:24 139:21 140:2, 4, 9 162:21 189:12 191:14, 18 192:5, 6 213:11 215:11 225:19 244:22 245:1, 4 256:23policy-wise 191:5politely 112:1pong 68:24 77:9 89:13 231:3 271:7, 11, 23 277:14, 15 279:16 281:18 283:8porn 3:16 140:18,22portion 94:22 116:20 117:23 194:22posing 141:2position 9:23 10:23, 25 20:6 22:13, 20, 21 23:4,8, 23 24:17 25:2 26:3 28:9 30:9 33:6 71:24 139:17 161:25 163:20 166:10, 13 176:4 178:6 198:13 203:16, 18 209:4 215:21 240:7 245:20 248:13, 14, 16, 19,

21, 23 249:3, 8 256:9positions 19:19 20:25 23:25 24:5 145:1 195:1, 6, 18,19 197:15 204:23,25positive 96:11positively 24:19possible 93:24 275:25possibly 27:19 45:6 135:20, 21 268:8Post 4:21 213:7 267:17 268:2, 7 269:3Posted 3:17 22:22 74:12 108:5 239:1, 5Posting 76:25 108:1, 22 269:11potential 61:3potentially 63:23 134:21practice 87:2 90:15, 16 91:6 95:8 113:25 245:4practices 98:22 250:21predecessors 97:9preference 235:14premises 265:12prepare 115:23 117:23prepared 101:1 107:3, 6, 10 109:19 117:11 224:23 281:16prerogative 99:20 127:7Present 2:20 6:19 25:1 73:22 103:9 142:7 193:18 197:2, 3 230:12, 14 260:1 271:14 274:11 275:21, 22presented 48:3 51:7 53:24 54:20 62:3 73:10 98:20 101:14, 20 102:17

116:6 141:9 149:21 159:18 182:9 184:22 185:11 188:14 201:14 265:7 277:1presenting 116:6president 103:7, 7 104:25 107:20presidents 103:4press 44:6 54:7 139:8pressure 165:22presume 167:4pretend 238:17pretty 45:11 58:7 63:13 64:23 137:21 144:15 145:19 181:10 215:12 237:5 251:22 253:4prevent 8:24 183:23 273:12previous 38:22 174:25 217:1previously 266:20 279:8primarily 47:24 216:14principal 114:6print 121:13, 14printed 31:4 121:5Printout 4:18prior 30:15 32:15 33:7 41:18 53:13 62:13 72:14 75:4,10 95:12 109:22 146:2 147:6 153:11 158:4 175:6 218:23 228:22 242:7 255:9 277:24 278:18 279:10 283:15 287:9private 29:14 239:24 262:23 264:1privy 28:7 114:9 233:1 236:9pro 143:13probable 70:3

probably 60:9 106:21 107:7 119:12probe 3:16problem 149:6, 9 156:25 207:11 226:13, 24 230:18 247:1 264:6problems 193:13 199:12procedural 139:15procedure 88:23 140:2, 5, 9 269:10procedures 29:4 138:24 139:22, 25Procedure's 8:15proceed 199:18proceeded 26:12 70:17 71:15proceeding 164:8,10, 10proceedings 101:7process 7:18 9:3 23:12, 14 88:17 97:1, 8 105:18 130:8 132:8 171:8 191:13 193:8, 15, 16 194:7,20, 20, 22 195:11,21, 22, 25 196:4, 13 197:13 198:11 216:2produced 31:9 70:15professional 65:24 101:8program 25:5 97:1, 6, 7, 12, 15 170:17, 25 171:2, 8,11 192:25 193:3,11 201:7programs 96:22 97:15progress 176:7 193:2progressed 204:21promise 227:1promote 248:16promoted 62:5 143:20 144:3 145:1, 3 161:23

202:8 237:24, 24 243:20 270:2promotion 10:13,17 144:8 159:13 161:22 163:21 194:14 198:15 248:10promotions 143:15 158:22 160:5, 8 224:14prompted 21:23 119:23 120:1 143:16 171:2pronouns 111:25proper 153:3 162:14 170:16 237:1 250:21 256:15, 15 273:11 280:14properly 152:2, 3property 12:8 13:11 67:16 68:19 114:1 205:5, 6, 8proportion 219:17prosecute 142:18prospective 79:10protocol 153:3 162:14 170:16 186:22protocols 276:16proud 21:8provide 70:1 136:7 191:21 217:24 252:25provided 35:19 47:7 48:21 50:17 52:4 72:9 76:3 77:17 94:1 109:9 117:10 173:2 188:10 225:12 252:2, 4 255:12 280:15 287:12providing 133:14 135:15 172:19 255:11 256:7proximate 219:14public 139:2, 3, 6 262:22 276:9pull 121:17 253:11

pulled 106:18 209:24pulling 232:20 233:6punish 133:14 135:15 136:25punished 132:19Purcell 167:22, 22,23, 25 168:23 236:20purpose 151:17purposes 173:1pursuant 287:18pursue 224:14pushed 224:20put 23:8 39:6, 19 51:20, 25 52:8 58:11 95:13, 21 96:2 97:8 98:9 117:12 121:3 126:22 132:8 195:20 205:7 206:10 228:17 238:16 283:11, 12putting 132:8Pyatt 2:18

< Q >qualification 198:2qualifications 196:2 197:4 249:7, 12qualified 249:2 263:25Quality 192:24 193:11question 8:20, 21 9:4 27:10 32:8 34:17 41:19 43:25 48:2 57:9 67:3 84:23 123:5 126:4 135:10 153:16 158:8 163:12 165:9, 12,20 166:1, 6 180:9 181:23 188:5 216:22 225:2 271:8, 24 283:16questionable 257:15

questioned 234:3 235:17 237:19 287:18questioning 237:18questions 7:15 8:16 25:21 28:10 30:12 33:11 37:21 76:10 85:12 130:9 156:22 163:14 164:12 197:3 219:9 243:12 265:18 270:16, 25 277:3 280:22quick 58:10quickly 251:22Quintanilla 2:7 4:9 7:6 49:9, 25 50:4 55:18 79:8 80:10 123:22 125:24 152:16, 19 153:20 154:3 155:15, 24 157:22 158:16 159:8 188:9, 18, 25 217:6 240:8, 15 246:22 282:11Quintanilla's 79:11 123:13quite 215:16quote 106:17, 20 116:14, 23 118:19Quotes 95:23 96:2

< R >Rainbow 228:9Rainey 4:18raise 11:23range 65:3 129:1 139:14rank 11:5, 10, 13 20:12, 14rapport 103:3rate 175:1reached 41:10reaction 208:18, 25read 74:15 94:1, 8,15, 17 106:22 128:5, 7 129:7 138:19, 22 139:18 155:12 165:8, 11

166:1 206:22 219:6 226:16 266:21 278:3 286:21reading 126:10 128:1, 3 147:15, 22 148:23 227:3, 4real 113:16 239:10 268:20, 24realist 149:23Realistically 280:13 284:12reality 111:5 112:13really 73:17 180:17 205:19 208:11reason 21:10, 15 23:13 24:16 30:10, 17 34:3 41:5 49:11 56:9 102:11 119:4 133:5 182:16 190:24 212:3 232:6, 8 261:18 266:18 269:2, 23 286:2reasonably 185:6 284:5 287:18reasons 14:25 30:17 33:17, 22 34:4, 5, 7 40:4 41:6, 7, 23 42:1, 4 61:13, 17 73:14 215:19 236:20reassigned 40:10,12 41:20reassignment 41:5,7, 16 42:5, 8, 10, 12 43:22reassured 110:19Rebecca 72:24 84:18 123:7 149:3 154:23 157:11, 19, 23 159:5, 6 187:23 189:15 239:25 251:17 271:4recall 16:23 18:13 47:13 50:4, 8 52:20 55:7, 11

56:13 58:13 59:6,16 60:7 81:10 82:4 86:8 94:5, 7,8 106:5 116:4 128:1, 3, 19, 21, 23,24 129:3 132:20,23 133:4 145:9 175:11 180:7 182:23 183:1, 8 190:10 198:17, 22 199:23 204:23, 25 205:10 207:10 209:8, 17 211:12,16, 22 227:17 238:25 239:4 260:9receive 98:10 274:21received 16:15 24:4 47:4 57:7 127:21 154:3, 10 171:12 177:4 180:2 209:18 235:25 251:16 274:22, 22 280:15receiving 162:15Recess 58:23 100:16 129:22 187:15 218:17 254:14recessed 285:8recognize 96:6 123:14 127:23 179:20, 22 278:14,22recognized 96:17recollection 130:20 153:19recommendations 197:10Recommended 123:11record 6:20 52:9 58:22, 25 100:14,20 115:19 129:21 130:3 165:10 187:7, 14, 17 218:14, 19 254:13,16 285:7 287:12records 200:10

201:1red 283:11redo 124:13reestablish 158:8refer 268:8 269:2reference 196:20references 148:22 169:4referring 70:19refilled 277:13reflect 161:14regain 108:6regard 33:10 42:20 95:16 140:22 157:12 177:18 194:4 206:11 212:22 214:22 218:25 225:6 227:18 228:3 238:8regarding 32:9 37:3, 11 47:4, 19 54:24 60:22 81:5 91:24 108:13 111:12 122:12, 15 130:16 131:7 139:20, 21 142:8,15 146:18 158:4 165:24 175:15 176:9 191:22 198:18 207:22 212:5 217:2, 21 219:2 255:12 256:12 268:10regardless 99:13 146:3regards 8:2 67:14 141:14 191:20 206:12 283:3Regatta 6:10regs 77:1regular 112:7 145:2 172:13regularly 103:6 137:21regulations 33:2reimbursement 221:25reinforce 98:14reinforcement 108:11



RELATED 1:12 30:4 133:7 147:25 163:15, 22 177:14 212:23 249:21relation 17:17, 24 18:13, 20 44:3, 17 81:18 208:1 238:10Relations 89:9, 21 90:1 171:5relationship 204:22 224:2 287:17relative 287:14, 15released 116:2 134:1 159:22 160:11releases 136:7releasing 210:9, 9,11relevant 165:3relocated 11:25 19:8relocating 15:2 21:19relying 51:11remain 244:3 285:4remaining 187:8 257:25remember 17:9, 16,17 18:10 19:2 29:10 37:15, 16 40:11 49:14, 24 50:6 55:13 56:10,12, 16 60:24 61:11 99:15 101:18 102:15 107:19 108:2 116:5, 15, 25 117:1, 4 128:5, 6,14 132:21 146:7,17, 22 148:18, 23 150:19 162:5 170:24 190:11 194:17 199:20 209:13, 15 210:21 212:1 216:19 227:20 243:2 246:23 251:24

253:8, 14 266:24 278:12reminded 178:11removed 178:3 245:11rep 194:5repaired 107:5repeat 9:5 271:8rephrase 9:5 204:18Report 4:9, 12 15:10, 12 33:3 68:21 75:13 76:21 83:2, 3 84:14, 24 85:3 140:6 146:9, 16 151:12, 17, 18 157:22 168:4, 5 169:13 170:7 183:15, 18 184:23 185:10 200:12, 15 201:2 226:8 232:3 250:2 251:17 280:6Reported 1:24 40:2 77:24 87:8 159:9 229:5, 10 287:7reporter 6:12, 21 116:9, 16 120:20 165:11 222:24 287:5REPORTER'S 287:1Reporting 6:10, 13 26:13 32:11 140:11 152:15 178:6 190:9 285:4reports 134:3 183:12 205:21 226:6, 20 227:12 228:16 242:20 276:10, 12represent 7:14 31:3, 12 176:10 193:19 265:19 270:18, 23representation 131:20representative

38:12 196:19represented 194:6representing 108:23request 36:22 37:10 42:3 48:7 255:17requested 6:18 287:19requesting 53:20require 16:4requirement 183:11, 17 196:22requirements 198:13researched 117:5resolved 85:9respect 101:16respond 39:17 68:21responded 115:14 209:19, 22response 39:25 159:12 160:4, 8responsibilities 32:18 250:21responsibility 119:7 125:12, 25 256:22 257:6 274:17responsible 99:16rest 31:16 94:23 100:10 215:5restrict 191:15restricting 57:7result 219:14 220:14 221:18 222:14retire 262:12, 15,25retiring 11:24return 175:25returned 15:15, 15 23:11reversed 79:13revert 196:1review 46:16 48:8 53:21 54:21 95:5 96:1 116:18 132:10 193:8

225:17 287:18reviewed 57:15reviewing 210:5reword 26:1rewrites 126:14ridiculous 102:19rifles 116:7right 14:21 18:12,24 20:20 29:22 30:1, 24 37:9 38:16 39:13 45:21 46:14, 14 47:22 51:14 56:25 59:20 62:24 71:1, 7 77:13 84:12 92:12 93:18 104:20 110:1 111:20 117:17 121:16 123:4 136:10 143:18 146:23 154:4 158:20 159:3 160:21 161:11 168:3 170:19 176:8 178:22 180:24 181:2 182:18 188:21 189:19 190:25 192:10, 18 210:23 220:20 232:3 233:14 239:13, 14 248:3 252:14, 22 257:3, 10, 11 259:11 268:4, 15,25 269:6, 11 271:22 272:20 279:23 280:7 281:14 284:25rights 18:6rises 66:1risk 193:18RJ 116:13Robbery 10:2 93:24Robbins 2:10 4:21 7:2 155:25 156:1, 9 175:9, 15,23 176:3, 15 182:20, 23 191:4 202:16, 22 203:3,

11, 19, 24 204:2, 4 216:16, 17, 24, 25 217:2, 3 225:4 239:17 249:23, 25 250:7, 10 265:19 266:10, 13, 23 267:4, 8, 10, 11, 18 268:2 269:2 272:12, 12 273:1, 4,17 274:2 275:21 277:8, 17 279:7 281:16, 18 283:6, 9Robert 2:12 253:20Roberto 143:24 154:24 242:4, 24Robinson 251:5Roca 2:13roll 44:20 62:8rolled 64:21rolls 284:18Ron 154:25room 78:6 94:8 100:10 205:5, 8, 8rooms 205:6rough 11:23Roughly 12:16 13:17 14:1, 2 23:3round 198:2RPR 1:24 287:23Ruelas 2:12 7:2 156:6, 10 247:15 250:10, 11 251:6 265:19 266:5 277:16 279:9 281:18 283:8rule 105:14 272:7Rulffes 32:17 47:21 103:13 193:4 225:19rumor 102:12, 14 103:9, 20, 22 104:3,17 105:15 110:5,22 111:6 112:6, 14,17 118:11 134:12 135:5 193:15 206:8 207:25 212:17 243:4, 5rumors 62:7 102:19, 22 104:7, 7 110:24 118:3, 14

134:11 143:6, 17,21 144:1 145:7 207:13, 16 261:8, 9run 12:1 13:11 28:18 31:1 39:16 214:16 216:14running 13:8 129:14 139:8 174:25rushing 134:16

< S >salary 248:13sale 13:21sales 98:18sand 238:16 284:6sat 196:25 207:6saw 51:24 56:14 60:16 75:6 76:2 86:5 137:18 181:18 223:10 268:7saying 13:12 26:9 27:8, 14 56:14 75:6, 22 76:18 82:4 110:24 212:7 227:18, 20 232:17 236:14 240:24, 25 260:8 272:25 282:1says 31:19 33:2 36:9 43:5 60:16 90:8 94:20 100:25 101:4 109:18 117:24 125:22 126:15, 16 135:12 141:4 146:24 152:19 154:2, 9 167:21 175:22 189:15 216:23 217:18 219:12 220:4 221:8 234:2 236:8 240:3 244:23 245:9 253:12 268:17 283:5scenar 241:12scenario 65:19 104:14 191:20 264:3

scenarios 103:18 259:21scene 64:9 93:25 114:8 115:15scenes 65:2School 2:6 3:16,18 7:4 19:17, 22 20:1, 10 21:3, 12,16, 23 22:4, 8 24:1,17 25:3 26:5 27:23 28:11 31:13, 24 40:5, 7 41:11 63:10, 20 65:12 69:19 71:11, 13 72:8, 8,22 77:5 85:24 86:21 88:24 89:4 90:12, 19 91:12 92:9 93:11, 17 98:16, 16, 25 99:3,5, 7, 7, 12, 13, 14, 24 100:1 102:4, 17 110:4 111:2, 12 118:13 120:3 137:22 139:15 141:13, 18, 20 145:20 154:16 163:3, 14 172:1 176:1 177:7 179:10, 13 180:23,25 183:2, 6 189:9,11 190:2 191:2, 16 192:3, 4, 25 193:3 194:2 195:11, 22 198:19, 20, 24 201:8, 16 205:1 213:17 214:20 215:1 216:14 224:1 229:7 238:12 239:12, 24 242:3, 5 249:15 262:5, 22, 23 271:6,19 272:8 276:15 282:24 283:19, 20 284:3, 5schools 98:2, 3, 13screen 6:4 58:21 59:3 100:15, 21 129:20 130:6 187:13, 20 218:15,

20 254:12, 19 285:7screening 105:10se 62:3 98:13 141:10 225:21 274:15second 35:14 39:15 52:14, 16, 17 56:7 58:5 76:4 104:24 113:5, 5, 8 146:23 148:11, 12 169:3 193:23 210:4 220:10 227:5, 22 237:14,15secondary 216:15secondhand 103:1 104:2secretary 95:21section 107:6 139:20 153:10 200:17Security 13:20 209:11see 22:22 26:1 27:17 28:16 64:20 73:4 76:25 82:21 96:5 120:16 123:7 140:10 152:15, 19 167:19 169:9 186:25 187:23 188:2 213:10 216:13 223:19 226:14 227:2 238:17 239:6 240:5 256:19 258:16 268:17 269:13seeing 49:14 75:10, 24, 24 234:3seen 73:6, 10 74:19, 20 93:16 102:2 122:6, 8, 9,15 151:7, 8 161:4 164:20 172:9 174:11 184:5 210:7 223:2 235:9 238:23 267:23 275:24sees 68:5



segment 10:16 38:5, 6 95:14 98:7 152:21, 22 196:3segments 107:18 139:21 225:15selected 195:4 215:21selects 196:15self 149:20sell 12:8selling 98:25send 89:20 90:2, 4 123:25 124:11, 12 125:14, 20 126:21 197:7, 10 201:4, 9 257:3, 11, 16sending 125:21, 25 162:12 256:25sends 191:4sense 111:21 204:17 246:11sent 108:3 121:22 128:17 137:16, 17 223:18sentence 226:16 228:12 229:2 230:25 234:2, 7 236:8 237:15, 23sentences 226:18sentencing 45:21separate 68:1 85:8 96:4 176:21 240:18 260:17, 22separated 40:7 261:6separately 88:9 97:23 127:2 136:23 233:19 278:10separation 38:3 39:10 40:5, 6 41:8, 9, 14, 16 42:5,10, 12 74:25 138:17 139:18September 4:5 40:10 136:15, 17 261:6sergeant 11:14 15:18 20:23 48:20 77:16

114:9 115:14 141:22, 24 144:6,16, 22 145:8, 9 159:9 161:8, 23 165:22, 25 178:2 190:7 194:8, 11, 18 197:23 198:10 202:8, 9 209:8 217:23 224:15 230:6, 21 234:22 242:4 263:10, 19,20, 25 264:1, 5, 9 269:13, 14, 17 270:6 284:15sergeants 20:25 98:5, 21 144:7, 10 145:1, 3 198:9 199:15 200:1 249:11sergeant's 161:22,25serial 182:18series 7:15 8:16 261:1serious 145:19seriously 181:11servants 220:25Serve 4:18served 265:8 271:7, 11, 14 272:3service 21:7 98:4Services 6:10, 13 31:18, 20, 23 285:5SESSION 130:1,10 243:2set 33:1, 2 193:6 220:9 244:19 270:20 277:11 287:20settled 16:22 18:12, 14 157:11,20settlement 17:1, 24 18:1, 21settling 159:5seven 12:8seventh 221:7sexual 29:12Sgt 230:20 231:2 234:11, 24 235:8

236:11 237:15, 17 245:15share 109:22 194:19 261:24shared 60:20 112:8 217:21She, 154:22Shepard 147:1sheriff 48:5 52:13 53:12 57:11 92:21 132:4 230:1

[email protected] 5:2 223:19sheriff's 46:23shield 120:7, 11shoot 16:5 181:3,19shooting 179:24 185:13, 14short 24:21 205:2,17 231:17 259:17shorthand 287:11shortly 22:1 44:4 45:13 46:21 61:8,20 62:4 157:17 161:22 250:13shots 278:8show 33:1 90:12 120:4 196:23 210:12, 14 215:13showed 73:8, 21 282:12shows 31:23sic 155:2 159:7 212:17 251:5side 91:25 114:21 260:2sign 148:1 197:11signature 122:17,23 123:2, 13 124:6,17, 17, 23 126:2 127:21, 24 147:14 148:5, 8, 9 286:22signatures 126:7 146:2 148:4signed 122:24 147:15 148:1significant 61:5 64:23 82:1 185:23 186:1

signing 123:22 197:13signs 123:7Silvestri 2:18similar 174:23 182:11 208:25sincere 18:10 127:25 135:23 148:10 251:24sincerely 65:9single 130:13Sir 7:13 8:9, 13,22 9:1, 7, 10, 13, 20 10:24 11:16 13:3,5 14:24 16:14, 17 19:6 21:14, 18 22:11 23:1 24:3,6, 15 28:20, 25 31:3, 22 32:1, 4, 24 33:9, 14, 19, 21 36:21 39:7, 24 41:3, 4 43:4, 12 45:11 46:1 48:12 51:10, 15 59:5, 25 61:18 62:20, 25 63:3, 7, 8, 14, 16 64:5, 10, 19, 22 73:5 74:14, 22 75:1, 5 76:22 77:2, 6, 14 80:5, 8,12 84:10, 20, 21, 22 85:4, 5, 17, 17 86:10, 12 88:4, 12 89:1 90:1, 17 91:13 92:5, 19 93:5, 9, 12, 19 94:2,25 95:7 96:20 97:19 100:23 101:2 102:8 103:24 106:23 109:1, 8, 17 113:20 115:23, 24 116:19 117:15, 25 118:18 119:17, 18 130:8,11 132:13, 22 134:15, 17 135:20 143:19 151:6 152:17 153:4, 8, 16 154:8 155:3, 22 156:21 159:2 163:7 166:4, 19



169:2 170:1, 6, 9,12 172:10 183:16 188:4 201:19 203:21 213:4, 6 215:17 218:22, 24 219:5, 21, 22 220:12, 19 222:3,19 223:3, 17, 20 228:25 229:4 230:17 231:21 234:23 237:25 239:15 249:22 252:17 253:4 254:21 257:17 258:3 265:23 266:3, 8, 25 267:7,13, 25 268:3, 5 269:16, 25 270:9,12, 17 272:11 274:5, 8 276:2, 5, 8,17, 21 277:20 278:8 279:12, 22 281:3, 20 282:7, 17 284:25sirens 175:1sit 69:13 137:9 176:13 196:17 216:22 230:9, 16 231:8 234:5 243:15 253:19 264:23 265:2 274:6Site 4:18 56:10 110:4 111:15sit-in 200:1sitting 66:11 148:15 277:9 278:14, 25 280:24situation 46:7, 9 60:3 65:16 95:14 104:5 109:24 111:5, 6, 7 115:5 144:20 157:17 159:18 209:21 210:3 231:17 234:12 241:13 257:5situations 103:11situation's 66:19six 12:7, 20 13:2

200:14 242:3Sixth 3:18size 172:25skipped 20:23sky 102:19sneak 272:3, 23snowballed 111:19snuck 272:15, 17,19sole 33:6 34:3Solo 283:11somebody 57:5 67:10 75:18 76:8 79:25 85:2, 2 87:5 89:14 95:18 96:17 105:7 108:17 143:12 148:1 149:14 153:22 159:12 167:12 185:6, 13 188:19 191:2 218:1 236:13, 17 238:10 249:25 278:14 281:15 283:20 284:4somebody's 125:25someone's 101:8someplace 264:2Somewhat 94:10 238:21son 79:12 181:18 262:5soon 129:15 239:13sooner 208:24sorry 18:20 22:16 25:12, 18 27:4 41:15 48:17 59:8 63:8, 17 77:23 78:16 79:22 85:12 88:21 89:23 92:24 109:5 119:22 120:8 126:5 134:17 141:15 147:10 156:24 157:16 166:8 173:4, 12 178:8, 13 194:5 195:4 204:12 214:5 218:6 224:25

226:17, 17 263:14 269:20 270:21 271:9 275:22sort 256:10sorta 215:9sound 45:21 162:17 180:23Sounds 100:9source 70:21, 22South 1:21 2:4 6:5speak 253:16 274:19speaker 184:17speaking 272:10Specialist 2:23 6:8specific 48:15 109:9 164:5 185:3 189:21 207:21 255:16, 16,18specifically 19:24 29:1 48:15 49:24 50:15, 24 56:10 60:20 88:9 162:2 181:6 205:20 207:18 209:22 214:21 231:1 248:24 250:23 258:20 268:23 273:24specifics 55:1 88:5 101:18 106:5 108:15 112:22 216:12 236:9 259:24 273:24spectator 172:16speech 101:19 102:16speed 175:1 200:21 236:24Spencer 179:24 180:19spiritual-type 101:22spite 260:18spoke 23:17 51:13 130:15, 17 131:1 207:20 248:7sponsored 211:1

spot 195:8, 15 197:20 198:1squad 58:11 132:9ss 287:3staff 53:7 72:12 73:22 93:15 95:11, 11 103:14 107:17 119:5 132:6 144:6 162:13 182:22 196:23staffing 237:3stage 87:16 88:14stages 198:4stamp 31:10 227:4stance 103:15stand 58:18 75:14 76:7 100:13 218:13 285:1standard 87:25 125:7standards 108:4 193:5standing 277:17standpoint 251:9stands 37:14 117:19 269:7star 120:4, 7, 11Starbucks 258:18,20start 27:17 34:8 68:7 82:10, 20 112:13 168:6 170:17 171:2 182:13 185:14 192:19 239:10 243:12 274:20started 10:8 25:17 26:14 44:21 46:2 62:8 63:1 90:16 93:9 110:6 145:7 229:19 236:24 244:3 263:23 275:1, 6starting 138:23 172:18State 91:15 92:6 99:16 106:2 146:4 287:1, 5, 20



stated 47:24 67:13 149:4, 11 260:2statement 44:5, 8,10, 13 45:18, 20 125:8, 15, 19 126:10, 20 127:16 132:15, 17 136:7 137:11 138:10 149:21 158:25 159:7, 8 160:2 208:5, 17 229:9 232:7, 9 238:9 240:14, 14 245:12 255:12 259:25 260:14, 18statements 128:13 132:19 157:3 202:16 208:19 217:2 231:22 240:12 265:10STATES 1:1 149:24 215:6stating 154:10station 245:7 264:2statistical 98:12stats 98:9, 12status 10:14 39:3statute 268:20, 24 269:1, 7, 8, 10stay 11:4 20:17 37:7 42:25 43:2,7 114:7 203:11 236:21 264:13stayed 282:4, 5staying 33:10stays 203:5Steering 207:2, 3 216:1stenographic 115:19step 160:15 197:8 214:18stepped 23:21steps 46:8 47:18,23 85:7 108:12 110:20 134:11sterile 73:25stick 49:10 118:25

119:2, 3 284:6stirring 101:24stood 31:14 215:12stop 35:23 62:19 129:14 163:12 212:18 281:9stopped 93:25, 25stops 86:25 99:24stories 44:20, 22 53:22 60:21 71:15 101:6 102:7 137:15, 22 139:7 148:23 157:3 160:10 234:25 235:13 242:15 245:8 248:17 259:22story 44:5 45:14,18, 23 46:4, 12, 21 47:10 55:7, 8, 12,13 56:6, 13, 17 57:16, 21, 22 58:2 60:4, 13 61:8, 10,11, 12, 15, 20, 21 75:15 77:8 86:4,9 117:14 118:16 129:4, 6 135:19 136:6, 12 141:4 143:1, 18, 22 144:1 145:8 153:11 155:2 156:3, 17 158:23 159:12, 14,21 160:3, 12 163:21 164:4 170:2 190:10, 14,17 202:1 206:15,16 213:7 223:16 224:14 228:16 229:19, 20 233:20 239:1, 14 240:9 248:15 252:10 253:3 261:9, 11 265:1straight 10:10 168:14 234:25 235:14 241:1straightforward 202:13streaming 105:22 106:12

Street 1:21 2:4 6:6 11:3 114:15 147:1strife 101:13Strike 18:20 21:9 23:23 30:20 41:24 59:8 62:13 69:14 123:4 131:12, 17 135:12 143:13 154:4 160:5 161:6 204:24 208:16 223:15 248:20Structurally 40:8structure 31:12 108:6 244:12, 17,19structured 52:12 121:11student 31:18 179:24 180:22 228:7students 98:18 114:3, 7 119:8student's 99:6stuff 97:17 108:24 114:25 207:11 284:2Style 4:15sub 43:10subject 146:9, 15 147:25 163:16 276:14subjects 62:15submitting 159:6subordinates 109:25subpoenaed 34:1 39:15subsequent 42:16 43:3 146:1subsequently 231:23substance 42:13 43:11 60:18 107:19 203:16substantive 207:13 210:8substantively 39:22 258:1

sue 16:18 220:14sued 276:22Sufana 154:25suffered 219:13sufficient 112:8 141:11 220:7suggest 69:16suggested 264:16suggestions 209:1suit 18:6 146:15,18, 20Suite 2:9, 14, 19 6:11summarize 158:13Sunday 93:22sup 125:9super 55:22 133:19superintendent 24:18 25:3 26:3,4 28:10 31:5, 24 32:7, 11, 17, 23 33:4, 7, 23 34:4, 11,12 36:5, 9, 14 37:21 39:13 40:1,3 42:19 46:3 47:20 48:6 52:17,18, 19 53:6, 14, 16,19 54:6, 18 56:18,23, 24 57:10 59:11,17 61:9 73:8 74:16 82:24 85:19 103:13 130:12, 23 132:14 133:10, 13, 18, 21 134:3 135:12, 13 136:24 137:6, 16 138:10, 16 139:1 144:12 184:6 193:4 194:15, 16,18 196:23 197:10,12 213:21 214:8 215:23 224:9 225:12 227:17superiors 217:9superseding 221:15, 18, 19supervise 26:21 99:16

supervised 27:19 44:11 150:5 205:20supervising 26:19supervision 97:3supervisor 32:22 34:25 35:1, 8, 10,13, 22, 25 42:3 43:18 55:23 114:8 125:11, 13,21 178:6 284:14supervisors 98:7Supplement 3:18support 31:18 102:23 104:2 105:25supposably 108:20 111:9, 13 114:12 141:1supposed 83:17 96:7, 9 125:19 167:1 181:5 236:14 247:9supposedly 167:3sure 8:17 9:3, 6 25:25 27:12, 13 31:16 56:21 66:19 67:9, 14 68:18 72:4 79:13 94:3 104:16 106:11 115:3 116:3 127:25 129:2 133:6 134:12 135:21, 23 146:13 148:10 160:20 170:20 180:10, 21 184:6 189:10, 14 190:3 214:11 215:17 218:11, 12 235:21 251:8 258:17 267:17 271:1 281:15 282:3, 5surely 82:14surprise 52:19 73:12, 13 92:11surprised 73:9 92:7 208:20, 21 215:7, 10 224:5surprises 74:21

surrounding 149:10 266:1, 6survival 101:9suspect 93:24 183:24suspended 40:9 118:8sustained 70:2 220:23swear 6:21swirling 102:22switch 120:6switched 167:8swore 106:1sworn 7:7, 9 171:16 274:10 287:9synopsis 86:8system 63:22 77:5 121:9, 12 193:2, 24 200:24, 25

< T >table 66:11 68:10 75:25 250:1 277:9, 10, 11, 13, 14 278:15, 25 280:24 283:7tail 151:10tailored 248:24take 14:2 24:8 58:11, 16 64:18 67:23 69:12 85:7 87:19, 19 93:20 96:15 100:11, 24 119:7 123:15 129:15 134:11 137:8 150:7, 9 153:4 155:16 160:14 171:13 178:4 181:10 182:17 184:13 187:4 190:8 200:14 210:20 218:9 224:8 246:8 254:8 259:8 261:13 262:21, 22 272:5,17 274:4Taken 1:18 7:16,21, 24 9:11 46:8

47:18, 23 58:23 74:24 100:16 108:5, 12, 20 115:5 118:3 129:22 167:21 171:8 180:18 187:15 206:9 218:17 238:20 241:11 246:9 250:5 254:14takes 168:3, 9tales 106:11talk 29:15 44:1,16, 25 53:15 65:10 68:4 82:24 140:1,4 187:23 188:2 207:24 232:21 233:7 244:11 245:17, 21, 23 246:3 247:6, 7, 10,15, 16 249:16 250:7 251:8, 12 256:12 258:21 259:11 264:1 267:16talked 19:1 41:23 42:14 53:16 59:12, 20, 23 92:25 93:3 134:10 136:24 137:21, 25 138:1 140:16 142:21 143:9 176:3 183:20 184:4 190:5 206:20 224:11 234:5 238:7 253:2, 6 257:24 259:7 261:7 263:1talking 18:3 28:19,24 35:1, 2 37:8 41:6 42:1 50:13 63:21, 24 75:2 88:18 101:4 103:22 112:1, 5 118:1 140:15 143:6 158:12 168:5 175:8 184:7 192:11 202:21 203:3 207:19 211:17 212:21 243:3

246:14, 25 248:4 257:19 260:18 264:25 265:1, 1talks 203:6 237:23Tampa 12:13 13:21tape 129:14 209:24 210:12, 14 254:8targeted 98:3Task 10:3T-boned 175:2team 114:4tear 203:20 276:19tearing 203:10 276:19technicality 91:14technology 200:3,6 201:12, 14Teens 4:18 172:20 231:18telephone 112:2tell 29:23 33:17,23 34:3, 10, 12 35:11 36:19 50:14, 20 51:5, 16 54:3 56:23 57:14 63:24 65:2 78:9,15 81:10 82:2 125:21 126:23 175:25 189:23 191:1 203:22 206:22 211:14, 23 212:2, 7, 9 225:4 235:9, 15 247:5, 7,18, 20 249:14 268:25telling 27:22 33:13 35:24 50:15 57:5, 10, 11,21 84:5 150:4 180:7 182:23 202:17 203:17 207:10 241:1, 6 263:19 267:3, 11tells 35:8 247:11 251:5template 121:22 167:14ten 45:7, 8, 10 46:11 59:11



148:6 257:23 258:14 259:7tend 202:17ten-month 122:23tens 15:16tenure 193:4term 181:25, 25Terminable 182:2terminal 181:24,24, 25terminally 11:25terminals 118:4terminated 118:9 174:22 262:10, 13termination 43:22 175:7 180:6terminology 71:1terms 272:10 274:20testi 182:4testified 7:10 123:17 130:13 132:14 160:7 182:20 188:9 221:25 259:6 260:3 266:9 268:6 272:22 274:21 277:10, 11testify 34:1 281:16 287:9testifying 136:25testimony 8:25 25:9 28:22 30:15 34:15 131:11, 20 133:14 135:15, 16 136:8 137:5 143:3 147:2, 6 158:4, 14 159:4 180:2 183:9 208:15 217:19 218:23 231:11, 12 232:19 233:12 255:9 257:25 260:9 266:21 267:2, 9 271:2 272:5 277:24 278:2, 5, 7, 19 283:5, 16 287:12text 162:5 263:23texting 161:24 162:10

Thank 132:2 138:14 161:2 166:20 174:9 176:24, 25 178:16 182:3 222:22 265:15 267:21 279:24 284:25Thanks 172:19 173:12Thanksgiving 146:25thereof 54:8 221:25thing 42:17 53:10 54:16 81:18 83:23 84:12 95:5 101:14 105:14 108:10 118:22 124:8 125:2 126:16 157:6 210:4 230:14 232:4 237:1 252:16 283:10things 28:17 32:6 35:12 39:14 43:23, 23 44:3 55:7 58:15 60:24 101:11 103:2 108:1 138:24 139:12, 15 143:11 191:13 200:16, 17,21 205:25 206:8, 8 217:17, 18 254:3 268:14, 16 269:5 280:5think 15:21 18:2,14, 18 28:12 30:13 33:17 35:13 39:13 42:19 45:8 58:7 61:21 65:2 68:7 77:8 78:5 79:12 86:12 100:7 108:3 112:19 117:16 124:1, 7 126:13 127:6 137:3 138:25 139:1, 5, 25 142:23 143:21 144:16, 16, 21 146:17, 19 157:7 158:14 160:4, 12,

13, 16 168:4, 12 169:6 183:9 185:7 188:9 189:5, 12, 22 194:22 195:14 197:22 198:7, 8 201:14, 23 202:5 203:23 204:4 207:5 211:13 214:17 216:24 225:3 234:5 239:3 242:7 257:23 268:21 277:9 282:4, 16, 18 284:23thinks 206:24third 73:20 118:2 119:10 139:20 180:4 219:10 220:21, 24 221:4 249:18Thomas 4:12 145:5, 14 161:15,21, 23 163:5, 9, 12 164:6 165:14 166:11 190:7 204:11 211:13, 16,23 212:11, 17, 19 224:16 263:2Thomas's 163:16,25 164:18, 20 165:4thought 29:2 60:15 82:1 83:1 96:17 143:10 160:8 165:18, 19 179:16 182:7 190:6 202:25 252:21 260:3, 6, 12 267:3thousand 185:20three 10:20 15:15,16 21:20 38:24 39:3 73:18 106:3 126:7 130:3 136:16, 18 180:16 187:11 190:13 195:19 196:6 198:8 210:1, 25 239:10 258:13, 13

259:14 278:9three-month 62:7Three-quarters 13:19threw 25:18thrown 230:3tickets 139:12, 14,20tidbits 103:19 107:18tied 107:14till 8:19 9:22 18:21 40:24 73:10 82:5 84:13,16 86:4 122:24 136:15 139:18 155:1 157:3 190:15time 6:3 10:1 12:17, 18 15:11 17:16, 20, 23 18:21,22 19:21 20:24 21:25 24:7, 19, 22 31:11 32:21 38:17 40:17 47:2,11, 25 48:9, 25 50:13 51:7 55:23 56:3, 12, 18 58:10,21 59:2 62:17 69:15 71:8, 25 72:14 73:4 75:6,10 76:2, 8 77:16 78:25 79:4, 15 80:7, 9, 19 81:9, 19 82:22 85:18 89:16 94:15 96:21 97:3 99:20 100:14, 20 101:18 105:1 110:21 115:25 118:7 120:2 124:23 129:10, 12, 19 130:5, 15 136:12 138:24 141:11, 12 144:23 148:14 155:3, 11, 16 162:16 163:8 165:13 167:24 168:12 178:21 187:12, 19 188:2 190:17 193:12

194:24 196:5 199:9 202:10 204:21 205:3, 15,17 206:21 207:24 218:15, 19 223:21 224:1, 3 226:11 227:10, 11 229:10,16 231:18 236:22 237:5 239:16 242:23 245:5 246:8 250:8 252:4, 16 254:8, 11,18 255:3 258:4, 14,19 260:19, 20, 20,22 261:5, 11, 12 262:2, 5 263:8 265:7 281:2, 5 282:17 283:7 285:6 287:7, 13times 7:22 8:4 9:8 15:6, 24 42:11, 23 44:25 45:2, 5, 7, 8 104:7 176:3 200:22 203:7 204:20 207:6 224:12 257:24 259:7, 11,15Tina 2:10 148:16,20 154:15, 19 155:14 157:7 265:25 277:15 279:8Tina's 154:10, 13title 136:14, 14Today 6:2 8:25 69:13 137:9 148:15 176:14 184:4 216:22 218:23 222:1 225:3 230:9, 16 231:8 243:15 253:19 264:23 265:2 266:10 267:23 268:6 271:3 274:7, 22today's 59:1 129:18 130:4 187:11, 18 254:10,17 285:2

told 36:18 38:11 39:23 50:24 51:9,25 55:14 57:18 73:9 114:15 115:12 117:8 135:25 161:14 181:13 182:21 202:16 203:4, 4, 22 206:7 212:17 216:24 217:8 224:15 231:1 234:10 239:17 245:22 247:16 252:5ton 76:10top 94:22 138:20 145:17 152:16 170:19 268:25topic 42:25 107:10 199:23total 19:12 24:7,12 165:5totality 65:16 87:22totally 65:9 101:7 241:11town 107:14track 9:6tracking 152:13Tracy 193:20 194:3 207:8traffic 35:23 62:19 228:8tragedy 239:11training 168:13transcribed 287:11transcript 287:12,18transcription 286:21Traurig 2:8trespass 111:12trial 8:3trouble 111:22 206:19 241:18true 61:6 105:16 106:13 114:23 124:9 125:2 128:13 134:19 136:20 138:10 151:25 203:17

206:10 207:13 228:12 229:2, 9 230:10, 15, 16 231:9 232:13 235:19 237:20 242:25 243:6 253:13 260:7 287:12trust 43:15, 16, 17,21 217:4Trustees 31:25 139:4 248:15trustworthy 202:6truth 44:22 202:18 204:8 225:4 234:13 235:15 237:18 247:19 267:4, 11 287:9, 10, 10truthful 103:22 132:18, 19 133:14 135:14, 16 136:8 137:4 266:17truthfully 135:7 136:25try 8:17 25:25 75:18 83:12 88:21 96:23 103:15 104:1, 5 136:19 160:5 193:13 199:16 203:11 225:17 273:12Trying 26:23 29:3 49:21 70:25 76:4 101:25 111:4 112:4, 5 113:11, 13 165:21 166:8, 11,15, 15 210:21 214:6 240:18 260:16 263:2, 9, 17 272:24 273:14 280:7turn 15:11, 12 92:2 149:15 246:17 251:18 252:20, 22 276:10turned 15:19 50:14, 16 117:13 141:5 142:16 151:22 152:2, 3

177:25 246:19 247:21, 25 251:25TV 172:17twice 45:3two 14:12 15:25 17:19 23:3, 3, 23,25 41:23, 25 42:4 44:1 47:17 50:9 55:5 58:25 59:5,19, 23 60:10 62:5 76:21 78:23 79:6,7, 24 80:9 81:11,15 82:11, 19, 21 84:25 89:2 91:21 99:25 109:24 110:2, 15 111:8, 10 112:12 114:5 129:18 130:19 132:9 136:16, 18 143:13, 17 151:10 174:24 178:1 188:25 193:9 195:10, 17 196:6 203:7 205:7 226:18 240:11, 17 241:16 257:24 258:10 259:12 260:17, 22two-minute 54:10type 32:19 36:22 51:8 54:21 65:19 69:18 70:16 71:12 74:7 83:10,23 95:1, 15, 17, 18,19 97:14 98:22 104:13 108:9 121:18 184:19, 21 189:13, 21 191:20 206:17 214:9 225:20, 23 264:20typed 95:2types 103:17, 18 140:11, 14 191:15typewriting 287:11typewritten 287:11typical 96:13typically 83:24 105:13 148:6

U.S 6:15

Uh-huh 12:25 13:17 14:1 31:6 41:2, 22 63:6 67:8 74:17 90:21 92:22 94:4 119:20 126:9 134:14 136:9 145:11, 25 158:18 166:24 170:4 194:9 216:20 226:10, 22 228:10 239:9 240:2 243:7 257:21 258:9 260:13 263:4 266:16 274:25Uh-uh 132:25ultimate 41:7 194:25 195:7ultimately 36:19 159:22unauthorized 16:9,11, 16 181:14uncomfortable 42:4 44:2 231:16,18unconditional 105:25Undated 5:4underage 171:25 234:4undermine 101:25 102:8 118:23undermined 180:5,5undermining 119:6understand 9:2, 4 26:9, 21 27:21 32:8 38:13, 22 39:8 41:19 42:15 49:18 52:22 57:9 65:7, 9 67:3 79:12 87:17 113:20, 21 121:7 126:4 135:10 143:4 153:16 159:15, 17 165:2 182:14, 14 183:10 187:3 198:3 207:18 214:4 215:17 219:21

222:11 230:9 236:14 240:23, 25 252:5, 14, 18 258:6 260:8 264:17 271:2 278:7 279:9 280:8 283:23understanding 23:13 26:18 30:19 32:2, 5, 12,13 38:19 52:6 72:5 79:5 111:4 131:15, 19 137:6 165:21 166:25 183:22 225:1 264:24 265:3understood 32:6,22 112:14 140:10undivided 105:25unfolding 172:17Unfortunately 54:5 119:6unhappy 44:13, 14uniform 108:24 253:20 274:2uninvited 149:1, 5union 103:2, 4, 4, 6 104:11, 11, 13, 24 107:20 114:14 204:19 206:23, 24 211:1, 12 250:17 251:4 256:23Unit 10:2, 11 11:2,3 167:23 209:22 271:5UNITED 1:1 215:5units 10:3unlawful 36:11UNLV 198:14, 20 228:7unproper 108:1untruthful 73:18 269:23up, 186:10uphold 106:2upset 65:8 143:12,13, 17, 21, 25 194:19 197:20upstairs 53:13 54:14

use 37:10 121:8 167:5, 13, 15usually 59:20 95:19 172:13 185:8Utah 140:18, 22utilizing 108:19 167:10

< V >Valley 21:10 180:23various 7:23Vegas 1:22 2:4,10, 15, 20 6:6, 11 97:13 99:19 100:2 147:1 235:18, 21vehicle 15:14 154:12, 17 174:25 175:5 198:19 249:24 253:25 262:6, 16, 19vehicles 201:9, 10vehicular 174:23 265:12veracity 204:8verbal 115:9, 9 250:18 251:3verbally 115:8verbatim 274:15verified 127:20verify 54:21 128:12 176:24 178:3 181:23version 252:9versions 278:11versus 35:2 75:24 183:20vice 10:10, 12, 15 103:7victims 220:18 276:11Video 2:23 6:4, 8 8:10 58:21 59:2 100:15, 21 129:20 130:6 187:13, 20 210:6 218:15, 20 254:12, 19 285:7videographed 6:17 58:19 59:1

129:18 130:4 187:11, 18 254:10,17 285:2VIDEOGRAPHER 6:2 58:18, 24 100:13, 19 129:17 130:2 138:12 184:12, 16 187:6,10, 16 218:13, 18 254:9, 15 270:19 285:1Videographers 6:9Videotape 1:19view 55:18 233:20 246:5 256:5Vincent 174:18violate 272:14 273:4violated 271:19 272:6, 8 273:17 274:10violates 36:15violating 269:11violation 111:12,13 162:21 256:6violence 98:3 209:12, 21, 23violent 65:17voluntary 149:21volunteering 150:6vs 1:8

< W >Wack 19:9Wackenhut 13:20,22, 25 14:23 19:3,7, 9, 13, 15 24:9wait 8:19 70:23 82:5 270:19waited 71:18waiver 220:7walk 100:8walked 92:15walking 98:17 99:12, 25Walt 32:16 225:19Wamsley 4:9 49:8,12 92:13 122:12 123:7, 25 124:12 126:14 147:3 149:4 154:23



157:20 159:5, 6 169:12 175:15 187:23 189:15 208:3 211:14, 18 212:24 219:1 230:4 238:8 239:25 240:14 246:24 247:14 249:17 251:17 258:21 259:3, 9, 12 261:3 265:21 271:4 272:1 275:14Wamsley's 72:24 84:18 126:16 157:11, 24 169:4 264:25want 27:11, 12 33:23 34:10, 11 36:24 37:7, 10 38:6, 18 62:14 65:10 66:13 67:9 68:1, 4, 12, 24 76:14 88:10 99:21 107:10 113:23 127:12, 13 138:21 150:23 151:1 165:4 173:19 184:6 211:24 214:19 218:9 223:9 243:22 267:16 271:2 272:17 273:18 278:2 280:3wanted 21:20 36:20 53:17, 25 103:3 118:25 120:16 135:4 137:8 138:18 176:19 182:15 194:19 213:21 226:12, 23 246:3 261:24 264:1wanting 114:22 214:15wants 263:18warehousing 205:6Warren 95:25 106:21 107:7

116:15, 20watch 153:25watched 154:14 275:23watching 68:23 134:2 137:11 279:15water 187:2way 13:19 30:10 37:10 39:20 43:23 44:2 59:18 99:6, 12, 17 107:13 110:5 111:13 113:14 119:13 123:4 125:17 146:21 156:2 159:19 177:23 181:9 193:14 194:24 213:15 220:13 221:3 222:18 227:7 229:17 244:23 248:21 283:9, 12 284:18, 18weapon 181:19Web 4:18Week 3:22, 23, 25 4:2, 4, 5 46:14 47:10 60:10 93:10 94:16, 20 95:23 107:2 108:10, 18 109:11,23 112:10 113:2 116:23 118:15 133:6 223:5, 23 226:21 258:17week, 226:7weekend 48:22Weekly 4:17 95:11weeks 59:19, 24 76:21 180:16 258:15well 11:7 21:19 27:7, 9 30:6 39:19 40:6 44:8 56:1, 22 57:1 62:6 65:15 67:21 75:14 78:13 79:19 80:16 82:14, 23 83:5 86:25 89:16 90:4

91:1 96:9, 24 99:9 102:24 103:9 104:19 112:23 113:3 115:3 117:12 119:3 120:2 121:8, 21 122:4 125:18 135:25 145:18, 21 154:7 156:8 166:16 179:1 180:15, 21 185:8, 16 194:24 195:17 207:9, 15 214:18 217:3, 13 223:9 225:7, 15 229:8 232:1 243:3 246:11 247:12 248:19 256:1 257:4 268:10, 16 272:16 279:7 280:10 283:5 284:12went 10:10, 12, 15 13:20 15:17 23:7,11, 21 53:16 59:5 62:5 72:10 94:17 95:6 96:12 101:19 104:19 106:22 114:20 116:18 118:9 129:8 132:16 133:17, 20 137:6 141:7 144:12 157:23 167:9 171:13 183:2, 2, 6 194:15, 20 200:23 201:1, 3 203:9 205:4 210:21, 25 226:9 260:6 263:22 277:14we're 9:6 13:8 18:24 27:12 58:22, 24 62:15 87:19 88:18 99:16 100:14, 19 101:3 112:20 119:4 121:3 129:13, 14 130:2 135:8 136:25 184:7 187:6, 13, 16

191:16 218:14, 18 252:25 254:15west 11:25 12:10,23 19:8, 10 22:3, 9,10 63:1 141:7, 10,12we've 24:8 41:6 42:1 59:12 71:4 82:19 101:23 183:9 232:19whatever, 272:7whatsoever 155:13 180:1 206:5 208:14When's 59:6 245:5Where'd 13:18WHEREOF 287:20Why'd 250:14wide 65:3wife 13:14 14:6 21:19 79:11, 11 156:10, 10, 10 209:20 210:7 211:2wife's 14:6William 1:24 6:12 287:5, 23Williams 157:5wish 184:13WITNESS 3:2 7:7 25:19, 23 28:4 29:20 30:16 100:10 120:10 153:6, 13 164:2 166:20 170:24 174:9 222:22 223:7 286:1, 20, 25 287:7, 9, 13, 20witnesses 65:11, 13witnessing 65:20 96:16witness's 138:13woman 60:16wondering 173:5word 37:9 51:23 114:15worded 61:11words 97:21 148:7 152:11 185:20 203:17

211:2 248:19 263:18work 9:14, 25 12:5 13:20 21:11 24:19, 25 26:13 27:16 33:7 36:24 40:13, 15 52:22 77:24 91:19 98:6 121:2 181:7 182:12 205:4 214:9 215:6 251:9 257:9 269:14worked 13:24 15:16 22:3, 9 24:22 29:11 32:14, 16 97:16 245:16 266:10working 7:23 12:14 15:9 19:9 27:18, 23 38:23 39:3 43:2 66:17 91:18 102:10 103:8, 12 108:19 140:25 171:4, 5 193:22 204:21 205:10, 14workmen's 74:7workplace 257:2workshop 53:6, 11 56:11 131:6worry 25:19 206:7 250:19worth 185:7, 19Wow 180:14write 94:13 106:6,10 119:10 126:23,23 256:19writing 57:8 159:8 238:3writings 177:14written 49:15 66:6 90:11 94:12,13 101:20 126:20 167:3 227:11, 12 240:13, 15 244:22 245:1, 3 274:14wrong 22:16 147:15 220:16 246:13

wrote 10:6 15:19 106:8, 9

< X >X, 126:17XYZ 271:19

< Y >yeah 13:17 16:12 18:18 20:24 25:10 43:20 54:11 58:2 60:2 62:25 64:14 65:9 67:6 75:14 76:4,18 81:4 84:8 94:18, 22 96:15 97:19 102:8 105:17 106:21 108:11 115:9, 17 118:14, 20 119:13 120:23 121:10 122:2, 4 123:16, 18 124:14 126:4 127:14 136:2 150:23 156:5, 15,18 157:9, 9 158:10 171:16, 19 178:10,23, 23 179:6 180:21, 25, 25 188:23 206:22 209:3 212:9 215:9 218:9 223:7 224:7 227:9, 14 232:18 239:6 260:21, 25 261:12 263:16 268:5, 13 270:19 274:14 281:8yeah, 75:23year 9:24 12:8, 16,18 13:16, 17, 23, 25,25 14:13 15:9 16:6 17:19 18:8,14, 16, 17, 19 20:20 21:5, 7 23:12 54:24 62:1, 11, 22 81:21, 22 84:13 97:6 102:17 128:4, 7 148:13 171:6 229:6

years 10:1, 5, 20 14:10 17:20, 25 18:23 19:14 20:16 23:3 24:11,14 32:16 38:25 39:4 62:18 64:9 66:13 101:13 102:11 106:3 193:9, 9 200:19yelling 251:6Yep 186:10YORK 93:21 95:3young 69:9 95:3 203:10, 20 209:18 210:2, 18 265:9

< Z >Zeddies 93:23 94:11 96:3zone 139:15Zuniga 2:10 7:2 148:16 154:15, 19 155:15 157:7 229:8, 15 230:13 240:12 246:24 247:14 265:19, 25 277:15 281:17 283:8Zuniga's 148:21 279:8

WORD LIST

< , >, (1)

< 0 >000043-045 (1)000047-048 (1)000057 (1)00037 (1)002-13 (1)007-12 (1)09 (2)

< 1 >1 (7)1.152 (1)10 (13)10:00 (2)10:06 (1)10:17 (1)100 (1)102 (1)1032 (1)106 (1)109 (1)11 (16)11:07 (1)11:11 (1)11:51 (1)11-29-09 (1)115 (1)117 (1)119 (2)12 (7)120 (1)122 (1)129 (1)13 (3)130 (1)1302 (1)14 (2)1413 (1)1422 (1)15 (2)1503 (1)151 (1)1511 (1)152 (4)1557 (1)

16 (6)160 (1)1607 (1)1638 (1)167 (1)17 (4)170 (1)172 (1)174 (1)177 (1)178 (1)179 (1)17th (2)18 (3)18th (1)19 (3)190 (1)1993 (1)1994 (2)19th (1)

< 2 >2 (9)2:11-cv-01919-LRH-RJJ (2)20 (4)2000 (2)2002 (1)2003 (3)2005 (5)2007 (2)2008 (3)2009 (27)2010 (17)2011 (66)2012 (2)2013 (4)20th (1)21 (7)21st (3)22 (6)2200 (2)222 (1)23 (5)238 (1)24 (1)25 (4)25th (1)2620 (1)265 (1)

26th (1)270 (1)277 (1)27th (1)28 (1)280 (2)281 (1)283 (1)283.143 (3)29 (4)29th (2)

< 3 >3 (3)30 (6)303 (5)30th (2)31 (1)35 (2)3-5 (1)360 (1)3773 (1)3993 (1)

< 4 >4 (4)4:38 (1)40 (3)400 (1)40-minute (1)41 (2)44 (1)4th (1)

< 5 >5 (6)517 (3)5th (1)

< 6 >6 (2)60 (1)600 (2)64 (1)65 (1)673 (2)6734 (1)

< 7 >7 (6)

701 (1)7-18-11 (1)7th (2)

< 8 >8 (6)83 (1)85 (3)86 (1)87 (1)89101 (3)89128 (1)89169 (2)

< 9 >9 (4)9:06 (2)90 (1)9000 (1)91 (4)93 (2)94 (7)95 (2)96 (3)9-millimeter (1)

< A >a.m (1)abide (1)ability (3)able (15)Absolutely (3)Academy (3)acceptable (2)accessed (1)accident (23)accidents (1)accompanying (1)accord (1)account (3)accounting (1)accounts (4)accreditation (4)accumulating (1)accurate (10)accurately (2)achieve (2)Acknowledge (1)Acknowledged (8)acknowledgment



(1)acquaintances (1)acquire (5)acquired (2)acquiring (2)act (6)acted (3)acting (4)action (29)actions (11)action-taking (1)actively (2)activities (3)activity (4)acts (6)actual (25)add (1)addition (2)additional (5)additions (1)address (6)addressed (6)adhered (1)adjacent (1)adjust (3)administered (2)administration (5)Administrative (13)administratively (3)administrator (11)administrators (4)admitted (1)admittedly (1)adult (2)advancement (1)advice (1)advised (5)affair (1)Affairs (46)affect (1)affirmative (6)affix (1)aforesaid (1)AFTERNOON (3)age (1)agency (9)agency's (1)agent (3)

agents (1)ago (1)agree (7)agreed (2)agreements (1)Ah (1)ahead (12)air (3)aired (3)al (3)Alan (1)alcohol (11)alcoholic (4)Aldays (13)Aleister (1)Alex (1)Alexander (1)Alfred (3)alive (1)all-day (1)alleg (1)allegation (3)allegations (20)allegations, (1)allege (4)alleged (4)allegedly (4)alleging (1)allow (3)allowed (18)allows (1)Alvarado (1)amended (1)American (1)amount (4)ample (1)AN-017-10 (1)Andrea (12)ANGELA (21)Angela's (8)anonymous (7)anonymously (1)answer (26)answered (2)answering (1)answers (2)antagonistic (1)antics (1)anti-gang (1)antiviolence (2)

anybody (38)anybody's (1)anymore (1)anyway (2)apart (2)apologize (1)apparently (2)appear (4)APPEARANCES (1)appeared (2)appearing (1)appears (4)applied (5)apply (3)appreciate (4)apprehend (1)approaching (3)appropriate (7)appropriately (6)approval (1)approved (2)Approved, (1)approving (1)approximate (13)approximately (8)April (2)aptitude (1)area (15)areas (5)argument (1)arises (1)Armando (9)arrangements (1)arrest (16)arrested (6)arrests (1)arrival (1)arrived (3)Arroy (1)ARROYO (31)ARROYO, (1)article (4)ascertain (1)aside (1)asked (29)asking (19)aspect (2)aspects (7)asserting (1)

assess (4)assign (2)assigned (8)assignment (2)assist (3)assistant (4)associated (1)Association (1)assume (5)assumed (1)assuming (8)assumption (2)Atlanta (1)attached (1)attained (1)attempt (2)attempted (4)attempting (4)attempts (1)attend (3)attendance (1)attended (7)attendee (1)attendees (2)attending (1)attention (9)attest (1)Attorney (8)attorneys (5)attributable (1)at-will (7)audibly (1)audit (2)audited (1)August (16)authorities (1)authority (6)authorization (2)authorized (3)automat (1)automated (1)automatically (3)available (1)Avenue (1)average (2)avoid (1)award (4)awards (1)aware (51)

back (39)backed (2)background (1)bad (5)badge (5)Bailus (2)bajillion (1)balance (1)ball (3)bankruptcy (1)barred (2)Barris (3)base (1)Based (32)basement (1)basically (82)basing (1)basis (7)Bates (2)bathroom (1)Beach (13)beaten (1)beating (1)becoming (3)beer (14)beer, (1)began (7)beginning (12)begins (1)behalf (7)behavior (2)belabor (1)belief (4)believe (86)believed (6)believes (2)believing (1)Belinda (4)belly (1)belongings (1)beneath (1)benefit (1)Beretta (1)best (4)better (8)beverages (4)beyond (4)bicker (1)big (1)

biggest (2)Bill (3)birth (1)bit (8)blown (2)blowup (1)blue (1)Board (10)Bob (2)bodies (1)body (1)booster (1)born (4)boss (1)bottom (7)Bounty (1)Boyett (12)Boyette (3)Boyett's (2)boyfriend (4)boys (1)brain (1)breach (1)break (10)breaks (3)Brian (8)Bridger (2)BRIEF (5)briefed (1)briefing (1)Briefly (2)bring (18)bringing (1)brings (1)broke (15)brought (17)Brown (4)buck (1)budging (2)bugged (3)building (8)bulletin (1)bunch (1)Bureau (1)Burgess (18)Burgess's (1)business (6)bust (1)busy (1)buy (1)

bypass (1)Byrd (2)Byrd's (1)

< C >cabinet (5)CAD (1)café (1)cafeteria (1)calculate (1)CALEA (2)call (16)called (4)calling (1)calls (5)camera (1)cameras (1)candidacy (2)candidate (1)candidates (2)Canons (1)Cap (1)capabilities (1)capability (1)capable (2)capacity (4)captain (47)captains (1)Car (7)card (1)care (15)Carrie (1)carrier (1)carry (1)carrying (4)Case (93)cases (16)casino (1)categorize (1)category (3)caught (1)cause (14)caused (3)causing (1)CCR (2)CCSD (33)CCSD000125-130 (1)CCSD000129 (1)CCSD000143 (1)

CCSD000155 (1)CCSD000172 (1)CCSD000174 (1)CCSD000219 (1)CCSD000227 (1)CCSD-issued (1)CCSDPD (3)center (3)certain (27)certainly (4)CERTIFICATE (2)certification (3)Certified (4)certify (3)chain (12)Chambers (1)chance (1)change (16)changed (6)changes (3)Channel (3)channels (1)characterization (1)characterize (1)charge (3)charged (2)Chart (1)charts (1)Chary (1)Chavez (8)check (2)checked (3)chief (50)CHIEF, (1)Chiefs (1)chief's (2)child (1)choice (1)chose (4)chosen (2)Chris (2)Christmas (3)CHRISTOPHER (1)circumstances (15)citizen (1)City (6)civil (6)

civilian (2)claim (2)claims (1)clarification (3)clarifications (1)clarified (1)clarify (2)clarifying (1)Clark (43)clashed (1)Class (4)classes (1)clause (3)clear (8)clearly (1)clears (1)Cleveland (7)Clinic (8)close (3)closed (1)coach (4)coast (5)Code (13)Codes (1)coerce (7)coexist (2)cohesive (1)Coke (1)collaborating (1)collected (1)Color (2)column (1)combination (1)come (42)comes (5)comfortable (4)coming (11)command (21)commendation (1)commendations (1)comment (3)commit (1)committed (1)Committee (3)committing (1)common (3)communicate (1)Communications (2)community (3)

comp (1)company (2)compartment (1)compatible (1)competently (1)complain (1)complains (2)complaint (7)complaints (1)complete (5)completed (3)Completely (1)compliance (1)complicated (2)composed (1)computer (11)computer-aided (1)computers (1)con (1)concept (3)Concern (26)CONCERN, (1)concerned (8)concerning (3)concerns (3)conclude (1)concluded (2)concludes (3)conclusion (5)concrete (1)concurrent (1)conditioning (1)condone (1)conduct (24)conducted (7)conducting (5)conference (2)confidence (5)confidential (3)confines (1)confirmed (1)confiscated (1)confrontation (2)confrontational (2)confrontational, (1)connected (1)consisting (1)constant (1)constantly (1)constitute (1)

Constitution (1)consumed (1)consumption (1)contact (15)contacted (8)contacting (1)contained (1)content (4)continue (5)continued (3)continuously (1)contract (17)contractor (2)contractual (1)contribution (3)control (3)conversation (37)conversations (18)conversing (1)convey (4)conveyed (5)conveying (1)convicted (2)conviction, (1)COOK (205)Cook's (1)cooler (1)cooperate (1)cop (8)copied (2)cops (8)corner (1)corporation (1)corporations (1)correct (284)corrected (3)correction (2)corrections (1)correctly (5)corridors (1)costs (1)Counsel (6)Counselor (3)count (2)counterpart (1)country (1)County (52)couple (10)course (11)COURT (9)

courtyard (1)Cover (3)covered (5)covering (1)cover-up (9)cover-up, (1)Craig (1)create (1)created (2)creating (2)credence (1)crime (7)Crimes (3)criminal (34)criminally (4)criteria (3)Crowley (1)CRR (2)crush (1)culture (2)cup (2)cups (2)current (2)currently (3)curtail (1)custody (1)cutting (1)Cynthia (5)

< D >DA (1)dad (3)daily (1)damage (1)damages (7)Daniel's (4)Darren (1)date (7)dated (5)dates (1)daughter (6)daughters (1)daughter's (1)day (16)days (10)day-to-day (3)dead (2)deal (3)dealing (2)dealt (1)

death (13)debacle (1)deceased (1)December (15)decide (1)decided (2)decides (4)decision (4)declare (1)dedicated (1)deeds (1)defend (1)defendant (1)Defendants (19)defending (1)defense (5)defenses (2)definitely (7)definition (1)degree (7)deliver (2)delivered (3)demise (2)demonstrate (1)Dennis (3)Department (158)departmental (2)departments (5)departure (1)dependent (1)depending (4)depends (3)deployment (1)depo (2)deponent (2)depos (1)deposed (2)DEPOSITION (37)derived (1)described (1)DESCRIPTION (4)destroy (1)destroyed, (1)detail (4)detailing (1)details (12)detective (24)detective, (1)detectives (5)

detective's (1)detector (2)determination (4)determinations (1)determine (1)determines (1)developed (1)died (2)difference (8)differences (2)different (18)differentiate (1)differently (6)difficulty (1)diminish (1)dinner (3)direct (24)directed (7)directing (4)direction (13)directive (3)directives (1)directly (5)directors (2)disagreed (2)disagreement (1)disagreements (4)disapprove (5)Disapproved (3)disciplinary (4)discipline (7)disciplined (9)disciplines (2)disciplining (1)disclose (2)discord (1)discounted (1)discovered (3)discretion (1)discuss (11)discussed (16)discusses (1)discussing (4)discussion (5)discussions (2)disgruntled (5)disk (8)disks (3)dismissed (2)dispatch (20)

dispatcher (23)dispatchers (32)dispatcher's (3)displeased (1)dispute (4)disseminate (2)dissipate (1)dissolved (1)distance (1)distinction (3)distinguish (1)distort (1)distributed (1)DISTRICT (124)districts (1)District's (2)division (5)doctoral (2)doctrine (1)document (19)documentation (5)documented (2)documents (4)document's (1)doing (22)domestic (3)

DontServeTeens.gov (1)DontServeTeens.gov, (1)double-negative (1)Doug (2)downloaded (1)drank (3)draw (1)drink (7)drinking (47)drinks (4)Drive (3)driver (2)drives (1)driving (1)dropped (3)drove (2)drug (2)drugs (1)drunk (6)due (1)DUI (7)

duly (3)duration (1)duties (11)duty (29)Dwight (1)dysfunction (1)

< E >earlier (31)early (1)easiest (1)easy (1)education (1)effect (8)effort (1)efforts (1)eight (1)either (16)elaborate (1)elected (2)electrical (1)eliminate (3)else's (1)EM (1)E-mail (2)E-mails (2)embark (1)embarrassment (1)emblem (4)emergency (2)employee (18)Employee-Man (1)Employee-Management (2)employees (12)employment (1)EMR (26)encourage (1)ended (3)enforce (1)enforcement (13)engaged (3)English (1)Enough, (1)entered (1)entire (4)entirety (4)entities (1)entitled (3)entity (2)

EOC (1)Eric (2)Erik (3)ES (1)ESQ (4)essence (2)essentially (5)establish (5)established (4)estimate (4)estoppel (1)et (3)Ethics (1)evaluate (1)evening (3)event (3)events (4)eventually (5)everybody (9)everything's (1)evidence (4)ex (2)exact (6)exactly (15)Examination (14)examined (2)example (9)excessive (1)exclude (1)exclusively (1)Excuse (7)exec (1)executive (4)Exhibit (49)exhibits (2)exist (1)existed (1)expanded (1)expect (8)expectation (2)expected (1)experience (5)experiences (1)expired (1)explain (2)explained (1)extended (1)extent (5)extort (4)extorted (1)

extortion (3)extra (2)Extremely (3)eye (6)eyes (1)

< F >Facebook (14)Facebooks (1)faced (1)facilitate (1)facilitated (1)facilities (1)fact (25)facts (6)factual (2)factually (4)failed (9)failure (1)fair (14)fairy (1)fairytales (1)fall (2)falling (1)falls (1)false (5)familiar (7)families (1)family (7)far (25)fashion (3)fast (1)fatal (1)fatality (2)father (1)father's (2)fault (1)favorites (1)favoritism (1)FBI (9)February (24)feedback (1)feel (3)feeling (1)fees (4)felony (1)felt (2)female (8)festivities (1)Fetcho (4)

fight (2)fighting (1)figure (5)file (13)filed (8)files (1)FILIBERTO (18)fill (1)filled (5)filling (3)final (1)finalized (1)finally (1)financially (1)find (34)finding (1)fine (3)finish (6)finished (3)fire (3)firearm (11)firearms (2)fired (1)firm (2)first (65)firsthand (4)fit (2)five (24)five-minute (1)Flamingo (2)flier (17)fliers (5)Flip (1)flipped (1)Florida (8)flyers (2)folder (4)folding (1)follow (20)followed (1)following (6)follows (2)follow-through (2)follow-up (5)follow-ups (1)font (1)football (2)Force (2)foregoing (1)forever (2)

forged (1)forgot (6)form (82)formal (2)format (1)forms (1)Form-wise (1)forth (17)forward (22)forwarded (6)found (7)foundation (39)four (11)fourth (5)frame (6)FRANCIS (3)frankly (1)fraud (1)FRCP (1)free (2)fresh (1)friend (3)friends (5)front (8)fueled (2)fulfill (4)full (3)full-blown (1)fully (3)function (1)further (5)furthermore (4)

< G >gag (3)Gamboa (19)Gamboa's (1)game (2)gap (1)Garcia (1)Gardens (1)gather (1)geared (2)geez (1)general (14)generally (6)generated (1)gentleman (1)George (3)Gervasi (6)

get-go (1)getting (23)Gil (1)Gillespie (31)girl (3)girlfriend (1)gist (1)Give (31)given (18)gives (2)giving (9)glad (1)Glaviano (9)Glaviano's (1)glove (1)go (73)go-ahead (1)God (1)goes (10)going (106)Gold (2)Goldman (1)good (15)Goodwin (1)Google (1)Googling (4)gotten (6)grabbed (1)granted (1)gray (2)great (1)Green (1)Greenberg (1)group (4)guess (9)guest (4)guests (1)guidance (1)guidelines (1)Guild (1)guilty (1)gun (11)guns (2)guy (13)guy, (1)guys (9)guy's (2)

< H >habit (1)

half (12)halfway (1)hand (6)handed (9)handgun (1)handing (1)handle (7)handled (15)handling (3)hands (1)handwritten (1)hang (1)hanging (1)happen (10)happened (38)happening (1)happens (3)happenstance (1)Harbor (1)head (6)headed (2)headquarters (1)heads-up (1)hear (22)heard (29)hearing (2)Hector (1)he'd (1)held (4)he'll (1)hellos (1)help (11)helpful (1)helps (1)Henderson (7)HENDRICKS (108)hereunto (1)hesitant (1)Hey (3)Hickey (1)hidden (1)hide (3)Higgins (21)high (4)higher (1)Highlight (7)highlighted (1)Highlights (11)high-school (1)

hindsight (1)hired (5)hiring (1)history (3)Hoffman (5)hold (1)holding (1)holiday (1)home (18)homeowner (1)Honest (1)Honor (1)hope (5)hosted (3)hour (1)hours (8)house (9)Howard (2)how'd (1)how's (2)HR (4)Hughes (2)Hull (3)hundred (6)Hundreds (2)hurricanes (1)hurt (1)husband (2)hypothetical (2)hypotheticals (1)

IA (1)ICE (4)ID (1)idea (12)ideally (1)identification (22)identified (2)identify (3)idiot (1)Iliana (1)I-l-i-a-n-a (1)ill (1)illegal (1)illicit (1)illness (1)immediate (2)immediately (2)impact (1)

impaired (2)impartiality (1)impede (1)impetus (2)implemented (1)implied (2)implying (1)important (1)impression (6)inaccurate (1)inadequate (1)inappropriate (4)incidences (1)incident (18)incidents (3)include (7)included (3)including (4)incomplete (2)incorrect (3)increase (1)incurred (1)independent (4)indicated (14)indication (1)indirect (1)indispensable (2)individual (29)individually (3)individuals (22)individual's (1)inebriated (3)influence (1)info (3)infor (1)inform (1)information (177)information, (2)informed (15)informing (1)ingrained (2)initial (5)initials (1)initiate (6)initiated (3)initiating (1)initiative (2)initiatives (4)innuendos (4)in-passing (1)

input (2)inside (1)instance (4)instances (1)instruct (3)instructing (3)instruction (1)insurance (3)inten (1)intensity (1)intentionally (1)interact (2)interaction (11)interactions (2)interested (2)interfere (2)interfering (5)interior (1)intermediate (1)Internal (54)International (1)Internet (2)Interoffice (2)interpreted (2)intervening (3)interview (14)interviewed (1)interviewing (1)interviews (1)intoxicated (2)intoxicating (1)introduce (1)introduced (1)introducing (1)introductions (1)invading (1)investi (2)investigate (9)investigated (4)investigating (12)investigation (132)investigation, (1)investigations (16)investigator (7)investigators (4)invited (2)involve (3)involved (36)involvement (9)involving (7)

Ironically (1)ISO (1)issue (17)issued (3)issues (32)items (4)its (2)

< J >Jack (4)Janu (1)January (9)Jerry (1)Job (9)Joe (3)Johnson (37)Join (32)joined (1)joint (3)Jones (55)Jones's (7)Journal (2)Journalism (1)JR (2)July (40)July's (1)jumped (1)jurisdiction (3)justifications (1)Jutta (1)juvenile (3)

< K >Kadlub (1)kajillion (1)KARA (4)Karma (1)keep (9)Kelesis (2)KELLER (25)Ken (2)KENNETH (2)kept (3)Ketsaa (70)Ketsaa's (4)KEVIN (13)Kevin's (1)keys (1)kid (17)kids (8)

kid's (1)kids, (1)kill (1)killed (10)kills (4)kind (10)Kinda (1)Knapp (8)knew (26)know (202)knowing (7)knowledge (4)known (3)knows (8)

< L >LaBorde (4)laches (1)lack (2)language (1)laptops (1)large (1)Las (13)lasted (1)late (1)Laundromat (9)laundry (1)LAURSEN (2)law (15)lawful (2)lawsuit (13)lax (1)laxed (3)lead (4)leads (1)learned (2)leave (8)leaves (2)leaving (9)led (36)Lee (4)left (46)Legal (7)legislation (1)Letter (15)letters (3)letting (4)level (7)levels (1)leverage (1)

Lewis (1)liability (1)liable (1)liaison (1)licensed (1)lie (5)lied (5)lies (2)lieu (2)lieutenant (32)lieutenants (2)Life (2)light (4)lights (1)liked (1)likelihood (1)limit (3)limited (5)limiting (1)LINDA (3)line (12)lined (1)lines (1)linked (1)list (3)listed (3)lists (2)lit (1)literally (1)little (16)lives (1)LLP (2)local (1)located (1)location (4)locks (1)logged (2)logo (6)long (17)longer (5)longstanding (1)look (18)looked (3)looking (4)looks (9)Loren (21)loss (1)lost (2)lot (2)loudly (1)

love (3)lunch (2)Luncheon (1)LVMPD (2)lying (5)

< M >made-up (3)magazine (2)magistrate (2)mail (1)mailed (1)main (4)maintain (2)majority (2)making (11)man (2)manage (1)Management (3)manager (4)manner (4)manpower (1)manual (1)MARC (8)March (2)Marisa (1)Mark (14)MARKED (29)married (2)Master (1)match (1)Matt (2)matter (20)MATTERS (4)MATTHEW (1)Mayer (2)me, (1)mean (39)means (7)meant (2)media (24)medication (1)meet (10)meeting (42)meetings (12)meltdown (1)Member (4)members (8)memo (11)Memorandum (12)

memorandum's (1)memory (1)memos (2)mentioned (16)mentioning (1)merely (1)MESSAGE (9)messages (1)messaging (1)met (27)metal (2)Metro (98)Metro, (3)Metropolitan (9)Metro's (5)Miami (20)Miami-Dade (1)Michael (1)micromanage (1)microphone (1)middle (6)mid-February (1)Mike (25)mile (1)miles (1)mill (6)mill, (1)mills (1)mind (9)mind-set (1)Mine (1)Minimally (1)minimum (1)minor (18)minors (3)minutes (10)MIRANDA (31)Mirandas (1)Miranda's (8)Mischaracterizes (1)misdemeanor (1)misinterpreted (1)misstate (1)misstatement (1)misstates (10)mistaken (12)mitigate (2)mitigating (1)mixed (2)

model (2)modify (1)mom (1)moment (1)Monday (17)Month (4)months (15)moot (1)moral (8)morale (1)Morales (39)morality (1)morally (2)morning (22)morning's (1)motivation (5)motivational (1)mouth (1)move (2)moved (1)MPS (3)Multiple (3)

< N >nagged (1)name (18)named (5)names (26)name's (1)naming (1)Narcotics (6)narrowed (1)national (1)nationwide (1)nature (6)Nebeker (24)Nebeker's (1)necessarily (6)necessary (2)necessity (1)need (16)needed (7)needs (3)negative (2)negligence (2)negotiation (1)nephew (1)NEVADA (15)never (44)new (12)

news (42)newspaper (4)nice (1)Nichole (1)Nick (3)niece (1)night (4)Ninth (3)no, (1)Nobody's (2)nodding (2)normal (1)normally (1)North (4)note (2)notes (2)nothing.' (1)Notice (8)Noticeable (1)notification (4)notifications (3)notified (5)notify (12)noting (1)not-investigated (1)November (14)nowhere, (1)NRS (4)NUMBER (33)Numbers (3)numerous (1)

< O >Oasis (3)object (5)Objection (98)obligated (1)obligation (8)observe (1)observed (3)obstructed (1)obvious (3)obviously (7)occasion (6)occasions (2)occur (4)occurred (11)occurring (2)October (8)off-duty (2)

offensive (3)offering (1)office (45)office, (1)officer (71)officer-level (1)officers (60)offices (1)officials (1)oh (33)Okay (241)okaying (1)old (9)older (1)omission (2)omissions (1)Once (18)on-duty (1)ones (3)ongoing (5)on-line (1)onset (1)open (11)opened (5)opening (5)openings (2)openly (1)open-minded (1)opinion (8)opportunity (1)opposed (8)option (1)oral (2)orchestrated (1)order (11)ordered (5)ordering (1)orders (2)organization (8)Organizational (1)original (2)outlandish (2)outside (2)outstanding (1)overadjusted (1)overall (3)overnight (1)overseeing (1)overstating (1)owned (1)

owner (4)

P.A.R.C (2)P.A.R.C. (1)p.m (1)package (1)packed (1)PAGE (16)Pages (5)paid (2)Palm (17)panel (1)paper (6)paperless (1)papers (1)paragraph (28)paragraphs (1)Pardon (2)parent (1)parents (5)PARK (73)Parkway (2)part (30)partic (1)participated (5)participating (4)particular (33)particularly (3)particulars (2)parties (10)partly (1)party (140)pass (9)passed (16)passenger (2)passes (3)passing (9)passively (1)patrol (10)patrolman (4)pause (1)pay (1)paying (1)payment (2)PD (1)penalty (1)pending (4)Penny (11)people (37)

people's (1)perceived (2)percent (5)percentage (1)perfect (2)performed (1)performing (2)period (12)perjury (1)permission (1)permitted (2)person (11)personal (8)personally (6)personnel (15)persons (1)perspective (1)pertain (1)pertaining (2)pertinent (1)PETERSON (32)PETERSON00705 (1)PETERSON00736 (1)PETERSON00791 (1)Petersons (1)Peterson's (1)Phil (6)phone (9)Photograph (3)Photographs (1)photos (3)phrase (1)physically (2)picked (1)picking (3)picture (5)pictures (5)picture's (1)piece (4)piecemeal (1)pieces (1)pilot (5)Pinellas (1)pinned (2)PIO (1)piping (1)place (14)

plain (1)plaintiff (3)Plaintiffs (12)plan (4)play (3)played (1)playing (5)please (9)pled (2)plus (2)pocket (1)point (57)pointed (1)points (1)police (185)policies (5)policy (30)policy-wise (1)politely (1)pong (12)porn (3)portion (4)posing (1)position (40)positions (12)positive (1)positively (1)possible (2)possibly (5)Post (6)Posted (6)Posting (4)potential (1)potentially (2)practice (7)practices (2)predecessors (1)preference (1)premises (1)prepare (2)prepared (8)prerogative (2)Present (16)presented (21)presenting (1)president (4)presidents (1)press (3)pressure (1)presume (1)

pretend (1)pretty (12)prevent (3)previous (3)previously (2)primarily (2)principal (1)print (2)printed (2)Printout (1)prior (25)private (4)privy (4)pro (1)probable (1)probably (4)probe (1)problem (9)problems (2)procedural (1)procedure (5)procedures (4)Procedure's (1)proceed (1)proceeded (3)proceeding (3)proceedings (1)process (28)produced (2)professional (2)program (15)programs (2)progress (2)progressed (1)promise (1)promote (1)promoted (11)promotion (9)promotions (5)prompted (5)pronouns (1)proper (9)properly (2)property (8)proportion (1)prosecute (1)prospective (1)protocol (4)protocols (1)proud (1)

provide (5)provided (19)providing (5)proximate (1)public (5)pull (2)pulled (2)pulling (2)punish (3)punished (1)Purcell (6)purpose (1)purposes (1)pursuant (1)pursue (1)pushed (1)put (23)putting (1)Pyatt (1)

< Q >qualification (1)qualifications (4)qualified (2)Quality (2)question (31)questionable (1)questioned (4)questioning (1)questions (21)quick (1)quickly (1)Quintanilla (28)Quintanilla's (2)quite (1)quote (5)Quotes (2)

< R >Rainbow (1)Rainey (1)raise (1)range (3)rank (5)rapport (1)rate (1)reached (1)reaction (2)read (22)reading (8)

real (4)realist (1)Realistically (2)reality (2)really (4)reason (23)reasonably (3)reasons (18)reassigned (3)reassignment (8)reassured (1)Rebecca (15)recall (54)receive (2)received (16)receiving (1)Recess (6)recessed (1)recognize (7)recognized (1)recollection (2)recommendations (1)Recommended (1)record (19)records (2)red (1)redo (1)reestablish (1)refer (2)reference (1)references (2)referring (1)refilled (1)reflect (1)regain (1)regard (15)regarding (34)regardless (2)regards (6)Regatta (1)regs (1)regular (3)regularly (2)regulations (1)reimbursement (1)reinforce (1)reinforcement (1)RELATED (9)relation (9)

Relations (4)relationship (3)relative (2)released (4)releases (1)releasing (3)relevant (1)relocated (2)relocating (2)relying (1)remain (2)remaining (2)remember (56)reminded (1)removed (2)rep (1)repaired (1)repeat (2)rephrase (2)Report (36)Reported (8)reporter (8)REPORTER'S (1)Reporting (9)reports (10)represent (8)representation (1)representative (2)represented (1)representing (1)request (5)requested (2)requesting (1)require (1)requirement (3)requirements (1)researched (1)resolved (1)respect (1)respond (2)responded (3)response (4)responsibilities (2)responsibility (6)responsible (1)rest (4)restrict (1)restricting (1)result (4)retire (3)

retiring (1)return (1)returned (3)reversed (1)revert (1)review (11)reviewed (1)reviewing (1)reword (1)rewrites (1)ridiculous (1)rifles (1)right (74)rights (1)rises (1)risk (1)RJ (1)Robbery (2)Robbins (59)Robert (2)Roberto (4)Robinson (1)Roca (1)roll (2)rolled (1)rolls (1)Ron (1)room (6)rooms (1)rough (1)Roughly (5)round (1)RPR (2)Ruelas (14)rule (2)Rulffes (5)rumor (23)rumors (18)run (7)running (4)rushing (1)

< S >salary (1)sale (1)sales (1)sand (2)sat (2)saw (10)saying (20)

says (36)scenar (1)scenario (4)scenarios (2)scene (4)scenes (1)School (124)schools (3)screen (14)screening (1)se (5)second (23)secondary (1)secondhand (2)secretary (1)section (4)Security (2)see (31)seeing (5)seen (23)sees (1)segment (8)segments (3)selected (2)selects (1)self (1)sell (1)selling (1)send (16)sending (4)sends (1)sense (3)sent (6)sentence (9)sentences (1)sentencing (1)separate (7)separated (2)separately (6)separation (14)September (5)sergeant (47)sergeants (11)sergeant's (2)serial (1)series (3)serious (1)seriously (1)servants (1)Serve (1)

served (5)service (2)Services (6)SESSION (3)set (8)settled (5)settlement (4)settling (1)seven (1)seventh (1)sexual (1)Sgt (9)share (3)shared (3)She, (1)Shepard (1)sheriff (7)

[email protected] (2)sheriff's (1)shield (2)shoot (3)shooting (3)short (5)shorthand (1)shortly (10)shots (1)show (7)showed (3)shows (1)sic (4)side (3)sign (2)signature (16)signatures (3)signed (3)significant (5)signing (2)signs (1)Silvestri (1)similar (3)sincere (5)sincerely (1)single (1)Sir (207)sirens (1)sit (14)Site (4)sit-in (1)

sitting (6)situation (20)situations (1)situation's (1)six (5)Sixth (1)size (1)skipped (1)sky (1)sneak (2)snowballed (1)snuck (3)sole (2)Solo (1)somebody (32)somebody's (1)someone's (1)someplace (1)Somewhat (2)son (3)soon (2)sooner (1)sorry (44)sort (1)sorta (1)sound (3)Sounds (1)source (2)South (3)speak (2)speaker (1)speaking (1)Specialist (2)specific (9)specifically (21)specifics (10)spectator (1)speech (2)speed (3)Spencer (2)spiritual-type (1)spite (1)spoke (7)sponsored (1)spot (4)squad (2)ss (1)staff (14)staffing (1)stage (2)

stages (1)stamp (2)stance (1)stand (6)standard (2)standards (2)standing (1)standpoint (1)stands (3)star (3)Starbucks (2)start (15)started (17)starting (2)State (8)stated (5)statement (35)statements (9)STATES (3)stating (1)station (2)statistical (1)stats (2)status (2)statute (6)stay (10)stayed (2)staying (1)stays (1)Steering (3)stenographic (1)step (3)stepped (1)steps (7)sterile (1)stick (5)stirring (1)stood (2)stop (6)stopped (2)stops (2)stories (19)story (80)straight (5)straightforward (1)streaming (2)Street (6)strife (1)Strike (20)Structurally (1)

structure (5)structured (2)student (4)students (4)student's (1)stuff (5)Style (1)sub (1)subject (5)subjects (1)submitting (1)subordinates (1)subpoenaed (2)subsequent (3)subsequently (1)substance (5)substantive (2)substantively (2)sue (2)sued (1)Sufana (1)suffered (1)sufficient (3)suggest (1)suggested (1)suggestions (1)suit (4)Suite (4)summarize (1)Sunday (1)sup (1)super (2)superintendent (80)superiors (1)superseding (3)supervise (2)supervised (4)supervising (1)supervision (1)supervisor (17)supervisors (1)Supplement (1)support (4)supposably (5)supposed (8)supposedly (1)sure (47)surely (1)surprise (4)

surprised (7)surprises (1)surrounding (3)survival (1)suspect (2)suspended (2)sustained (2)swear (1)swirling (1)switch (1)switched (1)swore (1)sworn (5)synopsis (1)system (8)

< T >table (13)tail (1)tailored (1)take (44)Taken (28)takes (2)tales (1)talk (34)talked (31)talking (39)talks (2)Tampa (2)tape (5)targeted (1)Task (1)T-boned (1)team (1)tear (2)tearing (2)technicality (1)technology (4)Teens (3)telephone (1)tell (42)telling (20)tells (3)template (2)ten (9)tend (1)ten-month (1)tens (1)tenure (1)term (2)

Terminable (1)terminal (3)terminally (1)terminals (1)terminated (4)termination (3)terminology (1)terms (2)testi (1)testified (16)testify (3)testifying (1)testimony (43)text (2)texting (2)Thank (14)Thanks (2)Thanksgiving (1)thereof (2)thing (21)things (31)think (79)thinks (1)third (10)Thomas (22)Thomas's (5)thought (18)thousand (1)three (25)three-month (1)Three-quarters (1)threw (1)thrown (1)tickets (3)tidbits (2)tied (1)till (15)time (149)times (23)Tina (10)Tina's (2)title (2)Today (24)today's (8)told (31)ton (1)top (6)topic (3)total (4)totality (2)

totally (3)town (1)track (1)tracking (1)Tracy (3)traffic (3)tragedy (1)training (1)transcribed (1)transcript (2)transcription (1)Traurig (1)trespass (1)trial (1)trouble (3)true (29)trust (5)Trustees (3)trustworthy (1)truth (13)truthful (9)truthfully (2)try (16)Trying (26)turn (9)turned (14)TV (1)twice (1)two (68)two-minute (1)type (31)typed (1)types (5)typewriting (1)typewritten (1)typical (1)typically (3)

U.S (1)Uh-huh (35)Uh-uh (1)ultimate (3)ultimately (2)unauthorized (4)uncomfortable (4)unconditional (1)Undated (1)underage (2)undermine (3)

undermined (2)undermining (1)understand (54)understanding (21)understood (4)undivided (1)unfolding (1)Unfortunately (2)unhappy (2)uniform (3)uninvited (2)union (18)Unit (7)UNITED (2)units (1)unlawful (1)UNLV (3)unproper (1)untruthful (2)up, (1)uphold (1)upset (8)upstairs (2)use (5)usually (4)Utah (2)utilizing (2)

< V >Valley (2)various (1)Vegas (13)vehicle (11)vehicles (2)vehicular (2)veracity (1)verbal (4)verbally (1)verbatim (1)verified (1)verify (5)version (1)versions (1)versus (3)vice (4)victims (2)Video (18)videographed (10)VIDEOGRAPHER (19)

Videographers (1)Videotape (1)view (4)Vincent (1)violate (2)violated (5)violates (1)violating (1)violation (4)violence (4)violent (1)voluntary (1)volunteering (1)vs (1)

< W >Wack (1)Wackenhut (10)wait (4)waited (1)waiver (1)walk (1)walked (1)walking (3)Walt (2)Wamsley (41)Wamsley's (7)want (42)wanted (19)wanting (2)wants (1)warehousing (1)Warren (5)watch (1)watched (2)watching (4)water (1)way (36)weapon (1)Web (1)Week (27)week, (1)weekend (1)Weekly (2)weeks (5)well (77)went (47)we're (30)west (12)we've (9)

whatever, (1)whatsoever (4)When's (2)Where'd (1)WHEREOF (1)Why'd (1)wide (1)wife (11)wife's (1)William (4)Williams (1)wish (1)WITNESS (24)witnesses (2)witnessing (2)witness's (1)woman (1)wondering (1)word (3)worded (1)words (8)work (26)worked (11)working (22)workmen's (1)workplace (1)workshop (4)worry (3)worth (2)Wow (1)write (7)writing (3)writings (1)written (16)wrong (4)wrote (4)

< X >X, (1)XYZ (1)

< Y >yeah (78)yeah, (1)year (36)years (24)yelling (1)Yep (1)YORK (2)young (8)

< Z >Zeddies (3)zone (1)Zuniga (18)Zuniga's (2)

deposition of: filiberto arroyo francis c. peterson, et al...

Documents