James R. Ketsaa - KTNV-TVmediaassets.ktnv.com/document/2016/05/...1464241205280_38999… · James...

Deposition of:

James R. Ketsaa

Case:

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

Date:

04/02/2014

James R. Ketsaa 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 JAMES R. KETSAA

18 Taken on Wednesday, April 2, 2014

19 By Videotape

20 At 9:05 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. 9134



1 APPEARANCES:

2 For the Plaintiffs:

3 MARC P. COOK, ESQ.

4 Bailus Cook & Kelesis, Ltd. 517 South Ninth Street

5 Las Vegas, Nevada 89101

6 For the Defendants Clark County School District,

7 Filiberto Arroyo, Brian Nebeker, Loren Johnson and Armando Quintanilla:

8 KARA B. HENDRICKS, ESQ.

9 Greenberg Traurig, LLP 3773 Howard Hughes Parkway

10 Suite 400 North Las Vegas, Nevada 89169

11

12 For the Defendants Tina Zuniga, Mark Robbins, Cynthia Ruelas and Roberto Morales:

13 MATTHEW W. PARK, ESQ.

14 Lewis Roca Rothgerber LLP 3993 Howard Hughes Parkway

15 Suite 600 Las Vegas, Nevada 89169

16

17 For the Defendant Kevin Miranda:

18 JAMES P.C. SILVESTRI, ESQ. Pyatt Silvestri

19 701 Bridger Avenue Suite 600

20 Las Vegas, Nevada 89101

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 JAMES R. KETSAA

4 Examination by Mr. Cook 6

5

6

7

8 E X H I B I T S

9 NUMBER DESCRIPTION MARKED

10 1 Document With Map Beginning "Happy 38 Holidays Everyone!" 1 page

11 2 Typewritten Document with Three 55

12 Names and Other Information, CCSD000129

13 3 January 7, 2010 Interoffice 61

14 Memorandum, Wamsley to Quintanilla, CCSD000143

15 4 11-29-09 Concern Report, 77

16 CCSD000125-127

17 5 7-18-11 Concern Report, 82 CCSD 000047-048

18 6 Document Handwritten by Witness, 92

19 CCSD 000084

20 7 Undated Letter To Whom It May 169 Concern, 4 pages

21 8 February 17, 2011 E-mail, Hoffman 170

22 to [email protected], CCSD 000043-045

23 9 Aug 11, 2011 "I-Team: Witness 229

24 Speaks of CCSD Police Employees Drinking with Teens,"

25 PETERSON00122-124



1 NUMBER DESCRIPTION MARKED

2 10 July 30, 2008 Highlights of the 234 Week, CCSD000219

3 11 August 4, 2011 Highlights of the 236

4 Week, 1 page

5 12 February 5, 2010 Highlights of the 239 Week, CCSD000172

6 13 10/31/2011 Memorandum, Rainey to 240

7 Ketsaa, CCSD 000057

8 14 July 11, 2012 Department 244 Administrative Notice AN 002-13,

9 1 page

10 15 October 13, 2011 Letter, Giles To 250 Whom It May Concern, 8 pages

11

12

13

14 QUESTIONS WITNESS INSTRUCTED NOT TO ANSWER

15 PAGE LINE

16 220 24

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 Wednesday,

3 April 2nd, 2014. The time is approximately 9:05, 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 400 South

11 Seventh Street, Suite 400, Box 7, Las Vegas, Nevada

12 89101. The court reporter is William LaBorde from

13 the firm Oasis Reporting Services.

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

15 in United States District Court, District of Nevada.

16 The case is entitled Peterson v. Miranda and all

17 related matters. The deponent is James R. Ketsaa.

18 The videographed deposition is requested by the

19 plaintiff.

20 Counsel and all present will please

21 identify themselves for the record, and then the

22 court reporter will swear in the deponent.

23 MR. COOK: Marc Cook of Bailus Cook &

24 Kelesis on behalf of the plaintiffs.

25 MR. SILVESTRI: Jim Silvestri here on



1 behalf of Kevin -- Kevin Miranda.

2 MR. PARK: Matt Park on behalf of Roberto

3 Morales, Tina Zuniga, Mark Robbins and Cynthia

4 Robbins.

5 MS. HENDRICKS: Kara Hendricks on behalf

6 of the Clark County School District, Phil Arroyo,

7 Loren Johnson, Brian Nebeker and Armando

8 Quintanilla.

9 (Witness sworn.)

10 JAMES R. KETSAA,

11 having been first duly sworn, was

12 examined and testified as follows:

13 EXAMINATION

14 BY MR. COOK:

15 Q. Sir, could you state your name for the

16 record, please.

17 A. James R. Ketsaa, K-e-t-s-a-a.

18 Q. Have you ever had your deposition taken

19 before?

20 A. Yes.

21 Q. Approximately how many times?

22 A. Once.

23 Q. What were the circumstances in that?

24 A. It was a federal lawsuit, something to do

25 with the -- the Police Department, School District



1 against some kind of a union issue, I believe.

2 Q. Were you a percipient witness?

3 A. What does that mean?

4 Q. Were you being deposed as somebody who

5 observed something, saw it, heard it?

6 A. Yes.

7 Q. Okay. About how long ago was that

8 deposition?

9 A. Approximately 1995 maybe, '4, somewhere

10 in that range.

11 Q. Have you ever testified in a court of

12 law?

13 A. Yes.

14 Q. About how many times?

15 A. Half a dozen times.

16 Q. All related to your work as an officer?

17 A. Yes.

18 Q. All related to criminal cases?

19 A. Yes.

20 Q. With regard to the deposition process,

21 I'm going to ask you a series of questions. You can

22 see we have a court reporter taking down what you

23 say. Even though we have the videographer, I need

24 you to respond audibly to make sure we have a clean

25 record of whether your answer is a "yes" or a "no"



1 or whatever your answer may be. Is that fair?

2 A. Yes.

3 Q. Presumably I'm going to ask you some

4 questions that you have an idea where I'm going and

5 in normal conversation we kind of interrupt each

6 other and talk over each other and we can't do that

7 here, so if I cut off one of your answers, please

8 let me know. I'll give you all the time you need to

9 give an answer, and by the same token, I'd ask that

10 you wait till I'm done asking my question before you

11 start to answer it.

12 Do you understand that?

13 A. Yes.

14 Q. Do you have any questions about the

15 deposition process?

16 A. No.

17 Q. Are you under the influence of any

18 medication or suffering any illness or have any

19 condition that would prevent you from giving your

20 best testimony here today?

21 A. I am on high blood pressure medication.

22 Q. Does that affect your memory?

23 A. No.

24 Q. Does that affect your ability to sit here

25 through a deposition?



1 A. No.

2 Q. All right. If you need a break for any

3 reason, let me know. We'll take a break, but I need

4 you to make sure there's no question pending while

5 you take that break. Do you understand that?

6 A. Yes.

7 Q. I inevitably will ask a question

8 inarticulately. If you understand it, that's fine

9 to answer, but if you don't, please let me know.

10 I'll repeat it, rephrase it or even just let you

11 know what I'm trying to get to just to make sure

12 we're on the same page.

13 Do you understand that?

14 A. Yes.

15 Q. Did you meet with anybody in preparation

16 for your deposition today?

17 A. Yes.

18 Q. Who'd you meet with?

19 A. Kara Hendricks and Carlos McDade from the

20 Clark County School District.

21 Q. And I'm sorry. Who?

22 A. Carlos McDade from the Clark County

23 School District.

24 Q. And who's Carlos McDade?

25 A. He's the chief general counsel.



1 Q. And did you meet with them together or

2 separately?

3 A. Separately.

4 Q. How long did you meet with Mr. McDade?

5 A. Approximately an hour.

6 Q. And when was that?

7 A. I don't remember. A few -- a week or ten

8 days ago or more, a couple weeks ago.

9 Q. And when did you meet with Ms. Hendricks?

10 A. Monday and last Wednesday.

11 Q. Total time with Ms. Hendricks?

12 A. Seven to eight hours.

13 Q. Did you review anything in preparation

14 for your deposition through those seven to eight

15 hours with Ms. Hendricks and/or the one hour with

16 Mr. McDade?

17 A. Just with Ms. Hendricks.

18 Q. What did you review?

19 A. Documents I guess related to this case.

20 Q. What documents did you review related to

21 this case?

22 A. Documents that I provided to the School

23 District upon discovery and I guess some other maybe

24 depositions and other paperwork that was related to

25 the case.



1 Q. Okay. I'm trying to get a list of actual

2 documents so I understand what you looked at.

3 You're not giving me anything that would let me

4 identify a single document yet.

5 A. I --

6 Q. So what I'm trying to find out is:

7 Specifically and identifiably, what documents did

8 you review in preparation for your deposition today?

9 A. Well, I didn't actually have them in my

10 hand, so I don't know what they all were. We went

11 over numerous documents -- documents, most I believe

12 depositions and other -- other paperwork involved in

13 the case, you know.

14 Q. Okay. You said documents that you had

15 initially provided upon investigation. I'm assuming

16 you know then what you provided. Correct?

17 A. Yes.

18 Q. What were those documents?

19 A. My notes from the incident that I

20 provided to Metro.

21 Q. What notes from -- from the incident,

22 like handwritten notes?

23 A. Yeah, my handwritten notes.

24 Q. And when did you prepare those notes?

25 A. The day of -- of when I was notified of



1 the incident.

2 Q. And what was on those notes?

3 A. It was the names of the people that I was

4 told were at the party and some other notes on

5 there. It was also a sticky note that had the name

6 of Sergeant Oscar Chavez from Las Vegas Metro

7 traffic fatal detail.

8 Q. And where'd you get that?

9 A. It's my note. I wrote it down.

10 Q. When did you write it?

11 A. The day of the -- when I reported it to

12 Metro.

13 Q. And how did you get the name of Sergeant

14 Oscar Chavez?

15 A. I got it from at the time Captain Pat

16 Neville from Las Vegas Metro.

17 Q. What other documents did you look at that

18 you had identified were documents you provided?

19 A. I think that's the only one that I

20 provided. I'm not -- I'm not sure. I don't -- you

21 know, I don't remember every piece of paper I looked

22 at.

23 Q. Did you -- are you -- do you recall

24 whether you provided more than the documents you've

25 described here today?



1 A. I really don't remember. I don't -- I

2 don't -- I don't know whether there was other

3 documentation in there.

4 Q. I --

5 A. That I provided?

6 Q. Right.

7 A. The only thing that I believe I

8 provided -- and I could be wrong -- is -- is that

9 paperwork that I -- that my notes from that

10 incident.

11 Q. Which is a one-page note and a Post-it?

12 A. As far as I remember.

13 Q. Any other documents you reviewed in

14 preparation for your deposition or had parts of read

15 to you in preparation for your deposition today?

16 A. Any others?

17 Q. Yes.

18 A. I -- I really don't understand the

19 question. I mean, we went over paperwork,

20 documentation, depositions. I -- I didn't hold them

21 in my hand. I didn't take a log of them, so I don't

22 know.

23 Q. And other than the depositions --

24 A. Uh-huh.

25 Q. -- and the one page of notes with the one



1 Post-it on it, are there any documents you recall

2 reviewing in preparation for your deposition --

3 A. Yeah, photographs.

4 Q. -- that you could identify?

5 A. I remember now a photograph.

6 Q. What photograph?

7 A. Of my son.

8 Q. That's the one with the gun?

9 A. Uh-huh.

10 Q. All right. And was that your service --

11 service gun he was using?

12 A. Absolutely not.

13 Q. Do you know where he got that gun?

14 A. Yes. It's my gun. I own it. It's a

15 9-millimeter Beretta Storm.

16 Q. And that's separate from your -- any

17 service gun you have issued by the School

18 Department -- School District; correct?

19 A. Absolutely correct.

20 Q. Anything else you recall reviewing?

21 A. I don't recall anything else. I mean,

22 nothing sticks in my mind right now.

23 Q. Do you recall being read or reviewing any

24 portions of anyone's depositions?

25 A. Yes.



1 Q. Whose?

2 A. Mike Thomas's, Phil -- Phil Arroyo's,

3 Loren Johnson's, Brian Nebeker. Let's see. Erik

4 Aldays, Joe Barris.

5 That's about all I remember at this time.

6 Q. Do you remember anything out of any of

7 those depos in particular that you looked at or

8 reviewed?

9 MS. HENDRICKS: And I'm going to object

10 here. I think we're getting into attorney-client

11 privilege. He can give you a list of documents that

12 he looked at, but beyond that I don't think he needs

13 to tell you what we reviewed and discussed.

14 BY MR. COOK:

15 Q. Any document -- anything from the

16 deposition of Mike Thomas you recall reviewing as

17 you sit here today?

18 MS. HENDRICKS: Same -- same objection.

19 MR. COOK: You can't instruct him not to

20 answer that. I'm asking what he remembers from the

21 deposition, not from what you told him.

22 MS. HENDRICKS: And I want that to be

23 clear. If you remember something specifically from

24 a document or something you reviewed, that's fine,

25 but any discussions that we had are protected by the



1 attorney-client privilege.

2 BY MR. COOK:

3 Q. Do you understand the distinction?

4 A. Yes, but I don't remember everything that

5 was -- that he said or the details in his

6 deposition, no.

7 Q. I didn't ask if you remember everything

8 from his deposition. I asked if you remember

9 anything from his deposition.

10 A. Something about a Christmas party.

11 Q. Anything else from his deposition you

12 remember?

13 A. Something about that -- I don't know; I

14 think it might have been from his -- that I've

15 fixed -- fixed things for the department or things

16 like that before. I think that's -- that's

17 something like that.

18 Q. Anything else about his deposition you

19 remember?

20 A. No.

21 Q. All right. And when you said "something

22 about a Christmas party," what about the Christmas

23 party?

24 A. That he made allegations that I acted

25 inappropriately at a Christmas party.



1 Q. Do you remember what the allegations that

2 he alleged you had --

3 A. That I took --

4 Q. -- participated in were?

5 A. Yeah, that I took a water bottle and

6 squirted it or aimed it towards him and made some

7 derogatory remarks.

8 Q. And do you remember specifically what you

9 recall from his deposition that you fixed things for

10 the department?

11 A. That I drove Jack Lazzarotto, I think,

12 drunk or picked him up when he was drunk and fixed

13 his DUIs.

14 Q. Anything else from his deposition that

15 you recall?

16 A. No.

17 Q. Anything you recall from his deposition

18 that you believe was not accurate?

19 A. I really don't recall a lot of stuff from

20 his deposition. We didn't -- I didn't read the

21 whole deposition.

22 Q. Okay. So nothing as you sit here today?

23 A. Nothing right now, no.

24 Q. What do you recall from Phil Arroyo's

25 deposition?



1 A. I -- I really don't remember. I mean,

2 I -- I don't recall anything from his deposition

3 specifically that sticks in my mind right now.

4 Q. Do you recall me asking him who dropped

5 the ball with regard to the investigation of

6 Angela's death and any cover-up and his answer,

7 "Well, realistically the information that came

8 directly from the dispatchers through the chain of

9 command via the dispatch supervisor via the sergeant

10 and then to -- to Captain Ketsaa, who was the

11 intermediate with the Metropolitan Police Department

12 conducting the investigation"?

13 Do you recall that part of his testimony?

14 MS. HENDRICKS: Objection as to form.

15 A. No.

16 MS. HENDRICKS: I believe, Marc, he's

17 already indicated he didn't read the whole -- the

18 deposition.

19 MR. COOK: I -- I understand his

20 testimony.

21 MS. HENDRICKS: Okay.

22 BY MR. COOK:

23 Q. Do you believe that statement is true

24 with regard to who dropped the ball as to this

25 investigation?



1 A. No.

2 Q. Who do you believe dropped the ball with

3 regard to this investigation?

4 A. Chief Arroyo.

5 Q. And how do you believe he dropped the

6 ball?

7 A. Because he was -- had complete control

8 over the department, Internal Affairs, and he -- and

9 I reported it to him, what I had done, and it was

10 his job to follow that up and -- and -- and deal

11 with it.

12 Q. And you don't believe he did that?

13 A. I don't believe he did that?

14 Q. Right. That's what I asked you.

15 A. Did what?

16 Q. Followed up as he should have in this

17 investigation.

18 A. I don't know whether he did, but I don't

19 think he did.

20 Q. All right. I'll get back to Chief Arroyo

21 in a few minutes here.

22 What do you recall from Loren Johnson's

23 deposition?

24 A. I -- nothing. I don't remember anything

25 from his.



1 Q. And how about Brian Nebeker's?

2 A. I just remember I think going over the

3 parts where -- how -- how he reported it to me on

4 Monday morning.

5 Q. Okay. Anything else from his?

6 A. Not that I can think of right now.

7 Q. And how about Erik Aldays? Do you recall

8 what you reviewed with regard to Sergeant Aldays'

9 deposition?

10 A. Not specifically. I don't know whether

11 maybe he -- I don't know whether he said something

12 about -- I don't know. I really -- I don't.

13 Q. All right. And you said Joe Barris's

14 deposition?

15 A. I believe, yeah.

16 Q. What do you recall from his deposition?

17 A. Asked if he knew me.

18 Q. Okay. Because I didn't see your name

19 come up in his, at least of substance. Do you

20 recall anything from his deposition besides being

21 asked if he knew you?

22 A. That's it.

23 Q. Okay. Aside from those depositions and

24 the notes you provided, including the Post-it, you

25 don't recall any particular document you reviewed in



1 preparation for your deposition; is that correct,

2 sir?

3 A. Well, I reviewed documents from the Legal

4 Department and I signed some forms and I did -- did

5 things like that, but you're talking about with my

6 attorney or you're talking about at what -- at what

7 forum?

8 Q. At -- you said in preparation for this

9 deposition you spent an hour with Carlos McDade and

10 seven to eight hours --

11 A. It was actually --

12 Q. -- with Ms. Hendricks.

13 A. -- a phone conversation with Carlos

14 McDade.

15 Q. Okay. So fair to say in that phone

16 conversation you weren't reviewing any documents?

17 A. No.

18 Q. It was a bad question. Let me ask it

19 again because I had a double negative in it.

20 Did you review any documents during your

21 phone conversation with Mr. McDade?

22 A. No.

23 Q. Okay. With regard to your preparation

24 for this deposition with Ms. Hendricks, have you

25 identified for me with regard to your notes and the



1 Post-it and these depositions all the documents you

2 specifically could identify for me that you reviewed

3 in preparation for the deposition?

4 A. I don't really understand that question.

5 Q. Okay. You said, "I didn't look at all

6 the documents and some were read to me, but I don't

7 really know what some of them were," and then I

8 asked you, "Okay, but what are the ones that you

9 know what they are?" I'm trying to find out do I

10 now have a complete laundry list of the documents

11 you know what they are that you reviewed,

12 understanding you reviewed some other documents that

13 you can't identify for me?

14 A. I -- yes, I guess, yes.

15 Q. Okay. Can you identify in any manner

16 topically what you read or was read to you out of

17 any of the other documents that you can't identify

18 for me?

19 A. Not right now, no.

20 Q. Not right now. I'm going to go through

21 some documents with you during the depo.

22 A. Okay.

23 Q. What I'm going to ask you to do is if I

24 show you a document that you've seen before --

25 A. Uh-huh.



1 Q. -- let me know, yeah, this is one of the

2 ones that you reviewed.

3 A. Okay.

4 Q. All right. Any other photographs? You

5 mentioned the photographs too.

6 A. Not that I can remember right now.

7 Q. What is your current employment position?

8 A. Chief of the Clark County School District

9 Police.

10 Q. And you've held that since when?

11 A. May 1st of 2012.

12 Q. And what was your position before that?

13 A. Acting chief, deputy chief without --

14 that's not a real rank. It was kind of a -- it's

15 just not a real rank. I was technically still a

16 captain, was paid as a captain, but Chief Arroyo

17 made me a deputy chief while he was out of town

18 attending the FBI Academy. Lieutenant, acting

19 lieutenant, sergeant, patrol officer, campus

20 officer.

21 Q. When did you start with the Clark County

22 School District Police Department?

23 A. January 2nd, 1991.

24 Q. What was your job before that?

25 A. I was a firefighter/paramedic/EMT,



1 EMT/paramedic, in a Fire Department in New York.

2 Q. Did you move out to work for the School

3 District Police Department?

4 A. No. I moved out 'cause my mother was

5 dying.

6 Q. And then while you were out here, you had

7 taken that job?

8 A. Yes.

9 Q. All right. And what was the rank you

10 started at in '91?

11 A. Police officer.

12 Q. What was your next level advancement?

13 A. Sergeant.

14 Q. And when was that; do you recall?

15 A. '93 or '94.

16 Q. And then how long before you were

17 lieutenant?

18 A. I was made lieutenant in 1999, and then

19 there was --

20 Q. And then captain?

21 A. -- then there was some sort of an issue

22 with the -- HR issues and things with -- internal

23 issues in the School District, so I then was made

24 acting lieutenant, held that till 2005.

25 Q. What's the --



1 A. And I was promoted to captain in 2005.

2 Q. What's the difference between acting

3 lieutenant and lieutenant?

4 A. Really it just wasn't an actual permanent

5 position. I was named permanent. I was selected,

6 and then there was some issue in HR with the

7 proc- -- not the process, but -- I really wasn't

8 told, but there was an issue with -- with the

9 administrators' union versus -- because a lieutenant

10 is an administrator but you can't be a member of the

11 administrators' union, so they balked at it or

12 something to that effect and it was just kind of put

13 on -- tabled, so I was remaining acting lieutenant

14 until 2005 technically.

15 Q. And then in 2005 you became a captain?

16 A. Uh-huh.

17 Q. Is that a yes, sir?

18 A. Yes.

19 Q. As a captain, what were your job duties

20 on a day-to-day basis?

21 A. Overseeing a div- -- a division, either

22 the administrative division or the operations

23 division.

24 Q. You said "or." Which did you do in 2005?

25 A. I've done -- I've done them both.



1 Q. When you started, which were you doing?

2 A. I am not a hundred percent sure, but I

3 believe the operations division.

4 Q. And then from 2005 to 2012, you had

5 switched back and forth? Is that what you'd said?

6 A. Yeah. There was times we went back and

7 forth. There were different times, and I was --

8 when -- when Arroyo was promoted to chief, then

9 there was another captain brought in.

10 Q. Who was that?

11 A. Captain Bill Goodwin.

12 Q. And did that change -- when Captain Bill

13 Goodwin was brought in, did that change any of your

14 day-to-day operations as captain?

15 A. Yeah. He took one division and I took --

16 or, you know, I was assigned one division and he was

17 assigned the other division.

18 Q. All right. Have you been a police

19 officer anywhere else?

20 A. Yes, in New York.

21 Q. Prior to the Fire Department I take it?

22 A. Actually, during.

23 Q. You were a fireman and a policeman at the

24 same time?

25 A. Yes, I was.



1 Q. Okay. When were you a policeman in New

2 York?

3 A. Oh, boy, let's see. About 1988 to '90,

4 somewhere around there, '87, '88 to '90.

5 Q. Were you full time at both?

6 A. I was a full-time firefighter. I was a

7 part-time police officer and I -- but we worked

8 full-time hours, but by law we were only allowed to

9 be part time.

10 Q. As a police officer or as a fireman, have

11 you had any training with regard to drunk drivers

12 and how to tell when somebody's been drinking?

13 A. Yes.

14 Q. Is that anything beyond on-the-job

15 training, any special seminars in that, or is that

16 just something you pick up over 20 years of police

17 work?

18 A. Well, just normal training at the

19 academy, some in-service training, FST training,

20 just in-service training.

21 Q. Do you believe if you were conversing

22 with a 19-year-old who was twice the legal limit you

23 would be able to tell?


25 You can answer.



1 BY MR. COOK:

2 Q. You can answer.

3 A. If I was conversing with a 19-year-old --

4 say that again. I'm sorry.

5 Q. If you were conversing with a 19-year-old

6 who was twice the legal limit for intoxication, do

7 you believe you would have been able to tell?

8 A. Probably, yes.

9 Q. In your position with the School District

10 from an officer on up, have you had an occasion to

11 deal with a student who was intoxicated?

12 A. Yes.

13 Q. About how often?

14 A. Personally, no more than two or three

15 times.

16 Q. Were those incidents when you saw the

17 student drinking and approached them?

18 A. No. They were all referred to me.

19 Q. And how were they referred to you?

20 A. By the school administration.

21 Q. So were these incidents where a student

22 was on premises intoxicated?

23 A. Yes.

24 Q. And you got a call?

25 A. Yes.



1 Q. What is it you did when you arrived on

2 each of these occasions? Well, strike that.

3 How many occasions did you say?

4 A. No more than, that I can recall, three,

5 maybe something like that. There's only one major

6 one that sticks in my mind.

7 Q. Okay. Well then let's talk about the one

8 that sticks in your mind. When you showed up at the

9 school, what'd you do?

10 A. Took the -- the -- the kid from the

11 staff, took him into custody, was -- I don't

12 remember all the details. This was in like '92.

13 Put him in -- put him in a -- he had committed a

14 crime also, but he was believed to be under the

15 influence. Put him in the car, handcuffed him,

16 searched him, all those procedures.

17 I had a part- -- a partner with me. Back

18 then we transported in the front seat of the car.

19 The other officer sat in the back seat of the car.

20 On the way to juvenile booking, the subject, he was

21 handcuffed behind his back but he was able to get up

22 out of the seat and headbutt me while I was driving

23 the car down the road numerous, numerous times on my

24 head. I almost blacked out. I had to pull over to

25 the side of the road.



1 The officer in the back of the car

2 panicked, didn't do anything, and I had to have a --

3 back then it was Centel -- had to have a phone guy

4 and a Nevada Power guy who was driving on the

5 opposite side of the road saw what was going on,

6 stopped and assisted, got out of the car, put the

7 guy -- you want to -- you know.

8 Q. I -- never mind. Okay.

9 And that whole time the guy in the back

10 seat, your partner, didn't do --

11 A. Did nothing.

12 Q. Okay. But the phone guy did?

13 A. The phone guy and the Nevada Power guy

14 did, yes. They held me, and then finally she, I

15 guess, came to her senses and then helped. Then we

16 took the subject out of the car. I was injured.

17 Put him on the sidewalk on the side of the road, had

18 backup arriving and medical arriving.

19 Since I was injured, I went over to go

20 get the first-aid kit and take care of my head

21 injuries and asked her to watch the prisoner. The

22 prisoner got up and ran away.

23 Q. Still cuffed?

24 A. Yes.

25 Q. The other two that don't stick out



1 obviously as much as that one, any about those that

2 you recall?

3 A. Just that probably the Dean's Office

4 called, went to the Dean's Office. It was a subject

5 that was either they had the evidence or they didn't

6 have evidence, they believed he was under the

7 influence of alcohol, probably smelled like it,

8 acted like it. Took him to the Police Office and

9 either called parents and cited for minor in

10 possession of alcohol or minor in consumption of

11 alcohol, one of those two or both.

12 I did forget to answer one thing. I

13 don't know whether it matters or not.

14 Q. Okay. Well, it seems like you may have

15 forgotten one thing. What is that, sir?

16 A. I just wanted to tell you that I also

17 worked for the UNLV Police Department during -- from

18 1990 to ninety -- I don't know. Oh, I'm trying to

19 think. Let's see. '90 to about '99, somewhere in

20 that range.

21 Q. '92 to '99?

22 A. '90 to '99.

23 Q. I thought you didn't come out here till

24 January '91.

25 A. No, I didn't say I came out here. That's



1 when I started with the Police Department.

2 Q. Okay. So you started at UNLV before you

3 started at --

4 A. Yes.

5 Q. -- CCSD?

6 A. Yes.

7 Q. And you started at UNLV in 1990 until --

8 A. November of 1990. I don't know exactly

9 when I separated because it was a conflict of

10 interest, so I -- somewhere in the '90s. I didn't

11 probably work there seven to nine years.

12 Q. And same thing as with the New York

13 situation, you were part time at both?

14 A. Yeah, part time there.

15 Q. What are your off-duty responsibilities

16 if you see a crime occurring in front of you now at

17 Clark County School District Police Department?

18 A. Off duty?

19 Q. Yes.

20 A. If it's a felony, violent felony,

21 we're -- that somebody has a propensity to be

22 injured or killed, you can take action. If it's a

23 misdemeanor or a gross misdemeanor, you take no

24 action. You -- you act basically as a good witness.

25 Q. Say you're outside of a restaurant going



1 in and you see somebody obviously drunk stumbling to

2 their car to put the keys in the door to drive away.

3 What is your obligation as an off-duty police

4 officer? What do you do?


6 MR. PARK: Join.

7 MS. HENDRICKS: You can go ahead and

8 answer.

9 A. Well, I wouldn't -- maybe nothing because

10 I don't know whether that person is -- how they got

11 there, how they're driving or whether they're

12 driving or they're not driving. It's not really my

13 business.

14 BY MR. COOK:

15 Q. Okay. And is the same true when you were

16 a New York Police Department officer and a UNLV

17 officer?

18 MS. HENDRICKS: Objection.

19 BY MR. COOK:

20 Q. Your answer would be the same?

21 MR. PARK: Join.


23 A. UNLV -- UNLV I would say yes because it's

24 a limited jurisdiction. Well, at the time it was a

25 limited-jurisdiction Police Department. In New York



1 the laws are different. You're a police officer 24

2 hours no matter what department you work for. There

3 aren't limited jurisdictions or -- or -- or

4 departments that have different jurisdictions have

5 jurisdictions statewide.

6 But I would say yes, the same thing. You

7 have no idea whether they're driving, whether

8 they've been driven, whether they're walking,

9 whether they -- you know.

10 BY MR. COOK:

11 Q. Okay. You did understand the

12 hypothetical was somebody stumbling to the car drunk

13 in front of you?

14 A. Oh, stumbling to the car?

15 Q. Yeah, and putting their keys in the car.

16 A. Oh, okay. Then if I saw somebody

17 stumbling to a car drunk, I would get the license

18 plate down and I would call the local jurisdiction,

19 the agency of jurisdiction.

20 Q. Would you make any effort to stop them?

21 A. I --


23 MR. PARK: Join.

24 A. It depends on how severe it was.

25 \\\



1 BY MR. COOK:

2 Q. What do you mean "depends on how severe

3 it was"?

4 A. Just it would just depend. I mean, I'm

5 not going to get involved in off-duty incidents that

6 you could end up getting hurt or killed over -- over

7 somebody, you know, fighting with you about getting

8 into a car.

9 Q. Have you ever attended a party held on

10 behalf of the Clark County School District for

11 holidays or any other occasions?

12 A. Say that again.

13 Q. Have you ever attended a Clark County

14 School District-sponsored party, holiday party,

15 Christmas party, something like that?

16 A. Well, the Clark County School District

17 hasn't sponsored parties. I've been to the

18 union-sponsored, POA-sponsored Christmas party a

19 couple times.

20 Q. The party we were talking about that you

21 recall Mike Thomas in his deposition commenting

22 about, which of those was that, if -- if either?

23 A. It was a POA-sponsored Christmas party.

24 Q. Okay. Have you ever attended a party not

25 sponsored by the School District where you saw



1 multiple people from the School District also

2 attending?


4 MR. PARK: Join.

5 A. I've been to parties before, yeah.

6 BY MR. COOK:

7 Q. How many occasions have you been to a

8 party where you saw multiple people from the School

9 District also attending?

10 A. I went to a high-school graduation party

11 one time and a -- there was a party over at the

12 executive assistant to the chief's house. I don't

13 remember what it was for. Not multiple people, but

14 there were some people from the School District

15 department there.

16 Q. And was that just by happenstance they

17 had to be there or was there some involvement with

18 the School District in either of those occasions?


20 A. It had nothing to do with the School

21 District. It was just private parties.

22 BY MR. COOK:

23 Q. The accident [sic] that led to Kevin

24 Miranda getting alcohol and driving and getting in

25 the accident that killed Angela was at Rebecca



1 Wamsley's house. Are you aware of that?

2 A. I am now, yes.

3 Q. All right. And that party was in

4 November 2009. Are you aware of that?

5 A. Yes.

6 Q. We've had testimony that there was fliers

7 of the party in and around the area of the

8 dispatcher center prior to the party. Are you aware

9 of that?

10 A. No.


12 A. No.

13 BY MR. COOK:

14 Q. Have you ever seen a copy of the flier

15 for this party?

16 A. No.

17 Q. Even as you sit here today, you've never

18 seen a flier for this party?

19 A. Not unless we looked at one, and I don't

20 recall that, so I'd have to say at this point no.

21 Q. You said "not unless we looked at one"

22 and you kind of gestured towards Ms. Hendricks.

23 A. Uh-huh.

24 Q. So unless you saw a flier for the party

25 within the last week or so in preparation for this



1 deposition, you would not have seen one before; is

2 that correct?

3 A. That's correct.

4 (Exhibit 1 was marked for

5 identification.)

6 MR. SILVESTRI: Thank you. Is this a

7 copy that we can keep?

8 MR. COOK: That's a copy.

9 MR. SILVESTRI: Okay. I didn't know if I

10 had to share it with anybody else.

11 MR. COOK: All you. We --

12 MR. SILVESTRI: Okay.

13 MR. COOK: We have dozens of them.

14 MR. SILVESTRI: All right. Thank you.

15 MR. COOK: Sure.

16 BY MR. COOK:

17 Q. Could you take a look at this, please,

18 sir, Exhibit 1.

19 A. Okay.

20 Q. Do you recognize having ever seen this

21 document before?

22 A. No.

23 Q. Would a document such as this be

24 appropriate to be sent out through Clark County

25 School District E-mail amongst the dispatchers or



1 anybody else in the department?

2 MS. HENDRICKS: Objection as to form and

3 foundation. Go ahead.

4 A. Probably not 'cause the InterAct system,

5 which is the InterAct system that we utilize, is for

6 official business only.

7 BY MR. COOK:

8 Q. So a holiday party, ". . . we will be

9 eating dinner around 6 pmsh and then drinks,

10 sandwiches, snacks and of course beer pong

11 afterwards," wouldn't be appropriate to be sent out

12 through that system; is that correct, sir?

13 A. If it was sent out in that system, I

14 would say no.

15 Q. Would this be appropriate to be posted in

16 the dispatch area?

17 A. I don't think it would be inappropriate.

18 Q. You don't think it would be

19 inappropriate?

20 A. No. You're -- you're saying you're

21 having a party and you're inviting people to a

22 party, I guess.

23 Q. Okay. And would it be appropriate or not

24 to have it in the mail area in the dispatch area?

25 A. I don't know what mail area you're



1 referring to.

2 Q. My understanding is you've got the

3 dispatch cubicles and then off to the side you have

4 in -- I don't recall if it's in another room or not,

5 but you've got some trays and somewhere documents

6 are picked up, things like that. Do you recall

7 that?

8 A. I believe I know the area you're speaking

9 about.

10 Q. Okay. Would it be appropriate to have

11 these fliers set up in there?

12 A. I don't see why not.

13 Q. Okay. And is that something that they

14 would have -- whoever was going to put them up would

15 have to get approval from somebody to do?

16 A. It's possible. I don't -- I don't know

17 who -- you know, if anybody did approve it or not,

18 but it is possible.

19 Q. I didn't ask if anybody approved it. I'm

20 just trying to find out if procedurally to post

21 something personal in nature like a party --

22 A. Uh-huh.

23 Q. -- is there an approval process you have

24 to go through to make sure what you're going to post

25 or put up is appropriate or acceptable?



1 MS. HENDRICKS: Are you talking about

2 today or in 2009?

3 MR. COOK: Any, ever I want to know.

4 A. I'm not aware of -- we didn't have a

5 written procedure. I'm not aware of a written

6 procedure that we had back then that says, you know,

7 you -- how you would do this.

8 BY MR. COOK:

9 Q. Are you aware of any now?

10 A. No.

11 Q. Did you ever become aware that there was

12 a flier for the party, the Wamsley party, in

13 existence at all in any manner?

14 A. When?

15 Q. Ever.

16 A. Well, I heard about that there was a

17 flier after the incident, yes.

18 Q. Okay. When after the incident did you

19 hear about a flier?

20 A. When the story broke, I believe that's

21 when I heard about it.

22 Q. When -- when you say "when the story

23 broke" --

24 A. When the news report came out.

25 Q. Are you talking about the news report



1 that had the flier in it?

2 A. I didn't see the news report, but I --

3 I -- it's possible if that's it.

4 Q. My recollection of the first news report

5 that referenced a flier was July 2011, so almost two

6 years after the event. Does that seem time-wise

7 about right as to when you found out that there was

8 a flier?

9 A. Yes.

10 Q. And how -- if you didn't watch that news

11 event, how did you find out that there was a flier?

12 A. Because that's what the story was going

13 around the department.

14 Q. And is it fair to say that you were the

15 School District's contact person with Metro about

16 the investigation with regard to any party?


18 A. Was -- say that again.

19 BY MR. COOK:

20 Q. Were you the contact person for Metro

21 with regard to this party?

22 A. I was the initial contact. I was the

23 initial person reporting.

24 Q. Are you aware of whether there was any --

25 when you say "initial," what I want to find out is:



1 Do you say "initial" because it was one and only one

2 contact or "initial" because somebody came along

3 later to replace you as the contact person?

4 A. Because I only did this one time. I

5 contacted Metro one time. I gave them all the

6 information that I had, and they -- you know, we

7 talked about it and they said that they would

8 contact us and, "If you need anything else

9 additional from us, please contact us. If you're

10 going to charge somebody, arrest somebody or you

11 have anything you need -- you know, you need or

12 you're going to -- you know, there's an issue with

13 one of our employees, let us know."

14 Q. So you had that in that one single

15 contact, but you didn't have any contact with Metro

16 after that?

17 A. No.

18 Q. All right. Okay. Let me get back to the

19 line we were on a moment ago.

20 So you find out for the first time about

21 a year and nine months, eight or nine months after

22 the party that there is a flier. Did you at any

23 point go back on-line since you didn't hear the

24 initial report and watch it on-line or read about it

25 anywhere?



1 A. I don't recall looking up the story at

2 all. It's possible, but I don't -- there was

3 certain times I did, but I don't remember right --

4 right -- right away then, no.

5 Q. When that story broke -- and in fact, if

6 you go on-line now and look at that July --

7 A. Uh-huh.

8 Q. -- 2011 story, there is still a link with

9 a picture of this flier in it.

10 A. Okay.

11 Q. And it's your testimony, as I recall,

12 that you have never seen the flier, so I guess what

13 I'm trying to find out is: You said you did at some

14 point go back and look at something. Do you know if

15 you went back ever and looked at this original

16 newscast and follow-up article on-line on Channel 8

17 that had the copy of the flier when this first

18 broke?


20 A. I don't recall ever seeing the flier in

21 anything I read, no, or saw on-line.

22 BY MR. COOK:

23 Q. Do you recall looking on-line at a story

24 and seeing the -- what at the time was an anonymous

25 letter with accusations against several people of



1 the School District Police Department?

2 A. No, no.

3 Q. You never looked at that letter?

4 A. No.

5 Q. And you never went on-line to read about

6 the allegations about that letter either; is that

7 true?


9 A. There was a -- there -- I'm sure I've

10 looked at the Channel 8 on-line site a few times. I

11 don't make it a habit to do that. I try to avoid

12 that because it's just -- I just didn't want to.

13 BY MR. COOK:

14 Q. Why not?

15 A. 'Cause I don't want to.

16 Q. I heard you. Why didn't you want to?

17 A. I -- you know, like I said, I -- I looked

18 at some -- I'm sure I've looked at Channel 8 before.

19 I usually don't like the comments and things like

20 that, so I try to avoid it.

21 Q. Okay. You understand you can read the

22 article without reading the comments?

23 A. Yeah, right.

24 Q. So why didn't you want to go on and look

25 at the article on-line?



1 MS. HENDRICKS: Objection, asked and

2 answered.

3 A. Because I didn't want to.

4 BY MR. COOK:

5 Q. Okay. You know, I'm trying to find out

6 if there is any reason why you didn't want to.

7 A. Because it was negative about our

8 department and I don't like to read negative things

9 about the department.

10 Q. All right. In Chief Arroyo's deposition,

11 he talked about that you were the person he had in

12 charge of Internal Affairs. Is that what your

13 understanding of your position was with regard to

14 Internal Affairs?

15 A. That's after November -- there's a

16 department special order -- I don't have it here --

17 after November something, right before this date in

18 November. He took Internal Affairs completely under

19 his control.

20 Q. At any point in time from November 2009

21 to April 30th, 2012, did you oversee Internal

22 Affairs?

23 A. I may have at some points over -- been

24 the overseer of Internal Affairs. I also did a lot

25 of stuff while he wasn't around as acting chief.



1 When cases would come in, I would have to make

2 decisions and assign them and -- and assign them to

3 who -- you know, the investigators and things like

4 that, but I was never officially ever reassigned

5 Internal Affairs ever again by Chief Arroyo.

6 Q. And you referred to a memo. Do you have

7 a memo that says he's in charge of Internal Affairs

8 and you're not that came out shortly before November

9 2009?

10 A. Absolutely.

11 Q. Where is that memo?

12 MS. HENDRICKS: It's been produced.

13 A. I don't have it here with me, but it

14 exists.

15 BY MR. COOK:

16 Q. Okay. And it was from who to who?

17 A. It was to the whole department,

18 department special order, and it had a number

19 assigned to it and it was put out by Chief Arroyo

20 taking -- taking Internal Affairs completely under

21 his supervision.

22 Q. And when's the last time you looked at

23 that document?

24 A. I have it myself in my records, my

25 paperwork at home.



1 Q. Okay. When's the last time you took a

2 look at that document?

3 A. A couple weeks ago.

4 Q. In preparation for your deposition?

5 A. No, not in preparation. I mean, I -- I

6 just -- I have it. It's in -- I have it with some

7 paperwork at home.

8 Q. What was the reason for looking at that

9 document two weeks ago if not in preparation for

10 your deposition today?

11 A. Just because I wanted to -- wanted to

12 look at it --

13 Q. Okay.

14 A. -- to reassure myself.

15 Q. To reassure yourself for what purpose?

16 A. Just that -- that I knew it existed and

17 it was correct and it was accurate.

18 Q. But not for any purpose of this

19 deposition?

20 A. It's possible, sure.

21 Q. When did you first find out that there

22 was going to be a party at Rebecca Wamsley's house

23 or was a party at Rebecca Wamsley's house?

24 A. Don't know the exact date. A few days or

25 maybe a week prior to, I was home with my



1 girlfriend. Her friend came over, who was a new

2 dispatcher in the dispatch center, and she said

3 something to the effect, "Hey, there's a party or

4 whatever, a holiday party or whatever. Should --

5 and I was invited. Should I go?"

6 Q. Okay. Who was the dispatcher that came

7 over?

8 A. Marci Caruso.

9 Q. And who was your girlfriend?

10 A. Martha Camman.

11 Q. And did Ms. Camman work for the School

12 District?

13 A. Yes.

14 Q. What did she do at the School District?

15 A. She's a human resources analyst.

16 Q. Is she still there?

17 A. Yes.

18 Q. Was that her position now or in 2009 or

19 both?

20 A. Both.

21 Q. And Marci Caruso was a new dispatcher.

22 Is that what you said?

23 A. Yes.

24 Q. And what was your response as to whether

25 she should go to the party or not?



1 A. Well, I didn't respond first, but Martha

2 did and she said, "Don't go." And the main reasons

3 were that, "You're on probation, and then just don't

4 go."

5 Q. Is there something about being on

6 probation that would have prohibited her from going

7 to a party where if she was off probation it would

8 have been okay?

9 A. No, just the fact that the -- the people

10 that train you in that position may be at that party

11 and that it might be a conflict.

12 Q. So you didn't answer Marci because Martha

13 already answered?

14 A. Yeah, and I -- I probably agreed with

15 her. I don't -- you know.

16 Q. And that's the manner in which you knew

17 about Rebecca Wamsley's party prior to the party?

18 A. Yes.

19 Q. Any other way you found out between that

20 point and the date of the party?

21 A. No.

22 Q. Did you attend the party?

23 A. No.

24 Q. Did Ms. Camman attend the party?

25 A. No.



1 Q. Do you know if Ms. Caruso attended the

2 party?

3 A. Don't know.

4 Q. Okay. So the only time you heard about

5 the Wamsley party prior to the Wamsley party was on

6 that occasion at your house?

7 A. Yes.

8 Q. Okay. When's the next time you heard

9 about the party?

10 A. The Monday morning after the accident.

11 Q. And what did you hear and from who?

12 A. Sergeant Brian Nebeker came into my

13 office first thing in the morning and told me that

14 there had been an accident after the party at

15 Wamsley's house and that it was a fatal accident.

16 He gave me a few names, some people, you know, that

17 were possibly there at the party. I wrote them down

18 on my notes.

19 I asked him to go back to the dispatch

20 center and find out who -- you know, if there was

21 anybody -- if he could get any further information.

22 While he was out of my office, I called

23 Captain Pat Neville and asked him who I should call

24 from Metro regarding the -- you know, who would be

25 investigating that from the fatal traffic unit. He



1 gave me the name of Sergeant Oscar Chavez and his

2 phone number.

3 Brian Nebeker came back into my office

4 sometime shortly thereafter and I believe he had

5 that typed-up piece of paper with, I think, three

6 names on it in addition to the notes that I had

7 taken. I called Sergeant Chavez and I told him

8 that -- asked him if he was investigating a fatal

9 traffic accident, and I gave him that information,

10 the -- the additional information.

11 Q. When Nebeker came into your office, were

12 you by yourself?

13 A. Yes.

14 Q. And what information did he give you

15 besides -- at that first time he came in there

16 besides that there was an accident after the party

17 at Wamsley's and that the accident was fatal?

18 A. What additional information?

19 Q. If any. During that first stop in into

20 your office.

21 A. I -- I believe that was it. He just told

22 me that there was an accident and somebody left that

23 party and caused a fatal accident, and -- and then

24 that was it. As far as I know, that's it.

25 Q. Okay. And then he leaves your office,



1 and now it's just you in your office; --

2 A. Uh-huh.

3 Q. -- is that right?

4 A. Yes.

5 Q. And you call Captain Pat Neville, who's

6 with Metro; is that correct?


8 Q. Why did you call Captain Pat Neville?

9 A. 'Cause I had a good working relationship

10 with him. We both were on the School Violence

11 Initiative -- School Violence Initiative, which is a

12 cooperative effort between the two departments. I

13 have his -- you know, had his phone numbers and all

14 that stuff. I called him as a good contact and

15 asked him who I should call.

16 Q. So the reason you called him was because

17 you knew him and you believed he could direct you to

18 the right person to call?

19 A. Yes.

20 Q. All right. And then he gives you the

21 name of Oscar Chavez; correct?

22 A. Yes.

23 Q. Okay. And then what do you do next

24 before Nebeker's back into your office?

25 A. Nothing. I waited.



1 Q. All right. And now Nebeker comes back

2 into your office and he provides you a list of

3 names. Is that what you said?

4 A. Oh, I -- I had already written down the

5 names that he had given me verbally, but I believe

6 he came back in then or shortly thereafter with a

7 piece of paper with three names on it.

8 Q. Typed?

9 A. Yes.

10 Q. And did you send him to go get

11 information on the three names he gave you, to type

12 something up and give you some additional

13 information on them before you contacted Metro?

14 A. I asked him to get -- to go back to

15 dispatch and confirm the information, see if he

16 could get any other information, and that's what he

17 came back with.

18 Q. I'm going to show you what has been

19 marked as -- I mean, Bates stamped as CCSD000129. I

20 just want to find out before we mark it if this is

21 the piece of paper you recall Nebeker coming back in

22 with.

23 A. Yes.

24 Q. Okay. Then let's get this marked.

25 MS. HENDRICKS: And then, Marc, can we



1 redact that if it's the -- that's the version that

2 we replaced that has the dates -- the birthdays and

3 social security numbers on it.

4 MR. COOK: Yeah. I'm not going to -- all

5 right. I'll hand out copies, but toss them. This

6 is -- this is the first version that still has

7 the --

8 MR. PARK: Yeah, I just want to see what

9 it is.

10 MR. COOK: -- confidential info.

11 MR. PARK: I can toss it. Thank you.


13 identification.)

14 MR. COOK: All right. You're all

15 personally responsible for redacting your own

16 copies.

17 MR. SILVESTRI: Okay.

18 MR. COOK: Thank you.

19 MS. HENDRICKS: Thanks.

20 BY MR. COOK:

21 Q. The additional information besides just

22 the names on this sheet with regard to Rebecca

23 Wamsley, Adriana Gamboa and Tina Zuniga, do you know

24 why he came back with this sheet with address, phone

25 number, date of birth and social security number?



1 A. No.

2 Q. All right. Do you know why it is these

3 three dispatchers whose names and information he

4 came back with?

5 A. I don't know for sure, but I believe it

6 was because those were the three that were either on

7 duty that day -- and I could be wrong -- and that

8 they were the ones that were confirmed by him to

9 being at the party.

10 Q. Do you know how he confirmed them being

11 at the party?

12 A. No.

13 Q. Do you know if he was at the party?

14 A. No.

15 Q. No, you don't know?

16 A. I don't know whether he was at the party,

17 no.

18 Q. Are these the same three names that you

19 wrote down as him telling you in his first trip that

20 were at the party?

21 A. I'd have to see the -- the original piece

22 of paper that I wrote the names down. I think

23 Wamsley was probably on there and Gamboa. I'm not

24 sure about Zuniga.

25 Q. Now, when Nebeker comes back into your



1 office the second time, were you still by yourself

2 in the office?

3 A. As far as I remember, yes.

4 Q. What's the conversation on this second

5 trip into your office?

6 A. I don't remember specifically any -- any

7 additional conversation other than, "Here's some

8 additional" -- these -- whatever he told me these

9 names were, why he provided these to me, and I got

10 on the phone and I called Chavez while he was in the

11 room.

12 Q. While Nebeker was still in the room, you

13 called Chavez?

14 A. As far as I remember, yes.

15 Q. And what did you tell Chavez?

16 A. I told him that -- identified myself,

17 told him that there was a party -- I mean, he was --

18 asked him if he was investigating an accident that

19 occurred Saturday night, Sunday morning, and I

20 advised him that I wanted to be completely open and

21 honest with him and tell him that the party where

22 that person allegedly left and caused the accident

23 was hosted by one of our dispatcher's houses, home,

24 and that there were possible -- well, there were

25 dispatchers there, other employees possibly and some



1 officers probably there.

2 I just wanted to be completely up front

3 with them and tell them, give them all the

4 information as the primary jurisdiction

5 investigating the case, that we didn't hold anything

6 back from them.

7 Q. Where did you get the information that

8 the individual in the -- involved in the accident

9 had probably come from this party?

10 A. 'Cause Nebeker told me that.

11 Q. And where did you get the information

12 that there were probably officers at the party?

13 A. 'Cause Nebeker told me that.

14 Q. Are these things he told you on the first

15 visit, the second visit or both?

16 A. Definitely the first and maybe both.

17 Q. Any other conversation with Nebeker on

18 this day about the party?

19 A. It's possible. I mean, I -- I don't

20 recall any other specific -- you know, any lengthy

21 meetings or discussions about it.

22 Q. Certainly no new information you acquired

23 during that same day from Nebeker?

24 A. No.

25 Q. Then after you hung up with Oscar Chavez,



1 what do you do?

2 A. Well, I'm not -- I don't recall whether

3 Arroyo was there that day or that time of the day,

4 whether he came in later or whether he came in the

5 next day. I believe he came in later that day, and

6 I went down to his -- where he was. He wasn't in

7 his office. He was in a conference room sitting at

8 the end of the conference room with his computer set

9 up when I saw him, and I walked in and I told him

10 what I had done. I told him what happened, and --

11 and he was already aware of it, I believe, and I

12 told him that I had notified Metro and given them

13 the names of the -- the information that I had that

14 I had gotten from Nebeker.

15 Q. And when you said you told him what

16 happened, that's -- was that anything beyond there

17 being a party at Wamsley's house, somebody leaving

18 and being involved in a fatal accident and that

19 there were dispatchers and possibly police officers

20 at the party?

21 A. And that I reported it to Metro.

22 Q. That was it?

23 A. As far as I recall.

24 Q. Did he instruct you to do anything at

25 that point?



1 A. No.

2 Q. Why did you call Metro? In other words,

3 was there a specific policy you were following to

4 contact Metro or what was the impetus for that phone

5 call?

6 A. Because I thought it would be in the best

7 interests of our department to be completely open

8 and up front with them right at the beginning and so

9 they knew, that they could do a thorough

10 investigation of the accident and possibly the --

11 the reason why the accident occurred.

12 Q. So you didn't believe that there was any

13 particular policy compelling you to do it. You just

14 thought it was the right thing to do, and you did

15 it?

16 A. We work cooperative -- cooperatively with

17 each other. We try to on cases, and I just felt it

18 was the best thing to do, to be completely open and

19 up front with them so that they couldn't come back

20 to us at a later date and say, "Why didn't you tell

21 us this?"

22 Q. Is that generally, if not a written

23 policy, the practice between CCSD and Metro, is to

24 be open and up front and provide them information

25 that you have that you believe may be relevant to a



1 case?

2 A. Sure, yes. We have numerous systems in

3 place to share information.

4 Q. All right. When is the next time that

5 you heard anything about the party or the accident

6 or anything along those lines?

7 A. I don't know specifically, but I remember

8 at some point I think Wamsley -- there was -- she

9 provided the department with a -- I want to say a

10 memo stating that she hosted a party and there was

11 maybe a payment from her insurance company or

12 something like that.

13 Q. What did you say about the insurance

14 company, and --

15 A. Something -- I believe she put in there

16 that there was -- that her insurance -- at some

17 point I remember hearing or seeing that her

18 insurance company paid -- paid out a claim, and I

19 think she -- at some point she self-reported that.


21 identification.)

22 BY MR. COOK:

23 Q. Is this the memo you're talking about?

24 A. Yes.

25 Q. Are your initials anywhere on this?



1 A. I would say they're down there on the

2 third one down from the top: Quintanilla, Nebeker,

3 me and Arroyo.

4 Q. And was that on or about the time that

5 you received this memo?

6 A. It says that I received it, I believe, on

7 2/16 of '10 from what it looks like here.

8 Q. Right. What I'm asking is: That

9 signature on 2/16/10, is that on or about the time

10 you received the memo?

11 A. Yeah. I don't hold memos. I sign them

12 immediately if I get them.

13 Q. After you signed this document, did you

14 do anything with it?

15 A. Forwarded it to Arroyo. It goes --

16 Q. Anything after that or aside from that I

17 should say?

18 A. Not that I know of or can recall, no.

19 Q. This document --

20 A. When --

21 Q. I'm sorry. Go ahead.

22 A. When it's finalized, when the last person

23 signs it off, it -- it goes to Laura Tappen. On

24 this date she logged it into the -- to the system

25 electronically so it's maintained in the memo



1 database.

2 Q. On February 23rd, 2010, LMT is Laura

3 Tappen; is that right?

4 A. Laura, yes.

5 Q. And that's supposed to happen after the

6 last person signs it; is that right? Is that what

7 you said?

8 A. Yeah. When you're done, when this is --

9 when the -- when action is complete, it goes -- it

10 goes to that -- that person who is in charge of that

11 at the time and they log it electronically into the

12 system and then it's -- it's there electronically.

13 Q. Do you see where Arroyo signed this

14 December 17th, 2010?

15 A. Okay.

16 Q. Do you see that at the bottom, sir?

17 A. Uh-huh. It says 12/17.

18 Q. Right. He didn't recall when he signed

19 it, but LMT says February 23rd, 2010. Any idea if

20 maybe that should have been 12/23/10?

21 MR. PARK: Objection, foundation.

22 BY MR. COOK:

23 Q. Or you understand what I'm talking about,

24 the discrepancy in dates? I've got Arroyo's

25 signature dated ten months --



1 A. Uh-huh.

2 Q. -- after LMT's signature and you're

3 saying procedurally that would have happened the

4 other way around, so do you have any idea whether

5 this is a somebody-wrote-down-the-wrong-date

6 situation or policy wasn't followed, or you just

7 don't have any idea?


9 MR. PARK: Join.

10 A. Well, I would say that everything follows

11 in order and the last person signing it wouldn't

12 date it ahead of somebody who did it first, so --

13 and then she did it on the 23rd. I would have to

14 say that he put a 12 there instead of a 2 or the

15 12 -- the 1 could have been added after the fact. I

16 don't know, but I believe that Laura Tappen would

17 have -- she does them immediately, or she's deceased

18 now, but she would have done -- she did them as soon

19 as she receives them.

20 BY MR. COOK:

21 Q. This -- this begins, "This communication

22 is written in accordance with GO 303 (3-5), Code of

23 Conduct." Are you aware of what that was or what

24 that is?

25 A. I'm aware of general order 303.



1 Q. Do you know what Code of Conduct prompted

2 her to be required to write this?

3 A. No. I'd have to see it to be exact, but

4 I -- I would say it has to do that you self-report

5 when you're under investigation by an outside law

6 enforcement agency.

7 Q. And what does "under investigation by an

8 outside law enforcement agency" mean?

9 A. If you're contacted by law enforcement

10 and questioned about something.

11 Q. Okay. Were you aware that by the date of

12 this memo other dispatchers had been contacted and

13 conducted interviews with Metro in relation to this

14 party?

15 A. No.

16 Q. Is that something that those dispatchers

17 should have reported?

18 A. They probably should have, yes.

19 Q. Now, you told me when you contacted Oscar

20 Chavez you told him that -- I think you said it was

21 alleged that the person who -- a person who was at

22 the party was involved in a fatal accident. Do you

23 recall that?

24 A. I believe I told him that -- that -- that

25 from what I was told that someone left that party



1 and caused the fatal accident.

2 Q. This memo seems to at least confirm that

3 a little more where it says, "One of the guests that

4 I invited, invited her daughter and 18 year old

5 Kevin Miranda to . . . dinner" -- sorry, "to the

6 dinner. At some point later in the evening or early

7 the next morning, the uninvited guest, Kevin

8 Miranda, caused a fatal accident and was arrested

9 for DUI."

10 Did you forward this information to

11 Chavez or anyone at Metro?

12 A. I didn't, no.

13 Q. Now, this doesn't say anything about an

14 insurance payment. Do you know where you got that

15 information?

16 A. I just heard it somewhere. I remember

17 hearing it somewhere. I don't know whether it was

18 an official document or whether it was -- or in a

19 document or whether it was just verbal. I remember

20 something about an insurance payment.

21 Q. You say you're not sure where you heard

22 it. Is the School District, particularly a dispatch

23 area, something where there's a lot of conversation

24 that goes around about different things, sort of a

25 rumor mill, if you will?




2 A. Well, there's -- there's always rumors

3 everywhere. I would say that they -- they spread

4 rumors, yes.

5 BY MR. COOK:

6 Q. All right. I'm going to represent to you

7 that the insurance did not notify Rebecca Wamsley of

8 any claim until August, September 2010, so a good

9 eight months after this memo.

10 A. Okay.

11 Q. And I know you said you had heard some

12 rumors about that. Is that about the time frame

13 that you heard the rumors?

14 A. I have no clue.

15 Q. Was this something that was talked about

16 continually through October 2010?

17 A. No.


19 A. No.

20 BY MR. COOK:

21 Q. It was not?

22 A. Not with me.

23 Q. I understand. I can't -- I know you

24 can't speak for what was happening in the dispatch

25 center necessarily when you weren't there. I was



1 talking about if there were conversations you had

2 heard about with regard to Rebecca Wamsley and any

3 insurance payment or anything about the party from

4 January to October.


6 A. Very little that I heard. I -- no.

7 BY MR. COOK:

8 Q. Okay. You said "very little." What was

9 it you had heard in that time frame, that ten

10 months?

11 A. I -- I don't even remember. Just -- I

12 really don't -- I don't recall anything specific.

13 MS. HENDRICKS: Are we at about a good

14 place for a break?

15 MR. COOK: Sure.

16 THE VIDEOGRAPHER: Please stand by. This

17 is the end of disk number one in today's

18 videographed deposition of James R. Ketsaa. The

19 approximate time, as indicated on the video screen,

20 10:18 and we're now off the record.

21 (Recess taken.)

22 THE VIDEOGRAPHER: We're back on the

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

24 today's videographed deposition of James R. Ketsaa.

25 The approximate time, as indicated on the video



1 screen, 10:26.

2 BY MR. COOK:

3 Q. Sir, in continuing with our deposition,

4 during the break -- or I should say after the break

5 do you have any changes or additions or

6 clarifications to any of your testimony so far this

7 morning?

8 A. No.

9 Q. Okay. Prior to the break, a little

10 earlier on in the morning I asked you if you had

11 ever attended any parties where there were some

12 other School District employees, and you said two,

13 maybe three as I recall. Is that right?

14 A. That's what I told you. I don't -- I

15 don't know how many parties I've been to.

16 Q. You said one of them, I think you said,

17 might have been a graduation party; is that right?


19 Q. Have you -- when you attended these two

20 to three or more when you observed Clark County

21 School District employees that you knew were Clark

22 County School District employees there, did you ever

23 observe any minors drinking at those parties?

24 A. No.




1 A. No.

2 BY MR. COOK:

3 Q. If you had observed a minor drinking in

4 your presence at one of these parties, what would

5 you have done?


7 MR. PARK: Join.

8 A. Would have left and I would have told

9 the -- the person hosting the party that I didn't --

10 maybe not agree with if they were -- if they were

11 drinking alcohol, maybe not that that's -- that's

12 not right, and -- and I would leave.

13 BY MR. COOK:

14 Q. Anything else?

15 A. I mean, hypothetically?

16 Q. Well, it didn't happen.

17 A. No.

18 Q. Okay. So then hypothetically.

19 A. If there was -- if there was a need or I

20 thought, I might have notified the agency of

21 jurisdiction that there was a party where there was

22 minors drinking and left.

23 Q. How about if you saw a minor playing beer

24 pong at one of those parties, what would you do?




1 MR. PARK: Join.

2 A. Same thing.

3 BY MR. COOK:

4 Q. As you sit here today, who do you believe

5 from the Clark County School District was at the

6 party at Wamsley's house?


8 foundation.

9 BY MR. COOK:


11 A. Who do I believe to be there?

12 Q. Yes.

13 A. Well, the -- Wamsley, Zuniga, Morales,

14 Robbins and his wife, Adriana Gamboa. I'm trying to

15 think of some of the other people. I don't -- maybe

16 Ron Sufana, Armando -- Armando Quintanilla and some

17 other dispatchers. I don't know all their names.

18 Q. Any other officers?

19 A. Robbins.

20 Q. Yeah, you said Robbins --

21 A. Morales.

22 Q. -- and Morales. Owens?

23 A. I have no idea, never heard that.

24 Q. Nebeker?

25 A. I -- he -- I was -- he told me he never



1 went to the party.

2 Q. The names you initially turned over to

3 Chavez were Gamboa, Zuniga and Wamsley. As you

4 heard of the other individuals --

5 A. Those were not the only names.

6 Q. Okay. What other -- who else did you --

7 A. The ones that are on my handwritten note.

8 Q. And you don't know who they are --

9 A. I'd have --

10 Q. -- as you sit here today?

11 A. Yeah, whatever I wrote on that note. I

12 believe --

13 Q. I don't think I have that note in that

14 stack, in this stack, and --

15 A. Okay.

16 Q. -- I don't recall the Bates number. I

17 mean, if you want to -- if you've got it, I'm happy

18 to refresh your recollection with it, but if you

19 don't, you know, what names do you recall turning

20 over to Metro then? I thought it was just the

21 three.

22 A. No, absolutely not.

23 Q. Okay. Who -- who were the others?

24 A. The ones that were on the list in my

25 handwritten notes.



1 Q. Okay. Did they include Morales, Robbins

2 and his wife and Sufana and Quintanilla?

3 A. I don't know whether it had -- I know

4 Robbins, I think Morales and I think Quintanilla,

5 Adriana Gamboa, Zuniga. Maybe not Zuniga. She was

6 on the other one. I'm not sure.

7 Q. Let me ask it this way: The list you

8 gave me, this is a list of people that as you sit

9 here today you -- you believe were at the party;

10 correct?

11 A. Yeah. That's who I believe to be there.

12 Q. Okay. Did you find out all of these

13 names in that first day with Nebeker or do you

14 believe you found out about some people some point

15 later on?

16 A. I -- like I said, I wrote down the names

17 that Nebeker initially gave me. Then he came back

18 with the typewritten one that's here with three

19 names on it. Those were all the names that were

20 given to Metro. If there was somebody else that was

21 omitted on there that I -- that -- I don't know.

22 Q. Do you know why his list only had three

23 if there were more people that you knew about at

24 that time that were at the party?

25 A. I don't know why he only gave me three



1 names.

2 Q. Okay.

3 A. But he gave me names verbally prior to

4 that.

5 Q. Is it your testimony that all of the

6 names of people you knew about on that Monday after

7 the party you told Chavez about?

8 A. Yes.

9 Q. Do you recall if after that day you later

10 found out about somebody else being at the party

11 that you weren't previously aware of?

12 A. In what time frame?

13 Q. Any time frame. From December 1st, 2009

14 to today, did you find out about anybody being at

15 that party that you weren't aware of on December

16 1st -- I'm sorry, November 30th?

17 MS. HENDRICKS: Marc -- Marc, I think

18 let's see if we can get the document to refresh his

19 memory because he says he doesn't remember who was

20 on that list, and so I don't want him guessing.

21 I mean, if you -- if you remember more,

22 that's fine, but I'm trying to get that document for

23 you so you can -- we can refresh his memory. I just

24 don't want him guessing beyond that.

25 MR. COOK: That's fine, but this is a



1 different question.

2 BY MR. COOK:

3 Q. I'm trying to find out if after November

4 30th, which was the Monday after the party, 2009,

5 you heard about other people being at the party that

6 you didn't know.

7 A. Only when -- when that news story broke

8 because I heard that Nebeker and Morales were at --

9 supposedly at the party.

10 Q. Okay. So from November 30th, 2009, which

11 is that Monday after the party, until that news

12 story broke sometime in July 2011, there were no new

13 names you heard were at the party that you --

14 A. No, nobody came --

15 Q. Let me finish the question.

16 A. Sorry.

17 Q. That you previously were unaware of. Is

18 that accurate?

19 A. As far as I know, nobody came -- nobody

20 came to me at any point after I made my initial

21 report and gave me any additional names.

22 Q. Okay. At any point from November 30th,

23 2009 to the date of that news story in July 2011,

24 did you learn of any information about the party

25 that you didn't already know as of November 30th,



1 2009?

2 A. About the party?

3 Q. Right.

4 A. No.

5 Q. Okay. From November 30th, 2009, the

6 knowledge you knew then, to the date of the news

7 story in July 2011, did you learn any other

8 information about anything involving Angela's death

9 or anybody's reaction thereto in the department?


11 Q. Let me -- let me break it down in two

12 questions.

13 The question you just answered was if you

14 learned any new information about the party between

15 November 30th, 2009 and that news story in July

16 2011.

17 A. Okay.

18 Q. Now what I'm trying to find out is if

19 there's any information of any manner that relates

20 to Angela's death or Kevin Miranda's arrest that you

21 learned in that same time frame.

22 A. Not that I can recall.

23 Q. Okay. Now, we did talk earlier that you

24 had heard something about an insurance payment.

25 That you learned later?



1 A. At some point later. I don't know when.

2 Q. Okay. But there's no other information

3 as you sit here today you can recall hearing about

4 the party or any allegations of a cover-up or any

5 behavior related to the death of Angela from

6 November 30th till that news story in July 2010

7 [sic]; is --

8 MS. HENDRICKS: Objection.

9 BY MR. COOK:

10 Q. -- that correct?


12 A. No.


14 identification.)

15 MR. COOK: Do you need another one of

16 that?

17 MR. PARK: If you got one.

18 MR. COOK: Yeah, I do.

19 MR. PARK: Thanks.

20 BY MR. COOK:

21 Q. Sir, Exhibit 4 is a document entitled

22 "CONCERN REPORT" with Armando Quintanilla's name in

23 the upper left, and it is CCSD000125, 126,

24 et cetera. Have you seen this document before?

25 A. With my legal counsel.



1 Q. Okay. So this is one of the documents

2 that you reviewed that you --

3 A. Uh-huh.

4 Q. -- didn't recall?

5 A. Right.

6 Q. And that's the first time you had seen

7 this document?

8 A. Yes.

9 Q. Bottom left of this document, "Others

10 that were there from our department (that I knew)"

11 has the names you mentioned and then it also has

12 Penny Higgins and Carrie Williams. Do you recall

13 when you first heard that they were at the party?

14 A. No, I don't recall when I first heard

15 that.

16 Q. Okay. When, if ever, did you find out

17 that Kevin Miranda was Tina Zuniga's daughter's

18 boyfriend?

19 A. I -- I don't really know exactly when.

20 It may have been when Nebeker told me initially

21 about the accident at the -- you know, that it

22 was --

23 Q. So you don't recall hearing sometime way

24 later down the road, "Oh, my gosh, I didn't know

25 Kevin Miranda was the boyfriend of Tina Zuniga's



1 daughter," or anything like that; correct?

2 A. No.

3 Q. Okay. Is this information that you, if

4 it was in your possession, would have turned over to

5 Metro?

6 A. Yes.

7 Q. Is this Concern Report something that

8 Armando Quintanilla should have done in conjunction

9 with getting the call about the party and who was

10 there?

11 A. Should he have done a Concern Report?

12 Q. Right. Strike that. Let me ask you a

13 different question.

14 When Armando Quintanilla gets a phone

15 call from Adriana Gamboa stating that Tina Zuniga's

16 daughter and boyfriend were in a car accident and

17 that a girl was killed --

18 A. Uh-huh.

19 Q. -- and that they were at a party at

20 Rebecca Wamsley's house and he then feels compelled

21 to tell Nebeker that, who then feels compelled to

22 tell you that, and you then feel compelled to tell

23 Metro, is that something, that information, that

24 Quintanilla should document somehow for a file

25 somewhere at CCSD?




2 A. Yes.

3 BY MR. COOK:

4 Q. Is this the appropriate form to have

5 documented it in?

6 A. It could be.

7 Q. It would be acceptable at least?

8 A. It would be acceptable.

9 Q. Okay. When a Concern Report like this

10 gets filled out, what's supposed to happen with it?

11 Does it get turned in to somebody?

12 A. Yeah. If it's -- if it's an actual

13 concern, it would -- it would list -- all the

14 information that's missing here should be filled in,

15 who the concern was filed against and what the

16 violations or general order violations, law

17 violations, procedural violations would be listed on

18 there or at least a general one.

19 It would be forwarded to -- since, well,

20 this lists one officer, so civilians don't --

21 they -- you can do a concern form on a civilian. A

22 concern form is mainly for an officer. Then it's

23 given a number and it's logged in, and then the

24 chief assigns who he wants to investigate it down

25 here at the bottom.



1 The other ones, you could do -- you could

2 do a concern form for civilian employees also, but

3 it would be investigated a different -- different

4 route.

5 Q. This bottom of this first page here says,

6 "CASE WILL BE ASSIGNED BY CHIEF OF SCHOOL POLICE OR

7 HIS DESIGNEE."

8 A. Uh-huh.

9 Q. And there is no writing in that. If this

10 document was turned in and it was turned in to you,

11 what would you have done with it?

12 A. If I had gotten this, I would have given

13 it to the chief for his disposition.

14 Q. And is there anything you would fill out

15 that you were moving it on forward? For instance,

16 in Exhibit 3 there was a signature line and

17 acknowledgment and you said you then sent it up to

18 the next guy, which was Arroyo. Is there a similar

19 process for this document?

20 A. No. It goes to the -- the chief or

21 dis- -- whoever the chief designates to assign it to

22 either the supervisor or the Internal Affairs to --

23 to investigate. I could have written notes or

24 something in here or typed it. Well, I wouldn't

25 have typed it because it was already. I would have



1 written in notes. I could have written in notes and

2 then initialed it and dated it, what I did.

3 Q. But you don't recall ever seeing this

4 document before; correct?


6 Q. Okay.

7 MS. HENDRICKS: Marc, here's the Bates

8 number for the documents he was referencing are his

9 notes.

10 MR. COOK: Okay. I'll be able to get

11 those in a break. Thank you.

12 MS. HENDRICKS: Uh-huh.

13 MR. COOK: Let me have her do it now.


15 identification.)

16 BY MR. COOK:

17 Q. Sir, Exhibit 5 is a Concern Report

18 submitted to the Clark County School District Police

19 Department dated July 18th, 2011. Do you see that?

20 A. Yes.

21 Q. This was, I think, a week or two before

22 the story was broadcast on Channel 8. Do you recall

23 seeing this Concern Report kind of giving a heads-up

24 that the news story was going to come out before it

25 did?



1 A. Well, I don't know about that time line.

2 I obviously saw this and -- and assigned it, yes.

3 Q. Say that again. I'm sorry.

4 A. I don't know the time line of exactly

5 when the -- when the story -- what I'm saying is I

6 got this and I -- and I -- yes, I dealt with this.

7 I don't know whether this was prior to or after or

8 what.

9 Q. Okay. So the Detective Purcell date of

10 7/19 and then yours is not dated; is that correct?

11 A. No. That's me down there on the bottom.

12 I assigned it to Detective Purcell on 7/19 of '11,

13 my initials and my P number.

14 Q. Oh, I got it. All right. I thought that

15 was Detective Purcell acknowledging he got it.

16 A. No. Detective Purcell filled it out on

17 7/18 at 1455 and then forwarded it. For whatever

18 reason, the chief was not here that -- he was out of

19 town, he was whatever, I was acting chief, I

20 believe, during this period of time, and since this

21 was a concern filed against Rebecca Wamsley and it

22 mentions that $300,000 and it alleges some of these

23 other things in here, I assigned it to him on the

24 19th and discussed this after that with District

25 Legal and was directed to forward to District Legal



1 LVMPD was reopening the investigation due to

2 concerns/allegations that police officers were

3 allegedly involved. No misconduct noted at this

4 time. Will review when LVMPD completes its

5 investigation.

6 Q. Did you have any conversation with

7 anybody at LVMPD on or around August 9th, 2011 to

8 see what they were investigating or what they needed

9 or anything along those lines?

10 A. No. They came to us.

11 Q. Okay. Who did they come to?

12 A. Well, I don't know the circumstances how

13 it all happened, but they came to our -- came to our

14 station and conducted interviews.

15 Q. Did you have any conversations similar to

16 what you had with Detective Chavez in November of

17 2009 and say, "Hey, I want to be open. I want to

18 give you guys what we got. What do you need?"

19 A. No. It wasn't that -- it was -- it was

20 they were -- they were investigating. I don't know

21 the circumstances how, but they were -- they were --

22 from what I believe, it says that they were re- --

23 or they were reopening the investigation.

24 Q. So let me back up. Do you recall who

25 specifically at Metro came to who specifically at



1 the School District Police Department?

2 A. I just know who contacted me.

3 Q. Okay. Who contacted you?

4 A. I can't remember his name now. A

5 detective from the -- from their intel unit. I

6 can't remember his name. If I heard it, I -- if you

7 told me, I could tell you whether that was it or

8 not.

9 Q. Is there a reason you were contacted that

10 you're aware of as opposed to Arroyo being

11 contacted?

12 A. We were all contacted from what I

13 understand. I was there. Arroyo was again out of

14 town. He wasn't around. I believe he -- I don't

15 know where he was, but he wasn't there.

16 Q. So you were acting chief or deputy chief

17 or --

18 A. Yeah, something like that, yeah.

19 Q. Were you interviewed by Metro with regard

20 to any of the allegations in this complaint?

21 A. The allegations or about the incident or

22 about what we did as a department?

23 Q. Anything about the party or any

24 allegations of a cover-up.

25 A. Yes.



1 Q. Was it Mark Gregory?

2 A. Mark Gregory.

3 Q. Okay. Is he the person who interviewed

4 you?

5 A. Him and another gentleman.

6 Q. Okay. Both there, one of them writing on

7 a pad, is that kind of the way it happened?

8 A. Yeah. Mark was asking questions. The

9 other guy was -- I don't know whether he was taking

10 notes. He'd add something occasionally. Then we

11 got all done and we -- okay. That's it.

12 Q. "We got all done and" what?

13 A. No. Just we got all done. That was it.

14 Q. When did this interview happen?

15 A. I have no clue the date. I don't know.

16 Q. Before or after your August 9th note that

17 Metro's going to reopen an investigation?

18 A. I don't know.

19 Q. Do you know how you found out Metro was

20 going to reopen the investigation?

21 A. No, not specifically. I don't know

22 whether they just arrived or whether we knew ahead

23 of time. I don't -- I don't really remember.

24 Q. Do you recall if it was in this general

25 time frame, August, September of 2011, that you



1 spoke to Mark Gregory and somebody else from Metro?

2 A. I don't know. I don't remember.

3 Q. Do you recall what you talked about?

4 A. We talked about how we handled the

5 incident, what I did, how I reported it to -- to --

6 to Chavez, talked about if I was -- if I knew if

7 there was any cover-up, if there was ever an

8 Internal Affairs investigation, different

9 relationships between different people within the

10 department.

11 That's about -- you know, that's mostly

12 what I remember at this point.

13 Q. Do you recall where this interview took

14 place?

15 A. In my office.

16 Q. Do you recall how long this interview

17 took?

18 A. At least an hour probably.

19 Q. And one of the items you talked about was

20 how you handled the investigation?

21 A. No, not handled the investigation. What

22 I did, how I turned it over to -- to their agency.

23 Q. And was that testimony -- I mean, was --

24 that conversation with Metro, did it include

25 anything other than what we already talked about,



1 that you got the names and the phone call to Chavez?

2 A. Not that I know. I don't remember

3 exactly everything that we talked about.

4 Q. Are there any substantive differences in

5 your recollection from when you interviewed with

6 Metro as opposed to when you first called Chavez?

7 A. Not that I can recall, no.

8 Q. Okay. And you provided truthful

9 information to Gregory?

10 A. Yes.

11 Q. And did you provide truthful information

12 to me when you conveyed what you had told Chavez in

13 November of 2009?

14 A. Yes.

15 Q. All right. So your discussion on that

16 topic would be substantively similar; correct?

17 A. Should have been.

18 Q. One of the other topics you said you

19 discussed with them was was there an Internal

20 Affairs investigation. What was that discussion

21 about specifically?

22 A. They asked if our department did an

23 Internal Affairs investigation.

24 Q. And how'd you respond?

25 A. That I didn't -- that I didn't know or



1 that we didn't or I didn't think we did, that I'm

2 not aware of one.

3 Q. Did they ask why not?

4 A. I don't know. They may have.

5 Q. Do you recall anything else about the

6 Internal Affairs investigation they may have asked

7 you?

8 A. No.

9 Q. And you said they asked about

10 relationships between different people in the

11 department.

12 A. Uh-huh.

13 Q. Who did they ask about and what were your

14 responses?

15 A. They asked specifically about Nebeker and

16 Arroyo, their friendship.

17 Q. And what were your responses?

18 A. That they went to lunch pretty much every

19 day and, as far as I knew, they were pretty good

20 friends or, you know, acquaintances. You know, they

21 were friendly with each other.

22 Q. Anything else, any other relationships

23 they talked about?

24 A. I don't remember. I --

25 Q. Do you get interviewed by Metro a lot



1 with an investigation of your department?

2 A. No.

3 Q. But you don't particularly remember

4 anything from this conversation with any

5 specificity; is that correct?


7 A. No, not really. I don't -- don't

8 remember every question and every answer, no, I

9 don't.

10 BY MR. COOK:

11 Q. All right. To the best of your ability,

12 what do you remember about that interview besides

13 what you've already told me?

14 A. I've already told you what I remember.

15 Q. So there's nothing about that interview

16 besides what you've already told me that you can

17 recall as you sit here today. Is that your

18 testimony, sir?

19 A. I can't think of anything right now above

20 and beyond that.

21 Q. All right. Do you recall if you had read

22 or observed any news stories about this instance --

23 incidence prior to talking to Gregory?

24 A. It's possible.

25 Q. Do you recall?



1 A. My answer is I -- it's possible. I don't

2 recall anything specific or a specific date or time

3 or whatever.

4 Q. So you know you read or heard something

5 about this story in the news, but not when, and you

6 know you talked to Gregory, but not when, and you're

7 not sure which was first; is that correct?

8 A. I don't know the order of -- of how that

9 all happened.

10 Q. So was my statement correct, sir?

11 A. Can you say it again.

12 Q. Yeah.

13 You know you read or saw something on the

14 news related to this story, the Peterson death, the

15 Miranda accident, but you don't recall when;

16 correct?

17 A. Correct.

18 Q. You know you talked to Gregory and

19 somebody from his office for about an hour in your

20 office, but you don't know when; is that correct?


22 Q. And you also do not know which happened

23 first; is that correct?

24 A. Correct.

25 Q. Okay.




2 identification.)

3 MS. HENDRICKS: It looks like here's

4 another one with social security numbers, so if we

5 can just cross those out.

6 MR. COOK: Do I have to get these back or

7 can you do that on those two? Can you notate it?

8 THE REPORTER: I'll do it.

9 MR. COOK: Perfect. So the court

10 reporter's going to take care of the confidentiality

11 info on the original exhibit, so I'd ask everybody

12 to take care of it on their own copies, please.

13 MS. HENDRICKS: Thank you.

14 MR. PARK: We will.


16 And this is 6; correct?

17 THE REPORTER: Yes.


19 BY MR. COOK:

20 Q. Sir, Exhibit 6, is this your handwriting?

21 A. Yes.

22 Q. Okay. It says, "SATURDAY NIGHT

23 PARTY/DINNER AT WAMSLEY'S HOUSE." Did you

24 understand that to be one event or two separate

25 events, or did you have any understanding?



1 A. I was told that it was a party/dinner at

2 Wamsley's house.

3 Q. All right. And when you say "told," this

4 was by Nebeker because he was the person you had

5 talked to; correct?

6 A. Yes.

7 Q. Just to the right of that it says,

8 "ADRIANA GAMBOA SUNDAY NOON - 2." Do you know what

9 that is?

10 A. I believe it's he told me that Adriana

11 called Mondo, her supervisor, dispatch supervisor,

12 on Sunday sometime between noon and 2:00.

13 Q. And just so the record's clear, Mondo is

14 Armando Quintanilla?

15 A. Armando Quintanilla, yes.

16 Q. There is a name with a hyphen "8:45."

17 What does that say?

18 A. It says "MANDO" and then "8:45 PM."

19 Q. And what does that indicate?

20 A. I believe he, Nebeker, told me that Mondo

21 told him he left about 8:45.

22 Q. Dispatcher Ron Sufana question mark, what

23 does that indicate?

24 A. No, "DISPATCHERS" is one point.

25 Q. Okay. So then you're going to give a



1 list under that of dispatchers?

2 A. No. There were dispatchers there.

3 Q. All right.

4 A. Okay. Just general dispatchers. And

5 then specifically Ron Sufana, but there was a

6 question mark whether he was really there or not.

7 Q. The next one is --

8 A. "ZUNIGA

9 "ZUNIGA DAUGHTER WAS IN VEHICLE

10 (BOYFRIEND)

11 "ROBBINS," and "MORALES" with a question

12 mark.

13 Q. And then it says, "8:30 PM TINA" what?

14 A. "TINA ZUNIGA CALLED MANDO."

15 Q. Is that the Sunday after the party called

16 Mondo?

17 A. I have no idea what that meant.

18 Q. All right.

19 A. I don't know.

20 Q. So when I asked you as you sit here today

21 who was your understanding that was at the party,

22 you said Wamsley and -- do you have Exhibit 2 in

23 front of you, sir? It's the three typed list with

24 names.

25 A. Yes.



1 Q. So let me just back up for a second.

2 A. Okay.

3 Q. At the time you called Chavez, the list

4 of names is included -- the universe of names you

5 knew being at the party is included in Exhibit 2 and

6 6 in front of you; is that correct?

7 A. Yes.

8 Q. Okay. And when I asked you to give me

9 the laundry list of names you believe to be as you

10 sit here today who was at the party, you gave me a

11 list that included Wamsley, and we see her on

12 Exhibit 2, so you knew about her the first day you

13 heard about this; correct?

14 A. Yeah. She's also on Exhibit 6.

15 Q. Okay. And you also gave me Gamboa --

16 A. Uh-huh.

17 Q. -- who is also on both sheets; correct?

18 A. Uh-huh.


20 A. Yes.

21 Q. You also gave me Zuniga, who is on both

22 sheets; correct?

23 A. Yes.

24 Q. You gave me Morales, and you have a

25 "MORALES" with a question mark and "ROBBINS" with a



1 question mark; correct?

2 A. "ROBBINS" doesn't have a question mark.

3 Q. Is that an "S"?

4 A. That's an "S."

5 Q. "ROBBIN PLUS S," is that what that says?

6 A. No, it's "ROBBINS" with an "S."

7 Q. And is that because it's his name is Mark

8 Robbins or was that to indicate two Robbinses --

9 A. No.

10 Q. -- as in him and his wife?

11 A. Mark Robbins.

12 Q. Okay. I don't see his wife, Cynthia, and

13 actually I believe at the time of the party it was

14 Cynthia Ruelas.

15 A. Right.

16 Q. She's not down here; correct?

17 A. No, but there's a general "DISPATCHERS"

18 up here that lists there were other dispatchers

19 there, but he didn't have all the names. This is

20 not all inclusive. This is not all -- all the

21 people, just dispatchers and then specific names of

22 ones that -- that he was told.

23 Q. And Armando Quintanilla, is he listed on

24 either one of these as being at the party?

25 A. Yeah, "MANDO." On 6, "MANDO" right under



1 Wamsley, "8:45."

2 Q. Okay. And then "SUFANA" with a question

3 mark; correct?

4 A. Yes.

5 Q. Now, when you talked to Chavez with

6 regard to Morales with a question mark and Sufana

7 with a question mark, what did you tell him about

8 them?

9 A. Well, I don't remember specifically

10 exactly how I told him anything. I gave him the

11 information that I had from these two pieces of

12 paper.

13 Q. And nowhere on these two pieces of paper

14 does it say Cynthia Ruelas was at the party;

15 correct?

16 A. No.

17 Q. No, that's not correct?

18 A. It doesn't say it on here. No, her name

19 is not on here.

20 Q. Okay.

21 A. But there's the general "DISPATCHERS,"

22 which could include her, or it can include any

23 dispatcher.

24 Q. Okay. If you knew Cynthia Ruelas was

25 there when you wrote this sheet, would you have just



1 wrote "DISPATCHERS" or would you have written her

2 name out?

3 A. If I had known that she was there, I

4 would have written her name out.

5 Q. Okay. So you knew there were other

6 dispatchers, but you didn't know who, and some point

7 later you came to find out Cynthia Ruelas was one of

8 them. Is that fair?

9 A. Oh, I've heard that now, yes.

10 Q. Do you recall when you first heard

11 Cynthia Ruelas was at the party at Wamsley's house

12 on November 29th -- I'm sorry, 28th, 2009?

13 A. No.

14 Q. When you heard that information

15 regardless of the date, did you forward that new

16 information to Chavez?

17 A. No, because I forwarded everything I did

18 to the chief of police, who was in charge of

19 Internal Affairs and in charge of this case, this

20 incident.

21 Q. When you found out that one of the other

22 dispatchers was Cynthia Ruelas, did you turn that

23 information over to Arroyo?

24 A. I didn't find that out. I don't know

25 when I found that out.



1 Q. I didn't ask when.

2 A. Okay.

3 Q. I asked if. You already told me at some

4 point you found it out; right?

5 A. Yeah, but it might have been within the

6 last six months. I don't -- I don't remember.

7 Q. Okay.

8 A. When I know that, you know, she got a

9 deposition or whatever.

10 Q. So you didn't find out she was at the

11 party until her deposition was noticed?


13 A. I -- I don't know when I was notified or

14 whether I -- whether I knew when she was there or

15 not.

16 BY MR. COOK:

17 Q. Did you --

18 A. I --

19 Q. -- take any steps when you found out her

20 name was there to contact Metro and say, "I've got

21 another name to add to the list"?

22 A. No. I told you I turned this over to

23 Arroyo and I had no further involvement.

24 Q. Turned what over to Arroyo?

25 A. Everything, all this stuff, all the --



1 everything that I gave him. I mean, everything that

2 I told Metro I told him, and he had a copy of all

3 this stuff.

4 Q. Okay. That's not what I'm asking you.

5 When you found out Ruelas was at the party, did you

6 contact anyone at Metro and tell them?

7 A. Because I don't know when I was ever

8 notified that Ruelas was at the party. I could

9 assume she was because I wrote "DISPATCHERS" here

10 and her husband was there or boyfriend, whatever --

11 whatever it was.

12 MR. COOK: Can you read the question

13 back, please.

14 (The following record was

15 read by the court reporter:

16 "Question: Okay. That's

17 not what I'm asking you.

18 When you found out Ruelas

19 was at the party, did you

20 contact anyone at Metro and

21 tell them?")

22 A. No, because I never officially found out

23 that Ruelas was at the party.

24 Does that answer it or no?

25 \\\



1 BY MR. COOK:

2 Q. What do you mean by officially found out

3 she was --

4 A. I don't --

5 Q. -- at the party?

6 A. I don't know everybody that was at the

7 party.

8 Q. I'm -- I'm sure you don't know everyone

9 who was at the party, but what I asked you this

10 morning is give me a list of who you believe as you

11 sit here today was at the party, and one of the

12 names you gave me was Cynthia Robbins, who at the

13 time in 2009 was Cynthia Ruelas, so my question is

14 really defined to at some point before you sat down

15 today you found out Cynthia Ruelas was at the party.

16 Do I have that part correct?

17 A. Yes.

18 Q. Okay. And on November 30th, 2009 when

19 you talked to Chavez, you didn't have her name

20 written down, which indicates that you didn't

21 specifically know she was at the party at that time;

22 correct?

23 A. Correct.

24 Q. Okay. So it is unlikely you conveyed to

25 Chavez when you talked to him November 30th, 2009



1 that Cynthia Ruelas was at the party because you

2 didn't have her name then; correct?

3 A. Correct.

4 Q. Okay. Sometime after November 30th, 2009

5 and today, you found out Cynthia Ruelas was at the

6 party; correct?

7 A. I heard she was at the party at some

8 point some- -- somewhere. I don't know what time

9 line or where. Did I contact Metro with that

10 information? No.

11 Q. All right. Now you're going two

12 questions ahead.

13 A. Okay.

14 Q. So let me -- let me hang on here.

15 So between November 30th, 2009 and today,

16 you came to believe that Cynthia Ruelas was at the

17 Wamsley party; correct?


19 Q. Between November 2009 and today --

20 A. Okay.

21 Q. -- you came to believe that Ruelas was at

22 that Wamsley party on November 28th, 2009?

23 A. Okay.

24 Q. Is that correct, sir?

25 A. Yes.



1 Q. All right. Do you recall if you found

2 out about that before or after the lawsuit was

3 filed?

4 A. After.

5 Q. Okay. So at the time of the news

6 stories, you were not aware that Cynthia Ruelas was

7 at the party; is that correct?


9 Q. Okay. Once you found out that Cynthia

10 Ruelas was at the party, you were already chief of

11 Clark County School District Police Department;

12 correct?

13 A. Correct.

14 Q. Okay. When you found that out, did you

15 turn that information over to Metro?

16 A. No.

17 Q. Why not?

18 A. Because I didn't.

19 Q. No reason?

20 A. No reason.

21 Q. All right. This was former Chief

22 Arroyo's testimony during his deposition in this

23 case on July 8th, 2013: ". . . when the original

24 incident was brought to our attention the Monday

25 after the incident, I directed the current chief,



1 Ketsaa, who at the time was the captain over the

2 administrative division or department, to contact

3 Metro and inform Metro of the information we had

4 received regarding our employees having attended a

5 party. And Ketsaa contacted Metro -- if I'm not

6 mistaken, it was Detective Chavez -- and provided

7 them with the information."

8 Is that statement accurate?

9 A. No.

10 Q. Why not?

11 A. 'Cause I did it without his direction.

12 He wasn't even there.

13 Q. Okay. When he told you, did he say,

14 "Hey, contact Metro," and you say, "I already did"?

15 A. No.

16 Q. You conveyed to him you had the

17 information and you had already contacted Metro?

18 A. Yes.

19 Q. All right. Then I asked him, ". . . when

20 you said 'the information,'" that "'we gave them the

21 information,' what specific . . . information did

22 you have Ketsaa give" them?

23 "That Monday morning Sergeant Brian

24 Nebeker provided us with information" -- this is his

25 answer, by the way -- "that there had been a party



1 that weekend and several of our dispatchers had

2 attended. Several of them had already come forth,

3 and he had a list of names at that particular time.

4 "That information was passed on to the

5 detective by Captain Ketsaa," that detective being

6 Chavez.

7 A. Uh-huh.

8 Q. "Any other information you had that

9 Monday?"

10 "No. That's . . . basically it."

11 Now, it's your testimony that Nebeker

12 told you, not you and Arroyo; correct?

13 A. He told me and me only in my office

14 alone.

15 Q. All right. And you're not aware of

16 whether Nebeker then went separately into Arroyo's

17 office and told him?

18 A. He may have. I don't know.

19 Q. But your actions were based directly on

20 Nebeker talking to you and then you contacting Metro

21 on your own without any input from Arroyo; is that

22 correct?


24 Q. I asked, "What did Ketsaa tell you

25 happened with his conversation with Chavez?"



1 His response: "That Chavez took the

2 information down and he would follow up on the

3 names. I believe there's also a folder, a file,

4 that was put together by Captain Ketsaa, which had

5 the . . . individuals' names."

6 Let me break that down. Is it accurate

7 that you told Arroyo that Chavez took the

8 information down and would follow up on the names?

9 A. Yes.

10 Q. Okay. And he said that there's a folder

11 that you put together. Did you put a folder

12 together?

13 A. This right here.

14 Q. Exhibit 6 is your folder?

15 A. It was in a folder.

16 Q. Okay. So the only thing in the folder

17 was the one sheet of paper?

18 A. And this sticky note.

19 Q. The only thing in the folder --

20 A. And this -- this other exhibit, Exhibit

21 2.

22 Q. Okay. So the folder included Exhibit 2,

23 which was the three typed-out names --

24 A. Uh-huh.

25 Q. -- and your handwritten list, which is



1 Exhibit 6, and a Post-it on top that had Chavez's

2 contact information; is that correct?

3 A. Yes.

4 Q. And you -- what, did it go into a Manila

5 folder?

6 A. Yeah, just stuck it in a Manila folder

7 and kept it.

8 Q. What'd you title the Manila folder?

9 A. "The Wamsley Incident."

10 Q. And where'd you keep the folder?

11 A. In my office.

12 Q. In your like personal files or with some

13 other set of files?

14 A. With -- just in a -- in a -- in a file

15 drawer.

16 Q. What else was in the file drawer?

17 A. Other files.

18 Q. What kind of other files?

19 A. All kinds of files. I mean, you know --

20 Q. Okay. Were these other files personal

21 financial information? Were these other files open

22 CCSD case investigations, Internal Affair --

23 A. No, absolutely not.

24 Q. -- investigations -- let me finish the

25 question since you didn't understand when I asked



1 you generically -- or some combination of all of

2 them, or was it just some set of files that were not

3 going to be officially opened that you kept in your

4 file drawer?


6 MR. PARK: Join.

7 A. It was in a file drawer with other files,

8 no IA -- I don't keep IA files or any open criminal

9 cases or any files like that. This is just my

10 files.

11 BY MR. COOK:

12 Q. What other kind of your files are in your

13 file drawer that you kept this file in?

14 A. Things that I get from the Legislative

15 Counsel Bureau, maybe from -- from my boss, copies

16 of the POA contract, just my files, things that I go

17 in and I -- and I know where they are.

18 Q. Why did you keep this in those files as

19 opposed to sending it out to have an official file

20 opened?

21 A. Because Arroyo, he said, "Just keep --

22 just keep it." And I kept it. I wanted to make

23 sure that I kept it.

24 Q. So he told you to open the file?

25 A. No, no.




2 A. No. When I -- when I eventually told him

3 about it, he said, "Just make sure you keep a copy

4 of everything."

5 BY MR. COOK:

6 Q. I asked him who told Ketsaa to put

7 together a file, and he said, "He did" --

8 A. Uh-huh.

9 Q. -- meaning you, so that means you on your

10 own put the file together. Do you understand that?

11 A. I made this file myself and I told him

12 that -- that I -- that I made it, and he just told

13 me, "Make sure you keep it."

14 Q. Did he tell you, "Keep it privately with

15 your private stuff," or is that something you chose

16 to do on your own?

17 A. Something I chose to do on my own.

18 Q. What were the considerations you had

19 before deciding to keep the file on your own with

20 your private stuff?


22 A. The considerations were that I would have

23 access to it if I needed it and that it would be

24 safe.

25 \\\



1 BY MR. COOK:

2 Q. Do you have any policies and procedures

3 as to what you're supposed to do if you convey

4 information to Metro, if you're supposed to keep a

5 file on it, have something opened, get Concern

6 Reports, do a follow-up investigation, anything like

7 that?


9 A. Give me an example.

10 BY MR. COOK:

11 Q. You call up Metro and you give them names

12 of people you believe were involved --

13 A. Uh-huh.

14 Q. -- at a party where somebody died.

15 A. Okay.

16 Q. You want to keep that information.

17 A. Uh-huh.

18 Q. What's the policy on whether you open up

19 a file or how you go about keeping that information?

20 A. There isn't one because it's not an

21 investigation that we are conducting.

22 Q. It's an investigation that Metro is

23 conducting that you have information --

24 A. Right.

25 Q. -- on; is that correct?




2 Q. Okay. Is there a policy on how you

3 handle information you're conveying to Metro in a

4 cooperative fashion for the School District Police

5 Department?

6 A. You could do an officer's report with a

7 DR number, an event number on it, and maintain that

8 in records.

9 Q. Why didn't you do that here?

10 A. Because it -- it -- I told you I gave

11 this -- I did what I did. I gave this to the chief.

12 He was in complete control of the investigation. I

13 kept my own file for my own purposes so I had a

14 file.

15 Q. Did he tell you not to open a DR file on

16 it?

17 A. No. I turned it over to him. I'm not

18 the investigating officer, and I turned it over --

19 like I said, I turned it over to Metro. I wasn't

20 the investigating officer. We were not conducting

21 an investigation, and I didn't -- and I wasn't over

22 Internal Affairs.

23 I believe it was his place to do all

24 that.

25 Q. You kept your original sheet of paper and



1 the sheet of paper that Nebeker brought in with the

2 three names on it; correct?

3 A. Uh-huh, that's correct.

4 Q. You did not give that over to Arroyo.

5 You kept it; correct?

6 A. I made him a copy. I kept the original.

7 Q. Okay. When you kept the original, did

8 you -- did he tell you -- when he said, "No, go

9 ahead and keep the file," did he say, "but don't do

10 a DR number and don't officially open anything"?


12 A. He didn't tell me to do anything.

13 BY MR. COOK:

14 Q. So the reason you didn't do a DR file

15 is -- was solely your own personal decision; is that

16 correct, sir?

17 A. No. I turned it over to the chief. It

18 was his decision.

19 Q. But he didn't give you any input on

20 whether to open a DR file or not, did he?

21 A. No, he didn't.

22 Q. Okay. Did you keep that file in your own

23 office because you're the captain over the

24 administrative division and you're supposed to keep

25 that file?




2 A. I kept it because I didn't want to lose

3 it and I wanted to make sure it was safe.

4 BY MR. COOK:

5 Q. Do you have a problem with having

6 officially filed open -- officially open files

7 coming up missing or not being safe?

8 A. No.

9 Q. So the reason you chose to keep the file

10 in your personal office is not because you're the

11 captain over the administrative division then, is

12 it?


14 A. It could have been, but you don't mix --

15 you don't mix these type of things with criminal

16 investigations. They don't go together or records.

17 BY MR. COOK:

18 Q. Where do they go typically then?

19 A. This would go into an I- -- if it was an

20 IA, it would have gone to an IA -- into an IA file.

21 Q. Why wasn't an IA file opened then?

22 A. I have no idea. I was not over IA.

23 Q. If you were given that authority then,

24 you would have put it in an IA file?

25 A. Yes.




2 A. Yes, I would have.

3 BY MR. COOK:

4 Q. Okay. But he was over IA, so that was

5 up -- and that was up to him to decide to do that?

6 A. Yes.

7 Q. At any point in time, did he say, "What

8 do you think, should we open up an IA file?"

9 A. I -- the only thing that was ever said

10 was that if Metro comes back with any findings of

11 any wrongdoing on our officers or dispatchers, then

12 we would do something then.

13 Q. But you know you don't have to wait for

14 that to open up an IA file; right?


16 foundation.

17 A. Yes, you do. You wait. You don't do --

18 you don't do concurrent investigations. You always

19 wait for the criminal investigation to be completed

20 and closed out with a disposition one way or the

21 other before you initiate an Internal Affairs

22 investigation. They're never done at the same time.

23 BY MR. COOK:

24 Q. So then Arroyo -- is it true then that

25 Arroyo could not have opened up an Internal Affairs



1 investigation?

2 A. He could have -- he could have -- okay.

3 There's a difference between opening it

4 up and actually conducting one.

5 Q. Okay.

6 A. He could --

7 Q. So is it your testimony he could have

8 opened one up but he would have had to wait to do

9 the investigation?

10 A. Yes.

11 Q. All right. And if you were given the

12 choice, you would have opened it up but waited to do

13 the investigation?

14 A. Yes.

15 Q. All right. But the only way you know

16 whether or not to do the investigation, if you have

17 to wait for Metro to finish, is you've got to follow

18 up with Metro and find out when they're finished;

19 correct?


21 A. There has to be a determination of

22 either -- or a report of misconduct or something

23 illegal.

24 BY MR. COOK:

25 Q. You're not limited to do an Internal



1 Affairs investigation based on occasions wherein

2 only Metro comes up with a conclusion that there was

3 something illegal that happened, though; correct?

4 A. No.

5 Q. Okay. So to decide whether or not you

6 would conduct an Internal Affairs investigation, you

7 would not want to have a concurrent investigation,

8 so therefore you wouldn't begin any investigation

9 till Metro concluded theirs; is that correct?


11 A. No, because initially when we got this in

12 November, there was no allegation of any wrongdoing.

13 There was no -- it was just there was a party,

14 someone left the party, and there was a tragic

15 accident. There was no other information or any

16 other -- anything that said there was -- there was

17 misconduct.

18 If there was misconduct, the misconduct

19 would have been noted, and that could have been

20 investigated outside of the -- you know, when the --

21 when the other one was completed just in case there

22 wasn't going to be criminal. You don't want -- does

23 that make sense?

24 BY MR. COOK:

25 Q. Okay. So if -- if you believed Metro was



1 investigating something that has some kind of a

2 crossover with regard to your officers --

3 A. Uh-huh.

4 Q. -- you would not conduct an Internal

5 Affairs investigation while Metro is conducting

6 their investigation. I have that part right;

7 correct?

8 A. Yes.

9 Q. In instances such as those then, don't

10 you have to keep in communication with Metro to find

11 out when they're done with their investigation so

12 you can figure out whether you have to start an

13 investigation or not?


15 A. Yes, but it wasn't me who was responsible

16 for that.

17 BY MR. COOK:

18 Q. I'm getting there.

19 A. Okay.

20 Q. Okay. So -- and that will be my next

21 question. I just want to make sure I understand

22 this.

23 A. Uh-huh.

24 Q. Somebody's got to follow up with Metro

25 then to find out, "Are you guys done with your



1 investigation so we know if we have to do

2 something?"

3 A. It would be a good idea. It would also

4 be a good idea that if they would communicate and

5 convey information back and forth.

6 Q. Whose responsibility was it -- with

7 regard to whatever investigation you believed Metro

8 was doing after you called Chavez and then turned

9 the documents or copies of the documents over to

10 Arroyo, whose job was it to follow up with Metro and

11 find out, "Did you guys find anything? Are you

12 done? What's the status?"


14 A. That would have been the chief, who was

15 over IA, took complete control of IA and

16 responsibility, or his IA investigator or

17 investigators.

18 BY MR. COOK:

19 Q. I asked Chief Arroyo, did ". . . you ever

20 contact them," "them" being Metro, "to try and find

21 out what happened with the investigation or whether

22 it had been concluded?"

23 He said, "I did not."

24 I said, ". . . is anybody from your

25 office supposed to follow up on that?"



1 He said, "It would have been Captain

2 Ketsaa."

3 It's your position that that's not true.

4 It wouldn't have been you. It would have been him;

5 is that correct?

6 A. Absolutely his, yes, per that special

7 order, yes.

8 Q. And he never communicated to you that it

9 was your responsibility to follow up with Metro and

10 see the status of that investigation?

11 A. No.



14 Q. Okay. And it was not one of your duties

15 that he should have reasonably expected you to

16 follow up with Metro on your own?

17 A. No.

18 Q. I asked him at the time of this accident

19 or after the time of this accident, ". . . are you

20 making every call . . . or does" someone "have" a

21 "level of authority below you?"

22 He said, "Basically the Internal Affairs

23 investigator, Detective Loren Johnson, reported to

24 Captain Ketsaa, and it was handled at that level."

25 It's your testimony that that's not true?



1 A. It's absolutely not true in this case.

2 Q. There were other cases --

3 A. No. There -- I'm just saying I was not

4 over IA and it's still -- that -- that SO was never

5 rescinded. I was not over IA. I had no connection

6 with IA.

7 Q. He said --

8 A. Except for if I was acting chief in his

9 absence and something came to me for signature or

10 disposition.

11 Q. Then you wouldn't take over the case.

12 You would just conduct whatever minimal action was

13 necessary until he came back?

14 A. Right. It would be just basically

15 signing off on something and forwarding it or -- or

16 determining the level of discipline or whatever.

17 Q. So when he told me that, "When . . .

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

19 come into play," it's your position he came into

20 play at the investigation stage and in fact at the

21 determination of whether there would be

22 investigation; is that correct?


24 Q. He says he doesn't get involved till

25 there's a finding and he has to issue discipline.



1 A. Uh-huh.

2 Q. That's not true?

3 A. Well, it's very clear on the concern form

4 that it says the chief or chief's designee has to

5 assign it, so since I was not his designee, then he

6 could have assigned another captain to do it, if he

7 wanted to, or he could have assigned it himself.

8 But he did not assign me to do it, and I had, like I

9 said, a special order to back that up.

10 Q. And he is the one that would make the

11 decision whether in fact there was even an

12 investigation to occur on a particular instance; is

13 that correct?

14 A. Yes.

15 Q. This is what I asked him: "So the

16 decision to do an Internal Affairs investigation was

17 Ketsaa's unless you were separately specifically

18 given some information that led you to want to

19 direct an Internal Affairs investigation?"

20 He said, "Correct, sir."

21 You're saying, in fact, it was the

22 opposite. It was his unless he specifically gave

23 something to you; is that correct?

24 A. Yes.

25 Q. Okay. By the way, with regard to Nebeker



1 telling the both of you at [sic] the party, I said,

2 where ". . . did you hear from?"

3 He said, "It was Sergeant Nebeker at the

4 time. He's the one" who "provided us the

5 information . . . myself and Captain Ketsaa."

6 And I said, "Where was that, your office,

7 Ketsaa's office, or you just happened to be

8 together?"

9 And he said, "I think we were just

10 together. It could have been in the EOC room, which

11 is just adjacent to my office . . . ."

12 I know you already said that's not what

13 happened, but with that additional information as to

14 where it may have been, does that refresh your

15 recollection that maybe Arroyo was with you?

16 A. Initially, no.

17 Q. All right. When you say "initially,"

18 what does that mean?

19 A. When Nebeker reported to me, it was in my

20 office with him and I alone. That was it.

21 Q. And then when he came back and followed

22 up, it was still with you and Nebeker alone?

23 A. Yes.

24 Q. Now, you don't disagree that if Clark

25 County School District Police Department got new



1 information about the party that would be helpful to

2 the investigation it should have been turned over to

3 Metro. You're just saying you weren't involved in

4 that part and don't know if that happened?


6 foundation.

7 BY MR. COOK:

8 Q. Is that right, sir?

9 A. Say that again now.

10 Q. Sure.

11 We talked earlier about what information

12 you got about the party after you had your phone

13 call with Chavez --

14 A. Uh-huh.

15 Q. -- until filing the lawsuit -- actually,

16 not that -- until the July 2011 story.

17 A. Okay.

18 Q. You said, "I didn't get any new

19 information, so of course I didn't contact Metro

20 with any information. I didn't have any. In fact,

21 that would have been Arroyo's responsibility"; is

22 that right?

23 A. If I had gotten any information, I would

24 have given it to Arroyo.

25 Q. Okay. So you don't dispute that if Clark



1 County School District had more information about

2 the party that would help Metro's investigation that

3 the School District should have turned it over to

4 Metro. You're just saying, "I didn't have any and

5 that wouldn't have been my responsibility. It would

6 have been Arroyo's"; is that right?


8 A. Well, I'm saying I didn't have any

9 information, so I can't speak for somebody else.

10 BY MR. COOK:

11 Q. All right. But you are the current chief

12 of police, so --

13 A. Yes.

14 Q. -- I'm assuming you have some

15 understanding as to how that should work if you're

16 doing a cooperative investigation with Metro. Is

17 that fair?


19 A. This isn't -- this wasn't a co- -- well,

20 it wasn't a -- we weren't assisting them in the

21 investigation. You said "cooperative

22 investigation."

23 BY MR. COOK:

24 Q. Okay. As chief of police, if you got

25 information that your cops were playing beer pong



1 with Miranda at this party before he drove away and

2 killed somebody, is that information that if you had

3 and you were chief of police you would have made

4 sure Metro had that information?

5 A. Yes.

6 MR. PARK: Objection to form.

7 MS. HENDRICKS: Join.

8 A. Yes.

9 BY MR. COOK:

10 Q. But you didn't have that information and

11 you weren't chief of police; thus, you didn't do

12 that; correct?

13 A. Right.

14 Q. And when I was talking about Arroyo about

15 different information he would have learned after

16 what he described as his and your meeting with

17 Nebeker in 2009, I said when I asked -- when I asked

18 him about additional information, I said, "And did

19 you do anything to verify whether any of these

20 statements were true?" Subsequent information.

21 He said, "No. Basically from what I

22 remember, I would have forwarded it to Captain

23 Ketsaa to notify Metro."

24 And as you sit here today, he didn't give

25 you any new information to forward to Metro or



1 anybody else; is that --


3 Q. All right. Were there other cases where

4 you were doing -- let me be more specific.

5 I was talking to him here about the

6 Boyett case.

7 A. Uh-huh.

8 Q. And I said, "And were you aware of

9 whether any other agency was investigating Boyett's

10 actions as to whether they were criminal or not?"

11 He said, "How it came to be is we had a

12 ICE agent present Captain Ketsaa with the

13 information that I just described regarding the

14 individual being on the Internet and so forth," and

15 that you were that contact person.

16 Is that accurate?

17 A. That was a criminal case. There's a

18 difference between criminal and Internal Affairs or

19 administrative cases, so I was over the criminal

20 side of investigations, not that side.

21 Q. Okay. So while that may have been what

22 happened in Boyett, that's not because it was a

23 specific one he assigned to you. It was criminal so

24 it was your area anyway?

25 A. Yes. I had the detectives and --



1 underneath me at that time. That's what I -- yes.

2 Q. By the way, what's an ICE agent?

3 A. Immigrations and Customs Enforcement.

4 Q. Okay. Did Arroyo forward you a complaint

5 to handle through Internal Affairs where he was the

6 complainant and Mike Thomas was the person being

7 complained about?

8 MS. HENDRICKS: I'm going to -- you can

9 answer the question, but as you know our position on

10 Internal Affairs, you can answer if you were

11 forwarded a complaint from Arroyo.

12 A. Yeah. At some point for whatever

13 reason -- I don't know -- we had -- there was --

14 there was two captains for a while and then one was

15 no longer there, so I don't know the specific date

16 or whatever when that happened. But yeah, for

17 whatever reason, he gave that -- I -- well, I can't

18 say for sure. I believe he gave me that to --

19 'cause he was the person, so as he -- I was his

20 designee, so he assigned it, not that I was over the

21 investigation or monitoring it, but he assigned me

22 to assign it -- to assign it to IA.

23 Q. So for that one Internal Affairs

24 investigation, you were the designee as when we

25 looked at that Concern Report by Armando Quintanilla



1 there was that designee space, chief of police or

2 designee? You were the designee?

3 A. For that just assignment of the case, not

4 the supervision of or the -- at the time, no.

5 Q. So you didn't oversee any of the

6 specifics of the investigation. You just handled

7 that single administrative function?

8 A. Right. The only time I got back involved

9 with that was at the -- well, was at the end.

10 Q. I asked Arroyo about what his complaint

11 was about Thomas, and this was that testimony: I

12 said, ". . . what specifically did he do that you

13 believed was an attempt to coerce you into doing

14 that?"

15 He said, "I don't remember the exact

16 text. I actually had downloaded it. An Internal

17 Affairs case was initiated, and I handed it over to

18 Ketsaa . . . Captain Ketsaa and to Detective Loren

19 Johnson to follow."

20 You don't believe that's accurate;

21 correct?

22 A. I don't believe that's accurate.

23 Q. Okay. He continued, "After the texting,

24 he" would also "call me on my department number and

25 also he began sending E-mails through chain of



1 command to different individuals in my command staff

2 without the proper protocol, which is what led" him

3 to "finally receiving this." And he's talking about

4 what Thomas was doing.

5 I said, "At some point . . . did you have

6 him investigated for extortion? Does that sound

7 familiar?"

8 He said, "Extortion? I basically handed

9 the information to Loren Johnson to follow through

10 as a policy violation, not necessarily a criminal

11 extortion case. . . .

12 "I know what I basically directed Captain

13 Ketsaa and Loren Johnson to do." And he said he

14 didn't think there was any extortion.

15 Is that your recollection of what

16 happened with regard to the Thomas investigation?

17 MS. HENDRICKS: And --

18 A. Well --

19 MR. COOK: I was careful with that

20 question.

21 MS. HENDRICKS: Yeah, you were very

22 careful.

23 MR. COOK: I didn't ask him what he did.

24 I asked if Arroyo's testimony --

25 MS. HENDRICKS: I have to listen. It's



1 kind of a compound question, so I'll object as to

2 form.

3 And do your best to answer.

4 THE WITNESS: Okay. He didn't give me

5 any information on the case. I don't maintain

6 Internal Affairs files, cases, paperwork, any texts

7 or whatever he was referring to. He would give that

8 to the investigator and he would sit with the

9 investigator and go over -- he as the victim, so he

10 would go over that with -- with -- with Loren

11 Johnson and they would go over what he believes to

12 be the appropriate policy, procedure violations,

13 whatever the -- you know, whatever the wrongdoing is

14 alleged. He would figure that out solely between

15 him and the -- the -- you know, the IA investigator.

16 The IA investigator then would document

17 all that and investigate it.

18 BY MR. COOK:

19 Q. Okay. I asked him -- I did the same

20 thing you just did.

21 A. Yeah.

22 Q. I backed up to kind of the general

23 policy, and I said who decides "whether there's

24 going to be an investigation or not?"

25 And he said, ". . . I think he was



1 still . . . training, it would have gone to

2 Detective Loren Johnson. If not, it would have gone

3 straight to Captain Ketsaa, who was over the

4 department administration."

5 Let me break that down. Were you over

6 department administration?

7 A. It depends on what period of time we're

8 talking about.

9 Q. 2009, 2010, right before he was

10 suspended, which was in -- through 2011, when he was

11 suspended.

12 A. No. There were some different changes

13 back and forth. There was -- when Goodwin was

14 there, he was over administration there I think at

15 the -- and then over -- over operations for a while.

16 There was -- there was a flip-flop back and forth.

17 Q. Does being over administration mean

18 you're over Internal Affairs?


20 Q. Okay. So regardless of whether you were

21 over administration or not, it's your position that

22 an IA case would not go straight to Captain Ketsaa?

23 A. I would not investigate an IA case alone

24 or by myself or as a captain. That's not what I

25 would do.



1 Q. My next question: "Who would make the

2 call on whether an Internal Affairs investigation

3 of . . . facts in the 'BRIEF DETAIL OF CONCERN'

4 paragraph should occur?"

5 He said, "Basically the . . . detective

6 and/or the . . . captain by all means."

7 A. Okay. That's not correct.

8 Q. It was the chief of police?

9 A. That's the -- yes, that's -- that's --

10 again, I go back to the special order that I was not

11 over Internal Affairs at all. He made it very clear

12 that he and Loren Johnson reported directly to him.

13 The only time I stepped in is if -- like I said, if

14 he was out of town.

15 Q. So when he said if something goes to

16 Internal Affairs Department it would be Loren

17 Johnson, who then brings it to a captain, or the

18 captain over the Internal Affairs Division makes the

19 call, and at least from 2009 November until he left,

20 again it's your position that wasn't you, that was

21 him?

22 A. It flip-flopped around. A captain can

23 initiate, as his designee, a supervisor concern. If

24 you see on -- on Exhibit 5, they can do a

25 supervisor. A captain unless it's so egregious or



1 the chief isn't around or they're acting in his

2 capacity can assign it to Internal Affairs. During

3 that time and -- and subsequent is I'm now the

4 chief, but prior to that there was no rescinding of

5 that special order. I had nothing to do with

6 Internal Affairs.

7 Q. Can Johnson or the Internal Affairs

8 officer if something's obvious open a case up on his

9 own?

10 A. He can't open it up, but he can -- he can

11 take all the information and present it to the chief

12 of police.

13 Q. So when I asked --

14 A. He doesn't have the --

15 Q. Go ahead.

16 A. No, he doesn't have the authority to just

17 run free on an investigation on his own.

18 Q. I said, "If it's . . . something obvious

19 to Loren Johnson, can he say, 'Yep, I'm opening it

20 up,' or does he still have to go to his captain, in

21 this case Ketsaa, and say, 'Do I open it up or

22 not?'"

23 He said, "No, he can. He can actually

24 open it up on his own."

25 A. That's not correct.



1 Q. Okay. If you liked that question, you're

2 going to love this one: "Did you have any

3 involvement with regard to any investigation or

4 anything related to Angela's death or the Wamsley

5 party other than directing Ketsaa as you did at the

6 very beginning after that November meeting?" He

7 says, "That was the only contact, yes, sir."

8 Your position is it wasn't your

9 responsibility at all; it was Arroyo's. Is that

10 correct?

11 A. Absolutely not. I had nothing to do with

12 Internal Affairs as of November 20-something of

13 2009.

14 Q. It's kind of a long question, but for

15 context I think I got to give it to you here. This

16 is again from my deposition with Arroyo. I said,

17 "When I asked Quintanilla what he believes could

18 have been done or should have been done differently

19 in his depo, he said, 'I told my superiors. They

20 knew about it, everything that I knew. I would not

21 condone anything like that, and none of that's going

22 to help bring anything back now . . . and I just

23 hope that this will bring" me "some light to you at

24 least to say, 'Well, you know what? At least at

25 that part, at that level something was done. It



1 wasn't just nothing.'"

2 I continued my question by saying, "And"

3 then he "complains that he was . . . out of things.

4 I shouldn't say 'complains.' He says he was kept

5 out of things.

6 "Do you agree with that testimony?"

7 This was Arroyo's answer to that long

8 question: "I never had any direct involvement in

9 anything regarding his information. If he shared

10 that information up his chain of command, it would

11 have gone to Sergeant Nebeker and then to Captain

12 Ketsaa."

13 Is that your understanding of how that

14 chain of command was supposed to work and how it did

15 work?


17 A. And I'm kind of confused on the question.

18 BY MR. COOK:

19 Q. Okay. And that's because I'm asking you

20 about a question I asked Arroyo about a question I

21 asked Quintanilla, so let me clean that up a little.

22 A. Okay.

23 Q. When I deposed Quintanilla, he -- I don't

24 want to say "frustration." I don't want to express

25 his emotions, but one of the things he commented on



1 was he thought he did everything he did by turning

2 things over to his superiors and that if things

3 weren't handled after that it wasn't on him, it was

4 on his superiors that didn't handle things. And I

5 say "if" because he said "if."

6 So I asked Arroyo what he thought about

7 that comment, and Arroyo said, "It's not on me.

8 That was something that should have been handled by

9 Nebeker or Ketsaa," with regard specifically to

10 Angela's death and information about the party that

11 came out afterwards.

12 Do you agree with that statement?


14 A. If information was given to me either

15 through Armando Quintanilla or through Nebeker or

16 anybody else, I would have passed that information

17 on to the chief of police.

18 BY MR. COOK:

19 Q. And you don't have any specific

20 recollection as you sit here today of that

21 happening, but you can't be a hundred percent

22 certain you didn't get some information that you

23 passed on to Arroyo. Is that a fair statement?


25 A. I don't -- don't think I got any more



1 information on anything that I can recall.

2 BY MR. COOK:

3 Q. I asked him, "What would you have done in

4 November" 2009 "if you knew cops were there?"

5 Speaking about the party.

6 His answer: "It would have taken a

7 totally different scenar- --" it "would have been

8 informed" -- sorry, let me try that again.

9 I said, "What would you have done in

10 November if you knew cops were there?"

11 His answer was: "It would have taken a

12 totally different scenario --" it would have -- "if

13 I would have been informed of the situation, I would

14 have been more direct overseeing the case that Metro

15 was involved in through the notification of Captain

16 Ketsaa."

17 So he's taking the position that if he

18 knew cops were there, he would have done more, but

19 he didn't; that was your information.

20 Again, do you agree or disagree with

21 that?


23 A. Well, I disagree because he knew that

24 there was police officers listed on this initial

25 thing. He knew that right up front.



1 BY MR. COOK:

2 Q. Did the dispatchers know that their names

3 were turned over to Metro, at least the dispatchers

4 that were on those lists in Exhibit 2 and 6?

5 A. I don't know. I didn't tell them.

6 Q. Did you direct anybody to tell them or

7 not to tell them or anything?

8 A. I didn't direct anybody to -- to not tell

9 anybody or tell. I didn't even consider it.

10 Q. I asked him how he knew Metro received

11 all the appropriate information in a much less

12 articulate fashion. This was his answer: "When I

13 directed Ketsaa to pass on the information to Metro,

14 I was under the impression that he would give them

15 all the information we had."

16 Is that accurate?

17 A. He didn't direct me, and I gave them all

18 the information that I had.

19 Q. I followed up, I said, ". . . did you

20 understand, was it clear that your instruction to

21 Ketsaa was, 'Whatever information you have, turn it

22 over to Metro,' or was it less clear where Ketsaa

23 might have thought, 'The information I have right

24 now I turn over, but if I get anything new I get to

25 keep it'?"



1 His answer: "No. I made it very clear,

2 'Any information that we can provide Metro, we're

3 here to assist them.'"

4 That true or not?

5 A. I don't recall that at all.

6 Q. "And then you never talked to Ketsaa

7 about it again until after the story broke;

8 correct?"

9 His answer: "Pretty much, yes, sir."

10 I said, "And what were the circumstances

11 that you and Ketsaa talked about it again?"

12 He said, "In passing in the office from

13 what I remember."

14 ". . . just in passing."

15 Do you remember ever having conversations

16 with Arroyo about any of the circumstances of

17 Angela's death or the party in passing or otherwise

18 after November 30th, 2009?


20 A. I don't recall anything. I -- it was

21 just only after the -- after it came out on the

22 news.

23 BY MR. COOK:

24 Q. And then what were those discussions?

25 A. That he was just very upset and that --



1 it weren't just with me. I mean, he was just -- he

2 was just very upset and he was extremely agitated.

3 I think there was some incident where he couldn't --

4 he was told or was directed he couldn't respond on

5 behalf of the department to the media.

6 Q. Was that as a result of a School Board

7 meeting or a meeting with School Board

8 representatives, I should say?

9 A. I have no idea.

10 Q. Okay. I said, ". . . anybody under you,

11 Ketsaa, Johnson, any of the people that normally

12 would have investigated an Internal Affairs . . . ."

13 He said, "Yes," meaning those would be

14 the two people. Then he said, "I never gave the

15 order to commit to an investigation."

16 So it's his position at least in this

17 depo if an Internal Affairs investigation was going

18 to happen that was never at his direction; it was

19 always at somebody else's. Is that your

20 understanding of what happened at the School

21 District from November 2009 --

22 A. I'm going to say --

23 Q. -- till he left?

24 A. I'm going to say --




1 A. I'm going to say it one more time, and I

2 don't know where that piece of paper is. I wish we

3 could show it. I had nothing to do with Internal

4 Affairs. I want to make that very clear, and it was

5 never rescinded. I'm going to keep telling you

6 that.

7 It was very clear he took me out of

8 Internal Affairs as of November something, 2009.

9 That's it. I had nothing to do with Internal

10 Affairs.

11 BY MR. COOK:

12 Q. Did you ever go to the School Board with

13 regard to any conversation that led to complaints

14 about Arroyo?

15 A. Did I go to the School Board?

16 Q. Yes, or any members of the School Board.

17 A. In reference to what?

18 Q. Arroyo.

19 A. Not that I can recall.

20 MS. HENDRICKS: About time for a break?

21 MR. COOK: Sure. Why don't we take it

22 and take a lunch. I'm not doing bad on time, so

23 we'll finish today.


25 THE VIDEOGRAPHER: Stand by, please.



1 This is the end of disk number two in today's

2 videographed deposition of James R. Ketsaa. The

3 approximate time, as indicated on the video screen,

4 is 11:52. We are now off the record.

5 (Luncheon recess taken.)

6 -oOo-

7 AFTERNOON SESSION

8 -oOo-

9 THE VIDEOGRAPHER: This is the beginning

10 of disk number three in today's videographed

11 deposition of James R. Ketsaa. The approximate

12 time, as indicated on the video screen, 1309.

13 BY MR. COOK:

14 Q. Sir, do you have any changes or

15 clarifications to your deposition from this morning?

16 A. No.

17 Q. All right. This morning one of the

18 things we were talking about is at some point in

19 time -- and I don't recall if you said a point in

20 time or not, but at some point in time you heard

21 that there was some kind of an insurance issue

22 related to Rebecca Wamsley and the party; correct?

23 A. That's correct. It's in one of these

24 exhibits.

25 Q. Which exhibit?



1 A. Right here on this concern.

2 MS. HENDRICKS: Exhibit 5 is what --

3 THE WITNESS: Exhibit 5. I'm sorry.

4 BY MR. COOK:

5 Q. Can I just take a peek at it there.

6 (The witness hands Exhibit 5

7 to Mr. Cook.)

8 BY MR. COOK:

9 Q. That is the report right before the news

10 story. I thought you had testified this morning

11 that it was something you had heard around the

12 dispatch area. Is that right?

13 A. No.

14 Q. So the first time you heard about the

15 settlement was in that news story?


17 BY MR. COOK:

18 Q. Let me ask it better.

19 A. I'm confused.

20 Q. The first time you heard that there was

21 an insurance payment with regard to Rebecca Wamsley

22 was in that Concern Report filed by the news?

23 A. As far as I know, the first time was in

24 here.

25 Q. That Exhibit 5?



1 A. This Exhibit 5.

2 Q. Did you convey to Chief Arroyo, "Hey, it

3 looks like there was some kind of a payment with

4 regard to Wamsley as to this story"?

5 A. No. I don't -- like I said, when I

6 filled out this form, I don't believe he was around

7 at that time.

8 Q. He was still working for the department?

9 A. Right.

10 Q. Okay. When he eventually came around

11 within the next few days or weeks, did you tell him,

12 "Hey, we've got some information that Rebecca

13 Wamsley had paid out some money with regard to that

14 party"?

15 A. No. I understood he already knew about

16 it.

17 Q. How did you come to understand that he

18 already knew Rebecca Wamsley had paid out some

19 money --

20 A. Because --

21 Q. -- with regard to the party?

22 A. -- he had talked about it.

23 Q. When did he talk about it?

24 A. I don't know. I'd heard him talk about

25 it.



1 Q. Did you hear him talk about it before you

2 saw Exhibit 5?


4 Q. So in fact, you may have heard about it

5 from Arroyo before you ever saw Exhibit 5?

6 A. I don't think so.

7 Q. Did you at any point in time convey to

8 Arroyo, "Wamsley appears to have paid out money with

9 regard to this party"?

10 A. No.

11 Q. At any point in time, did you hear Arroyo

12 convey to you or in front of you that he was aware

13 that Rebecca Wamsley had paid out money with regard

14 to something that happened involving the party?

15 A. I heard it. I don't spec- -- I can't

16 specifically say it was him, but I believe he may

17 have said it at some point, at some time.

18 Q. Is the information that Rebecca Wamsley

19 paid out money in relation to that party something

20 that whoever is in charge of Internal Affairs should

21 have known about?

22 A. Possibly.

23 Q. You said if it's a dispatcher it's not

24 Internal Affairs but it's a different department.

25 What kind of investigation would that be?



1 A. Be an administrative investigation.

2 Q. So AI is how it's referred to sometimes;

3 is that right? Have you heard that?

4 A. I've never heard of it termed that way.

5 Q. All right. I did, but okay.

6 Administrative investigation?

7 A. Yes.

8 Q. Do you know if there was ever an

9 administrative investigation opened up with regard

10 to Rebecca Wamsley or anybody else with regard to

11 that party?

12 A. No, and that was at the advice of at some

13 point District Legal when this was referred to

14 District Legal.

15 Q. When was -- when you say "this," what do

16 you mean "this"?

17 A. This Exhibit 5.

18 Q. Okay. So before July 2011 but subsequent

19 to November 30th, 2009, was an administrative

20 investigation ever opened to any -- as to any of the

21 people that you knew about were in the party -- were

22 at the party?

23 A. No.

24 Q. Why not?

25 A. Because we don't conduct those.



1 Q. Who conducts those?

2 A. Employee-Management Relations.

3 Q. How do they find out about?

4 A. It's reported to them.

5 Q. Okay. Did anybody -- strike that.

6 You didn't report to them. You contacted

7 Metro; correct?

8 A. Yes.

9 Q. Are you aware of whether anybody

10 contacted them to conduct such an investigation?

11 A. I was told that Nebeker contacted EMR.

12 Q. And how were you told about that?

13 A. By him.

14 Q. And when did that conversation happen?


16 Q. Subsequent to November 30th, 2009?

17 A. Yes.

18 Q. Do you know what information EMR had?

19 A. No.

20 Q. Since that is considered an

21 administrative investigation and throughout this

22 morning you have talked about you intermittently

23 were in charge of administration, is that something

24 you would have been in charge of?

25 A. No. Employee -- it -- there's different



1 time frames here. Back then I believe

2 Employee-Management Relations was the only -- the

3 only area that would investigate this.

4 Q. And is that something that the

5 administrative captain would not be involved in?


7 Q. Would they get -- would the

8 administrative captain get any reports that would

9 reflect what was going on with the administrative

10 investigation?

11 A. Only if there was discipline or a finding

12 maybe.

13 Q. Do you -- does the administrative captain

14 know if an investigation is opened as to any

15 employee?

16 A. No. They deal -- back then they would

17 deal with the -- the dispatch supervisor and the

18 sergeant over dispatch.

19 Q. And in 2009, 2010, who was that?

20 A. Armando Quintanilla was the dispatch

21 supervisor, and Brian Nebeker was the dispatch

22 sergeant.

23 Q. So if there was any information about an

24 investigation going as to employees of the School

25 District related to this party, that is something



1 that would have gone to Nebeker?

2 A. Yes.

3 Q. But not to the administrative captain?

4 A. I don't get your question.

5 Q. Would that information also go up the

6 chain to the administrative captain?

7 A. What information?

8 Q. An investigation of employees related to

9 this party.

10 A. I would probably if I was the

11 administrative captain probably know if they were

12 going to do an investigation or not.

13 Q. Are you aware of whether there was ever

14 an investigation of any of the employees that

15 attended this Wamsley party?

16 A. No, there was no investigation.

17 Q. Do you know why not?

18 A. No, I don't.

19 Q. Did you look into why not?

20 A. I had a discussion at one point with

21 District Legal.

22 Q. When was that?

23 A. I don't know.

24 Q. Was it before or after the news story?

25 A. Before.



1 Q. So sometime between November 2009 and

2 before July 2011, you talked to District Legal about

3 whether or not there was any investigation from

4 employees related to this party?

5 A. At some forum, there was -- there was a

6 discussion about it, yes.

7 Q. Did you go to a meeting that District

8 Legal was previously scheduled or did you go to

9 convey this information to them?


11 A. It was brought up at a meeting,

12 previously scheduled meeting.

13 BY MR. COOK:

14 Q. So this wasn't something that you brought

15 to their attention?


17 A. They knew about it. They brought it up.

18 BY MR. COOK:

19 Q. All right. As you sit here today, what

20 is your understanding as to why there was no

21 investigation of any of the employees related to

22 this party?

23 MS. HENDRICKS: And I'm going to object.

24 To the extent that it involves any discussions with

25 legal counsel, that would be attorney-client



1 privilege.

2 BY MR. COOK:

3 Q. And you understand I don't -- I'm not

4 asking you what did legal counsel tell you. I want

5 to know as you sit here today what's your

6 understanding as to why there was no investigation.

7 A. Because it's regarding their answer that

8 they -- that why they told us.

9 Q. I'm sorry?

10 A. It was about the reason they gave for no

11 investigation, that there would be no investigation.

12 Q. Who told you there would be no

13 investigation?

14 A. District Legal.

15 Q. Did you have an understanding as to why

16 there would be no investigation?

17 MS. HENDRICKS: Again, I'm going to

18 object. To the extent if that involves anything

19 with your discussion with District Legal, then it's

20 protected by the attorney-client privilege.

21 BY MR. COOK:

22 Q. So what's your answer? Is your answer,

23 "I don't have information that wasn't otherwise

24 provided by the Legal Department," or do you have

25 some understanding independent?



1 A. No, it was from -- provided by the Legal

2 Department.

3 Q. Exclusively?

4 A. Exclusively.

5 Q. Aside from the Legal Department, if you

6 had an independent decision as to whether you could

7 have conducted an independent investigation of these

8 employees to see if there was any wrongdoing at the

9 party, would you have done so?

10 A. If there was an allegation of wrongdoing,

11 yes.

12 Q. All right. Was there something that

13 precluded you from conducting an investigation of

14 the employees when you first heard that there was an

15 insurance payout by Wamsley with regard to this

16 party?


18 foundation.

19 A. It was still covered under that initial

20 discussion with District Legal.

21 BY MR. COOK:

22 Q. If you had the decision-making ability to

23 determine whether an investigation would have

24 occurred and you did not have to get approval from

25 District Legal, would you have had one done?




2 A. There was no allegation of wrongdoing on

3 anybody -- anybody's part, so if there's no

4 allegation of wrongdoing, what would you do an

5 investigation for?

6 BY MR. COOK:

7 Q. Okay. Does Exhibit 5 suggest to you any

8 allegation that in your mind independent of District

9 Legal that you think there should be an

10 investigation conducted?

11 A. About the minors drinking.

12 Q. So there was an allegation; right?

13 A. At that point.

14 Q. Okay. So at this point, though, you had

15 already been told by District Legal that there

16 wouldn't be an investigation; is that right?

17 A. Yes, but -- yes, yes.

18 Q. Okay. But for being told that by

19 District Legal, if you had the ability to make your

20 own decision when you heard there was minors

21 drinking at a party with dispatchers, would you have

22 directed an investigation?


24 MR. PARK: Join.

25 A. It says on page 2 forward this to



1 District Legal. It was at their request it was

2 forwarded to them for disposition at a later date,

3 so I didn't have that right or that ability.

4 MR. COOK: Can you read back the

5 question.



8 "Question: Okay. But for

9 being told that by District

10 Legal, if you had the

11 ability to make your own

12 decision when you heard

13 there was minors drinking at

14 a party with dispatchers,

15 would you have directed an

16 investigation?")

17 A. Very possible, yes.

18 BY MR. COOK:

19 Q. What other information would you need to

20 make that determination when you say "very

21 possible"?


23 MR. PARK: Join.

24 A. No other information.

25 \\\



1 BY MR. COOK:

2 Q. Are you aware of whether anybody

3 subpoenaed or otherwise requested Rebecca Wamsley's

4 insurance file to see what their basis of making a

5 payment was?

6 A. No.

7 Q. Have you ever reviewed -- strike that.

8 Are you aware that there was an anonymous

9 letter included in the news broadcast in July 2011

10 that had allegations against the department?

11 A. I heard about it after the -- the -- the

12 news broadcast.

13 Q. You weren't aware of it before the news

14 broadcast; correct?

15 A. No.

16 Q. Once you heard about it, did you do

17 anything to see if you could find out what those

18 allegations were?

19 A. No.

20 Q. Why not?

21 A. Because I was not the chief and I was

22 not -- didn't have nothing to do with Internal

23 Affairs.

24 Q. At some time thereafter, you became the

25 acting chief; correct?




2 Q. At that time, did you take any action to

3 see if you could determine what happened at the

4 party?


6 A. That was -- that was discussions with

7 Legal again. I --

8 MS. HENDRICKS: Okay. Then that's --

9 then that's fine. Just leave it at that.

10 BY MR. COOK:

11 Q. Is it true that but for having

12 conversations with Legal you would have conducted an

13 investigation to see what happened at the party but

14 you were told not to by Legal and that's why you

15 didn't?


17 foundation.

18 A. I'm really confused with the question. I

19 don't --

20 BY MR. COOK:

21 Q. Is the sole reason you didn't conduct an

22 investigation to see what happened at the party

23 because you were instructed not to by Legal?

24 MS. HENDRICKS: Same objection.

25 A. Yes.



1 BY MR. COOK:

2 Q. If Legal had not told you, "No, don't do

3 it," then at some point in time when you became

4 chief would you have conducted an investigation to

5 see if you could figure out what happened with these

6 employees and officers at the party?

7 MS. HENDRICKS: And same objection and --

8 MR. COOK: Well, it -- it can't include

9 his conversations with Legal because I said

10 "excluding your conversations with Legal."

11 MS. HENDRICKS: As long as we're clear

12 we're excluding our discussions with Legal.

13 A. If I was the chief and there was no

14 direction from anybody else or any pending lawsuits

15 or anything like that, absolutely.

16 BY MR. COOK:

17 Q. What does a pending civil lawsuit have to

18 do with whether or not you could conduct an

19 investigation of an officer or employee?

20 A. Somehow the two could be tainted at each

21 other or whatever. I don't know.

22 Q. Is it because one could be tainted at

23 each other or you don't know?

24 A. I don't know.

25 Q. Okay. Is there any other reason you're



1 aware of that filing a civil suit would prevent the

2 School District from conducting a thorough

3 investigation?


5 A. No.

6 BY MR. COOK:

7 Q. What investigation, if any, are you aware

8 of occurred at the Clark County School District

9 through any department or any means as to anyone

10 related to this party?


12 foundation.

13 A. What type of investigation?

14 BY MR. COOK:

15 Q. I'm going to start broad and say any, and

16 if you have one, I'll ask you some specifics about

17 that one.

18 A. Not regarding this case, no.

19 Q. So as you sit here today, from November

20 2009 to today, you are not aware of any

21 investigation any CCSD department undertook with

22 regard to any of the events related to this party or

23 Angela's death; is that correct?

24 A. Can we take a break?

25 MS. HENDRICKS: You need to answer the



1 question.

2 BY MR. COOK:

3 Q. You have to answer the question first.

4 A. Oh, I'm sorry.

5 Not any kind of an administrative

6 investigation or Internal Affairs investigation, no.

7 Q. Okay. What other type of investigation

8 are you aware of then?

9 A. I -- I believe somebody made complaints

10 to the Affirmative -- Office of Affirmative Action

11 on some kind of stuff. I don't remember exactly

12 what it was.

13 Q. When you say "somebody," who?

14 A. Some of the dispatchers. I don't know

15 who specifically.

16 Q. A dispatcher made a complaint about what

17 as best as you understand?

18 A. Some type of -- maybe they -- I think

19 they felt harassed or something. I don't know.

20 Q. Okay. So you believe there was an

21 investigation based on whether a dispatcher was

22 harassed; is that correct?

23 A. There was an allegation of that. They

24 didn't go through me, so I don't -- I don't -- I saw

25 them at a later date. I don't know. I got a letter



1 back from them, from Employee -- from the

2 Affirmative Action Office, and it basically -- I

3 don't remember exactly what it said, but I know that

4 it was -- it was closed out as far as I know.

5 Q. Okay. So a dispatcher complained about

6 harassment, and you're aware that that was

7 investigated and closed out in some manner; is --

8 A. Yes.

9 Q. Okay. What about that allegation of

10 harassment leads you to believe it somehow involved

11 the party or this case?

12 A. I didn't say it did. You asked me if

13 there was any other --

14 Q. Well, right. I understand you didn't say

15 it did other than you gave me that information in

16 response to my question, which was, "Was there any

17 investigation by any agency or department of CCSD as

18 to anything that happened related to this party or

19 the death of Angela Peterson?"

20 A. It didn't mention the death and it didn't

21 mention the party.

22 Q. Okay. So what about it made you let me

23 know about that in response to that inquiry?

24 A. Because you asked me a question.

25 Q. Okay. Are you aware of any aspect of



1 this harassment allegation that involves the Wamsley

2 party or Angela's death?

3 A. No.

4 Q. Okay.

5 MS. HENDRICKS: Can we take a break,

6 Marc?

7 MR. COOK: Let me finish this line,

8 please.


10 MR. COOK: I mean, unless you need a

11 break.

12 MS. HENDRICKS: He had asked for one

13 earlier, but if we're about done with this, it's

14 fine.

15 MR. COOK: Yeah. I just got a couple

16 more on this topic --


18 MR. COOK: -- and then we can do it.

19 BY MR. COOK:

20 Q. All right. So as you sit here today,

21 you're not aware of any department at the School

22 District that conducted any investigation as to any

23 dispatcher or police officer as it relates to the

24 Wamsley party or Angela's death; is that correct,

25 sir?



1 A. Correct.

2 Q. Okay. Now, same question except Angela's

3 party -- I'm sorry, Rebecca's party or Angela's

4 death, instead what I want to find out is: Are you

5 aware of whether there was ever any investigation in

6 that same time frame from November 2009 to today,

7 any investigation as to whether there was a cover-up

8 involving the party or Angela's death?


10 A. No.

11 BY MR. COOK:

12 Q. So as far as you know, the School

13 District has not conducted any investigation as to

14 whether there was a cover-up either; correct?

15 A. Correct.

16 Q. Okay.

17 MR. COOK: If you want --

18 MS. HENDRICKS: Let's take a quick break.

19 THE VIDEOGRAPHER: We're going off the

20 record at the approximate time as indicated on the

21 video screen, 1331.

22 (Recess taken.)






1 BY MR. COOK:

2 Q. Sir, you had testified earlier about an

3 understanding about not conducting an investigation

4 with regard to civilian employees. Did you come to

5 the same understanding as to police employees, that

6 there wouldn't be an investigation conducted of

7 them?


9 A. No. We were under the impression that

10 Metro was doing an investigation, and if they came

11 back with any allegations of wrongdoing or any

12 criminal acts, then we would open up a criminal --

13 or an internal investigation.

14 BY MR. COOK:

15 Q. So you did not have a discussion with --

16 strike that.

17 You did not have an understanding that

18 there would be no investigation of police officers

19 involved at the party as you did with civilian

20 employees involved at the party; is that correct?


22 A. No.

23 BY MR. COOK:

24 Q. Was it both of them?

25 A. I don't -- I don't understand your



1 question.

2 Q. I'm just trying to find out. You said

3 that you came to an understanding after talking to

4 Legal that there wouldn't be an investigation of

5 civil employees at the party.

6 A. Uh-huh.

7 Q. I'm trying to find out did you have the

8 same understanding as to police officers as opposed

9 to civilian employees.

10 A. At some point, yes.

11 Q. Okay. Do you recall when that some point

12 was?

13 A. No.

14 Q. Now, you also said that you were under

15 the impression that Metro was conducting an

16 investigation. What was your understanding as to

17 what their investigation involved?

18 A. It's their case. It's their

19 investigation. They're to do whatever they need to

20 do to -- to figure it all out. They do the traffic

21 investigation, the fatal investigation, and then

22 they do anything that's above and beyond that.

23 Q. What information did you have, if any,

24 that Metro was conducting anything other than a DUI

25 investigation of Miranda?



1 A. I didn't have any other information.

2 Q. Did you have any information at any time

3 that anyone was conducting an investigation as to

4 where Miranda got the alcohol?

5 A. No. They never got back to me.

6 Q. Okay. So as you sit here today, you have

7 no information that Metro ever conducted an

8 investigation as to how Miranda got the alcohol; is

9 that correct, sir?


11 foundation.

12 A. I believe now I -- that they did an

13 investigation. They talked to dispatchers and

14 people and officers and -- and other people.

15 BY MR. COOK:

16 Q. And when is it you understood that that

17 occurred?

18 A. When -- at -- during that time when

19 Chavez had the information.

20 Q. What is your understanding as to when --

21 strike that. Let me -- let me back it up and go

22 before this Exhibit 5 notification where your note

23 says that Metro's going to reopen some

24 investigation.

25 A. Uh-huh.



1 Q. From December 1st, 2009 to June 2011, did

2 you have an understanding as to whether Metro

3 conducted any investigation as to where Miranda got

4 the alcohol at the party?


6 Q. So I understand that your testimony

7 earlier this morning was that Metro can't con- -- I

8 mean, that the School District will not conduct a

9 concurrent investigation as to the same info Metro

10 is investigating. Correct?

11 A. Okay. There was no allegation of any

12 wrongdoing when the information was turned over to

13 Metro. Okay? We had no reason to start an internal

14 investigation or do -- or any other investigation.

15 We left it up to them to do their investigation, and

16 then if they came back with something, then I'm sure

17 the department would have done something with that.

18 Q. And why are you sure of that?

19 A. Because that's the way it works.

20 Q. All right.

21 A. And I would hope that that's what would

22 have happened.

23 MR. COOK: Can you read back my question,

24 please.





2 "Question: So I understand

3 that your testimony earlier

4 this morning was that Metro

5 can't con- -- I mean, that

6 the School District will not

7 conduct a concurrent

8 investigation as to the same

9 info Metro is investigating.

10 Correct?")

11 BY MR. COOK:



14 Q. Let me ask again. This is the question

15 I'm asking you right now.

16 A. Okay.

17 Q. Okay. Is it true that the School

18 District Police Department's policy is that if Metro

19 is conducting an investigation on a topic, you're

20 not going to conduct the same investigation as to

21 the same people at the same time?

22 A. Yes.

23 Q. And you cannot make the determination as

24 to what Metro's investigating as to whether you

25 should unless there's some communication between you



1 and Metro to know what they're investigating;

2 correct?


4 A. Correct.

5 BY MR. COOK:

6 Q. Okay. At any point in time from December

7 1st, 2009 to July 30th, 2011, are you aware of

8 anybody at the School District that had information

9 to suggest that Metro was conducting an

10 investigation as to how Miranda got the alcohol at

11 the party?


13 A. From the School District? Repeat that

14 again.

15 BY MR. COOK:

16 Q. Sure. What I'm trying to find out, sir,

17 is: Are you aware of anyone at the School

18 District --

19 A. Okay.

20 Q. -- that had information that Metro was

21 conducting an investigation --

22 A. Uh-huh.

23 Q. -- as to how Miranda got the alcohol at

24 the party?

25 A. No.




2 foundation.

3 THE WITNESS: Sorry. No.

4 BY MR. COOK:

5 Q. All right.

6 MS. HENDRICKS: Do you need to take that?

7 THE WITNESS: Just two seconds. Just let

8 me text something back.


10 identification.)


12 MS. HENDRICKS: Do you have another copy?

13 MR. COOK: I have a bunch. Just I wasn't

14 going to get to it yet. I just --

15 MS. HENDRICKS: Oh, okay.

16 MR. COOK: -- used that downtime to get

17 it marked.

18 BY MR. COOK:

19 Q. We had discussed earlier that there was

20 an anonymous letter that was part of the July 2011

21 newscast on Channel 8, and I just frankly don't

22 recall. Did you say that you had ever seen the

23 anonymous letter before?

24 A. No, I've never seen it.

25 Q. Okay. You've just been handed a copy and



1 it is Exhibit 7, and if you would, please read

2 through it.

3 Is this the first time you've heard the

4 substantive comment -- content of this letter?

5 A. I saw it with legal my first time.

6 Q. Okay. So this is one of the documents

7 you reviewed?

8 A. Well, we didn't go over every- --

9 everything in here, but I -- I saw it for the first

10 time.

11 Q. Are you aware of whether anyone in the

12 School District was aware of any of the information

13 in this letter prior to July 2011?


15 foundation.

16 A. I'm not aware.

17 BY MR. COOK:

18 Q. Okay.


20 identification.)

21 MR. COOK: That has a different exhibit

22 number on the bottom, but it is Exhibit 8.

23 MR. PARK: Thank you.

24 MR. COOK: Did I give you one already?

25 MS. HENDRICKS: No. Either one. Thank



1 you.

2 MR. COOK: Sure.

3 BY MR. COOK:

4 Q. I'll have you flip over past the first

5 page and take a look at this letter as well.

6 Had you read that second letter, which is

7 pages 2 and 3 of Exhibit 8?

8 A. Just now, yes.

9 Q. Is this the first time you've seen it?

10 A. Yes. I saw it, just knew about it from

11 meeting with legal counsel.

12 Q. These -- these letters both in a very

13 general sense talk about drinking involving officers

14 and dispatchers at Rebecca Wamsley's party, the

15 death of Angela Peterson and then a cover-up

16 thereafter; correct?

17 A. Yes.

18 Q. Okay. Anything in either of these

19 letters that would be enough, in your view, for CCSD

20 to conduct an administrative investigation of the

21 civilian employees?


23 A. Well, on this one it was sent to the

24 sheriff.

25 \\\



1 BY MR. COOK:

2 Q. Okay. That's -- that's not the question

3 I'm asking.

4 A. Well --

5 Q. Did you -- do you want me to have the

6 question read back or --

7 A. Sure.

8 Q. Okay.



11 "Question: Okay. Anything

12 in either of these letters

13 that would be enough, in

14 your view, for CCSD to

15 conduct an administrative

16 investigation of the

17 civilian employees?")

18 A. Yes.

19 BY MR. COOK:

20 Q. What basically? I don't need you to go

21 word for word for it, but --

22 A. Well, it says that -- well, there's a --

23 well, the part about somebody specifically seeing,

24 observing Sergeant Morales drinking beer or playing

25 beer pong on that one.



1 Q. Okay. These letters, the allegations of

2 civilian employees of the School District,

3 dispatchers, drinking with, playing beer pong and

4 covering up their involvement to the extent it may

5 have led to the death of Angela Peterson, the

6 information in both of these Exhibits 7 and 8 to

7 those extent, is that enough for somebody at CCSD to

8 open an administrative investigation of those

9 civilian employees?


11 A. Again, it was -- it was -- I guess you

12 could, but Metro was investigating the case as far

13 as I know.

14 BY MR. COOK:

15 Q. Okay. What information do you have, if

16 any, that Metro knew that Tina Zuniga was playing

17 beer pong with Kevin Miranda?

18 A. I don't have any information on that.

19 Q. Okay. What information do you have, if

20 any, that would suggest that Cynthia Ruelas -- that

21 Metro knew Cynthia Ruelas was playing beer pong with

22 Kevin Miranda?

23 A. I don't know what information they have.

24 Q. Okay. So and you don't know if they were

25 then conducting an investigation to see if any of



1 these dispatchers were drinking with the minor;

2 correct?

3 A. That's their investigation.

4 Q. All right. Is there enough information

5 in either of these letters then for you now as you

6 sit here today as chief of police, if you would have

7 got these and you were chief of police on that day,

8 would you have recommended an administrative

9 investigation of the civilian employees mentioned in

10 this letter?

11 A. Right now, yes.

12 Q. Okay. As you sit here today and you

13 had -- we can go back in time.

14 You're chief of police. You get these

15 letters, either of these letters. Is this enough

16 for you to open up an Internal Affairs investigation

17 of the officers?


19 A. If I was the chief then?

20 BY MR. COOK:

21 Q. Correct.

22 A. Possibly. If -- I would check with Metro

23 and figure out where their -- what their status is

24 on their investigation, and then I would provide

25 this information to them.



1 Q. Okay. And as you sit here today and you

2 heard me read the parts from Arroyo's deposition

3 where he said he didn't have contact with Metro, you

4 were that guy, so based on that, I'm going to make

5 the assumption that Arroyo didn't have contact with

6 Metro. So if he didn't have any contact with Metro,

7 he wouldn't know whether Metro was investigating

8 this or not; correct?


10 foundation.

11 MR. PARK: Join.

12 BY MR. COOK:


14 A. I guess he -- he -- yeah.

15 Q. Okay. So if you were chief of police and

16 you got this info, you would have done one or two

17 things or maybe both of them: Contact Metro, see if

18 they know the information --

19 A. Uh-huh.

20 Q. -- and/or open up an Internal Affairs

21 file and start investigating these guys?

22 A. If they weren't going to continue an

23 investigation.

24 Q. Okay. So you would call up, see if they

25 were going to conduct an investigation. If they



1 weren't, you would conduct your own Internal Affairs

2 investigation, and if they were, you would open the

3 file but not start an investigation. You would wait

4 for the outcome for their investigation?

5 A. Yes.


7 THE WITNESS: Sorry. Yes.

8 BY MR. COOK:

9 Q. Okay. Now, Exhibit 8, that front page --

10 A. Uh-huh.

11 Q. -- shows the School District's general

12 counsel sending this letter to Metro, and it's dated

13 February 17th, 2011. Do you see that, sir?

14 A. Yes, sir.

15 Q. Okay. Now, the Concern Report, Exhibit

16 5, from the news agency is July of that same year.

17 You had testified earlier this afternoon that you

18 came to an understanding from Legal not to conduct

19 an investigation of the civilian employees or police

20 officers somewhere before that July 2011 Concern

21 Report came to your date [sic].

22 What I want to find out is: Does this

23 February 17th, 2011 E-mail help refresh your

24 recollection as to maybe the time frame you had that

25 conversation with Legal that led to your



1 understanding to not conduct an investigation?


3 A. No.

4 BY MR. COOK:

5 Q. So you don't know whether it was on or

6 about February 17th, 2011 that you had that

7 discussion with Legal that came to your

8 understanding to not conduct an investigation or if

9 it was sometime before that or after that?

10 A. It would be after -- before that.

11 Q. Okay. And did those instructions ever

12 change?

13 A. Not to me.

14 Q. Do you recall when Chief Arroyo went to

15 the FBI Academy?

16 A. Yes.

17 Q. You became acting chief or deputy chief

18 or whatever you called it then; correct?

19 A. Yes.

20 Q. Do you recall when that was in relation

21 to the Wamsley party?

22 A. I think it was in 2011.

23 Q. Okay.

24 A. Prior -- yeah, prior to the summer of

25 2011 or ended sometime maybe June, May, June.



1 Q. I asked Loren Johnson who he reported to

2 after Arroyo left for the FBI Academy, and he said,

3 "Chief Arroyo went to the FBI Academy. In his

4 absence for that ten weeks, pretty much Chief --

5 Acting Chief, then Deputy Chief Ketsaa, I reported

6 to him for that ten weeks. There would be things

7 that I would discuss with Chief Arroyo on the phone

8 if they were of any magnitude depending on what the

9 cases were that we were involved in. We were in the

10 middle of some arbitrations and some other things,

11 so that was information I needed to feed directly to

12 him.

13 "When Chief Arroyo came back, I was still

14 under Captain Ketsaa, day-to-day operations again,

15 but, you know, the three of us during Chief Arroyo's

16 whole time there, pretty much the three of us

17 would -- would talk and discuss what we had going

18 and what cases looked like, so he was always updated

19 and knew what was happening."

20 Do you agree with Loren Johnson's

21 testimony there?

22 A. Who was updated?

23 Q. It looks like Chief Arroyo and you were

24 updated because he says, ". . . the three of us

25 during Chief Arroyo's whole time there, pretty much



1 the three of us would . . . talk and discuss what we

2 had going and what" the "cases looked like . . . ."

3 A. Well, we didn't discuss anything in a

4 group. I would talk to the chief occasionally

5 through E-mail or phone calls, and he would do the

6 same on his end.

7 Q. All right. So you don't recall the three

8 of you sitting down together and discussing what

9 cases looked like or being updated on cases or

10 anything of that nature?

11 A. He was in Quantico, Virginia.

12 Q. Aside from the time that he was out of

13 state.

14 A. I never resumed any control over Internal

15 Affairs after that date in 2009 except for when the

16 chief was out of town.

17 Q. Notwithstanding the fact that you may not

18 have had control over any Internal Affairs decision

19 after that November 2009 memo, did Johnson still

20 update you on what the Internal Affairs cases looked

21 like on a regular basis?

22 A. What dates, what period of time?

23 Q. After Arroyo got back from the FBI

24 Academy.

25 A. After Arroyo got back from the FBI



1 Academy, did Loren keep me updated on any cases?

2 Q. Correct.

3 A. I don't recall anything specific that

4 we -- that was going on during that period of time

5 that I was updated on. I mean, he may have, but I

6 don't -- there's nothing.

7 Q. Okay. How about before Arroyo left for

8 the FBI Academy?

9 A. No.

10 Q. Have you ever had to discipline Johnson

11 for anything professionally?

12 MS. HENDRICKS: Objection as to

13 relevance.

14 A. If I did, it would be -- I don't recall,

15 but if I did, it would be part of a personnel

16 record.

17 BY MR. COOK:

18 Q. "Have you ever been disciplined while at

19 Clark County School District Police Department?"

20 Johnson asked, "Formally?"

21 I said, "We can start there, sure."

22 He said, "No."

23 I said, "Okay. Informally?"

24 "Sure."

25 "Give me an example."



1 His response: "Off the top of my head,

2 there was a time myself and Chief Ketsaa were having

3 a heated discussion and it was about a particular

4 case, specific case, and it -- it was just a

5 professional banter out in the parking lot and it

6 really wasn't that -- let me back" me up -- "let me

7 back up."

8 And he starts talking about, "It was just

9 a situation about a particular case," a property

10 that you were aware of. I skipped a page here.

11 Does that refresh your recollection as to

12 having any informal discipline of Johnson?

13 A. No. You'd have to tell me exactly what

14 you're talking about.

15 Q. Otherwise you don't have any idea?

16 A. I don't know. You'd have to tell me what


18 Q. Okay. Do you recall him shutting off the

19 power system at the dispatch center?

20 A. Yes.

21 Q. Did he receive any discipline for that?

22 A. There was an Internal Affairs

23 investigation and it was -- it was an Internal

24 Affairs investigation.

25 Q. So that was a formal one, so there was a



1 separate one that was informal as well. Is that

2 correct, or you don't know?

3 A. No, I didn't say that.

4 Q. If Internal Affairs does an

5 investigation, is that a formal discipline or an

6 informal discipline, or does it depend on something?


8 A. I -- I don't know what you're asking.

9 BY MR. COOK:

10 Q. If Internal Affairs was investigating him

11 with regard to the shutting off of the power --

12 A. Uh-huh.

13 Q. -- would you consider that a formal

14 disciplinary action, an informal disciplinary action

15 or something else?

16 A. Yes, but that would be formal. You'd

17 have to tell me the date when that occurred.

18 Q. For what purpose do I have to tell you

19 the date?

20 A. Because that would be whether I was the

21 chief or the acting chief when the chief was no

22 longer here, so that would clarify that for me.

23 Q. All right. And as you sit here today,

24 you don't recall?

25 A. I believe I was the chief and the chief



1 was gone.

2 Q. I thought so too. Okay.

3 Now, we went through all of the

4 conversations you had with anybody with regard to

5 information you gathered about the party and who was

6 there already; correct? That was that one con- --

7 or two conversations with Nebeker and then the phone

8 call to Chavez, and then you conveyed that to --

9 what you did to Arroyo; correct?

10 A. Yes.

11 Q. And you didn't have -- you didn't have

12 any other conversations about that topic before at

13 least July 2011, correct, other than the ones with

14 Legal that we already talked about; correct?

15 A. I don't recall any specific conversations

16 or discussions.

17 Q. Do you recall conveying to Loren Johnson

18 what happened, what your understanding was of what

19 happened at the Wamsley party?

20 A. No.

21 Q. Are you outside of the office friends

22 with Loren Johnson?

23 A. Not -- not really that friendly, no. You

24 know, we've done stuff over the years occasionally.

25 Q. Not part of one of your close-knit



1 friends. Is that fair?

2 A. No.

3 Q. Okay. But you had socialized with him

4 intermittently over the last ten-plus year?

5 A. Sure. I've known him for over 20 years.

6 Q. Do you -- if you're having conversation

7 with him about something that happened in the

8 workplace, do you have it as part of just your

9 friendship banter, or if it's workplace stuff, are

10 you telling him because of his position with

11 Internal Affairs?


13 A. I don't know what specific conversation


15 BY MR. COOK:

16 Q. All right. He says -- I said, "Tuesday,

17 December 1st, 2009, what exactly was it you heard on

18 that day, to the best of your recollection, with

19 regard to the party?"

20 "Just what I said. I came in. I was

21 with Captain Ketsaa, and he said, 'Hey, there was a

22 party over the weekend, actually two parties, and

23 one of the parties was at' -- and again, I don't

24 recall if he said 'Rebecca Wamsley' or just 'a

25 dispatcher,' 'at one of the dispatcher's house.'



1 'And it proceeded after'" the "'party there was a

2 fatal accident involving a juvenile who had been

3 drinking at the party, and we may or may not have

4 officers -- had officers there attending the party.'

5 "That was pretty much the gist of it

6 right then."

7 First, do you remember having that

8 conversation with Loren Johnson?

9 A. Probably, and I -- like I said earlier, I

10 think I said that the chief may not have been there

11 on Monday. He may have not come in till Tuesday. I

12 don't remember what day I told him, whether it was

13 Monday or Tuesday, when he got back to work. So I

14 may have given him the heads-up.

15 Q. You may have given Loren Johnson the

16 heads-up?

17 A. Yeah.

18 Q. What do you mean "given him the

19 heads-up"?

20 A. To let him know that there was an issue

21 because he was the Internal Affairs investigator and

22 the -- and he worked directly for the chief.

23 Q. So you were giving him a heads-up that

24 there was an issue because you anticipated at least

25 the possibility that Arroyo would turn that issue



1 over to him as Internal Affairs agent?


3 A. Yes.

4 BY MR. COOK:

5 Q. Okay. Was there any speculation as to

6 where the drinking happened at this party with

7 regard to the minor that you had shared with Loren

8 Johnson?


10 A. Not that I remember.

11 BY MR. COOK:

12 Q. When I read that first quote, I mentioned

13 two parties is what Johnson said that you said. Do

14 you recall telling him two parties?

15 A. No.

16 Q. And in fact, your notes say dinner/party,

17 so it appeared you thought it was one event;

18 correct?

19 A. Yes.

20 Q. Okay. I asked him, ". . . you said 'two

21 parties.' Where was the other party?"

22 This was his answer: "I don't know. It

23 seems like the day when I first" heard "about it,

24 when -- when Captain -- then Captain Ketsaa told me

25 what I said, it was shortly after Chief Arroyo, I



1 believe, walked in, and I don't remember if -- and

2 this may have been another day. There's a couple

3 days in there, but my understanding was there was

4 two parties. There was a party at a dispatcher's

5 house; then they left and went to another party.

6 "So the speculation was where did the

7 drinking happen? Did it happen at the dispatcher's

8 house or did it happen at this other party?

9 "I believed that" was "up until the news

10 articles were released."

11 As you sit here today, you don't recall

12 any discussion with Loren Johnson or anybody else

13 regarding the number of parties or where the

14 drinking happened; is that correct?


16 Q. Absolutely not correct or --

17 A. Absolutely I don't recall ever talking

18 about anything about two parties.

19 Q. Okay. Is Loren Johnson a chatty, gossipy

20 kind of guy? Is that how you would describe him?


22 A. Chatty and gossipy about what?

23 BY MR. COOK:

24 Q. In general as a character trait for

25 somebody you've known 20 years.



1 A. He talks to people if you're friendly

2 with him.

3 Q. Would you describe him as gossipy?

4 A. Don't really know. I don't -- I don't

5 know any specific cases where he's gossiped. It's

6 possible.

7 Q. Is this the kind of information, this,

8 "Is there two parties or not, and where did he get

9 the alcohol?" is this the kind of conversation he

10 should be having with third parties in his

11 unofficial capacity if he's an Internal Affairs

12 officer who might get a case to look at at some

13 point down the road?


15 foundation.

16 A. Who did he talk to that with?

17 BY MR. COOK:

18 Q. That's not what I'm asking you. I'm

19 trying to find out. If he's going to be talking

20 about, "Was there one party or two? Where did the

21 alcohol happen?" is that the kind of thing -- strike

22 that. Let me back up even more.

23 You told me that you were giving Johnson

24 a heads-up when you told him about the party;

25 correct?



1 A. I said it's possible that I gave him a

2 heads-up, and I'm not sure whether I gave it to him

3 on Monday before the chief came in or whether the

4 chief came in on Tuesday.

5 Q. Okay. But you don't have anything to

6 specifically dispute his recollection that on

7 Tuesday you told him at least some information about

8 the party; correct?

9 A. I never talked to him again after that,

10 after I told him once. I didn't include myself in

11 any of these conversations.

12 Q. Okay. But that's not what I'm asking

13 you. You don't have anything to dispute that you

14 had a conversation with Loren Johnson sometime

15 within a day or two after you heard about the party

16 or maybe even the same day you heard about the party

17 where you conveyed to him some general information

18 that you knew about the party to give him a heads-up

19 in case he was going to be assigned this case in an

20 Internal Affairs investigation; is that right?


22 A. I gave him the same information that I

23 had on that -- on that piece of paper.

24 BY MR. COOK:

25 Q. And you did that to give him a heads-up



1 because you anticipated he may get that case back

2 from Arroyo; correct?

3 A. Corr- -- as far as I can recall, that

4 would be the reason why, yes.

5 Q. He shouldn't be talking about an Internal

6 Affairs case or information about a case that he

7 might get as an Internal Affairs officer with third

8 parties. Is that fair?

9 MS. HENDRICKS: Objection as --

10 BY MR. COOK:

11 Q. Do you understand what I'm asking you?


13 A. But I don't know whether he did that or

14 not.

15 BY MR. COOK:

16 Q. I'm not saying he did it, and you keep

17 getting ahead of me in my questions. Okay? I'm

18 just trying to find out as a general policy --

19 A. It's a confidential position.

20 Q. -- is your Internal Affairs officer

21 supposed to be talking about a case he might get

22 before he gets it?

23 A. Probably not, no. It's confidential.

24 Q. Okay. So if he is saying, "I discussed

25 with Arroyo" or you or anybody above him at Clark



1 County School District Police Department that he's

2 speculating on how -- what happened at this party

3 and how this kid got the alcohol, that should be

4 part of an official investigation, shouldn't it?


6 A. I didn't have -- I wasn't involved in

7 the -- in that conversation, so if he did it with

8 the chief, he would be appropriate to do it with the

9 chief.

10 BY MR. COOK:

11 Q. And that would be with regard to

12 determining whether there would be an investigation

13 or not or even part of his investigation. Is that

14 fair?

15 A. I -- I don't get what you're saying.

16 Q. He's not having conversations with third

17 parties trying to figure out where the kid got the

18 alcohol and how many parties there were that night

19 because he has nothing else to say. He's trying to

20 find out because he's doing some type of an

21 investigation; correct?


23 foundation.

24 A. No. He's discussing it with his boss.

25 \\\



1 BY MR. COOK:

2 Q. For what purpose?

3 A. I don't know what the purpose would be.

4 Q. If he comes in and discusses his thoughts

5 or considerations on a case he might get with you,

6 are you understanding he's doing it in an official

7 capacity or is he just being chatty?


9 foundation.

10 MR. PARK: Join.

11 A. If he's coming to me to -- if he came to

12 me to tell me something, I would assume it would be

13 official capacity.

14 BY MR. COOK:

15 Q. Johnson said it was within days before

16 the Peterson fatality -- those are his words -- that

17 he was reassigned from under Captain Ketsaa to Chief

18 Arroyo. That's the same time frame you remembered;

19 correct?

20 A. Say that again. Before what?

21 Q. He said "days before."

22 A. Okay. Within a week before.

23 Q. So same time frame that you're talking

24 about; right? You said sometime in December. He

25 says "days before." You don't quibble with --



1 A. No, not December. It was November.

2 Q. Strike that. Let me ask it again.

3 You had said it was November 2009 at some

4 point this memo came out.

5 A. Right.

6 Q. And he's saying it was days before, which

7 is still November 2009. Since you're not sure in

8 November and he remembers it being days before, so

9 the tail end of November, I'm just trying to find

10 out do you have any quarrel with his suggestion that

11 it was late November as opposed to early November?

12 A. The paper's here somewhere. We have the

13 date. I -- it was December -- November -- I don't

14 know -- 20-something. It was before this, before

15 the incident.

16 Q. Do you have any dispute with Loren --

17 A. It was the week before, I believe.

18 Q. Okay. And your conversation with

19 Johnson, Arroyo was not present; is that correct?


21 MR. COOK: Strike that. Let me ask it

22 again.

23 BY MR. COOK:

24 Q. Your conversation with Johnson with

25 regard to the information you had about the Wamsley



1 party was you and Johnson alone. Arroyo wasn't

2 there; correct?

3 A. I really don't know 100 percent, but I

4 don't believe Arroyo was there.

5 Q. After this story came out in the news,

6 are you aware of whether Johnson started to

7 undertake an investigation of any nature with regard

8 to anybody related to the allegations in Exhibits 7

9 and 8?

10 A. No.

11 Q. Okay. Did you direct Loren Johnson after

12 the news report to go down to Metro and get a copy

13 of the accident report?

14 A. No.

15 Q. Did Loren Johnson bring the

16 information -- or bring you information about the

17 accident report after the story in July 2011 was in

18 the media?

19 A. Bring it to me specifically?

20 Q. Yes.

21 A. The report?

22 Q. The information in the report, maybe not

23 the documents, but convey to you the information he

24 ascertained from the report.

25 A. I -- I don't know whether he -- what I



1 thought, it was Courtney Purcell that got the

2 report, but I'm not -- that's the understanding I

3 have. So --

4 Q. Have you ever seen the accident report,

5 whether it was from Loren Johnson or Purcell?

6 A. No.

7 Q. Whether it was Johnson or Purcell, did

8 anybody convey to you the information that was in

9 the accident report?

10 A. You have to give me a time line because

11 that was most -- after I was the chief, people told

12 me, only after I was the chief.

13 Q. August 2011.

14 A. Not that I can recall, no.

15 Q. Do you recall having any conversations

16 with Johnson in July, August 2011 after the news

17 report that there would be no direction to start an

18 investigation based on the allegations of the

19 anonymous letter?

20 A. I don't recall any conversations.

21 Q. Is Courtney Courtney Purcell?

22 A. What about him?

23 Q. Is that -- is Courtney Purcell's first

24 name?

25 A. Courtney is his first name.



1 Q. Okay. So do you recall having a meeting

2 with Courtney Purcell, Arroyo and Johnson where he

3 conveyed to you information he learned from the

4 police report after the news report was aired?

5 A. Who? Who?

6 Q. Johnson.

7 A. No.

8 Q. And do you recall having any

9 conversations with Johnson about anything related to

10 the investigation from the date the news story broke

11 till today?

12 A. Yeah. After I was the chief, he wanted

13 to assure me that there was no investigation,

14 that -- that there was things saying that he did an

15 investigation. He wanted to assure me that there

16 wasn't an investigation, that there was -- that he

17 did nothing wrong.

18 Q. When was that conversation or

19 conversations in relation to when you became chief?

20 A. Right after I became chief at some point.

21 Q. Did you call him in to talk about it or

22 did he come in on his own and mention it?

23 A. No, he came in on his own.

24 Q. What else was discussed with regard to

25 Wamsley's party or Angela's death or any allegations



1 of a cover-up -- cover-up during that meeting?

2 A. Nothing that I can recall. I just know

3 that he wanted to assure -- reassure me or assure me

4 that he had no -- there was no wrongdoing, that he

5 didn't do any -- that there was no investigation,

6 that there's all these rumors going around, all

7 these things that are being said and that they're

8 not true so -- so that he could bring me, I guess,

9 up to speed or to clarify so I would feel okay.

10 Q. Did you review -- strike that.

11 I'm pretty sure your testimony this

12 morning was you listened or read some of the news

13 reports at least in part but not all of them. Is

14 that right?

15 A. No. I had -- people would tell me

16 things. I don't -- like I said, I don't go -- make

17 a habit to go on there and look at negative stories.

18 I may have looked at something on the Review-Journal

19 or whatever. I believe there was a picture of

20 Wamsley's house or something in one of those news

21 articles, and that's about all I remember from that.

22 Q. Do you recall seeing any articles where

23 Penny Higgins discussed what she felt happened at

24 the party?

25 A. No.



1 Q. So you didn't look at any of the articles

2 that discussed Penny Higgins, what she believed

3 happened or anything -- any of those type of

4 stories?

5 A. No.

6 Q. All right. So when Johnson comes to you

7 and he's telling you, "Look, there's been some

8 rumors out there and they're not true, and this is

9 what happened," since you hadn't heard any of the

10 news reports, at that point in time when you become

11 chief and shortly thereafter he comes to you, what

12 was your understanding as to what happened on

13 November 28th, 29th, 2009?


15 MR. PARK: Join.

16 A. What date?

17 BY MR. COOK:

18 Q. You're first chief and you said, "Shortly

19 after that" --

20 A. Right.

21 Q. -- "Johnson comes to me and he talks to

22 me about what his involvement was and that he did

23 everything appropriately" or words to that effect;

24 right?

25 A. That there was no Internal Affairs



1 that -- that was done by him, that there was

2 something that came out somewhere that said that he

3 did an -- he started an investigation or did an

4 investigation.

5 Q. And all I want to know is: At the time

6 he talked to you on that day --

7 A. Uh-huh.

8 Q. -- what understanding did you have as to

9 what happened at that party on November 28th and the

10 events that followed it?

11 A. Just -- I don't know. I -- I didn't talk

12 to anybody really much about it except for people

13 who maybe had read the -- read these stories and

14 they would say things.

15 Q. And that's why I'm asking, because I

16 understand that you're saying that and so what I've

17 got from you is in late November and maybe even a

18 couple days into early December you have a couple of

19 conversations that, "These were the dispatchers that

20 were there and there may have been a couple cops

21 there at the party and one of the people at the

22 party left and killed somebody," and then sometime

23 later you have a conversation with Legal that leads

24 you to the understanding that there's not going to

25 be any investigation by you guys as to those events.



1 And then you get the Exhibit 5 Concern Report, which

2 has some more information that leads you to write a

3 note that says police officers were allegedly

4 involved; Metro's opening an investigation. But you

5 didn't really listen to any of the news reports, but

6 you did get info from some other people during that

7 time frame from July to when you become chief.

8 What I'm trying to find out is: While

9 Loren Johnson is talking to you, what did you know

10 or understand or believe happened that night other

11 than what you knew December 1st, 2009?


13 A. Not much difference until the story came

14 out and people said things about officers being

15 there that were drinking with the minors.

16 BY MR. COOK:

17 Q. Okay. So until the story came out, what

18 we talked about was basically your foundation of

19 information: "There were some people there; some

20 may have been cops; these were the names I knew,"

21 and not anything else until the story comes out;

22 correct?


24 A. As far as I know.

25 \\\



1 BY MR. COOK:

2 Q. Okay. Sorry about that.

3 Now, the story comes out and some people

4 are telling you stuff, but you're not reading -- I

5 mean, you're not watching the stories. What

6 information did you gather from July 2011 to May

7 2012 that happened at the story -- I'm sorry, that

8 happened at the party?


10 A. It goes back to the same thing.

11 People -- people would read the comments in the

12 paper and things like that and come back and say,

13 "Hey, they said this. They said that."

14 BY MR. COOK:

15 Q. Okay. I'm trying to find out what you

16 knew then, and what you keep telling me is, "Well,

17 people kept coming up and telling me stuff," but I

18 don't know what that stuff is because I wasn't

19 there, so what I'm asking you is: What's the stuff

20 they were telling you?

21 A. They weren't telling me all kinds of

22 things. All they told me was what I guess they

23 heard on the news -- the news story, that -- which I

24 don't even really remember what it was, that there

25 was -- Morales was there. Maybe Nebeker was there.



1 People were drinking. That's about it.

2 Q. That's -- that's -- that's it. That's

3 all you --

4 A. Yeah, that's it.

5 Q. And you don't remember any more

6 specifically than that?

7 A. No.

8 Q. Okay. You're now chief of the department

9 May 2012. Do you want to find out more?

10 A. Sure.

11 Q. What do you do to find out more?

12 A. Like when this is over, Legal -- there's

13 a possibility that we will do an investigation.

14 Q. Okay. Right now you're chief of police.

15 You've got allegations that a couple of your

16 officers were drinking with minors and allegations

17 that your dispatchers were too. If you're in

18 control of these people, don't you want to know

19 whether the allegations are true or not?


21 A. Yes, and I was directed by Legal that

22 when this is all complete, when this lawsuit is

23 complete and everything's over with, there will be

24 an investigation.

25 \\\



1 BY MR. COOK:

2 Q. So you want to know, but you're not

3 allowed to because you were directed not to; is that

4 correct?


6 foundation.

7 A. I was advised by legal counsel that we're

8 going to wait until after everything's complete

9 before we do any investigations.

10 BY MR. COOK:

11 Q. But you would like to do it now if you

12 had your choice; correct?

13 MS. HENDRICKS: Same objection.

14 MR. PARK: Asked and answered.

15 A. It just needs to be done at an

16 appropriate time.

17 BY MR. COOK:

18 Q. Okay. So you don't care when it's done?


20 foundation.

21 A. I can't control that.

22 BY MR. COOK:

23 Q. I didn't ask if you could control it or

24 not. I said do you care when it's done? Do you

25 have a preference for when it's done?



1 A. As soon as possible.

2 Q. And the reason as soon as possible didn't

3 start May 2012 is because Legal told you you

4 couldn't, and is that the only reason why not or are

5 there other reasons?

6 MS. HENDRICKS: I'm going to object.

7 Again, your discussions with Legal are privileged

8 and we're not going to go into those discussions.

9 He's -- he's told you already what

10 decision has been made.

11 MR. COOK: What I'm asking wasn't that.

12 What I said was -- 'cause he's already said Legal

13 told him not to. What I said was were there reasons

14 besides that that he's not conducting an

15 investigation, so that wouldn't be part of the

16 privilege. I'm not asking him that privileged

17 information.

18 BY MR. COOK:

19 Q. I'm saying: Is there any other reason

20 why you don't get to do the investigation now

21 besides Legal telling you not to?

22 A. I'm following their direction, so no.

23 Q. Okay.

24 MS. HENDRICKS: Are we close to a

25 stopping point? I just need to run to the rest



1 room.

2 MR. COOK: I got four pages of Johnson's

3 depo, but it's sort of a new topic, so your choice.

4 We can stop now or I can kill the four pages and

5 stop, whatever you want. It's five minutes or less.

6 MS. HENDRICKS: It's five minutes. Okay.

7 I can -- I can wait five minutes.

8 MR. COOK: Okay.

9 BY MR. COOK:

10 Q. I was talking to Loren Johnson about

11 shutting off that toggle switch, and he said when --

12 I said, well, "When you flipped" the "switch when

13 you were talking . . . Ketsaa was the chief?"

14 "Well, Ketsaa was standing there. I

15 believe he was the chief or he might have been

16 acting chief at the time."

17 What happened with the switch? And he

18 told me about everything going off.

19 I asked, "Were you disciplined for that?"

20 He said, "I was chastised . . . ."

21 "By who?"

22 "I believe it was Ketsaa."

23 Does that help you with regard to the

24 earlier questions about what your response was when

25 he shut off the power in the CCSD Police Department



1 dispatch area?

2 A. Well, that whole thing is -- I don't even

3 know whether that whole accuracy of the switch and

4 all that is actually that accurate, but it went to

5 an Internal Affairs investigation and it was

6 investigated, and there was -- there was some

7 discipline taken.

8 Q. When you say you don't know if the

9 accuracy of that switch was there, I don't

10 understand what you mean.

11 A. Well, what I'm saying is the switch was

12 shut off. The switch was an unlocked switch on the

13 outside of the building. Okay. For many years it

14 had been unlocked and it didn't have a padlock or

15 anything on it, and nobody knew what that switch

16 did. We were told years ago when we first moved

17 into that building that building -- that switch did

18 nothing.

19 So Loren Johnson flipped the switch and

20 it shut off the power. It didn't just shut off the

21 power to dispatch. It shut off the building.

22 Q. Okay.

23 A. And power was restored within minutes.

24 Q. Did dispatchers -- were they able to stay

25 in touch and in communication with the patrolmen at



1 the time?

2 A. Yes, they were, and that was part of the

3 internal investigation.

4 Q. But they had to go from the handsfree to

5 some handheld set? Is that what happened?

6 A. That may be partially accurate.

7 THE VIDEOGRAPHER: This is the end of

8 disk number three in today's videographed deposition

9 of James R. Ketsaa. The approximate time, as

10 indicated on the video screen, 1436. We're now off

11 the record.

12 (Recess taken.)


14 record. This is the beginning of disk number four

15 in today's videographed deposition of James R.

16 Ketsaa. The approximate time, as indicated on the


18 BY MR. COOK:

19 Q. Have we discussed all the conversations

20 you've had with any third parties that you recall as

21 you sit here today regarding the party, Angela's

22 death or any of those events surrounding it or any

23 investigation of it?

24 A. I haven't talked about it a lot with --

25 with too many people, so I'd have to say that's



1 pretty accurate.

2 Q. We've at least covered them up and

3 through the filing of the lawsuit; correct?

4 A. As far as I know, yeah.

5 Q. Okay. And you're confident that

6 certainly through November 2009, December 2009 we've

7 talked about all of the discussions you had with

8 anybody at the School District or anywhere else

9 about this party or the events that followed;

10 correct?

11 A. As far as I can remember, yes.

12 Q. Okay. Armando Quintanilla, you don't

13 recall meeting with him personally, you, Nebeker and

14 Quintanilla, in your office the days following the

15 party; correct?

16 A. I can't recall that.

17 Q. Okay. You don't recall telling him to go

18 get the information that is on Exhibit 3?

19 A. No.

20 Q. You don't recall telling him to go get

21 you any information; correct?

22 A. Correct.

23 Q. And in fact, your recollection is that

24 Nebeker is the one that prepared that exhibit with

25 the three names on it; correct?



1 A. Well, I don't know who prepared it.

2 Nebeker gave it to me.

3 Q. Okay. Do you recall talking to Nebeker

4 about the party and what followed the party after

5 the news story broke?

6 A. The only time that I remember

7 specifically was that when I was -- after I was

8 chief, again he came in and told me that he wasn't

9 at the party, that -- and I think that was the only

10 part, that he wasn't at the party, because it was

11 said that he may have been at the party. He wanted

12 to assure me that he was not at the party.

13 Q. So basically he did similar to what

14 Johnson did, which was shortly afterwards came to

15 you and said, "Hey, I did everything I was supposed

16 to do" kind of thing?

17 A. Pretty much, yeah.

18 Q. Now, if Quintanilla says that, "On

19 December 2nd I met with him, Nebeker, and Captain

20 Ketsaa," and that's when he handed over the

21 document, that's not your recollection; correct?

22 A. I don't -- no, I don't remember it that

23 way. I don't -- I don't ever remember, you know,

24 getting that handed to me or being in a meeting

25 where that was handed to me.



1 Q. And how about time frame? I thought you

2 had said that Nebeker came to you and told you what

3 happened, then came back later on the same day with

4 that information and then you called Chavez at Metro

5 that very same day, which was that Monday, the 30th.

6 Correct?

7 A. Yes. It was within ten minutes maybe.

8 Q. Okay. So if Quintanilla says a couple

9 days later Nebeker tells him -- he called -- Nebeker

10 calls him into Ketsaa's office, "Sergeant Nebeker

11 called me into Ketsaa's office to meet with him and

12 Ketsaa, so I go in. He goes, 'Okay, tell him.' So

13 I told him everything that I told Nebeker, and --"

14 then I interrupted him, "Which was what Andrea had

15 told you?"

16 Yes, what Andrea had told you.

17 "And what did . . . Ketsaa or Nebeker

18 tell you to do?"

19 "And then Ketsaa asked me to get three of

20 the dispatchers' DOB, social, addresses for Metro."

21 "Which three?"

22 "I believe it was Zuniga, Wamsley and I

23 think Adriana."

24 You don't recall any of that happening;

25 correct?



1 A. No. I recall having that -- that on the

2 morning it was first reported, on that Monday

3 morning, that Nebeker brought me that piece of

4 paper.

5 Q. Without ever talking to Quintanilla?

6 A. He was not in any of those meetings, no.

7 Q. All right. Did you go to the

8 superintendent when Arroyo was still chief and tell

9 the superintendent that the problems going on were

10 because of Arroyo or Arroyo was the reason all this

11 stuff is going on?


13 foundation.

14 A. No, not -- it didn't happen like that.

15 BY MR. COOK:

16 Q. How did it happen?

17 THE WITNESS: That's a personnel matter.

18 I don't know. May I? You tell me.

19 MS. HENDRICKS: Can we take a break? Let

20 me -- I don't -- let me take a quick break, and I

21 think we can probably shortcut this for you.

22 THE VIDEOGRAPHER: Going off the record

23 at the approximate time as indicated on the video

24 screen, 1454.

25 (Recess taken.)



1 THE VIDEOGRAPHER: Back on the record at

2 the approximate time as indicated on the video

3 screen, 1457.

4 BY MR. COOK:

5 Q. You had a pending question when you took

6 the break.

7 A. Can you ask it again?

8 Q. Yeah. I had asked you if you went to the

9 superintendent and advised that the problem with the

10 stuff that was going on in the department was

11 because of Arroyo, and you said, "It didn't happen

12 like that," so I said, "How did it happen?"

13 A. Okay. I was directed by District Legal

14 to come forward with any information that I had,

15 which I did, and I met with Legal and the

16 superintendent.

17 Q. Regarding Arroyo?

18 A. Regarding Arroyo.

19 Q. And what did you convey regarding Arroyo?

20 MS. HENDRICKS: And I'm going to object.

21 Because counsel was present, it was done -- it's

22 attorney-client privilege.

23 BY MR. COOK:

24 Q. Is it your understanding that your

25 conversations with the superintendent would be



1 protected by an attorney-client privilege, sir?

2 A. I was -- I was -- Legal was present at

3 that time, so I was told that anything -- that I

4 couldn't discuss any of that at the time.

5 Q. Prior to going to that meeting, what

6 concerns did you have about Chief Arroyo that would

7 lead you to want to discuss him with the

8 superintendent?


10 foundation.

11 BY MR. COOK:


13 A. Arroyo told me he was being investigated,

14 there was some sort of an official investigation and

15 he was the subject.

16 Q. And if he's the subject of an

17 investigation, isn't he supposed to fill out one of

18 these Concern Reports, the 303?

19 A. No.

20 Q. What's he supposed to do?

21 A. He answers to the superintendent. It's a

22 different process.

23 Q. What's the process supposed to be if the

24 chief of police is being investigated?

25 A. I -- that's their process. It's not our



1 process. By statute the superintendent is the

2 supervisor of the chief of School Police.

3 Q. Right, but if -- you're the chief of

4 police now. If you find out you're the subject of

5 an investigation, what are you supposed to do?

6 A. I'm the subject of an investigation?

7 Q. Yeah.

8 A. I'm not supposed to do anything except

9 comply with what they direct me to do.

10 Q. Okay. So when Arroyo told you he was the

11 subject of an investigation, what was it you

12 expected that he should have done?


14 foundation.

15 A. Comply with his investigation.

16 BY MR. COOK:

17 Q. And do you have any information that he

18 didn't?

19 A. Nothing that -- that -- it was all

20 discussed with Legal.

21 Q. I'm not asking you what you discussed

22 with Legal. I'm asking you what you knew before you

23 had those discussions with Legal.

24 MS. HENDRICKS: And I'm -- I'm going to

25 object that it's attorney-client privilege. His



1 discussions with Legal and what -- and what happened

2 there and what led to -- 'cause, Marc, what he said

3 is that Legal called him in to have the discussion.

4 He didn't go to -- go to Legal. Legal and the

5 superintendent called him in, so therefore --

6 MR. COOK: That may have been what he

7 told you, but that's not on the record yet.

8 MS. HENDRICKS: I believe that is on the

9 record.

10 BY MR. COOK:

11 Q. When did this happen?

12 A. Around September of '11.

13 Q. September 2011?

14 A. Yes, I believe.

15 Q. In August through September 2011, did you

16 have any information that Arroyo was the subject of

17 an investigation from any agency?

18 A. Yes.

19 Q. And is that information you attained

20 through Arroyo himself?

21 A. No.

22 Q. Who did you attain that information from?

23 A. From the FBI.

24 Q. And what was that information you

25 attained?



1 MS. HENDRICKS: And again, I'm going to

2 object. This is a confi- -- this is not relevant to

3 these proceedings. Arroyo's investigation are his

4 private personnel matters, and I'm not going to

5 get -- let him go into information on any kind of

6 investigation that he was a part of.

7 MR. COOK: Relevance is not an objection

8 where you can instruct somebody not to answer.

9 MS. HENDRICKS: But if you're --

10 MR. COOK: What is the basis that you're

11 instructing him not to answer?

12 MS. HENDRICKS: If we're going into a

13 personnel matter and that's what you're asking

14 about, is a confidential personnel matter, that is

15 something that you -- that I can object to and

16 instruct him not to answer. We can suspend the

17 deposition and get clarification from the court on

18 if you can go into confidential personnel matters

19 regarding the former chief of police, but I don't

20 think that's relevant to this investigation -- or

21 relevant to these proceedings, and we're talking

22 about something that happened two years after the

23 accident involving your clients' daughter.

24 BY MR. COOK:

25 Q. Okay. I'm not asking you about any of



1 your conversations with the School District or any

2 of their internal human resources or personnel

3 issues. You had a conversation with the FBI, and

4 let me just be clear.

5 The FBI isn't running personnel for the

6 School District, are they? Do they do the hiring

7 and firing for the School District?

8 A. No.

9 Q. Do they assign schedules for the School

10 District?

11 A. No.

12 Q. Okay. What did the FBI tell you about

13 Arroyo?

14 A. They didn't give me the specifics of the

15 investi- -- what they were investigating him for. I

16 asked them if I was a subject of the investigation,

17 and they told me no.

18 Q. Why was the FBI talking to you? Do you

19 have an idea?

20 MR. PARK: Objection, foundation.

21 A. Yeah.


23 A. Yeah. It was a -- it was about a

24 use-of-force case that somebody went to the FBI on.

25 \\\



1 BY MR. COOK:

2 Q. Okay. And what about that use-of-force

3 case made you think they might be investigating you?

4 A. I didn't -- I knew they weren't

5 investigating me. They told me they weren't

6 investigating me. They were -- they were -- they

7 were talking to me as a witness.

8 Q. All right. But you said you asked them

9 if they were investigating you; correct?

10 A. Of course.

11 Q. Okay. Why did you ask them if they were

12 investigating you?

13 A. Because I want to know whether I'm the

14 subject of an FBI investigation.

15 Q. What did they tell you at the outset of

16 your meeting with them?

17 A. They said, "You're not the subject of an

18 investigation. We just want to ask you some

19 questions."

20 Q. What about their conversation led you to

21 believe Arroyo was the subject of their

22 investigation?


24 foundation.

25 A. 'Cause all the questions were about



1 Arroyo.

2 BY MR. COOK:

3 Q. What were the questions?

4 A. I don't remember them all.

5 Q. Do you remember any of them?

6 A. Yeah. They asked me if he is friends

7 with a guy named Bob Mayer, personal friends with a

8 guy named Bob Mayer.

9 Q. Okay. What else did they ask you about

10 Arroyo?

11 A. Did he do an investigation or -- or fail

12 to do an invest- -- a use-of-force -- an IA

13 investigation regarding a use-of-force complaint.

14 Q. And what did you respond?

15 A. I don't recall exactly what I responded.

16 Q. Generally how did you respond?

17 A. That we didn't do an investigation that

18 I'm aware of.

19 Q. Were you in Internal Affairs then?

20 A. No.

21 Q. So how would you have known if Internal

22 Affairs did an investigation?

23 A. I wouldn't know. I didn't know for sure.

24 Q. So did you tell them, "I don't know. As

25 of November 2009, Arroyo is exclusively in charge



1 of" --

2 A. Absolutely, and --

3 Q. -- "Internal Affairs and I'm out of it"?

4 A. Absolutely, and I provided them with that

5 special order.

6 Q. Okay. What else did you talk to them

7 about?

8 A. I don't remember everything.

9 MS. HENDRICKS: And again, Marc --

10 A. I -- you know, we're not going to -- I

11 don't know everything they asked me.

12 BY MR. COOK:

13 Q. I'm not asking you everything they asked

14 you. I'm kind of categorically going down the list

15 here.

16 A. I don't even remember everything they

17 asked me about Arroyo.

18 Q. Have you been interviewed by the FBI a

19 lot?

20 A. No.

21 Q. Have you ever been interviewed by the FBI

22 other than this one occasion?

23 A. No.

24 Q. Okay. It would seem to me if I was

25 concerned at the outset that they might be



1 investigating me and this is my once-in-a-lifetime

2 interview with the FBI I'd remember what they told

3 me and what we talked about. Are you telling me

4 that the extent of your recollection of your meeting

5 with the FBI is what you have told me on the record

6 here today?

7 MS. HENDRICKS: I'm going to object to

8 the form, foundation. You're harassing the witness,

9 and this is not relevant to these proceedings.

10 You don't have to answer.

11 THE WITNESS: That's fine on the record.

12 I answered it.

13 MR. COOK: What is the basis for

14 instructing him not to answer?

15 MS. HENDRICKS: Because you're harassing

16 the witness. It has nothing to do --

17 MR. COOK: He's lying --

18 MS. HENDRICKS: -- with this case.

19 MR. COOK: -- of course.

20 MS. HENDRICKS: He is not lying. Marc,

21 you are -- you are out of bounds here. You're

22 harassing the witness.

23 MR. COOK: I'm out of bounds?

24 MS. HENDRICKS: You just accused him of

25 lying.



1 MR. COOK: You're instructing him not to

2 answer based --

3 MS. HENDRICKS: You just accused --

4 MR. COOK: -- on relevance, and I'm out

5 of bounds?

6 MS. HENDRICKS: Want to call the

7 magistrate? Let's call the magistrate. Let's ask

8 her.

9 MR. COOK: What are we going to call her

10 for?

11 MS. HENDRICKS: I --

12 MR. COOK: I got one question, which is,

13 "Did you tell me everything?" and you're instructing

14 him not to answer. Is that -- is that where we're

15 at?

16 MS. HENDRICKS: I'm instructing not to

17 answer because you accused my witness of lying.

18 MR. COOK: No, you instructed him --

19 MS. HENDRICKS: He's asked and

20 answered --

21 MR. COOK: -- not to answer before I

22 accused him of lying.

23 MS. HENDRICKS: We can -- we can have him

24 read back the record if you want. He's --

25 MR. COOK: Fine.



1 MS. HENDRICKS: -- answered it. We've

2 gone -- this is not anything that's relevant to this

3 case. You're going into matters that I have no idea

4 why, if you want to harass the department or

5 embarrass the department. It's not relevant to

6 these proceedings and --

7 MR. COOK: I don't have to do that.

8 They're doing that on their own.

9 I'm asking him a question. He's saying

10 that he had nothing to do with Internal Affairs, and

11 now he gets an FBI interview with regard to an

12 Internal Affairs matter. I'm allowed to explore his

13 knowledge. My question that you --

14 MS. HENDRICKS: And I let you.

15 MR. COOK: -- asked him not to answer is,

16 "Have you told me everything" --

17 MS. HENDRICKS: Well, that was after --

18 MR. COOK: -- "you recall" --

19 MS. HENDRICKS: -- you did a very long

20 narrative and he -- if you want to simply ask him,

21 "Have you told me everything?" that's fine, but we

22 don't need these long speaking things and you

23 summarizing things and regurgitating things and

24 adding information that's not in the record.

25 MR. COOK: Well, the problem is when I



1 ask him a single question he says, "I don't

2 understand it," and I've got to give him some

3 context, and then when I give him the context, I get

4 the objection as to form and then I have to give him

5 the context again. So, you know, it is what it is.

6 BY MR. COOK:

7 Q. Do you understand the question from about

8 ten minutes ago or should I repeat it?

9 A. Not really.

10 Q. All right. Have you told me on the

11 record everything you remember about your meeting

12 with the FBI in 2011?

13 A. No.

14 Q. What else do you know from that meeting?

15 A. I -- you know, I don't -- I don't -- I

16 don't know. I mean, it's -- you're -- I don't

17 remember everything I told them.

18 They asked me if I was in charge of

19 Internal Affairs because they were told that I was.

20 I said, no, I wasn't.

21 Q. Did they tell you --

22 A. And I provided them with the piece of --

23 the department special order, the same one I keep

24 referring to, to say "no."

25 Q. Did you have that with you at the time of



1 the meeting?

2 A. No. I provided it to them later.

3 Q. Okay. So did you have two meetings with

4 them or one?

5 A. I had a meeting with them, an official

6 meeting, and then I met them just to hand them that

7 piece of paper.

8 Q. Did you find out who told them you were

9 in charge of Internal Affairs?

10 A. No.

11 Q. So when they said, "We heard you were

12 in -- in charge of Internal Affairs," you didn't go,

13 "Who told you that?"

14 A. No.

15 Q. What else was your discussion with them

16 during that meeting?

17 MS. HENDRICKS: Again, Marc, what is the

18 relevance here? This has nothing to do with your

19 case.

20 MR. COOK: Of course it does.

21 MS. HENDRICKS: We're talking about an

22 incident two years after.

23 MR. COOK: You spent a day talking to

24 Thomas about his credibility and spent half of your

25 summary judgment motion on his credibility issues.



1 I've got a defendant, Arroyo, and the current chief

2 of police pointing fingers at each other,

3 challenging each other's credibility. I'm allowed

4 to explore what the, one, investigation of Arroyo is

5 and, two, what his knowledge of Internal Affairs and

6 how that works is.

7 MR. PARK: But, I mean, it also seems a

8 little bit like it's a little bit of a double

9 standard because we've had people -- other people in

10 this case deposed who have allegedly talked to

11 federal officials or the FBI, and I think every

12 single time they've said, "Listen, I talked to the

13 FBI. I don't want to discuss it," I think you said,

14 "That's fine," with everybody else except for

15 Ketsaa.

16 MR. COOK: Well, I don't recall

17 specifically with the others, but that doesn't

18 preclude me from doing it with this one.

19 MR. PARK: All right.

20 MS. HENDRICKS: Well, I think we're

21 walking a thin line here, and if you -- if I feel

22 like you are harassing the witness, I'm going to --

23 we'll stop it and we can get the magistrate on the

24 phone.

25 There -- there is relevancy here. You



1 don't get to just go to anything about the School

2 District -- the School District Police Department

3 because you don't like them. That's -- you don't

4 get a free-for-all in deposing the chief.

5 MR. COOK: I agree.

6 MS. HENDRICKS: So if there's some

7 relevancy here, I'll let him answer relevant

8 questions.

9 MR. COOK: I think I laid it out, and

10 let's get my last question read back.

11 MS. HENDRICKS: Let's see where we go.



14 "Question: What else was

15 your discussion with them

16 during that meeting?")

17 THE WITNESS: Am I answering or --

18 MS. HENDRICKS: If you --

19 THE WITNESS: I would like to get an

20 answer from the magistrate to be honest with you. I

21 don't know. I mean, that's just my opinion. I

22 don't know.

23 You can look at me like that. That's

24 fine.

25 \\\



1 BY MR. COOK:

2 Q. I'm waiting for an answer.

3 A. Okay. I'm not going to tell you

4 everything that I -- that the FBI and I spoke about

5 right now unless somebody tells me I have to.

6 MS. HENDRICKS: All right. Let's go

7 ahead and suspend the deposition then and get the

8 magistrate on the phone.

9 MR. COOK: Okay. Let's not suspend the

10 depo. Let's get the rest of it done so we've got

11 minimal left. I mean, if you want to cancel it now

12 and we'll pick up the rest afterwards --

13 MS. HENDRICKS: No, that's fine. If

14 you're ready to move on to something else and we can

15 go back to the magistrate on this issue, that's

16 fine.

17 BY MR. COOK:

18 Q. Did you ever find out you were accused of

19 being at this party?

20 A. Just with counsel.

21 Q. So up until you met with counsel, you had

22 no idea anybody had alleged you were at the party?

23 A. No.

24 Q. As you sit here today, do you have any

25 recollection of being at that party?



1 A. No, I was not at that party.

2 Q. And in the time from those news articles

3 forward, so July 2011 forward, when you had people

4 coming and telling you all these things the news

5 articles were saying, nobody mentioned, "Oh, by the

6 way, they said you were at the party"?

7 A. Not that I can remember, no.

8 Q. Well, and fair to say that's something

9 that would stick out in your memory?

10 A. Sure.


12 identification.)

13 MR. COOK: It's not Bates stamped, but --

14 MR. PARK: That's all right.

15 MR. COOK: -- it should be the same one.

16 MS. HENDRICKS: Do you have another copy?

17 MR. COOK: Yeah. I'll try and get a

18 clean one here. It's not Bates stamped. It should

19 be the same one.

20 MR. PARK: Thanks.

21 MR. SILVESTRI: Do you have --

22 MR. PARK: Marc, do you have one with all

23 the comments? This is a lot thicker packet than the

24 one you gave Jim.

25 MR. COOK: The one I gave him didn't have



1 all the comments on it?

2 MR. PARK: It doesn't. That's fine,

3 whichever one you gave me.

4 MR. COOK: If you want, I've got a

5 thicker one with it, but it's just got some

6 underlining in it. I don't care if you have it.

7 MR. SILVESTRI: Do you mind if I have

8 that?

9 MR. COOK: No.

10 MR. SILVESTRI: Either that or just tell

11 me if it's -- thank you, very much, Mrs. Peterson.

12 BY MR. COOK:

13 Q. Have you read this?

14 A. Just now?

15 Q. Right.

16 A. Yeah, I scanned over it.

17 Q. Okay. Any information in there you

18 weren't previously aware of?

19 A. I just looked at it just now.

20 Q. Okay. Start in the middle of the second

21 page. There's a paragraph that says, "But she had

22 no idea the party for police employees would

23 coincide with a birthday party for Wamsley's

24 17-year-old daughter until teenagers started showing

25 up, helping themselves to booze set up on tables



1 inside Wamsley's garage."

2 First, had you heard before today that

3 there was also a birthday party at that same

4 occasion for Wamsley's 17-year-old daughter?

5 A. When the news story broke at some point,

6 that was something. I don't know whether it was

7 this one or a previous one. I don't know.

8 Q. But at some point before today, you had

9 heard that?

10 A. No, I never -- I never read this. I

11 never saw this until just now.

12 Q. I understand that.

13 A. Right.

14 Q. Did you understand at some point between

15 August 2011 and today that Wamsley's 17-year-old

16 daughter had a birthday party at this same night at

17 the same place?

18 A. After -- after it came out here, yes.

19 Q. Okay. But you don't remember when after

20 it came out here?

21 A. No.

22 Q. Higgins says in that following paragraph,

23 "'They started drinking. They were getting into

24 hard alcohol. We had several teenagers ask us if we

25 could move so they could get into a beer cooler



1 behind' . . . ."

2 Do you recall hearing that information in

3 form or substance before today?

4 A. Never.

5 Q. The next paragraph, "Higgins" said "it

6 would be impossible for any of her police department

7 co-workers to have missed seeing the teenagers

8 drinking."

9 Did you hear that in form or substance

10 before today?

11 A. No.

12 Q. The next paragraph or two paragraphs

13 down, "Police dispatcher Tina Zuniga, whose Facebook

14 photo showed her at a bar drinking a margarita, was

15 at a table, Higgins says, drinking with her

16 16-year-old daughter Marissa and Marissa's

17 boyfriend, Kevin Miranda. Higgins also saw Miranda

18 playing beer pong with adults. Higgins and her date

19 decided to leave."

20 Have you ever heard that in form or

21 substance before today?

22 A. No.

23 Q. Next page, "When the news broke the next

24 day about a drunken Miranda killing Angela Peterson,

25 the coverup began, Higgins says. Back at work, she



1 was called into the office of Dispatch Supervisor

2 Mondo Quintanella."

3 Had you heard that before today?

4 A. No.

5 Q. "'He goes'" -- I'm starting on the next

6 paragraph where that presumably the "he" is

7 Quintanilla. "'He goes, "You didn't see any of the

8 kids drinking, did you?" and I said, "Yeah, I did."

9 And he said, "No, you didn't," and I said, "Yeah, I

10 did." And he said, "No you didn't,"' she said. 'He

11 said we need to put this in a good light. He said,

12 "You left early so you didn't see much and you won't

13 have anything to say." He said, "We need to protect

14 Rebecca. We don't want anything to happen to her."

15 And I said, "If I get called into IA, I'm not

16 lying."'"

17 Had you heard that information in form or

18 substance before today?

19 A. No.

20 Q. Next paragraph, "Next, Higgins says she

21 was visited by her immediate supervisor, Sgt. Brian

22 Nebeker.

23 "'He said, "You didn't see anything, did

24 you?" And I said, "Yeah." He said, "You saw kids

25 drinking?" I said, "Yeah." He said, "No, you



1 didn't see anything, did you?" and I was like,

2 "Yeah." And he got closer and . . . said, "You

3 didn't see anything, did you?"' she said."

4 Had you heard that in form or substance

5 before today?

6 A. No.

7 Q. If any of those allegations are true, do

8 they concern you about the conduct of members of

9 your department?

10 A. Yes.

11 Q. If any of those allegations are true, do

12 you believe you could take action against any of

13 those members from your department, including

14 termination?

15 A. Yes.

16 Q. But it's your position you have to wait

17 to look at that until after this case is over; is

18 that correct, sir?

19 A. At this time, that's the directions I'm

20 following, yes.

21 Q. Okay.


23 identification.)

24 MR. SILVESTRI: Thank you.

25 MR. PARK: You bet.



1 BY MR. COOK:

2 Q. Sir, Exhibit 10 is one of the Highlights

3 of the Week with the picture of Arroyo on the front

4 of it, and I've seen a bunch of these in this case.

5 Is this something, these Highlights of the Week,

6 that are issued on a somewhat regular basis?

7 A. They were for a period of time while he

8 was chief.

9 Q. Okay. Do you continue that?

10 A. No.

11 Q. This one is dated July 30th, 2008, and it

12 says, "As I commence to prepare this week's update,

13 I can't help thinking of the numerous rumors and

14 innuendos currently swirling throughout our

15 organization. The majority of these cases, stories

16 fueled by recent events and proceedings, are either

17 misinterpreted or totally forged out of someone's

18 necessity for professional or personal survival."

19 Do you have any idea what was going on

20 July 30th, 2008 in your department that he's

21 referring to here?

22 A. Not right this second, not right this

23 minute. If I look at this and think about it for a

24 minute.

25 Q. What was your position in July 30th, 2008



1 with the department?

2 A. Captain.

3 Q. But administration or operation; do you

4 recall?

5 A. Might have been operations then.

6 Q. You've now reviewed it?

7 A. Yeah, in 2008.

8 Q. Do you recall now? Did that help you as

9 to what that issue was?

10 A. No. The only thing I can think of is

11 maybe it had something to do with the Category I --

12 something to do with Category I versus Category II

13 status. I don't -- I really don't remember.


15 identification.)

16 BY MR. COOK:

17 Q. This second one, Exhibit 11, is dated

18 August 4th, 2011, right around the time that the --

19 right after that first series of news reports came

20 out about Angela's death and the allegations of a

21 cover-up with that flier and anonymous letter.

22 Are you aware of anything else going on

23 at that time that would lead him to say in that

24 third paragraph, "Because I have chosen not to give

25 credence to the many fairytales currently streaming



1 throughout our organization, justifications will not

2 be heard from my office"?

3 MS. HENDRICKS: Object as to form and

4 foundation.

5 A. Well, I'm sure he was referring to the

6 couple things that were going on at that time,

7 this -- this -- this story and the -- maybe the

8 other -- the other investigation.

9 BY MR. COOK:

10 Q. What other investigation, the

11 use-of-force one?

12 A. Yeah.

13 Q. All right. If you take a look at

14 Exhibits 10 and 11 next to each other, you can see

15 he took that "Because I have chosen not to give

16 credence to the many fairytales currently streaming

17 through our organization" paragraph from the 2008

18 one and essentially put it into the 2011 one. Do

19 you see that?

20 A. Yes.

21 Q. Now, there's a couple differences. That

22 second sentence in the 2011 one says, "One thing I

23 will say, you can all continue to count on the same

24 undivided and unconditional support my executive

25 staff and I have dedicated to offer" -- I skipped a



1 line there. Sorry. Let me try that again.

2 "One thing I will say, you can all

3 continue to count on the same undivided and

4 unconditional support my executive staff and I have

5 dedicated to offer since swearing to uphold the

6 Constitution of the State of Nevada when we each

7 first became members of this organization."

8 Does he pontificate like this a lot?


10 A. I would say so.

11 BY MR. COOK:

12 Q. This last on the bottom, "QUOTE OF THE

13 WEEK, 'A house divided against itself cannot

14 stand,'" in the context of what was going on at --

15 in August 4th, 2011 in the department, what does

16 that quote mean to you?


18 A. I -- I didn't write it. I don't know

19 what was going on in his mind. I can't give you an

20 accurate answer as to what he meant by that.

21 BY MR. COOK:

22 Q. When you read it, what did you understand

23 it to mean?

24 A. I'll have to be honest with you. I don't

25 even think I read too many of these. They were



1 pretty silly.

2 Q. Did you have a problem with officers

3 posting inappropriate or employees posting

4 inappropriate information on Facebook and public

5 media?

6 A. Specific incident or specific something?


8 identification.)

9 BY MR. COOK:

10 Q. Specific anything that led to this

11 Exhibit 12.

12 A. I didn't have anything, any specific

13 concerns on anything that was on Facebook. I don't

14 have Facebook. I don't look at Facebook, so I don't

15 know anything about what's on Facebook.

16 Q. But as captain in the department --

17 A. Uh-huh.

18 Q. -- were you aware of any officers having

19 any issues with regard to what they were posting on

20 social media?

21 A. Not specifically, no. I just -- at some

22 point we followed the IACP Best Practices Policy and

23 I believe Metro's policy, and we put our first

24 social media -- we can't call it a policy, but

25 procedure in our department manual. It might have



1 been around that time something happened, triggered

2 it. I don't know.


4 identification.)

5 BY MR. COOK:

6 Q. Do you recall receiving this memo from

7 Detective Thomas Rainey on or around October 31st,

8 2011?

9 A. I can't say that I do because it's not in

10 the appropriate format, so I don't know whether I

11 ever actually received this or not. I'd have to see

12 the one, if -- if there's actually one on file,

13 where it's -- where it was signed, where I signed

14 it, acknowledged it or whatever and put the date and

15 my name and P number and put it into the electronic

16 system.

17 Q. So by reading it, does that assist you as

18 to whether you received the memo or not? You at

19 least knew the information contained in the memo?

20 A. I haven't signed this. There's no

21 signatures on here, so I don't even know whether I

22 got this. I'd have to go -- I'd have to research

23 that.

24 Q. I understand that. What I'm asking you

25 is: The information conveyed in this memo --



1 A. Uh-huh.

2 Q. -- does it seem familiar, something you

3 had learned on or about October 2011?

4 A. I wouldn't have learned it unless I had

5 seen this.

6 Q. Okay. Who's Detective Thomas Rainey?

7 A. He's a detective that works for the

8 department.

9 Q. Do you deal with him on a regular basis?

10 A. I do now.

11 Q. Did you in 2011?

12 A. No.

13 Q. Did you ever have a discussion with him

14 on or about 2011 regarding any of the topics related

15 to the allegations of the School District and Angela

16 Peterson's death?

17 A. It's possible, but I don't recall

18 anything specific, no.

19 Q. And nothing about this memo sticks out in

20 your mind to be able to tell whether you received it

21 or not?

22 A. If I -- if I received it, I'd have to see

23 the finished -- finished product. I can't -- this

24 is not -- anybody could write one of these up and

25 then not do anything with it.



1 Q. All right. I understand --

2 A. Right.

3 Q. -- that that's your answer. What I'm

4 asking you is: In reading this --

5 A. Okay.

6 Q. -- does this look like information you

7 knew before, before today?

8 A. I don't remember. I don't remember

9 whether if I knew about this before or whether this

10 was written to me and I didn't get it or I did get

11 it. Like I said, I may have gotten it, but prior to

12 writing it, I don't know whether he asked me to --

13 to do it and I said, "Just document it," or whether

14 he just did it on his own. I don't recall.

15 Q. At the time you were acting chief. This

16 fourth paragraph says, "Glaviano then said he worked

17 with a guy who knew the Detective working the case

18 with Metropolitan Police Department and that Clark

19 County School District Officer Mark Robbins was

20 being looked at for lying on his interview about

21 drinking with kids because Penny Higgins had

22 pictures of him doing so."

23 A. Okay.

24 Q. Do you recall hearing that anytime prior

25 to the filing of this lawsuit?



1 A. Not unless I saw this and signed off for

2 it officially and read it here.

3 Q. If you had heard --

4 A. I didn't hear it.

5 Q. -- that -- if you had heard that one of

6 your officers was drinking with kids, is that

7 something you believe you would remember?

8 A. Yes.

9 MR. PARK: Objection to form.


11 BY MR. COOK:

12 Q. So the fact that that allegation is in

13 here and you don't particularly remember reading it

14 leads you to believe that you don't think you got

15 this memo or even this information; is that correct,

16 sir?


18 MR. PARK: Join.

19 A. This is not a completed form, so I don't

20 know whether -- if I got it on -- on October 31st or

21 sometime shortly after, I would have signed it and

22 done something with it.

23 BY MR. COOK:

24 Q. What would you have done with it?

25 A. Probably at that point forward it up



1 again to -- to Legal along with the other stuff.

2 They were maintaining a -- whatever they're

3 maintaining up there, you know, on this case.

4 Q. Do you recall forwarding anything on to

5 Legal in 2011, October, November-ish, regarding this

6 case?

7 A. I don't -- I don't remember unless it's

8 this other -- the other one, but that's not that

9 date, so --


11 identification.)

12 BY MR. COOK:

13 Q. This is a memo signed by you; correct?

14 A. Uh-huh.


16 A. Yes, sir. It's not -- it's an electronic

17 signature. It's not an actual true signature.

18 Q. Is this a document you reviewed before it

19 was distributed on July 11th, 2012?

20 A. Yes. It was at the request of Scott

21 Greenberg to put this out to all members.

22 Q. What was your understanding as to why

23 this document was being put out to all members?

24 A. 'Cause there was a pending lawsuit and

25 they were -- I guess it had to do with discovery or



1 whatever -- requesting assistance providing

2 documents.

3 Q. Did you prepare any of the language in

4 this memo?

5 A. I don't think so. They probably gave me

6 the -- the basis to write it.

7 Q. Where it says -- and I'm in the middle of

8 the third paragraph -- "Additionally, if as part of

9 your work duties you prepared or received any

10 document(s) related to allegations that the accident

11 was covered-up, you are to provide my office a copy

12 of the document(s), or if you do not have a copy of

13 the document(s), inform my office to whom the

14 document(s) was given," is any of that language

15 something you prepared?

16 A. I don't believe so, no.

17 Q. Okay. Did you receive documents in

18 response to this request?

19 A. No, not that I recall. I think they went

20 directly to Scott. Nobody sent anything directly to

21 me.

22 Q. Okay. Did you do anything to make sure

23 that the officers received a copy of this memo?

24 A. It was sent out the way all department

25 administrative notices or special orders are sent



1 out, and they are -- they have to check their

2 E-mails at least once a day, and then I -- I believe

3 the history probably was checked by someone to

4 determine if everybody, you know, read it and opened

5 it and complied.

6 Q. In Robbins' depo I asked him, "Did you

7 ever get a written request from Ketsaa to check and

8 see if you had any documents related to the party or

9 this case?"

10 He said, "No, sir."

11 "Did you ever check to" -- "Did you ever

12 check to see if you had any documents related to the

13 party or this case?"

14 He said, "No, sir, never asked."

15 He should have been on this mailing list;

16 is that correct?

17 A. Absolutely, and I'm sure we could

18 research, you know, if it's still available, the

19 history.

20 Q. But there wasn't any instruction to not

21 provide it to any parties in this case; correct?


23 Q. What is the Code of Conduct at the School

24 District for off-duty police officers? What are

25 they supposed to do if they see a crime?



1 A. Do you have that policy, procedure

2 available? I don't know it by heart.

3 Q. You -- I'm sorry?

4 A. I said I don't know it by memory.

5 Q. Do you know it generally? Do you have

6 any understanding as --

7 A. Yeah.

8 Q. -- you sit here today?

9 A. If it's a -- if it's a felony in

10 progress, a life-threatening felony where you or

11 someone else is in imminent danger of death or

12 serious injury, you can take action as a police

13 officer off duty, notify the primary jurisdiction,

14 and if it's a misdemeanor or a gross misdemeanor,

15 you are to basically be a good witness, take down

16 any information, get license plates, descriptions,

17 call the appropriate law enforcement agency and do

18 not get involved in anything that you're personally

19 involved in.

20 Q. Do not get involved in anything --

21 A. That you are personally involved in

22 unless you're the victim.

23 Q. And what does that mean?

24 A. Like a neighborhood dispute or something

25 like that.



1 Q. Are you aware of Robert Giles being

2 brought before a meeting by Tracy Byrd and referred

3 to as the rat that was leaking information to the

4 press in form or substance?


6 A. Well, he wasn't -- he wasn't brought

7 before the -- this committee. It was a committee

8 that was formed by Arroyo. I think it was -- I'm

9 trying to remember what it was called. The -- I

10 forget what it is.

11 Anyway, he was a participant as a -- as a

12 member of the civilian staff of the department, and

13 I do recall that incident, yes.

14 BY MR. COOK:

15 Q. To the best of your recollection, what --

16 what happened in that incident?

17 A. Well, Arroyo was -- I -- I don't know.

18 Do you know the date of it?

19 Q. Somewhere, but no.

20 A. No? Well, I'm not sure whether Arroyo

21 was still chief or not, but for some reason I was

22 sitting in as the representative of the department.

23 I may have been --

24 Q. October 11, 2011.

25 A. October 11th, two -- okay. So he was



1 not -- he was -- that was right after he was no

2 longer around.

3 Tracy Byrd and him were close, I would

4 say, and at this meeting she went off. I don't

5 exactly remember what -- what -- what she said, but

6 she basically went off on Robert Giles. Told her to

7 stop.

8 Q. You told her to stop?

9 A. Yeah.

10 Q. Okay. I just wasn't sure I heard you.

11 You can please continue.

12 A. Okay. Told her to stop, it wasn't

13 appropriate. I don't know whether she kept babbling

14 or going on for a little while, for, you know,

15 whatever -- for a certain period of time. Told her

16 to stop, that was it.

17 Okay. I -- I don't know how much more

18 the meeting went. I don't know whether Robert got

19 up and left or whatever. As soon as the meeting was

20 over, I immediately went into Robert Giles' office

21 and met with him privately, told him that was

22 totally inappropriate and that I apologized. I was

23 very sorry that that happened. I had no idea she

24 was going to do that, and I asked him if he -- if he

25 requested any remedy from me, if he wanted to make



1 it a formal complaint, concern, that I would

2 definitely handle it, and he said he would think

3 about it.

4 Again, I apologized, told him it was, you

5 know, totally out of line and, you know, that it was

6 not appropriate. He said -- I believe he said he'd

7 get back to me later, by the end of the day or the

8 next day or -- and that's -- that's that day as far

9 as I remember.

10 Q. And then do you remember that he did ask

11 you to take further action?

12 A. I remember he sent me an E-mail. I don't

13 remember exactly what was in it. I'd have to see

14 it.


16 identification.)

17 BY MR. COOK:

18 Q. Exhibit 15, the first three pages appear

19 to be a letter prepared by Robert Giles two days

20 after the incident accompanied with on page 4 what I

21 believe is the E-mail you're referring to.

22 A. No, this is not an E-mail.

23 Q. And --

24 MS. HENDRICKS: Take a look at page 4.

25 THE WITNESS: Oh, page 4.



1 BY MR. COOK:

2 Q. Page 4.

3 A. Okay.

4 Q. And some follow-up E-mails.

5 A. Okay.

6 Q. Is that your E-mail response on the

7 bottom of page 4, "Robert,

8 "Thank you for" your "understanding.

9 Please be assured that the appropriate

10 administrative action has been taken"?

11 A. Yes.

12 Q. What administrative action had been

13 taken?

14 A. It's part of a personnel con- -- concern.

15 I don't know. Am I free to divulge that?

16 MS. HENDRICKS: You can indicate if

17 you -- if there was a personnel concern filed. You

18 don't need to go into details.

19 A. There was a -- it was handled.

20 BY MR. COOK:

21 Q. Does "handled" mean disciplinary action

22 was initiated or you turned it over to somebody to

23 do an investigation or something else?

24 A. I handled it.

25 Q. And how did you handle it?



1 MS. HENDRICKS: If it's -- if it was a

2 personnel -- and I think where he's having a little

3 issue here, it was a -- was it a personnel matter

4 that was -- that --

5 THE WITNESS: She was given discipline.

6 BY MR. COOK:

7 Q. And what was the discipline?

8 MS. HENDRICKS: And that's where we're

9 going to have to object to the confidential

10 personnel issues.

11 BY MR. COOK:

12 Q. All right. Next page is an E-mail from

13 Robert Giles almost a month after the fact to Jon

14 Okazaki.

15 A. Uh-huh.

16 Q. Do you see that?

17 A. Yes.

18 Q. And it looks like a response from him as

19 well. "Please be advised that the

20 Employee-Management Relations office . . . with the

21 assistance of this office, will be investigating and

22 addressing your complaint against Det. Byrd. As

23 such, I have advised Det. Johnson to forward your

24 correspondence . . . to EMR and to not conduct a

25 separate BOPS investigation."



1 If you already took action, why was EMR

2 conducting an investigation as well?


4 foundation.

5 A. Because somewhere in here he said he

6 also -- he also reported it to EMR, which he has

7 every right to do.

8 BY MR. COOK:

9 Q. So --

10 A. He didn't report it to the -- he didn't

11 report it to the department. He chose to report it

12 to EMR.

13 Q. Well, he did report it to the department

14 in the prior E-mail to you; right?

15 A. No. That was after I went to him. He

16 said, "Thank you for coming to . . . me . . . ." He

17 didn't come to -- I came to him. He didn't come to

18 me.

19 Q. Right. You come to him after the

20 accident -- after the incident.

21 A. Uh-huh.

22 Q. And then he sends you an E-mail the next

23 day --

24 A. Uh-huh.

25 Q. -- that says, "Thank you for coming to



1 apologize to me, that was greatly appreciated." But

2 it concludes by asking you to take action against

3 her; correct?

4 A. Yes.

5 Q. Okay. So he did go to the department and

6 ask for action to be taken against her, and in fact

7 you said you took action; right?

8 A. Yeah, yes.

9 Q. Okay. Simultaneously EMR was also doing

10 an investigation. Is that your understanding?

11 A. No, I don't think they did an inve- -- I

12 don't know whether they actually did or not. They

13 shouldn't have or couldn't have because EMR does not

14 do investigations on sworn police officers. Since

15 she's a police officer, they are precluded by 289 to

16 do -- do investigations of police officers.

17 So they -- they wouldn't have done an

18 investigation. I'm sure once everybody got their

19 facts straight it was solved.

20 Q. Okay. Well, you see where Senior

21 Assistant General Counsel sends to Mr. Giles --

22 A. Yeah.

23 Q. -- "Please be advised that the

24 Employee-Management Relations office . . . with the

25 assistance of this office, will be investigating and



1 addressing your complaint against Det. Byrd," so

2 he --

3 A. Right.

4 Q. -- seems to know she's a detective;

5 correct?

6 A. Okay.

7 Q. Are you aware of whether that

8 investigation happened or not?

9 A. No. From what I -- I believe that it

10 wasn't handled 'cause it was already handled on --

11 on the department level by -- we already handled it,

12 but I don't know a hundred percent for sure, no. I

13 would assume they didn't do it.

14 Q. In this letter, the first three pages of

15 this exhibit, on page 3 on the top it says, "I feel

16 she may have" -- I'm sorry. The -- yeah. "I feel

17 she may have had a personal agenda with this line of

18 questions. Det. Byrd, in this meeting on October

19 11, and the previous Steering Committee meeting on

20 September 20, 2011, had made it known that she is

21 not in favor of individuals 'messin with her

22 paycheck'.

23 "I did not appreciate the fact that she

24 accused me of this in front of my co-workers, as I

25 am a private person. This incident has caused me



1 great stress and embarrassment along with health

2 issues that are effecting me deeply. I'm now

3 uncomfortable in my work environment. I was

4 humiliated in front of my co-workers and now I fear

5 they think I could be the informant."

6 And then she lists -- or rather, he lists

7 the violations that he believed Detective Byrd

8 violated in bringing him in front of that panel and

9 says, "Please" instigate -- I'm sorry, "Please

10 investigate this incident and appropriately

11 discipline those involved. I will be available for

12 whatever assistance is necessary in this

13 investigation."

14 Are you aware of any investigation and

15 discipline that took place October 3rd, 2011 or

16 anytime thereafter?

17 A. October 3rd?

18 Q. 13th.

19 A. The discipline that I did.

20 Q. And that was after October 13th?

21 A. I don't know the exact date, but I

22 answered him. He wrote me on October 12th and I

23 answered him. Unfortunately I don't know -- it

24 doesn't show the date that I answered him, whether

25 it was that same day or two days later. I don't



1 know why that doesn't do that.

2 Q. Well, it does. If you look at the top,

3 it says from James Ketsaa --

4 A. Okay.

5 Q. -- Wednesday, October 12th.

6 A. Okay. So then -- okay. Then that's when

7 I took care of it.

8 Q. Okay. So then as far as you know, there

9 was no discipline after his request for discipline

10 on October 13th, 2011 --

11 A. Because this didn't come to us.

12 Q. You got to let me finish the question.

13 A. I know, I know. You're right.

14 Q. As far as you know, there was no

15 discipline that occurred after October 13th, 2011 as

16 to the incident Giles complained of with regard to

17 Detective Byrd; correct, sir?


19 foundation.

20 A. Correct, because you can't discipline

21 twice for the same incident.

22 BY MR. COOK:

23 Q. Okay. Well, and that was my next

24 question. And the reason for that is because you

25 say you effectuated the appropriate discipline on



1 October 12th; correct?

2 A. Yeah, I guess so. That's -- if -- if

3 that's what the date is, then that's correct. It

4 was taken care of.

5 Q. Okay. So and you conveyed that you

6 administered the appropriate discipline on the 12th

7 to him in this E-mail, which is before he wrote

8 the -- the letter on the 13th, so did you go to him

9 after you heard about this letter on the 13th and

10 say, "Hey, did you not get the E-mail?" or "What's

11 up?" or anything like that?

12 A. I didn't get this letter.


14 BY MR. COOK:

15 Q. So you --

16 A. This letter didn't come to me. This is a

17 letter I believe he probably sent to EMR.

18 Q. So you didn't know that after your

19 October 12th E-mail he was still unhappy and wanted

20 discipline against Detective Byrd?


22 Q. Yeah. You said you didn't receive this

23 letter, so what I'm trying to find out is: Did you

24 know after your E-mail to him on October 12th that

25 he was still dissatisfied and wanted an



1 investigation and some discipline against Detective

2 Byrd to occur?


4 A. No. I thought everything was solved.

5 BY MR. COOK:

6 Q. So the first time you're finding out that

7 he wasn't satisfied with the October 12th response

8 you gave him is today sitting here reading his

9 letter?

10 A. I may have seen this in some -- some form

11 before. I don't -- I don't remember exactly where

12 or how, but -- but it doesn't -- the --

13 Q. Do you have any idea general time frame?

14 Do you recall whether you knew this in 2011 as

15 opposed to two weeks ago with your counsel?

16 A. I probably knew about it after --

17 sometime after this.

18 Q. Did you ever go up to him and see if you

19 could resolve the issue?

20 A. It was resolved. You don't resolve it

21 twice. You can only resolve it twice.

22 Q. Well, obviously since he wrote a letter

23 after you thought you resolved it, it wasn't

24 resolved to him, though; right?




1 A. I can't tell you why he wrote that.

2 BY MR. COOK:

3 Q. You understand that he wasn't happy with

4 the action you took on October 12th; right?

5 A. No, I don't understand that.

6 Q. No? Okay. Well, did you read this

7 letter of October 13th?

8 A. He says he would not be against the

9 decision if I -- if I handled it, and then he

10 believes that she violated these -- these -- you

11 know, these -- these regulations.

12 Q. And says, "Please investigate this

13 incident and appropriately discipline those

14 involved"; right?

15 A. But he's sending this to EMR.

16 Q. Okay. But you --

17 A. They don't investigate police officers.

18 Q. But you also told me you became aware

19 sometime thereafter that this complaint was out

20 there; right?

21 A. Yeah, and -- and it was resolved I'm

22 sure.

23 Q. What my question is, is: After you found

24 out he sent out the October 13th letter or at least

25 still had an ongoing complaint after you sent him



1 the E-mail on October 12th, did you ever talk to him

2 about it?

3 A. I may have.

4 Q. But you don't recall one way or the

5 other?

6 A. No.

7 Q. Is there some policy that prevents

8 employees of the School Department to talk to the

9 news media?

10 A. Well, there are -- there are -- you're

11 not -- well, you know what? I'd have to review it.

12 I don't know for sure the exact policy.

13 Q. Are you aware as you sit here today of

14 any policy that would preclude a CCSD employee from

15 talking to the news media?

16 A. Not that I'm aware of.

17 Q. So even if he was -- I'm trying to find

18 the word he used.

19 Even if he was the leak to the news

20 media, would he have been doing anything wrong that

21 you're aware of under Clark County School District

22 employee policies, procedures or practices?

23 A. No.

24 Q. In November 2009 through July 2010, who

25 was in charge of the dispatch center over Nebeker?



1 A. What's the dates again?

2 Q. November 2009 to July 2010.

3 A. I guess I was.

4 Q. Who was Sergeant Morales's supervisor

5 same time frame, November 2009, July 2010?

6 A. Captain Bill Goodwin.

7 Q. When did Goodwin leave?

8 A. Summer of -- oh, boy -- '10.

9 Q. After he left, who was in charge of

10 Morales?

11 A. Well, Captain York was promoted sometime

12 shortly thereafter, so I'd have to look at

13 something, you know, to refresh my memory from back

14 then who was in charge of what.

15 Q. Have you ever talked with Christina

16 Zeddies before?

17 A. No.

18 Q. She's never had any meetings in your

19 offices or anything like that?

20 A. Nope.

21 MR. COOK: Let's take five. Let me go

22 through this stuff and see. I may be done with the

23 obvious exception.


25 THE VIDEOGRAPHER: We're going off the





3 (Recess taken.)




7 BY MR. COOK:

8 Q. Sir, anything from any of the sessions

9 before now that you want to go back and correct,

10 clarify, expand upon, anything like that?

11 A. No.

12 Q. All right. We talked about you meeting

13 with Mark Gregory from Metro and somebody else whose

14 name you couldn't remember for about an hour in your

15 office. Do you recall that?

16 A. Yes.

17 Q. Okay. Anything else about any Metro

18 investigations that you have any information on with

19 regard to the party, Angela's death or any actions

20 the -- the department took thereafter?

21 A. No.

22 Q. Have I exhausted your memory about

23 every -- all information you have with regard to the

24 party and who attended it and who knew about it

25 ahead of time or afterwards?



1 A. As far as I can tell.

2 Q. Have I exhausted your memory about

3 anything and everything CCSD did and knew with

4 regard to any investigation of the party or the

5 death of Angela Peterson?

6 A. At this time, I think that's everything I

7 know, you know, can recall right now.

8 Q. I've asked you a number of questions with

9 regard to allegations of a cover-up. Any

10 information you have with regard to -- favorable or

11 disfavorable for my case or -- or the School

12 District's case about a cover-up that we haven't

13 talked about today?

14 A. No.

15 Q. Is there anything else of importance with

16 regard to Angela's death or this party or any

17 actions of the School District that you think are

18 important that I haven't asked you about?

19 A. No.

20 MR. COOK: All right. I don't have

21 anything else for him other than the fact that I'm

22 not closing the depo. We're suspending it pending,

23 and I'd like to have the transcript before we bring

24 it up with the magistrate.

25 MS. HENDRICKS: That sounds fair.



1 MR. PARK: I don't have anything.

2 MR. SILVESTRI: I have no questions.

3 Thank you.

4 MS. HENDRICKS: I don't. No questions.

5 THE VIDEOGRAPHER: This concludes today's

6 videographed deposition of James R. Ketsaa,

7 consisting of four disks. Master disks will remain

8 in the custody of Oasis Reporting Services.

9 The approximate time, as indicated on the

10 video screen, 1601. We are now off the record.

11 (Deposition recessed at 4:01

12 p.m.)

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, JAMES R. KETSAA, witness herein, do hereby certify and declare under penalty of perjury the

21 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 _________________________________ __________ JAMES R. KETSAA

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, JAMES R. KETSAA, 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 22nd day of April 2014.

22

23 _____________________________________ William C. LaBorde, CCR 673, RPR, CRR

24

25

WORD INDEX

< ' >' 133:22 233:16

< $ >$300,000 83:22

< 0 >000043-045 3:22000047-048 3:17000057 4:7000084 3:1900037 5:8002-13 4:8

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1448 207:171454 211:241455 83:171457 212:315 4:10 250:15, 181555 263:21559 263:616 62:7, 91601 265:10169 3:2016-year-old 232:1617 3:20 63:17170 3:2017th 63:14 176:13,23 177:617-year-old 230:24 231:4, 1518 66:4 83:1718th 82:1919 83:10, 121988 27:31990 31:18 32:7, 81991 23:231995 7:91999 24:1819th 83:2419-year-old 27:22 28:3, 51st 23:11 74:13,16 166:1 168:7 184:17 200:11

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74:13 75:4, 10, 23 76:1, 5, 15 84:17 88:13 98:12 101:13, 18, 25 102:4, 15, 19, 22 125:17 131:9 132:19 134:13 137:4 139:18 140:21 141:8 146:19 147:16 148:19 150:1 158:20 162:6 166:1 168:7 179:15, 19 184:17 193:3, 7 198:13 200:11 208:6, 6 219:25 261:24 262:2, 52010 3:12 4:5 63:2, 14, 19 67:8,16 77:6 131:9 148:19 261:24 262:2, 52011 3:20, 22 4:2,5, 10 42:5 44:8 75:12, 23 76:7, 16 82:19 84:7 86:25 123:16 131:10 146:18 150:2 155:9 166:1 168:7 169:20 170:13 176:13, 20,23 177:6, 22, 25 183:13 194:17 195:13, 16 201:6 215:13, 15 224:12 229:3 231:15 236:18 237:18, 22 238:15 240:8 241:3, 11, 14 244:5 248:24 255:20 256:15 257:10, 15 259:142012 4:8 23:11 26:4 46:21 201:7 202:9 204:3 244:192013 103:232014 1:18 5:3 267:21

20-something 134:12 193:14220 4:16229 3:2222nd 267:2123 63:20234 4:2236 4:2239 4:523rd 63:2, 19 64:1324 4:16 34:1240 4:5244 4:8250 4:10289 254:1528th 98:12 102:22 198:13 199:929th 98:12 198:132nd 5:3 23:23 209:19

< 3 >3 3:12 61:20 81:16 171:7 208:18 255:1530 4:2 267:19303 64:22, 25 213:1830th 46:21 74:16 75:4, 10, 22, 25 76:5, 15 77:6 101:18, 25 102:4,15 139:18 146:19 147:16 168:7 210:5 235:11, 20,2531 4:531st 240:7 243:203-5 64:223773 2:938 3:103993 2:143rd 256:15, 17

< 4 >4 3:14, 20 4:2 7:9 77:13, 21 250:20, 24, 25 251:2, 7

4:01 265:11400 2:10 5:10, 114th 236:18 238:15

< 5 >5 3:17 4:5 82:14,17 132:24 143:2, 3,6, 25 144:1 145:2,5 146:17 153:7 165:22 176:16 200:1517 1:21 2:4 5:555 3:10

< 6 >6 3:4, 17 39:9 92:1, 16, 20 95:6,14 96:25 106:14 107:1 138:4600 2:15, 1961 3:12673 1:24 267:23

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< 9 >9 3:22 229:119:05 1:20 5:3

90 27:3, 4 31:19,2290s 32:1091 24:10 31:249134 1:2592 3:17 29:12 31:2193 24:1594 24:1599 31:19, 21, 229-millimeter 14:159th 84:7 86:16

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anytime 242:24 256:16anyway 126:24 248:11apologize 254:1apologized 249:22 250:4appear 250:18APPEARANCES 2:1appeared 186:17appears 145:8appreciate 255:23appreciated 254:1approached 28:17appropriate 38:24 39:11, 15, 23 40:10,25 80:4 130:12 138:11 191:8 203:16 240:10 247:17 249:13 250:6 251:9 257:25 258:6appropriately 198:23 256:10 260:13approval 40:15, 23 152:24approve 40:17approved 40:19approximate 68:19,25 142:3, 11 162:20, 24 207:9,16 211:23 212:2 263:1, 5 265:9approximately 5:3 6:21 7:9 10:5April 1:18 5:3 46:21 267:21arbitrations 178:10area 37:7 39:16,24, 24, 25 40:8 66:23 126:24 143:12 148:3 206:1Armando 2:7 6:7 71:16, 16 77:22 79:8, 14 93:14, 15 96:23 127:25 136:15 148:20

208:12arrest 43:10 76:20arrested 66:8arrived 29:1 86:22arriving 30:18, 18Arroyo 2:7 6:6 19:4, 20 23:16 26:8 47:5, 19 59:3 62:3, 15 63:13 81:18 85:10, 13 89:16 98:23 99:23, 24 105:12, 21 106:7 108:21 112:4 114:24, 25 118:10,19 122:15 123:24 125:14 127:4, 11 128:10 134:16 135:20 136:6, 7, 23 139:16 141:14, 18 144:2 145:5, 8, 11 175:5 177:14 178:2, 3, 7, 13, 23 179:23, 25 180:7 183:9 185:25 186:25 190:2, 25 192:18 193:19 194:1, 4 196:2 211:8, 10, 10 212:11, 17, 18, 19 213:6, 13 214:10 215:16, 20 217:13 218:21 219:1, 10,25 220:17 226:1, 4 235:3 248:8, 17, 20Arroyo's 15:2 17:24 46:10 63:24 103:22 105:16 123:21 124:6 129:24 134:9 135:7 175:2 178:15, 25 216:3article 44:16 45:22, 25articles 187:10 197:21, 22 198:1 229:2, 5articulate 138:12ascertained 194:24

Aside 20:23 62:16 152:5 179:12asked 16:8 19:14 20:17, 21 22:8 30:21 46:1 51:19,23 52:8 53:15 54:14 57:18 69:10 88:22 89:6,9, 15 94:20 95:8 99:3 101:9 104:19 105:24 107:25 109:6 118:19 119:18 121:15 125:17, 17 128:10 129:24 130:19 133:13 134:17 135:20, 21 136:6 137:3 138:10 160:12, 24 161:12 178:1 180:20 186:20 203:14 205:19 210:19 212:8 217:16 218:8 219:6 220:11, 13,17 222:19 223:15 224:18 242:12 246:6, 14 249:24 264:8, 18asking 8:10 15:20 18:4 62:8 86:8 100:4, 17 135:19 151:4 167:15 172:3 182:8 188:18 189:12 190:11 199:15 201:19 204:11, 16 214:21, 22 216:13,25 220:13 223:9 240:24 242:4 254:2aspect 160:25assign 47:2, 2 81:21 121:5, 8 127:22, 22 133:2 217:9assigned 26:16, 17 47:19 81:6 83:2,12, 23 121:6, 7 126:23 127:20, 21

189:19assignment 128:3assigns 80:24assist 139:3 240:17assistance 245:1 252:21 254:25 256:12assistant 36:12 254:21assisted 30:6assisting 124:20assume 100:9 192:12 255:13assuming 11:15 124:14assumption 175:5assure 196:13, 15 197:3, 3 209:12assured 251:9attain 215:22attained 215:19, 25attempt 128:13attend 50:22, 24attended 35:9, 13,24 51:1 69:11, 19 104:4 105:2 149:15 263:24attending 23:18 36:2, 9 185:4attention 103:24 150:15attorney 21:6attorney-client 15:10 16:1 150:25 151:20 212:22 213:1 214:25audibly 7:24Aug 3:22August 4:2 67:8 84:7 86:16, 25 195:13, 16 215:15 231:15 236:18 238:15authority 113:23 119:21 133:16available 246:18 247:2 256:11Avenue 2:19avoid 45:11, 20

aware 37:1, 4, 8 41:4, 5, 9, 11 42:24 59:11 64:23, 25 65:11 74:11, 15 85:10 89:2 103:6 105:15 126:8 145:12 147:9 149:13 155:2, 8, 13 158:1, 7, 20 159:8 160:6, 25 161:21 162:5 168:7, 17 170:11, 12, 16 181:10 194:6 219:18 230:18 236:22 239:18 248:1 255:7 256:14 260:18 261:13, 16, 21

babbling 249:13back 19:20 26:5,6 29:17, 19, 21 30:1, 3, 9 41:6 43:18, 23 44:14, 15 51:19 52:3 53:24 54:1, 6, 14, 17, 21 55:24 56:4, 25 58:6 60:19 68:22 73:17 84:24 92:6 95:1 100:13 114:10 118:5 120:13 121:9 122:21 128:8 131:13, 16 132:10 134:22 148:1, 16 154:4 160:1 162:23 163:11 165:5, 21 166:16,23 169:8 172:6 174:13 178:13 179:23, 25 181:6, 7 185:13 188:22 190:1 201:10, 12 207:13 210:3 212:1 222:24 227:10 228:15 232:25 250:7 262:13 263:4, 9backed 130:22

backup 30:18bad 21:18 141:22Bailus 2:4 5:5, 23balked 25:11ball 18:5, 24 19:2,6banter 181:5 184:9bar 232:14Barris 15:4Barris's 20:13based 105:19 116:1 159:21 175:4 195:18 222:2basically 32:24 105:10 119:22 120:14 125:21 129:8, 12 132:5 160:2 172:20 200:18 209:13 247:15 249:6basis 25:20 155:4 179:21 216:10 221:13 235:6 241:9 245:6Bates 54:19 72:16 82:7 229:13, 18beer 39:10 70:23 124:25 172:24, 25 173:3, 17, 21 231:25 232:18began 128:25 232:25Beginning 3:10 60:8 68:23 134:6 142:9 207:14begins 64:21behalf 1:6 5:24 6:1, 2, 5 35:10 140:5behavior 77:5believe 7:1 11:11 13:7 17:18 18:16,23 19:2, 5, 12, 13 20:15 26:3 27:21 28:7 40:8 41:20 52:4, 21 54:5 56:5 59:5, 11 60:12, 25 61:15 62:6 64:16 65:24

71:4, 11 72:12 73:9, 11, 14 83:20 84:22 85:14 93:10, 20 95:9 96:13 101:10 102:16, 21 106:3 110:12 111:23 127:18 128:20, 22 144:6 145:16 148:1 159:9, 20 160:10 165:12 182:25 187:1 193:17 194:4 197:19 200:10 205:15, 22 210:22 215:8, 14 218:21 234:12 239:23 243:7, 14 245:16 246:2 250:6, 21 255:9 258:17believed 29:14 31:6 53:17 116:25 118:7 128:13 187:9 198:2 256:7believes 130:11 134:17 260:10Beretta 14:15best 8:20 60:6, 18 90:11 130:3 159:17 184:18 239:22 248:15 267:13bet 234:25better 143:18beyond 15:12 27:14 59:16 74:24 90:20 164:22Bill 26:11, 12 262:6birth 55:25birthday 230:23 231:3, 16birthdays 55:2bit 226:8, 8blacked 29:24blood 8:21Board 140:6, 7 141:12, 15, 16

Bob 219:7, 8booking 29:20booze 230:25BOPS 252:25boss 108:15 191:24bottle 17:5bottom 63:16 78:9 80:25 81:5 83:11 170:22 238:12 251:7bounds 221:21, 23 222:5Box 5:11boy 27:3 262:8Boyett 126:6, 22Boyett's 126:9boyfriend 78:18,25 79:16 94:10 100:10 232:17break 9:2, 3, 5 68:14 69:4, 4, 9 76:11 82:11 106:6 131:5 141:20 158:24 161:5, 11 162:18 211:19, 20 212:6Brian 2:7 6:7 15:3 20:1 51:12 52:3 104:23 148:21 233:21Bridger 2:19BRIEF 132:3bring 134:22, 23 194:15, 16, 19 197:8 264:23bringing 256:8brings 132:17broad 158:15broadcast 82:22 155:9, 12, 14broke 41:20, 23 44:5, 18 75:7, 12 139:7 196:10 209:5 231:5 232:23brought 26:9, 13 103:24 112:1 150:11, 14, 17 211:3 248:2, 6

building 206:13,17, 17, 21bunch 169:13 235:4Bureau 108:15business 33:13 39:6Byrd 248:2 249:3 252:22 255:18 256:7 257:17 258:20 259:2Byrd, 255:1

< C >call 28:24 34:18 51:23 53:5, 8, 15,18 60:2, 5 79:9, 15 88:1 110:11 119:20 123:13 128:24 132:2, 19 175:24 183:8 196:21 222:6, 7, 9 239:24 247:17called 31:4, 9 51:22 52:7 53:14,16 57:10, 13 88:6 93:11 94:14, 15 95:3 118:8 177:18 210:4, 9, 11 215:3, 5 233:1, 15 248:9calls 179:5 210:10Camman 49:10, 11 50:24campus 23:19cancel 228:11capacity 133:2 188:11 192:7, 13Captain 12:15 18:10 23:16, 16 24:20 25:1, 15, 19 26:9, 11, 12, 14 51:23 53:5, 8 104:1 105:5 106:4 112:23 113:11 119:1, 24 121:6 122:5 125:22 126:12 128:18 129:12 131:3, 22, 24 132:6,17, 18, 22, 25



133:20 135:11 137:15 148:5, 8, 13 149:3, 6, 11 178:14 184:21 186:24, 24 192:17 209:19 236:2 239:16 262:6, 11captains 127:14car 29:15, 18, 19,23 30:1, 6, 16 33:2 34:12, 14, 15, 17 35:8 79:16care 30:20 92:10,12 203:18, 24 230:6 257:7 258:4careful 129:19, 22Carlos 9:19, 22, 24 21:9, 13Carrie 78:12Caruso 49:8, 21 51:1Case 1:2 5:14, 16 10:19, 21, 25 11:13 58:5 61:1 81:6 98:19 103:23 107:22 116:21 120:1, 11 126:6, 17 128:3, 17 129:11 130:5 131:22, 23 133:8, 21 137:14 158:18 160:11 164:18 173:12 181:4, 4 188:12 189:19, 19 190:1, 6,6, 21 192:5 217:24 218:3 221:18 223:3 225:19 226:10 234:17 235:4 242:17 244:3, 6 246:9, 13,21 264:11, 12case, 181:9cases 7:18 47:1 60:17 108:9 120:2 126:3, 19 130:6 178:9, 18 179:2, 9, 9, 20 180:1 188:5 235:15categorically 220:14

Category 236:11,12, 12cause 24:4 39:4 45:15 53:9 58:10,13 104:11 127:19 204:12 215:2 218:25 244:24 255:10 267:18caused 52:23 57:22 66:1, 8 255:25CCR 1:24 267:23CCSD 3:17, 19, 22,24 4:7 32:5 60:23 79:25 107:22 158:21 160:17 171:19 172:14 173:7 205:25 261:14 264:3CCSD000125 77:23CCSD000125-127 3:16CCSD000129 3:12 54:19CCSD000143 3:14CCSD000172 4:5CCSD000219 4:2Centel 30:3center 37:8 49:2 51:20 67:25 181:19 261:25certain 44:3 136:22 249:15Certainly 58:22 208:6CERTIFICATE 266:1 267:1Certified 2:23 5:7 267:5certify 266:20 267:6, 14cetera 77:24chain 18:8 128:25 135:10, 14 149:6challenging 226:3change 26:12, 13 177:12 266:2changes 69:5 131:12 142:14

Channel 44:16 45:10, 18 82:22 169:21character 187:24charge 43:10 46:12 47:7 63:10 98:18, 19 145:20 147:23, 24 219:25 224:18 225:9, 12 261:25 262:9, 14chastised 205:20chatty 187:19, 22 192:7Chavez 12:6, 14 52:1, 7 53:21 57:10, 13, 15 58:25 65:20 66:11 72:3 74:7 84:16 87:6 88:1, 6, 12 95:3 97:5 98:16 101:19, 25 104:6 105:6, 25 106:1, 7 118:8 123:13 165:19 183:8 210:4Chavez's 107:1check 174:22 246:1, 7, 11, 12checked 246:3chief 9:25 19:4,20 23:8, 13, 13, 16,17 26:8 46:10, 25 47:5, 19 80:24 81:6, 13, 20, 21 83:18, 19 85:16, 16 98:18 103:10, 21,25 111:11 112:17 118:14, 19 120:8 121:4 124:11, 24 125:3, 11 128:1 132:8 133:1, 4, 11 136:17 144:2 155:21, 25 157:4,13 174:6, 7, 14, 19 175:15 177:14, 17,17 178:3, 4, 5, 5, 7,13, 15, 23, 25 179:4,16 181:2 182:21,21, 21, 25, 25 185:10, 22 186:25 189:3, 4 191:8, 9

192:17 195:11, 12 196:12, 19, 20 198:11, 18 200:7 202:8, 14 205:13,15, 16 209:8 211:8 213:6, 24 214:2, 3 216:19 226:1 227:4 235:8 242:15 248:21chief's 36:12 121:4choice 115:12 203:12 205:3chose 109:15, 17 113:9 253:11chosen 236:24 237:15Christina 262:15Christmas 16:10,22, 22, 25 35:15, 18,23circumstances 6:23 84:12, 21 139:10,16cited 31:9civil 157:17 158:1 164:5civilian 80:21 81:2 163:4, 19 164:9 171:21 172:17 173:2, 9 174:9 176:19 248:12civilians 80:20claim 61:18 67:8clarification 216:17clarifications 69:6 142:15clarify 182:22 197:9 263:10Clark 2:5 6:6 9:20, 22 23:8, 21 32:17 35:10, 13, 16 38:24 69:20, 21 71:5 82:18 103:11 122:24 123:25 158:8 180:19 190:25 242:18 261:21 267:3, 20clean 7:24 135:21 229:18



clear 15:23 93:13 121:3 132:11 138:20, 22 139:1 141:4, 7 157:11 217:4clients 216:23close 204:24 249:3closed 114:20 160:4, 7close-knit 183:25closer 234:2closing 264:22clue 67:14 86:15Code 64:22 65:1 246:23coerce 128:13coincide 230:23combination 108:1come 20:19 31:23 47:1 58:9 60:19 82:24 84:11 105:2 120:19 144:17 163:4 185:11 196:22 201:12 212:14 253:17, 17, 19 257:11 258:16comes 54:1 56:25 114:10 116:2 192:4 198:6, 11, 21 200:21 201:3coming 54:21 113:7 192:11 201:17 229:4 253:16, 25command 18:9 129:1, 1 135:10, 14commence 235:12comment 136:7 170:4commented 135:25commenting 35:21comments 45:19,22 201:11 229:23 230:1commit 140:15committed 29:13committee 248:7, 7 255:19communicate 118:4

communicated 119:8communication 64:21 117:10 167:25 206:25company 61:11, 14,18compelled 79:20,21, 22compelling 60:13complainant 127:6complained 127:7 160:5 257:16complains 135:3, 4complaint 85:20 127:4, 11 128:10 159:16 219:13 250:1 252:22 255:1 260:19, 25complaints 141:13 159:9complete 19:7 22:10 63:9 111:12 118:15 202:22, 23 203:8 267:12completed 114:19 116:21 243:19completely 46:18 47:20 57:20 58:2 60:7, 18completes 84:4complied 246:5comply 214:9, 15compound 130:1computer 59:8con 166:7 167:5 183:6 251:14Concern 3:14, 17,20 4:10 77:22 79:7, 11 80:9, 13,15, 21, 22 81:2 82:17, 23 83:21 110:5 121:3 127:25 132:3, 23 143:1, 22 176:15,20 200:1 213:18 234:8 250:1 251:14, 17concerned 220:25

concerns 84:2 213:6 239:13concluded 116:9 118:22concludes 254:2 265:5conclusion 116:2concurrent 114:18 116:7 166:9 167:7condition 8:19condone 134:21Conduct 64:23 65:1 116:6 117:4 120:12 146:25 147:10 156:21 157:18 166:8 167:7, 20 171:20 172:15 175:25 176:1, 18 177:1, 8 234:8 246:23 252:24conducted 65:13 84:14 152:7 153:10 156:12 157:4 161:22 162:13 163:6 165:7 166:3conducting 18:12 110:21, 23 111:20 115:4 117:5 152:13 158:2 163:3 164:15, 24 165:3 167:19 168:9, 21 173:25 204:14 253:2conducts 147:1conference 59:7, 8confi 216:2confident 208:5confidential 55:10 190:19, 23 216:14,18 252:9confidentiality 92:10confirm 54:15 66:2confirmed 56:8, 10conflict 32:9 50:11confused 135:17 143:19 156:18

conjunction 79:8connection 120:5consider 138:9 182:13considerations 109:18, 22 192:5considered 147:20consisting 265:7Constitution 238:6consumption 31:10contact 42:15, 20,22 43:2, 3, 8, 9, 15,15 53:14 60:4 99:20 100:6, 20 102:9 104:2, 14 107:2 118:20 123:19 126:15 134:7 175:3, 5, 6,17contacted 43:5 54:13 65:9, 12, 19 85:2, 3, 9, 11, 12 104:5, 17 147:6, 10,11contacting 105:20contained 240:19content 170:4context 134:15 224:3, 3, 5 238:14continually 67:16continue 175:22 235:9 237:23 238:3 249:11continued 128:23 135:2continuing 69:3contract 108:16contractor 267:14,15control 19:7 46:19 111:12 118:15 179:14, 18 202:18 203:21, 23conversation 8:5 21:13, 16, 21 57:4,7 58:17 66:23 84:6 87:24 90:4 105:25 141:13 147:14 176:25 184:6, 13 185:8 188:9 189:14



191:7 193:18, 24 196:18 199:23 217:3 218:20conversations 68:1 84:15 139:15 156:12 157:9, 10 183:4, 7, 12, 15 189:11 191:16 195:15, 20 196:9,19 199:19 207:19 212:25 217:1conversing 27:21 28:3, 5convey 110:3 118:5 144:2 145:7, 12 150:9 194:23 195:8 212:19conveyed 88:12 101:24 104:16 183:8 189:17 196:3 240:25 258:5conveying 111:3 183:17COOK 2:1, 4 3:4 5:5, 23, 23, 23 6:14 15:14, 19 16:2 18:19, 22 28:1 33:14, 19 34:10 35:1 36:6, 22 37:13 38:8, 11, 13,15, 16 39:7 41:3, 8 42:19 44:22 45:13 46:4 47:15 55:4, 10, 14, 18, 20 61:22 63:22 64:20 67:5, 20 68:7, 15 69:2 70:2, 13 71:3, 9 74:25 75:2 77:9,15, 18, 20 80:3 82:10, 13, 16 90:10 92:6, 9, 15, 18, 19 99:16 100:12 101:1 108:11 109:5 110:1, 10 112:13 113:4, 17 114:3, 23 115:24 116:24 117:17 118:18 123:7

124:10, 23 125:9 129:19, 23 130:18 135:18 136:18 137:2 138:1 139:23 141:11, 21 142:13 143:4, 7, 8,17 150:13, 18 151:2, 21 152:21 153:6 154:4, 18 155:1 156:10, 20 157:1, 8, 16 158:6,14 159:2 161:7, 10,15, 18, 19 162:11,17 163:1, 14, 23 165:15 166:23 167:11 168:5, 15 169:4, 11, 13, 16, 18 170:17, 21, 24 171:2, 3 172:1, 19 173:14 174:20 175:12 176:8 177:4 180:17 182:9 184:15 186:4, 11 187:23 188:17 189:24 190:10, 15 191:10 192:1, 14 193:21,23 198:17 200:16 201:1, 14 203:1, 10,17, 22 204:11, 18 205:2, 8, 9 207:18 211:15 212:4, 23 213:11 214:16 215:6, 10 216:7, 10,24 218:1 219:2 220:12 221:13, 17,19, 23 222:1, 4, 9,12, 18, 21, 25 223:7,15, 18, 25 224:6 225:20, 23 226:16 227:5, 9 228:1, 9,17 229:13, 15, 17,25 230:4, 9, 12 235:1 236:16 237:9 238:11, 21 239:9 240:5 243:11, 23 244:12 248:14 250:17 251:1, 20 252:6, 11 253:8 257:22 258:14 259:5

260:2 262:21 263:7 264:20cooler 231:25cooperative 53:12 60:16 111:4 124:16, 21cooperatively 60:16copies 55:5, 16 92:12 108:15 118:9cops 124:25 137:4,10, 18 199:20 200:20copy 37:14 38:7, 8 44:17 100:2 109:3 112:6 169:12, 25 194:12 229:16 245:11, 12,23Corr 190:3Correct 11:16 14:18, 19 21:1 38:2, 3 39:12 48:17 53:6, 7, 21 69:18 73:10 77:10 79:1 82:4 83:10 88:16 90:5 91:7, 10, 16, 17, 20,21, 23, 24 92:16 93:5 95:6, 13, 17,22 96:1, 16 97:3,15, 17 101:16, 22,23 102:2, 3, 6, 17,24 103:7, 8, 12, 13 105:12, 22, 23 107:2 110:25 111:1 112:2, 3, 5,16 115:19 116:3, 9 117:7 119:5, 12, 13 120:22 121:13, 20,23 125:12 128:21 132:7 133:25 134:10 139:8 142:22, 23 147:7 148:6 155:14, 25 156:1 158:23 159:22 161:24 162:1, 14, 15 163:20 165:9 166:10 167:10, 12 168:2, 4 171:16

174:2, 21 175:8 177:18 180:2 182:2 183:6, 9, 13,14 186:18 187:14,16 188:25 189:8 190:2 191:21 192:19 193:19 194:2 200:22 203:4, 12 208:3, 10,15, 21, 22, 25 209:21 210:6, 25 218:9 234:18 243:15 244:13 246:16, 21 254:3 255:5 257:17, 20 258:1, 3 263:9corrected 266:22correspondence 252:24Counsel 5:20 9:25 77:25 108:15 150:25 151:4 171:11 176:12 203:7 212:21 228:20, 21 254:21 259:15 267:15, 17count 237:23 238:3County 2:5 6:6 9:20, 22 23:8, 21 32:17 35:10, 13, 16 38:24 69:20, 22 71:5 82:18 103:11 122:25 124:1 158:8 180:19 191:1 242:19 261:21 267:3, 20couple 10:8 35:19 48:3 161:15 187:2 199:18, 18,20 202:15 210:8 237:6, 21course 39:10 123:19 218:10 221:19 225:20COURT 1:1 5:9,12, 15, 22 7:11, 22 92:9 100:15 154:7 167:1

172:10 216:17 227:13 267:5Courtney 195:1, 21,21, 23, 25 196:2covered 152:19 208:2covered-up 245:11covering 173:4coverup 232:25cover-up 18:6 77:4 85:24 87:7 162:7, 14 171:15 197:1, 1 236:21 264:9, 12co-workers 232:7 255:24 256:4credence 236:25 237:16credibility 225:24,25 226:3crime 29:14 32:16 246:25criminal 7:18 108:8 113:15 114:19 116:22 126:10, 17, 18, 19,23 129:10 163:12,12cross 92:5crossover 117:2CRR 1:24 267:23cubicles 40:3cuffed 30:23current 23:7 103:25 124:11 226:1currently 235:14 236:25 237:16custody 29:11 265:8Customs 127:3cut 8:7Cynthia 2:12 6:3 96:12, 14 97:14, 24 98:7, 11, 22 101:12,13, 15 102:1, 5, 16 103:6, 9 173:20, 21

< D >danger 247:11database 63:1

date 46:17 48:24 50:20 55:25 60:20 62:24 64:12 65:11 75:23 76:6 83:9 86:15 91:2 98:15 127:15 154:2 159:25 176:21 179:15 182:17, 19 193:13 196:10 198:16 232:18 240:14 244:9 248:18 256:21, 24 258:3 266:25dated 63:25 82:2,19 83:10 176:12 235:11 236:17dates 55:2 63:24 179:22 262:1daughter 66:4 79:16 94:9 216:23 230:24 231:4, 16 232:16daughter, 79:1daughter's 78:17day 11:25 12:11 56:7 58:18, 23 59:3, 3, 5, 5 73:13 74:9 89:19 95:12 174:7 184:18 185:12 186:23 187:2 189:15, 16 199:6 210:3, 5 225:23 232:24 246:2 250:7, 8, 8 253:23 256:25 267:21days 10:8 48:24 144:11 187:3 192:15, 21, 25 193:6, 8 199:18 208:14 210:9 250:19 256:25day-to-day 25:20 26:14 178:14deal 19:10 28:11 148:16, 17 241:9dealt 83:6Dean's 31:3, 4death 18:6 76:8,20 77:5 91:14

134:4 136:10 139:17 158:23 160:19, 20 161:2,24 162:4, 8 171:15 173:5 196:25 207:22 236:20 241:16 247:11 263:19 264:5, 16deceased 1:6 64:17December 63:14 74:13, 15 166:1 168:6 184:17 192:24 193:1, 13 199:18 200:11 208:6 209:19decide 114:5 116:5decided 232:19decides 130:23deciding 109:19decision 112:15, 18 121:11, 16 152:6 153:20 154:12 179:18 204:10 260:9decision-making 152:22decisions 47:2declare 266:20dedicated 237:25 238:5deeply 256:2Defendant 2:17 226:1Defendants 1:11 2:5, 12defined 101:14Definitely 58:16 250:2delivered 120:18Department 4:8 6:25 14:18 16:15 17:10 18:11 19:8 21:4 23:22 24:1,3 26:21 31:17 32:1, 17 33:16, 25 34:2 36:15 39:1 42:13 45:1 46:8,9, 16 47:17, 18 60:7 61:9 76:9 78:10 82:19 85:1,22 87:10 88:22

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< H >head 29:24 30:20 181:1headbutt 29:22heads-up 82:23 185:14, 16, 19, 23 188:24 189:2, 18,25health 256:1hear 41:19 43:23 51:11 122:2 145:1, 11 232:9 243:4heard 7:5 41:16,21 45:16 51:4, 8 61:5 66:16, 21 67:11, 13 68:2, 6, 9 71:23 72:4 75:5,8, 13 76:24 78:13,14 85:6 91:4 95:13 98:9, 10, 14 102:7 142:20 143:11, 14, 20 144:24 145:4, 15 146:3, 4 152:14 153:20 154:12 155:11, 16 170:3 175:2 184:17 186:23 189:15, 16 198:9 201:23 225:11 231:2, 9 232:20 233:3, 17 234:4 237:2 243:3, 5 249:10 258:9hearing 61:17 66:17 77:3 78:23 232:2 242:24heart 247:2heated 181:3He'd 86:10 250:6held 23:10 24:24 30:14 35:9

help 124:2 134:22 176:23 205:23 235:13 236:8helped 30:15helpful 123:1helping 230:25HENDRICKS 2:7 6:5, 5 9:19 10:9,11, 15, 17 15:9, 18,22 18:14, 16, 21 21:12, 24 27:24 33:5, 7, 18, 22 34:22 36:3, 19 37:11, 22 39:2 41:1 42:17 44:19 45:8 46:1 47:12 54:25 55:19 64:8 67:1, 18 68:5, 13 69:25 70:6, 25 71:7 74:17 77:8,11 80:1 82:7, 12 90:6 92:3, 13 99:12 108:5 109:1, 21 110:8 112:11 113:1, 13 114:1, 15 115:20 116:10 117:14 118:13 123:5 124:7, 18 125:7 127:8 129:17, 21,25 135:16 136:13,24 137:22 139:19 140:25 141:20, 24 143:2, 16 150:10,16, 23 151:17 152:17 153:1, 23 154:22 156:5, 8, 16,24 157:7, 11 158:4,11, 25 161:5, 9, 12,17 162:9, 18 163:8,21 165:10 168:3,12 169:1, 6, 12, 15 170:14, 25 171:22 173:10 174:18 175:9 176:6 177:2 180:12 182:7 184:12 186:2, 9 187:21 188:14 189:21 190:9, 12 191:5, 22 192:8 193:20

198:14 200:12, 23 201:9 202:20 203:5, 13, 19 204:6,24 205:6 211:12,19 212:20 213:9 214:13, 24 215:8 216:1, 9, 12 217:22 218:23 220:9 221:7, 15, 18, 20, 24 222:3, 6, 11, 16, 19,23 223:1, 14, 17, 19 225:17, 21 226:20 227:6, 11, 18 228:6,13 229:16 237:3 238:9, 17 243:10,17 248:5 250:24 251:16 252:1, 8 253:3 257:18 258:13 259:3, 25 262:24 264:25 265:4hereunto 267:20Hey 49:3 84:17 104:14 144:2, 12 184:21 201:13 209:15 258:10Higgins 78:12 197:23 198:2 231:22 232:5, 15,17, 18, 25 233:20 242:21high 8:21Highlights 4:2, 2, 5 235:2, 5high-school 36:10hiring 217:6history 246:3, 19Hoffman 3:20hold 13:20 58:5 62:11holiday 35:14 39:8 49:4Holidays 3:10 35:11home 47:25 48:7,25 57:23honest 57:21 227:20 238:24hope 134:23 166:21

hosted 57:23 61:10hosting 70:9hour 10:5, 15 21:9 87:18 91:19 263:14hours 10:12, 15 21:10 27:8 34:2house 36:12 37:1 48:22, 23 51:6, 15 59:17 71:6 79:20 92:23 93:2 98:11 184:25 187:5, 8 197:20 238:13houses 57:23Howard 2:9, 14how'd 88:24HR 24:22 25:6Hughes 2:9, 14human 49:15 217:2humiliated 256:4hundred 26:2 136:21 255:12hung 58:25hurt 35:6husband 100:10hyphen 93:16hypothetical 34:12hypothetically 70:15, 18

IA 108:8, 8 113:20, 20, 20, 21,22, 24 114:4, 8, 14 118:15, 15, 16 120:4, 5, 6 127:22 130:15, 16 131:22,23 219:12 233:15IACP 239:22ICE 126:12 127:2idea 8:4 34:7 63:19 64:4, 7 71:23 94:17 113:22 118:3, 4 140:9 145:3 147:15 166:5 181:15 217:19 223:3 228:22



230:22 235:19 249:23 259:13identifiably 11:7identification 38:5 55:13 61:21 77:14 82:15 92:2 169:10 170:20 229:12 234:23 236:15 239:8 240:4 244:11 250:16identified 12:18 21:25 57:16identify 5:21 11:4 14:4 22:2, 13, 15,17II 236:12illegal 115:23 116:3illness 8:18immediate 233:21immediately 62:12 64:17 249:20Immigrations 127:3imminent 247:11impartiality 267:18impetus 60:4importance 264:15important 264:18impossible 232:6impression 138:14 163:9 164:15inappropriate 39:17, 19 239:3, 4 249:22inappropriately 16:25inarticulately 9:8incidence 90:23incident 11:19, 21 12:1 13:10 41:17,18 85:21 87:5 98:20 103:24, 25 107:9 140:3 193:15 225:22 239:6 248:13, 16 250:20 253:20 255:25 256:10 257:16, 21 260:13

incidents 28:16, 21 35:5include 73:1 87:24 97:22, 22 157:8 189:10included 95:4, 5,11 106:22 155:9including 20:24 234:13inclusive 96:20independent 151:25 152:6, 7 153:8 267:14, 15indicate 93:19, 23 96:8 251:16indicated 5:4 18:17 68:19, 25 142:3, 12 162:20,24 207:10, 16 211:23 212:2 263:1, 5 265:9indicates 101:20individual 58:8 126:14individually 1:4, 4,10individuals 72:4 106:5 129:1 255:21inevitably 9:7influence 8:17 29:15 31:7info 55:10 92:11 166:9 167:9 175:16 200:6inform 104:3 245:13informal 181:12 182:1, 6, 14Informally 180:23informant 256:5Information 3:12 18:7 43:6 51:21 52:9, 10, 14, 18 54:11, 13, 15, 16 55:21 56:3 58:4,7, 11, 22 59:13 60:24 61:3 66:10,15 75:24 76:8, 14,19 77:2 79:3, 23 80:14 88:9, 11

97:11 98:14, 16, 23 102:10 103:15 104:3, 7, 17, 21, 24 105:4, 8 106:2, 8 107:2, 21 110:4, 16,19, 23 111:3 116:15 118:5 121:18 122:5, 13 123:1, 11, 19, 20, 23 124:1, 9, 25 125:2,4, 10, 15, 18, 20, 25 126:13 129:9 130:5 133:11 135:9, 10 136:10,14, 16, 22 137:1, 19 138:11, 13, 15, 18,21, 23 139:2 144:12 145:18 147:18 148:23 149:5, 7 150:9 151:23 154:19, 24 160:15 164:23 165:1, 2, 7, 19 166:12 168:8, 20 170:12 173:6, 15,18, 19, 23 174:4, 25 175:18 178:11 183:5 188:7 189:7, 17, 22 190:6 193:25 194:16, 16,22, 23 195:8 196:3 200:2, 19 201:6 204:17 208:18, 21 210:4 212:14 214:17 215:16, 19,22, 24 216:5 223:24 230:17 232:2 233:17 239:4 240:19, 25 242:6 243:15 247:16 248:3 263:18, 23 264:10information, 104:21information,' 104:20informed 137:8, 13initial 42:22, 23 43:1, 2, 24 75:20 137:24 152:19

initial, 42:25initialed 82:2initially 11:15 72:2 73:17 78:20 116:11 122:16initially, 122:17initials 61:25 83:13initiate 114:21 132:23initiated 128:17 251:22Initiative 53:11, 11injured 30:16, 19 32:22injuries 30:21injury 247:12innuendos 235:14input 105:21 112:19inquiry 160:23in-service 27:19, 20inside 231:1instance 81:15 90:22 121:12instances 117:9instigate 256:9instruct 15:19 59:24 216:8, 16INSTRUCTED 4:14 156:23 222:18instructing 216:11 221:14 222:1, 13,16instruction 138:20 246:20instructions 177:11insurance 61:11,13, 16, 18 66:14, 20 67:7 68:3 76:24 142:21 143:21 152:15 155:4intel 85:5InterAct 39:4, 5interest 32:10interested 267:16interests 60:7intermediate 18:11intermittently 147:22 184:4

Internal 19:8 24:22 46:12, 14, 18,21, 24 47:5, 7, 20 81:22 87:8 88:19,23 89:6 98:19 107:22 111:22 114:21, 25 115:25 116:6 117:4 119:22 121:16, 19 126:18 127:5, 10,23 128:16 130:6 131:18 132:2, 11,16, 18 133:2, 6, 7 134:12 140:12, 17 141:3, 8, 9 145:20,24 155:22 159:6 163:13 166:13 174:16 175:20 176:1 179:14, 18,20 181:22, 23 182:4, 10 184:11 185:21 186:1 188:11 189:20 190:5, 7, 20 198:25 206:5 207:3 217:2 219:19, 21 220:3 223:10, 12 224:19 225:9, 12 226:5Internet 126:14Interoffice 3:12interrupt 8:5interrupted 210:14interview 86:14 87:13, 16 90:12, 15 221:2 223:11 242:20interviewed 85:19 86:3 88:5 89:25 220:18, 21interviews 65:13 84:14intoxicated 28:11,22intoxication 28:6inve 254:11invest 219:12investi 217:15investigate 80:24 81:23 130:17

131:23 148:3 256:10 260:12, 17investigated 81:3 116:20 129:6 140:12 160:7 206:6 213:13, 24investigating 51:25 52:8 57:18 58:5 84:8, 20 111:18, 20 117:1 126:9 166:10 167:9, 24 168:1 173:12 175:7, 21 182:10 217:15 218:3, 5, 6,9, 12 221:1 252:21 254:25investigation 11:15 18:5, 12, 25 19:3,17 42:16 60:10 65:5, 7 84:1, 5, 23 86:17, 20 87:8, 20,21 88:20, 23 89:6 90:1 110:6, 21, 22 111:12, 21 114:19,22 115:1, 9, 13, 16 116:1, 6, 7, 8 117:5,6, 11, 13 118:1, 7,21 119:10 120:20,22 121:12, 16, 19 123:2 124:2, 16, 21,22 127:21, 24 128:6 129:16 130:24 132:2 133:17 134:3 140:15, 17 145:25 146:1, 6, 9, 20 147:10, 21 148:10,14, 24 149:8, 12, 14,16 150:3, 21 151:6,11, 11, 13, 16 152:7,13, 23 153:5, 10, 16,22 154:16 156:13,22 157:4, 19 158:3,7, 13, 21 159:6, 6, 7,21 160:17 161:22 162:5, 7, 13 163:3,6, 10, 13, 18 164:4,16, 17, 19, 21, 21, 25 165:3, 8, 13, 24 166:3, 9, 14, 14, 15 167:8, 19, 20

168:10, 21 171:20 172:16 173:8, 25 174:3, 9, 16, 24 175:23, 25 176:2, 3,4, 19 177:1, 8 181:23, 24 182:5 189:20 191:4, 12,13, 21 194:7 195:18 196:10, 13,15, 16 197:5 199:3,4, 25 200:4 202:13,24 204:15, 20 206:5 207:3, 23 213:14, 17 214:5, 6,11, 15 215:17 216:3, 6, 20 217:16 218:14, 18, 22 219:11, 13, 17, 22 226:4 237:8, 10 251:23 252:25 253:2 254:10, 18 255:8 256:13, 14 259:1 264:4investigations 107:22, 24 113:16 114:18 126:20 203:9 254:14, 16 263:18investigator 118:16 119:23 130:8, 9, 15,16 185:21investigators 47:3 118:17invited 49:5 66:4,4inviting 39:21involved 11:12 35:5 58:8 59:18 65:22 84:3 110:12 120:24 123:3 128:8 137:15 148:5 160:10 163:19, 20 164:17 178:9 191:6 200:4 247:18, 19, 20, 21 256:11 260:14 267:16, 17involvement 36:17 99:23 134:3

135:8 173:4 198:22involves 150:24 151:18 161:1involving 76:8 145:14 162:8 171:13 185:2 216:23issue 7:1 24:21 25:6, 8 43:12 120:25 142:21 185:20, 24, 25 228:15 236:9 252:3 259:19issued 14:17 235:6issues 24:22, 23 217:3 225:25 239:19 252:10 256:2it' 138:25it, 157:3 224:2 226:13 242:13I-Team 3:22items 87:19its 84:4

< J >Jack 17:11JAMES 1:17 2:18 3:3 5:17 6:10, 17 68:18, 24 142:2, 11 207:9, 15 257:3 265:6 266:20, 24 267:7January 3:12 23:23 31:24 68:4Jim 5:25 229:24Job 1:25 19:10 23:24 24:7 25:19 118:10Joe 15:4 20:13Johnson 2:7 6:7 119:23 128:19 129:9, 13 130:11 131:2 132:12, 17 133:7, 19 140:11 178:1 179:19 180:10, 20 181:12 183:17, 22 185:8,15 186:8, 13 187:12, 19 188:23

189:14 192:15 193:19, 24 194:1, 6,11, 15 195:5, 7, 16 196:2, 6, 9 198:6,21 200:9 205:10 206:19 209:14 252:23Johnson's 15:3 19:22 178:20 205:2Join 33:6, 21 34:23 36:4 64:9 70:7 71:1 108:6 125:7 153:24 154:23 175:11 192:10 198:15 217:22 243:10, 18Jon 252:13judgment 225:25July 4:2, 8 42:5 44:6 75:12, 23 76:7, 15 77:6 82:19 103:23 123:16 146:18 150:2 155:9 168:7 169:20 170:13 176:16, 20 183:13 194:17 195:16 200:7 201:6 229:3 235:11, 20, 25 244:19 261:24 262:2, 5June 166:1 177:25, 25jurisdiction 33:24 34:18, 19 58:4 70:21 247:13jurisdictions 34:3,4, 5justifications 237:1juvenile 29:20 185:2

< K >KARA 2:7 6:5 9:19keep 38:7 107:10 108:8, 18, 21, 22 109:3, 13, 14, 19 110:4, 16 112:9, 22,

24 113:9 117:10 138:25 141:5 180:1 190:16 201:16 224:23keeping 110:19Kelesis 2:4 5:5, 24KENNETH 2:20 5:7kept 107:7 108:3,13, 22, 23 111:13,25 112:5, 6, 7 113:2 135:4 201:17 249:13KETSAA 1:17 3:3 4:7 5:17 6:10, 17 18:10 68:18, 24 104:1, 5,22 105:24 106:4 109:6 119:2, 24 122:5 125:23 126:12 128:18, 18 129:13 131:3, 22 133:21 134:5 135:12 137:16 138:13, 21, 22 139:6, 11 140:11 142:2, 11 178:5, 14 181:2 184:21 186:24 192:17 205:13, 14, 22 207:9, 16 210:12,17, 19 226:15 246:7 257:3 265:6 266:20, 24 267:7K-e-t-s-a-a 6:17Ketsaa, 105:5 136:9 209:20Ketsaa's 121:17 122:7 210:10, 11KEVIN 1:9 2:17 6:1, 1 36:23 66:5,7 76:20 78:17, 25 173:17, 22 232:17keys 33:2 34:15kid 29:10 191:3,17kids 233:8, 24 242:21 243:6kill 205:4

killed 32:22 35:6 36:25 79:17 125:2 199:22killing 232:24kind 7:1 8:5 23:14 25:12 37:22 82:23 86:7 107:18 108:12 117:1 130:1, 22 134:14 135:17 142:21 144:3 145:25 159:5, 11 187:20 188:7, 9, 21 209:16 216:5 220:14kinds 107:19 201:21kit 30:20knew 20:17, 21 48:16 50:16 53:17 60:9 69:21 73:23 74:6 76:6 78:10 86:22 87:6 89:19 95:5, 12 97:24 98:5 99:14 134:20, 20 137:4,10, 18, 23, 25 138:10 144:15, 18 146:21 150:17 171:10 173:16, 21 178:19 189:18 200:11 201:16 206:15 214:22 218:4 240:19 242:7, 9, 17 259:14,16 263:24 264:3knew, 200:20know 8:8 9:3, 9,11 11:10, 13, 16 12:21 13:2, 22 14:13 16:13 19:18 20:10, 11, 12 22:7, 9, 11 23:1 26:16 30:7 31:13,18 32:8 33:10 34:9 35:7 38:9 39:25 40:8, 16, 17 41:3, 6 43:6, 11, 12,13 44:14 45:17 46:5 47:3 48:24 50:15 51:1, 3, 16,

20, 24 52:24 53:13 55:23 56:2, 5, 10,13, 15, 16 58:20 61:7 62:18 64:16 65:1 66:14, 17 67:11, 23 69:15 71:17 72:8, 19 73:3, 3, 21, 22, 25 75:6, 19, 25 77:1 78:19, 21, 24 83:1,4, 7 84:12, 20 85:2,15 86:9, 15, 18, 19,21 87:2, 11 88:2,25 89:4, 20, 20 91:4, 6, 8, 13, 18, 20,22 93:8 94:19 98:6, 24 99:8, 8, 13 100:7 101:6, 8, 21 102:8 105:18 107:19 108:17 114:13 115:15 116:20 118:1 122:12 123:4 127:9, 13, 15 129:12 130:13, 15 134:24 138:2, 5 141:2 143:23 144:24 146:8 147:18 148:14 149:11, 17, 23 151:5 157:21, 23,24 159:14, 19, 25 160:3, 4, 23 162:12 168:1 173:13, 23,24 175:7, 18 177:5 178:15 181:16 182:2, 8 183:24 184:13 185:20 186:22 188:4, 5 190:13 192:3 193:14 194:3, 25 197:2 199:5, 11 200:9, 24 201:18 202:18 203:2 206:3, 8 208:4 209:1, 23 211:18 218:13 219:23, 23,24 220:10, 11 224:5, 14, 15, 16 227:21, 22 231:6, 7 238:18 239:15

240:2, 10, 21 242:12 243:20 244:3 246:4, 18 247:2, 4, 5 248:17,18 249:13, 14, 17,18 250:5, 5 251:15 254:12 255:4, 12 256:21, 23 257:1, 8,13, 13, 14 258:18,24 260:11 261:11,12 262:13 264:7, 7knowledge 76:6 223:13 226:5known 98:3 145:21 184:5 187:25 219:21 255:20

< L >LaBorde 1:24 5:12 267:5, 23laid 227:9language 245:3, 14Las 1:22 2:5, 10,15, 20 5:6, 11 12:6,16late 193:11 199:17laundry 22:10 95:9Laura 62:23 63:2,4 64:16LAURSEN 2:20 5:7law 7:12 27:8 65:5, 8, 9 80:16 247:17laws 34:1lawsuit 6:24 103:2 123:15 157:17 202:22 208:3 242:25 244:24lawsuits 157:14Lazzarotto 17:11lead 213:7 236:23leads 160:10 199:23 200:2 243:14leak 261:19leaking 248:3learn 75:24 76:7

learned 76:14, 21,25 125:15 196:3 241:3, 4leave 70:12 156:9 232:19 262:7leaves 52:25leaving 59:17led 36:23 121:18 129:2 141:13 173:5 176:25 215:2 218:20 239:10left 52:22 57:22 65:25 70:8, 22 77:23 78:9 93:21 116:14 132:19 140:23 166:15 178:2 180:7 187:5 199:22 228:11 233:12 249:19 262:9Legal 2:23 5:8 21:3 27:22 28:6 77:25 83:25, 25 146:13, 14 149:21 150:2, 8, 25 151:4,14, 19, 24 152:1, 5,20, 25 153:9, 15, 19 154:1, 10 156:7, 12,14, 23 157:2, 9, 10,12 164:4 170:5 171:11 176:18, 25 177:7 183:14 199:23 202:12, 21 203:7 204:3, 7, 12,21 212:13, 15 213:2 214:20, 22,23 215:1, 3, 4, 4 244:1, 5Legislative 108:14lengthy 58:20Letter 3:20 4:10 44:25 45:3, 6 155:9 159:25 169:20, 23 170:4,13 171:5, 6 174:10 176:12 195:19 236:21 250:19 255:14 258:8, 9, 12,16, 17, 23 259:9, 22 260:7, 24

letters 171:12, 19 172:12 173:1 174:5, 15, 15level 24:12 119:21,24 120:16 134:25 255:11Lewis 2:14license 34:17 247:16licensed 267:5Lieutenant 23:18,19 24:17, 18, 24 25:3, 3, 9, 13life-threatening 247:10light 134:23 233:11liked 134:1limit 27:22 28:6limited 33:24 34:3 115:25limited-jurisdiction 33:25LINDA 1:4, 5 2:25LINE 4:15 43:19 81:16 83:1, 4 102:9 161:7 195:10 226:21 238:1 250:5 255:17 266:2lines 61:6 84:9link 44:8list 11:1 15:11 22:10 54:2 72:24 73:7, 8, 22 74:20 80:13 94:1, 23 95:3, 9, 11 99:21 101:10 105:3 106:25 220:14 246:15listed 80:17 96:23 137:24listen 129:25 200:5 226:12listened 197:12lists 80:20 96:18 138:4 256:6, 6little 66:3 68:6, 8 69:9 135:21 226:8, 8 249:14

252:2LLP 2:9, 14LMT 63:2, 19LMT's 64:2local 34:18located 5:10location 5:4log 13:21 63:11logged 62:24 80:23long 7:7 10:4 24:16 87:16 134:14 135:7 157:11 223:19, 22longer 127:15 182:22 249:2look 12:17 22:5 38:17 44:6, 14 45:24 48:2, 12 149:19 171:5 188:12 197:17 198:1, 7 227:23 234:17 235:23 237:13 239:14 242:6 250:24 257:2 262:12looked 11:2 12:21 15:7, 12 37:19, 21 44:15 45:3, 10, 17,18 47:22 127:25 178:18 179:2, 9, 20 197:18 230:19 242:20looking 44:1, 23 48:8looks 62:7 92:3 144:3 178:23 252:18Loren 2:7 6:7 15:3 19:22 119:23 128:18 129:9, 13 130:10 131:2 132:12, 16 133:19 178:1, 20 180:1 183:17, 22 185:8, 15 186:7 187:12, 19 189:14 193:16 194:11, 15 195:5 200:9 205:10 206:19lose 113:2

lot 17:19 46:24 66:23 89:25 181:5 207:24 220:19 229:23 238:8love 134:2lunch 89:18 141:22Luncheon 142:5LVMPD 84:1, 4, 7lying 221:17, 20,25 222:17, 22 233:16 242:20

< M >magistrate 222:7, 7 226:23 227:20 228:8, 15 264:24magnitude 178:8mail 39:24, 25mailing 246:15main 50:2maintain 111:7 130:5maintained 62:25maintaining 244:2,3major 29:5majority 235:15making 119:20 155:4MANDO 93:18 94:14 96:25, 25Manila 107:4, 6, 8manner 22:15 41:13 50:16 76:19 160:7manual 239:25Map 3:10MARC 2:1 5:23 18:16 54:25 74:17, 17 82:7 161:6 215:2 220:9 221:20 225:17 229:22Marci 49:8, 21 50:12margarita 232:14Marissa 232:16Marissa's 232:16

Mark 2:12 6:3 54:20 86:1, 2, 8 87:1 93:22 94:6,12 95:25 96:1, 2, 7,11 97:3, 6, 7 242:19 263:13MARKED 3:9 4:1 38:4 54:19,24 55:12 61:20 77:13 82:14 92:1 169:9, 17 170:19 229:11 234:22 236:14 239:7 240:3 244:10 250:15Martha 49:10 50:1, 12Master 265:7Matt 6:2matter 34:2 211:17 216:13, 14 223:12 252:3MATTERS 1:13 5:17 31:13 216:4,18 223:3MATTHEW 2:12Mayer 219:7, 8McDade 9:19, 22,24 10:4, 16 21:9,14, 21mean 7:3 13:19 14:21 18:1 35:2,4 48:5 54:19 57:17 58:19 65:8 70:15 72:17 74:21 87:23 100:1 101:2 107:19 122:18 131:17 140:1 146:16 161:10 166:8 167:5 180:5 185:18 201:5 206:10 224:16 226:7 227:21 228:11 238:16, 23 247:23 251:21meaning 109:9 140:13means 109:9 132:6 158:9

meant 94:17 238:20media 140:5 194:18 239:5, 20,24 261:9, 15, 20medical 30:18medication 8:18, 21meet 9:15, 18 10:1, 4, 9 210:11meeting 125:16 134:6 140:7, 7 150:7, 11, 12 171:11 196:1 197:1 208:13 209:24 213:5 218:16 221:4 224:11, 14 225:1, 5,6, 16 227:16 248:2 249:4, 18, 19 255:18, 19 263:12meetings 58:21 211:6 225:3 262:18Member 5:8 25:10 248:12members 141:16 234:8, 13 238:7 244:21, 23memo 47:6, 7, 11 61:10, 23 62:5, 10,25 65:12 66:2 67:9 179:19 193:4 240:6, 18, 19,25 241:19 243:15 244:13 245:4, 23Memorandum 3:14 4:5memory 8:22 74:19, 23 229:9 247:4 262:13 263:22 264:2memos 62:11mention 160:20, 21 196:22mentioned 23:5 78:11 174:9 186:12 229:5mentions 83:22messin 255:21

met 209:19 212:15 225:6 228:21 249:21Metro 11:20 12:6,12, 16 42:15, 20 43:5, 15 51:24 53:6 54:13 59:12,21 60:2, 4, 23 65:13 66:11 72:20 73:20 79:5,23 84:25 85:19 86:19 87:1, 24 88:6 89:25 99:20 100:2, 6, 20 102:9 103:15 104:3, 3, 5,17 105:20 110:4,11, 22 111:3, 19 114:10 115:17, 18 116:2, 9, 25 117:5,10, 24 118:7, 10, 20 119:9, 16 123:3, 19 124:4, 16 125:4, 23,25 137:14 138:3,10, 13 139:2 147:7 163:10 164:15, 24 165:7 166:2, 7, 9,13 167:4, 9, 18 168:1, 9, 20 173:12,16, 21 174:22 175:3, 6, 6, 7, 17 176:12 194:12 210:4, 20 263:13,17Metro, 104:14 138:22Metropolitan 18:11 242:18Metro's 86:17 124:2 165:23 167:24 200:4 239:23middle 178:10 230:20 245:7Mike 15:2, 16 35:21 127:6mill 66:25mind 14:22 18:3 29:6, 8 30:8 153:8 230:7 238:19 241:20

minimal 120:12 228:11minor 31:9, 10 70:3, 23 174:1 186:7minors 69:23 70:22 153:11, 20 154:13 200:15 202:16minute 235:23, 24minutes 19:21 205:5, 6, 7 206:23 210:7 224:8MIRANDA 1:9 2:17 5:16 6:1 36:24 66:5, 8 78:17, 25 91:15 125:1 164:25 165:4, 8 166:3 168:10, 23 173:17,22 232:17, 17, 24Miranda's 76:20misconduct 84:3 115:22 116:17, 18,18misdemeanor 32:23, 23 247:14,14misinterpreted 235:17missed 232:7missing 80:14 113:7mistaken 104:6mix 113:14, 15moment 43:19Monday 10:10 20:4 51:10 74:6 75:4, 11 103:24 104:23 105:9 185:11, 13 189:3 210:5 211:2Mondo 93:11, 13,20 94:16 233:2money 144:13, 19 145:8, 13, 19monitoring 127:21month 252:13months 43:21, 21 63:25 67:9 68:10 99:6

Morales 2:12 6:3 71:13, 21, 22 73:1,4 75:8 94:11 95:24, 25 97:6 172:24 201:25 262:10Morales's 262:4morning 20:4 51:10, 13 57:19 66:7 69:7, 10 101:10 104:23 142:15, 17 143:10 147:22 166:7 167:4 197:12 211:2, 3mother 24:4motion 225:25move 24:2 228:14 231:25moved 24:4 206:16moving 81:15multiple 36:1, 8, 13

< N >name 5:7 6:15 12:5, 13 20:18 52:1 53:21 77:22 85:4, 6 93:16 96:7 97:18 98:2,4 99:20, 21 101:19 102:2 195:24, 25 240:15 263:14named 25:5 219:7,8Names 3:12 12:3 51:16 52:6 54:3,5, 7, 11 55:22 56:3,18, 22 57:9 59:13 71:17 72:2, 5, 19 73:13, 16, 19, 19 74:1, 3, 6 75:13, 21 78:11 88:1 94:24 95:4, 4, 9 96:19, 21 101:12 105:3 106:3, 5, 8, 23 110:11 112:2 138:2 200:20 208:25narrative 223:20

nature 40:21 179:10 194:7Nebeker 2:7 6:7 15:3 51:12 52:3,11 54:1, 21 56:25 57:12 58:10, 13, 17,23 59:14 62:2 71:24 73:13, 17 75:8 78:20 79:21 89:15 93:4, 20 104:24 105:11, 16,20 112:1 121:25 122:3, 19, 22 125:17 135:11 136:9, 15 147:11 148:21 149:1 183:7 201:25 208:13, 24 209:2, 3,19 210:2, 9, 9, 10,13, 17 211:3 233:22 261:25Nebeker's 20:1 53:24necessarily 67:25 129:10necessary 120:13 256:12necessity 235:18need 7:23 8:8 9:2, 3 43:8, 11, 11 70:19 77:15 84:18 154:19 158:25 161:10 164:19 169:6 172:20 204:25 223:22 233:11, 13 251:18needed 84:8 109:23 178:11needs 15:12 203:15negative 21:19 46:7, 8 197:17neighborhood 247:24NEVADA 1:2, 22 2:5, 10, 15, 20 5:6,11, 15 30:4, 13 238:6 267:1, 5, 20never 30:8 37:17 44:12 45:3, 5

47:4 71:23, 25 100:22 114:22 119:8 120:4 135:8 139:6 140:14, 18 141:5 146:4 165:5 169:24 179:14 189:9 231:10, 10,11 232:4 246:14 262:18Neville 12:16 51:23 53:5, 8New 24:1 26:20 27:1 32:12 33:16,25 49:1, 21 58:22 75:12 76:14 98:15 122:25 123:18 125:25 138:24 205:3news 41:24, 25 42:2, 4, 10 75:7, 11,23 76:6, 15 77:6 82:24 90:22 91:5,14 103:5 139:22 143:9, 15, 22 149:24 155:9, 12,13 176:16 187:9 194:5, 12 195:16 196:4, 10 197:12,20 198:10 200:5 201:23, 23 209:5 229:2, 4 231:5 232:23 236:19 261:9, 15, 19newscast 44:16 169:21night 57:19 92:22 191:18 200:10 231:16nine 32:11 43:21,21ninety 31:18Ninth 1:21 2:4 5:5NOON 93:8, 12Nope 262:20normal 8:5 27:18normally 140:11North 2:10notate 92:7

note 12:5, 9 13:11 72:7, 11, 13 86:16 106:18 165:22 200:3noted 84:3 116:19notes 11:19, 21, 22,23, 24 12:2, 4 13:9,25 20:24 21:25 51:18 52:6 72:25 81:23 82:1, 1, 9 86:10 186:16 267:11nothing.' 135:1Notice 4:8noticed 99:11notices 245:25notification 137:15 165:22notified 11:25 59:12 70:20 99:13 100:8notify 67:7 125:23 247:13Notwithstanding 179:17November 32:8 37:4 46:15, 17, 18,20 47:8 74:16 75:3, 10, 22, 25 76:5, 15 77:6 84:16 88:13 98:12 101:18, 25 102:4, 15, 19, 22 116:12 132:19 134:6, 12 137:4, 10 139:18 140:21 141:8 146:19 147:16 150:1 158:19 162:6 179:19 193:1, 3, 7,8, 9, 11, 11, 13 198:13 199:9, 17 208:6 219:25 261:24 262:2, 5November-ish 244:5NUMBER 3:9 4:1 5:8, 14 47:18 52:2 55:25, 25 68:17, 23 72:16 80:23 82:8 83:13

111:7, 7 112:10 128:24 142:1, 10 170:22 187:13 207:8, 14 240:15 264:8numbers 53:13 55:3 92:4numerous 11:11 29:23, 23 61:2 235:13

< O >Oasis 5:10, 13 265:8object 15:9 130:1 150:23 151:18 204:6 212:20 214:25 216:2, 15 221:7 237:3 252:9objection 15:18 18:14 27:24 33:5,18, 22 34:22 36:3,19 37:11 39:2 42:17 44:19 45:8 46:1 63:21 64:8 67:1, 18 68:5 69:25 70:6, 25 71:7 77:8, 11 80:1 90:6 99:12 108:5 109:1, 21 110:8 112:11 113:1, 13 114:1, 15 115:20 116:10 117:14 118:13 123:5 124:7, 18 125:6 135:16 136:13, 24 137:22 139:19 140:25 143:16 150:10, 16 152:17 153:1, 23 154:22 156:5, 16,24 157:7 158:4, 11 162:9 163:8, 21 165:10 168:3, 12 169:1 170:14 171:22 173:10 174:18 175:9 176:6 177:2 180:12 182:7 184:12 186:2, 9 187:21 188:14

189:21 190:9, 12 191:5, 22 192:8 193:20 198:14 200:12, 23 201:9 202:20 203:5, 13,19 211:12 213:9 214:13 216:7 217:20 218:23 224:4 238:9, 17 243:9, 17 248:5 253:3 257:18 258:13 259:3, 25obligation 33:3observe 69:23observed 7:5 69:20 70:3 90:22observing 172:24obvious 133:8, 18 262:23obviously 31:1 33:1 83:2 259:22occasion 28:10 51:6 220:22 231:4occasionally 86:10 179:4 183:24occasions 29:2, 3 35:11 36:7, 18 116:1occur 121:12 132:4 259:2occurred 57:19 60:11 152:24 158:8 165:17 182:17 257:15occurring 32:16October 4:10 67:16 68:4 240:7 241:3 243:20 244:5 248:24, 25 255:18 256:15, 17,20, 22 257:5, 10, 15 258:1, 19, 24 259:7 260:4, 7, 24 261:1off-duty 32:15 33:3 35:5 246:24offer 237:25 238:5Office 31:3, 4, 8 51:13, 22 52:3, 11,20, 25 53:1, 24 54:2 57:1, 2, 5 59:7 87:15 91:19,

20 105:13, 17 107:11 112:23 113:10 118:25 122:6, 7, 11, 20 139:12 159:10 160:2 183:21 208:14 210:10, 11 233:1 237:2 245:11, 13 249:20 252:20, 21 254:24,25 263:15officer 7:16 23:19,20 24:11 26:19 27:7, 10 28:10 29:19 30:1 33:4,16, 17 34:1 80:20,22 111:18, 20 133:8 157:19 161:23 188:12 190:7, 20 242:19 247:13 254:15officers 58:1, 12 59:19 71:18 84:2 114:11 117:2 137:24 157:6 163:18 164:8 165:14 171:13 174:17 176:20 185:4, 4 200:3, 14 202:16 239:2, 18 243:6 245:23 246:24 254:14, 16 260:17officer's 111:6offices 5:5 262:19official 39:6 66:18 108:19 191:4 192:6, 13 213:14 225:5officially 47:4 100:22 101:2 108:3 112:10 113:6, 6 243:2officials 226:11Oh 27:3 31:18 34:14, 16 54:4 78:24 83:14 98:9 159:4 169:15 229:5 250:25 262:8

Okay 7:7 11:1, 14 17:22 18:21 20:5,18, 23 21:15, 23 22:5, 8, 15, 22 23:3 27:1 29:7 30:8,12 31:14 32:2 33:15 34:11, 16 35:24 38:9, 12, 19 39:23 40:10, 13 41:18 43:18 44:10 45:21 46:5 47:16 48:1, 13 49:6 50:8 51:4, 8 52:25 53:23 54:24 55:17 63:15 65:11 67:10 68:8 69:9 70:18 72:6, 15, 23 73:1, 12 74:2 75:10, 22 76:5, 17,23 77:2 78:1, 16 79:3 80:9 82:6,10 83:9 84:11 85:3 86:3, 6, 11 88:8 91:25 92:22 93:25 94:4 95:2,8, 15 96:12 97:2,20, 24 98:5 99:2, 7 100:4, 16 101:18,24 102:4, 13, 20, 23 103:5, 9, 14 104:13 106:10, 16, 22 107:20 110:15 111:2 112:7, 22 114:4 115:2, 5 116:5, 25 117:19,20 119:14 121:25 123:17, 25 124:24 126:21 127:4 128:23 130:4, 19 131:20 132:7 134:1 135:19, 22 140:10 141:24 144:10 146:5, 18 147:5 153:7, 14, 18 154:8 156:8 157:25 159:7, 20 160:5, 9, 22, 25 161:4, 9, 17 162:2,16 164:11 165:6 166:11, 13 167:16,

17 168:6, 19 169:15, 25 170:6,18 171:18 172:2, 8,11 173:1, 15, 19, 24 174:12 175:1, 15,24 176:9, 15 177:11, 23 180:7,23 181:18 183:2 184:3 186:5, 20 187:19 189:5, 12 190:17, 24 192:22 193:18 194:11 196:1 197:9 200:17 201:2, 15 202:8, 14 203:18 204:23 205:6, 8 206:13, 22 208:5,12, 17 209:3 210:8,12 212:13 214:10 216:25 217:12 218:2, 11 219:9 220:6, 24 225:3 228:3, 9 230:17, 20 231:19 234:21 235:9 241:6 242:5, 23 245:17,22 248:25 249:10,12, 17 251:3, 5 254:5, 9, 20 255:6 257:4, 6, 6, 8, 23 258:5 260:6, 16 262:24 263:17Okazaki 252:14old 66:4omitted 73:21Once 6:22 103:9 155:16 189:10 246:2 254:18once-in-a-lifetime 221:1one-page 13:11ones 22:8 23:2 56:8 72:7, 24 81:1 96:22 183:13ongoing 260:25on-line 43:23, 24 44:6, 16, 21, 23 45:5, 10, 25on-the-job 27:14oOo 142:6, 8

open 57:20 60:7,18, 24 84:17 107:21 108:8, 24 110:18 111:15 112:10, 20 113:6, 6 114:8, 14 133:8, 10,21, 24 163:12 173:8 174:16 175:20 176:2opened 108:3, 20 110:5 113:21 114:25 115:8, 12 146:9, 20 148:14 246:4opening 115:3 133:19 200:4operation 236:3operations 25:22 26:3, 14 131:15 178:14 236:5opinion 227:21opposed 85:10 88:6 108:19 164:8 193:11 259:15opposite 30:5 121:22order 46:16 47:18 64:11, 25 80:16 91:8 119:7 121:9 132:10 133:5 140:15 220:5 224:23orders 245:25organization 235:15 237:1, 17 238:7original 44:15 56:21 92:11 103:23 111:25 112:6, 7Oscar 12:6, 14 52:1 53:21 58:25 65:19other's 226:3outcome 176:4outset 218:15 220:25outside 32:25 65:5, 8 116:20 183:21 206:13

oversee 46:21 128:5Overseeing 25:21 137:14overseer 46:24Owens 71:22

P.C 2:18p.m 265:12packet 229:23pad 86:7padlock 206:14PAGE 3:2, 10 4:4,9, 15 9:12 13:25 81:5 153:25 171:5 176:9 181:10 230:21 232:23 250:20, 24,25 251:2, 7 252:12 255:15 266:2pages 3:20 4:10 171:7 205:2, 4 250:18 255:14paid 23:16 61:18,18 144:13, 18 145:8, 13, 19panel 256:8panicked 30:2paper 12:21 52:5 54:7, 21 56:22 97:12, 13 106:17 111:25 112:1 141:2 189:23 201:12 211:4 225:7paper's 193:12paperwork 10:24 11:12 13:9, 19 47:25 48:7 130:6paragraph 132:4 230:21 231:22 232:5, 12 233:6, 20 236:24 237:17 242:16 245:8paragraphs 232:12paramedic 23:25 24:1parents 31:9PARK 2:12 6:2, 2 33:6, 21 34:23

36:4 55:8, 11 63:21 64:9 70:7 71:1 77:17, 19 92:14 108:6 125:6 153:24 154:23 170:23 175:11 192:10 198:15 203:14 217:20 226:7, 19 229:14, 20, 22 230:2 234:25 243:9, 18 265:1parking 181:5Parkway 2:9, 14part 18:13 27:9 29:17 32:13, 14 101:16 117:6 123:4 134:25 153:3 169:20 172:23 180:15 183:25 184:8 191:4, 13 197:13 204:15 207:2 209:10 216:6 245:8 251:14partially 207:6participant 248:11participated 17:4particular 15:7 20:25 60:13 105:3 121:12 181:3, 9particularly 66:22 90:3 243:13parties 35:17 36:5,21 69:11, 15, 23 70:4, 24 184:22, 23 186:13, 14, 21 187:4, 13, 18 188:8,10 190:8 191:17,18 207:20 246:21 267:15, 15, 17, 17partner 29:17 30:10parts 13:14 20:3 175:2part-time 27:7party 12:4 16:10,23, 25 35:9, 14, 14,15, 18, 20, 23, 24 36:8, 10, 11 37:3, 7,

8, 15, 18, 24 39:8,21, 22 40:21 41:12,12 42:16, 21 43:22 48:22, 23 49:3, 4,25 50:7, 10, 17, 17,20, 22, 24 51:2, 5, 5,9, 14, 17 52:16, 23 56:9, 11, 13, 16, 20 57:17, 21 58:9, 12,18 59:17, 20 61:5,10 65:14, 22, 25 68:3 69:17 70:9,21 71:6 72:1 73:9, 24 74:7, 10,15 75:4, 5, 9, 11, 13,24 76:2, 14 77:4 78:13 79:9, 19 85:23 92:23 93:1 94:15, 21 95:5, 10 96:13, 24 97:14 98:11 99:11 100:5, 8, 19, 23 101:5, 7, 9, 11, 15,21 102:1, 6, 7, 17,22 103:7, 10 104:5,25 110:14 116:13,14 122:1 123:1, 12 124:2 125:1 134:5 136:10 137:5 139:17 142:22 144:14, 21 145:9, 14, 19 146:11, 21, 22 148:25 149:9, 15 150:4, 22 152:9, 16 153:21 154:14 156:4, 13, 22 157:6 158:10, 22 160:11,18, 21 161:2, 24 162:3, 3, 8 163:19,20 164:5 166:4 168:11, 24 171:14 177:21 183:5, 19 184:19, 22 185:3, 4 186:6, 16, 21 187:4,5, 8 188:20, 24 189:8, 15, 16, 18 191:2 194:1 196:25 197:24 199:9, 21, 22 201:8 207:21 208:9, 15

209:4, 4, 9, 10, 11,12 228:19, 22, 25 229:1, 6 230:22, 23 231:3, 16 246:8, 13 263:19, 24 264:4,16

< ' >'party 185:1

party, 16:22pass 138:13passed 105:4 136:16, 23passing 139:12, 14,17Pat 12:15 51:23 53:5, 8patrol 23:19patrolmen 206:25paycheck' 255:22payment 61:11 66:14, 20 68:3 76:24 143:21 144:3 155:5payout 152:15peek 143:5penalty 266:20pending 9:4 157:14, 17 212:5 244:24 264:22Penny 78:12 197:23 198:2 242:21people 12:3 36:1,8, 13, 14 39:21 44:25 50:9 51:16 71:15 73:8, 14, 23 74:6 75:5 87:9 89:10 96:21 110:12 140:11, 14 146:21 165:14, 14 167:21 188:1 195:11 197:15 199:12, 21 200:6,14, 19 201:3, 11, 11,17 202:1, 18 207:25 226:9, 9 229:3

percent 26:2 136:21 194:3 255:12percipient 7:2Perfect 92:9period 83:20 131:7 179:22 180:4 235:7 249:15perjury 266:20permanent 25:4, 5person 33:10 42:15, 20, 23 43:3 46:11 53:18 57:22 62:22 63:6,10 64:11 65:21, 21 70:9 86:3 93:4 126:15 127:6, 19 255:25 267:16personal 40:21 107:12, 20 112:15 113:10 219:7 235:18 255:17Personally 28:14 55:15 208:13 247:18, 21personnel 180:15 211:17 216:4, 13,14, 18 217:2, 5 251:14, 17 252:2, 3,10PETERSON 1:2, 4,5, 5, 6 2:24, 25 5:16 91:14 160:19 171:15 173:5 192:16 230:11 232:24 264:5PETERSON00122-124 3:25Peterson's 241:16Phil 6:6 15:2, 2 17:24phone 21:13, 15,21 30:3, 12, 13 52:2 53:13 55:24 57:10 60:4 79:14 88:1 123:12 178:7 179:5 183:7 226:24



228:8photo 232:14photograph 14:5, 6photographs 14:3 23:4, 5pick 27:16 228:12picked 17:12 40:6picture 44:9 197:19 235:3pictures 242:22piece 12:21 52:5 54:7, 21 56:21 141:2 189:23 211:3 224:22 225:7pieces 97:11, 13place 61:3 68:14 87:14 111:23 231:17 256:15 267:8plaintiff 5:19Plaintiffs 1:7 2:1 5:24plate 34:18plates 247:16play 120:20play, 120:19playing 70:23 124:25 172:24 173:3, 16, 21 232:18please 5:20 6:16 8:7 9:9 38:17 43:9 68:16 92:12 100:13 141:25 161:8 166:24 170:1 249:11 251:9 252:19 254:23 256:9, 9 260:12PLUS 96:5PM 93:18 94:13pmsh 39:9POA 108:16POA-sponsored 35:18, 23point 37:20 43:23 44:14 46:20 50:20 59:25 61:8,17, 19 66:6 73:14 75:20, 22 77:1

87:12 93:24 98:6 99:4 101:14 102:8 114:7 127:12 129:5 142:18, 19, 20 145:7, 11, 17 146:13 149:20 153:13, 14 157:3 164:10, 11 168:6 188:13 193:4 196:20 198:10 204:25 231:5, 8, 14 239:22 243:25pointing 226:2points 46:23Police 3:24 6:25 18:11 23:9, 22 24:3, 11 26:18 27:7, 10, 16 31:8,17 32:1, 17 33:3,16, 25 34:1 45:1 59:19 81:6 82:18 84:2 85:1 98:18 103:11 111:4 122:25 124:12, 24 125:3, 11 128:1 132:8 133:12 136:17 137:24 161:23 163:5, 18 164:8 167:18 174:6, 7, 14 175:15 176:19 180:19 191:1 196:4 200:3 202:14 205:25 213:24 214:2, 4 216:19 226:2 227:2 230:22 232:6, 13 242:18 246:24 247:12 254:14, 15,16 260:17policeman 26:23 27:1policies 110:2 261:22policy 60:3, 13, 23 64:6 110:18 111:2 129:10 130:12, 23 167:18 190:18 239:22, 23,

24 247:1 261:7, 12,14pong 39:10 70:24 124:25 172:25 173:3, 17, 21 232:18pontificate 238:8portions 14:24position 23:7, 12 25:5 28:9 46:13 49:18 50:10 119:3 120:19 127:9 131:21 132:20 134:8 137:17 140:16 184:10 190:19 234:16 235:25possession 31:10 79:4possibility 185:25 202:13possible 40:16, 18 42:3 44:2 48:20 57:24 58:19 90:24 91:1 154:17, 21 188:6 189:1 204:1, 2 241:17possibly 51:17 57:25 59:19 60:10 145:22 174:22post 40:20, 24posted 39:15posting 239:3, 3, 19Post-it 13:11 14:1 20:24 22:1 107:1Power 30:4, 13 181:19 182:11 205:25 206:20, 21,23practice 60:23Practices 239:22 261:22preclude 226:18 261:14precluded 152:13 254:15preference 203:25premises 28:22

preparation 9:15 10:13 11:8 13:14,15 14:2 21:1, 8, 23 22:3 37:25 48:4,5, 9prepare 11:24 235:12 245:3prepared 208:24 209:1 245:9, 15 250:19presence 70:4Present 2:20 5:20 126:12 133:11 193:19 212:21 213:2press 248:4pressure 8:21Presumably 8:3 233:6pretty 89:18, 19 139:9 178:4, 16, 25 185:5 197:11 208:1 209:17 239:1prevent 8:19 158:1prevents 261:7previous 231:7 255:19previously 74:11 75:17 150:8, 12 230:18primary 58:4 247:13Prior 26:21 37:8 48:25 50:17 51:5 69:9 74:3 83:7 90:23 133:4 170:13 177:24, 24 213:5 242:11, 24 253:14 267:9prisoner 30:21, 22private 36:21 109:15, 20 216:4 255:25privately 109:14 249:21privilege 15:11 16:1 151:1, 20 204:16 212:22 213:1 214:25privileged 204:7, 16

Probably 28:8 31:3, 7 32:11 39:4 50:14 56:23 58:1, 9, 12 65:18 87:18 149:10, 11 185:9 190:23 211:21 243:25 245:5 246:3 258:17 259:16probation 50:3, 6, 7problem 113:5 212:9 223:25 239:2problems 211:9proc 25:7procedural 80:17procedurally 40:20 64:3procedure 41:5, 6 130:12 239:25 247:1procedures 29:16 110:2 261:22proceeded 185:1proceedings 216:3,21 221:9 223:6 235:16process 7:20 8:15 25:7 40:23 81:19 213:22, 23, 25 214:1produced 47:12product 241:23professional 181:5 235:18professionally 180:11progress 247:10prohibited 50:6promoted 25:1 26:8 262:11prompted 65:1propensity 32:21proper 129:2property 181:9protect 233:13protected 15:25 151:20 213:1protocol 129:2provide 60:24 88:11 139:2

174:24 245:11 246:21provided 10:22 11:15, 16, 20 12:18,20, 24 13:5, 8 20:24 57:9 61:9 88:8 104:6, 24 122:4 151:24 152:1 220:4 224:22 225:2 267:12provides 54:2providing 245:1public 239:4pull 29:24Purcell 83:9, 12, 15,16 195:1, 5, 7, 21 196:2Purcell's 195:23purpose 48:15, 18 182:18 192:2, 3purposes 111:13pursuant 267:18put 25:12 29:13,13, 15 30:6, 17 33:2 40:14, 25 47:19 61:15 64:14 106:4, 11, 11 109:6, 10 113:24 233:11 237:18 239:23 240:14, 15 244:21, 23putting 34:15Pyatt 2:18

< Q >Quantico 179:11quarrel 193:10question 8:10 9:4,7 13:19 21:18 22:4 75:1, 15 76:13 79:13 90:8 93:22 94:6, 11 95:25 96:1, 2 97:2, 6, 7 100:12,16 101:13 107:25 117:21 127:9 129:20 130:1 132:1 134:1, 14 135:2, 8, 17, 20, 20 149:4 154:5, 8

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< V >Vegas 1:22 2:5,10, 15, 20 5:6, 11 12:6, 16VEHICLE 94:9verbal 66:19verbally 54:5 74:3verify 125:19

version 55:1, 6versus 25:9 236:12victim 130:9 247:22Video 2:23 5:4, 8 68:19, 25 142:3, 12 162:21, 25 207:10,17 211:23 212:2 263:2, 6 265:10videographed 5:18 68:18, 24 142:2, 10 207:8, 15 265:6VIDEOGRAPHER 5:2 7:23 68:16,22 141:25 142:9 162:19, 23 207:7,13 211:22 212:1 262:25 263:4 265:5Videographers 5:9Videotape 1:19view 171:19 172:14violated 256:8 260:10violation 129:10violations 80:16,16, 17, 17 130:12 256:7Violence 53:10, 11violent 32:20Virginia 179:11visit 58:15, 15visited 233:21vs 1:8

< W >wait 8:10 114:13,17, 19 115:8, 17 176:3 203:8 205:7 234:16waited 53:25 115:12waiting 228:2walked 59:9 187:1walking 34:8 226:21Wamsley 3:14 41:12 51:5, 5 55:23 56:23 61:8 67:7 68:2 71:13

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< Z >Zeddies 262:16Zuniga 2:12 6:3 55:23 56:24 71:13 72:3 73:5,5 94:8, 9, 14 95:21 173:16 210:22 232:13Zuniga's 78:17, 25 79:15

WORD LIST

< ' >' (2)

< $ >$300,000 (1)

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31 (1)31st (2)3-5 (1)3773 (1)38 (1)3993 (1)3rd (2)

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93 (1)94 (1)99 (3)9-millimeter (1)9th (2)

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DESIGNEE (9)Det (4)detail (2)details (3)Detective (22)detectives (1)determination (4)determine (3)determining (2)didn't, (2)died (1)difference (4)differences (2)different (20)differently (1)dinner (6)direct (9)directed (10)directing (1)direction (5)directions (1)directly (7)dis (1)disagree (3)disciplinary (3)discipline (24)disciplined (2)discovery (2)discrepancy (1)discuss (7)discussed (11)discusses (1)discussing (2)discussion (14)discussions (12)disfavorable (1)disk (6)disks (2)dispatch (20)dispatcher (12)dispatcher, (1)dispatchers (34)dispatcher's (4)DISPATCHERS, (1)disposition (4)dispute (5)dissatisfied (1)distinction (1)distributed (1)

DISTRICT (86)District's (3)District-sponsored (1)div (1)divided (1)division (11)divulge (1)DOB (1)Document (36)documentation (2)documented (1)Documents (35)doing (15)door (1)double (2)downloaded (1)downtime (1)dozen (1)dozens (1)DR (5)drawer (5)Drinking (29)drinks (1)drive (1)driven (1)drivers (1)driving (7)dropped (4)drove (2)drunk (6)drunken (1)due (1)DUI (2)DUIs (1)duly (3)duties (3)duty (3)dying (1)

< E >earlier (11)early (4)eating (1)effect (3)effecting (1)effectuated (1)effort (2)egregious (1)eight (5)

either (19)electronic (2)electronically (3)else's (1)E-mail (16)E-mails (3)embarrass (1)embarrassment (1)emotions (1)Employee (8)Employee-Management (4)Employees (30)employment (1)EMR (10)EMT (2)ended (1)enforcement (5)entitled (2)environment (1)EOC (1)Erik (2)ESQ (4)essentially (1)et (2)evening (1)event (5)events (7)eventually (2)everybody (5)everything's (2)evidence (2)exact (5)exactly (13)Examination (2)examined (2)example (2)exception (1)excluding (2)Exclusively (3)executive (3)exhausted (2)Exhibit (57)exhibits (4)existed (1)existence (1)exists (1)expand (1)expected (2)explore (2)

express (1)extent (5)extortion (4)extremely (1)

< F >Facebook (6)fact (16)facts (2)fail (1)fair (11)fairytales (2)familiar (2)far (20)fashion (2)fatal (12)fatality (1)favor (1)favorable (1)FBI (23)fear (1)February (7)federal (2)feed (1)feel (5)feels (2)felony (4)felt (3)fighting (1)figure (6)file (33)file, (1)filed (6)files (17)Filiberto (1)filing (4)fill (2)filled (4)finalized (1)finally (2)financial (1)financially (1)find (45)finding (3)findings (1)fine (13)fine, (1)fingers (1)finish (6)finished (3)

Fire (2)firefighter (2)fireman (2)firing (1)firm (2)first (49)first-aid (1)five (4)fixed (4)flier (16)fliers (2)flip (1)flip-flop (1)flip-flopped (1)flipped (2)folder (12)follow (11)Followed (8)following (10)follows (2)follow-up (3)foregoing (1)forged (1)forget (2)forgotten (1)form (123)formal (5)Formally (1)format (1)formed (1)former (2)forms (1)forth (6)forth, (1)forum (2)forward (12)Forwarded (7)forwarding (2)found (19)foundation (27)four (4)fourth (1)frame (14)frames (1)FRANCIS (3)frankly (1)FRCP (1)free (2)free-for-all (1)friend (1)

friendly (3)friends (5)friendship (2)front (16)frustration (1)FST (1)fueled (1)full (1)full-time (2)function (1)further (4)

< G >Gamboa (8)garage (1)gather (1)gathered (1)general (16)generally (3)generically (1)gentleman (1)gestured (1)getting (10)Giles (8)girl (1)girlfriend (2)gist (1)give (32)given (14)given, (1)gives (1)giving (5)Glaviano (1)go (67)goes (10)goes' (1)going (87)good (10)Goodwin (5)gosh (1)gossiped (1)gossipy (3)gotten (4)graduation (2)great (1)greatly (1)Greenberg (2)Gregory (8)gross (2)group (1)

guess (13)guessing (2)guest (1)guests (1)Guild (1)gun (5)guy (14)guys (5)

< H >habit (2)Half (2)hand (5)handcuffed (2)handed (6)handheld (1)handle (5)handled (14)hands (1)handsfree (1)handwriting (1)Handwritten (6)hang (1)happen (16)happened (46)happened, (1)happening (4)happenstance (1)Happy (3)harass (1)harassed (2)harassing (4)harassment (3)hard (1)

< ' >'He (3)

< H >head (3)headbutt (1)heads-up (9)health (1)hear (8)heard (63)hearing (6)heart (1)heated (1)He'd (2)held (4)

help (6)helped (1)helpful (1)helping (1)HENDRICKS (205)hereunto (1)Hey (9)Higgins (11)high (1)Highlights (5)high-school (1)hiring (1)history (2)Hoffman (1)hold (3)holiday (3)Holidays (2)home (4)honest (3)hope (2)hosted (2)hosting (1)hour (6)hours (5)house (17)houses (1)Howard (2)how'd (1)HR (2)Hughes (2)human (2)humiliated (1)hundred (3)hung (1)hurt (1)husband (1)hyphen (1)hypothetical (1)hypothetically (2)

IA (24)IACP (1)ICE (2)idea (22)identifiably (1)identification (15)identified (3)identify (7)

II (1)illegal (2)illness (1)immediate (1)immediately (3)Immigrations (1)imminent (1)impartiality (1)impetus (1)importance (1)important (1)impossible (1)impression (3)inappropriate (5)inappropriately (1)inarticulately (1)incidence (1)incident (25)incidents (3)include (6)included (5)including (2)inclusive (1)independent (6)indicate (4)indicated (15)indicates (1)individual (2)individually (3)individuals (4)inevitably (1)influence (3)info (6)inform (2)informal (4)Informally (1)informant (1)Information (164)information, (1)information,' (1)informed (2)initial (8)initial, (1)initialed (1)initially (6)initially, (1)initials (2)initiate (2)initiated (2)Initiative (2)

injured (3)injuries (1)injury (1)innuendos (1)input (2)inquiry (1)in-service (2)inside (1)instance (3)instances (1)instigate (1)instruct (4)INSTRUCTED (3)instructing (5)instruction (2)instructions (1)insurance (13)intel (1)InterAct (2)interest (1)interested (1)interests (1)intermediate (1)intermittently (2)Internal (83)Internet (1)Interoffice (1)interrupt (1)interrupted (1)interview (8)interviewed (6)interviews (2)intoxicated (2)intoxication (1)inve (1)invest (1)investi (1)investigate (8)investigated (8)investigating (27)investigation (210)investigations (9)investigator (7)investigators (2)invited (3)inviting (1)involved (27)involvement (6)involves (3)involving (6)

issue (14)issued (2)issues (7)it' (1)it, (4)I-Team (1)items (1)its (1)

< J >Jack (1)JAMES (17)January (4)Jim (2)Job (6)Joe (2)Johnson (48)Johnson's (4)Join (17)Jon (1)judgment (1)July (33)June (3)jurisdiction (6)jurisdictions (3)justifications (1)juvenile (2)

< K >KARA (3)keep (23)keeping (1)Kelesis (3)KENNETH (2)kept (14)KETSAA (58)K-e-t-s-a-a (1)Ketsaa, (3)Ketsaa's (4)KEVIN (13)keys (2)kid (3)kids (4)kill (1)killed (6)killing (1)kind (26)kinds (2)kit (1)knew (49)

knew, (1)know (250)knowledge (3)known (6)

< L >LaBorde (4)laid (1)language (2)Las (9)late (2)laundry (2)Laura (4)LAURSEN (2)law (7)laws (1)lawsuit (8)lawsuits (1)Lazzarotto (1)lead (2)leads (4)leak (1)leaking (1)learn (2)learned (7)leave (4)leaves (1)leaving (1)led (9)left (20)Legal (62)Legislative (1)lengthy (1)Letter (29)letters (7)level (6)Lewis (1)license (2)licensed (1)Lieutenant (9)life-threatening (1)light (2)liked (1)limit (2)limited (3)limited-jurisdiction (1)LINDA (3)LINE (13)lines (2)

link (1)list (21)listed (3)listen (3)listened (1)lists (5)little (9)LLP (2)LMT (2)LMT's (1)local (1)located (1)location (1)log (2)logged (2)long (9)longer (3)look (23)looked (20)looking (3)looks (5)Loren (31)lose (1)lot (9)love (1)lunch (2)Luncheon (1)LVMPD (3)lying (7)

< M >magistrate (7)magnitude (1)mail (2)mailing (1)main (1)maintain (2)maintained (1)maintaining (2)major (1)majority (1)making (2)MANDO (4)Manila (3)manner (5)manual (1)Map (1)MARC (13)Marci (3)margarita (1)

Marissa (1)Marissa's (1)Mark (20)MARKED (20)Martha (3)Master (1)Matt (1)matter (6)MATTERS (6)MATTHEW (1)Mayer (2)McDade (8)mean (37)meaning (2)means (3)meant (2)media (8)medical (1)medication (2)meet (6)meeting (29)meetings (4)Member (3)members (6)memo (22)Memorandum (2)memory (8)memos (1)mention (3)mentioned (5)mentions (1)messin (1)met (5)Metro (101)Metro, (2)Metropolitan (2)Metro's (6)middle (3)Mike (4)mill (1)mind (9)minimal (2)minor (6)minors (7)minute (2)minutes (7)MIRANDA (22)Miranda's (1)misconduct (5)misdemeanor (4)

misinterpreted (1)missed (1)missing (2)mistaken (1)mix (2)moment (1)Monday (14)Mondo (5)money (5)monitoring (1)month (1)months (6)Morales (15)Morales's (1)morning (18)mother (1)motion (1)move (3)moved (2)moving (1)multiple (3)

< N >name (23)named (3)Names (46)narrative (1)nature (3)Nebeker (57)Nebeker's (2)necessarily (2)necessary (2)necessity (1)need (21)needed (3)needs (2)negative (4)neighborhood (1)NEVADA (15)never (28)Neville (4)New (17)news (46)newscast (2)night (5)nine (3)ninety (1)Ninth (3)NOON (2)Nope (1)

normal (2)normally (1)North (1)notate (1)note (10)noted (2)notes (21)nothing.' (1)Notice (1)noticed (1)notices (1)notification (2)notified (5)notify (3)Notwithstanding (1)November (55)November-ish (1)NUMBER (26)numbers (3)numerous (5)

< O >Oasis (3)object (12)objection (118)obligation (1)observe (1)observed (4)observing (1)obvious (3)obviously (4)occasion (4)occasionally (3)occasions (6)occur (3)occurred (7)occurring (1)October (25)off-duty (4)offer (2)Office (46)officer (27)officers (28)officer's (1)offices (2)official (8)officially (8)officials (1)Oh (13)

Okay (261)Okazaki (1)old (1)omitted (1)Once (6)once-in-a-lifetime (1)one-page (1)ones (8)ongoing (1)on-line (9)on-the-job (1)oOo (2)open (25)opened (11)opening (3)operation (1)operations (6)opinion (1)opposed (6)opposite (2)order (13)orders (1)organization (4)original (7)Oscar (6)other's (1)outcome (1)outset (2)outside (6)oversee (2)Overseeing (2)overseer (1)Owens (1)

P.C (1)p.m (1)packet (1)pad (1)padlock (1)PAGE (22)pages (7)paid (8)panel (1)panicked (1)paper (15)paper's (1)paperwork (7)paragraph (11)

paragraphs (1)paramedic (2)parents (1)PARK (36)parking (1)Parkway (2)part (24)partially (1)participant (1)participated (1)particular (7)particularly (3)parties (27)partner (2)parts (3)part-time (1)party (223)

< ' >'party (1)

party, (1)pass (1)passed (3)passing (3)Pat (4)patrol (1)patrolmen (1)paycheck' (1)payment (8)payout (1)peek (1)penalty (1)pending (6)Penny (4)people (43)percent (4)percipient (1)Perfect (1)period (6)perjury (1)permanent (2)person (22)personal (8)Personally (5)personnel (13)PETERSON (16)PETERSON00122-124 (1)

Peterson's (1)Phil (4)phone (19)photo (1)photograph (2)photographs (3)pick (2)picked (2)picture (3)pictures (1)piece (10)pieces (2)place (7)plaintiff (1)Plaintiffs (3)plate (1)plates (1)play (1)play, (1)playing (7)please (20)PLUS (1)PM (2)pmsh (1)POA (1)POA-sponsored (2)point (47)pointing (1)points (1)Police (70)policeman (2)policies (2)policy (18)pong (8)pontificate (1)portions (1)position (19)possession (2)possibility (2)possible (16)possibly (6)post (2)posted (1)posting (3)Post-it (5)Power (8)practice (1)Practices (2)preclude (2)precluded (2)

preference (1)premises (1)preparation (14)prepare (3)prepared (5)presence (1)Present (7)press (1)pressure (1)Presumably (2)pretty (11)prevent (2)prevents (1)previous (2)previously (5)primary (2)Prior (18)prisoner (2)private (5)privately (2)privilege (8)privileged (2)Probably (22)probation (3)problem (4)problems (1)proc (1)procedural (1)procedurally (2)procedure (5)procedures (3)proceeded (1)proceedings (5)process (9)produced (1)product (1)professional (2)professionally (1)progress (1)prohibited (1)promoted (3)prompted (1)propensity (1)proper (1)property (1)protect (1)protected (3)protocol (1)provide (6)provided (22)

provides (1)providing (1)public (1)pull (1)Purcell (9)Purcell's (1)purpose (5)purposes (1)pursuant (1)put (25)putting (1)Pyatt (1)

< Q >Quantico (1)quarrel (1)question (63)questioned (2)QUESTIONS (17)quibble (1)quick (2)Quintanella (1)Quintanilla (25)Quintanilla's (1)quote (3)

< R >Rainey (3)ran (1)range (2)rank (3)rat (1)reaction (1)read (42)reading (6)ready (1)real (2)realistically (1)really (26)reason (25)reasonably (2)reasons (3)reassigned (2)reassure (3)Rebecca (20)Rebecca's (1)recall (117)receive (3)received (11)receives (1)

receiving (2)Recess (6)recessed (1)recognize (1)recollection (15)recommended (1)record (29)records (3)record's (1)redact (1)redacting (1)reference (1)referenced (1)referencing (1)referred (6)referring (6)reflect (1)refresh (7)regard (51)regarding (15)regardless (2)regular (3)regulations (1)regurgitating (1)RELATED (24)relates (2)relation (4)Relations (4)relationship (2)relationships (3)relative (2)released (1)relevance (4)relevancy (2)relevant (8)remain (1)remaining (1)remarks (1)remedy (1)remember (85)remembered (1)remembers (2)reopen (3)reopening (2)repeat (3)rephrase (1)replace (1)replaced (1)Report (39)Reported (16)

reporter (11)reporter's (2)Reporting (4)Reports (7)represent (1)representative (1)representatives (1)request (5)requested (4)requesting (1)required (1)rescinded (2)rescinding (1)research (2)resolve (3)resolved (4)resources (2)respond (6)responded (1)response (10)responses (2)responsibilities (1)responsibility (6)responsible (2)rest (3)restaurant (1)restored (1)result (1)resumed (1)review (9)reviewed (16)reviewing (5)Review-Journal (1)right (147)road (6)ROBBIN (1)Robbins (16)ROBBINS, (1)Robbinses (1)Robert (7)Roberto (2)Roca (1)Ron (3)room (7)Rothgerber (1)route (1)RPR (2)Ruelas (21)rumor (1)rumors (7)

run (2)running (1)

< S >S, (1)safe (3)sandwiches (1)sat (2)satisfied (1)Saturday (2)saw (22)saying (19)says (43)scanned (1)scenar (1)scenario (1)scheduled (2)schedules (1)School (82)Scott (2)screen (14)searched (1)seat (4)second (9)seconds (1)security (3)see (51)seeing (8)seen (15)selected (1)self-report (1)self-reported (1)seminars (1)send (1)sending (4)sends (2)Senior (1)sense (2)senses (1)sent (12)sentence (1)separate (4)separated (1)separately (4)September (6)Sergeant (17)series (2)serious (1)service (3)Services (3)

SESSION (1)sessions (1)set (7)settlement (1)Seven (4)Seventh (1)severe (2)Sgt (1)share (2)shared (2)sheet (6)sheets (2)sheriff (1)

[email protected] (1)shortcut (1)shorthand (1)shortly (9)show (4)showed (2)showing (1)shows (1)shut (5)shutting (3)sic (4)side (6)sidewalk (1)sign (1)signature (8)signatures (1)signed (10)signing (2)signs (2)silly (1)SILVESTRI (14)similar (4)simply (1)Simultaneously (1)single (5)Sir (40)sit (29)site (1)sitting (4)situation (4)six (1)skipped (2)smelled (1)snacks (1)social (6)

socialized (1)sole (1)solely (2)solved (2)somebody (31)somebody, (2)somebody's (2)somebody-wrote-down-the-wrong-date (1)someone's (1)something's (1)somewhat (1)son (1)soon (4)sorry (22)sort (4)sound (1)sounds (1)South (4)space (1)speak (2)speaking (3)Speaks (1)spec (1)special (10)Specialist (2)specific (21)Specifically (29)specificity (1)specifics (3)speculating (1)speculation (2)speed (1)spent (3)spoke (2)sponsored (2)spread (1)squirted (1)ss (1)stack (2)staff (5)stage (1)stamped (3)stand (2)stand,' (1)standard (1)standing (1)start (11)started (10)

starting (1)starts (1)state (6)statement (5)statements (1)STATES (2)statewide (1)stating (2)station (1)status (4)statute (1)stay (1)Steering (1)stepped (1)steps (1)stick (2)sticks (5)sticky (2)stop (9)stopped (1)stopping (1)stories (7)Storm (1)story (36)straight (3)streaming (2)Street (4)stress (1)strike (10)stuck (1)student (3)stuff (16)stuff, (2)stumbling (4)subject (13)submitted (1)subpoenaed (1)Subsequent (4)substance (7)substantive (2)substantively (1)Sufana (6)suffering (1)suggest (3)suggestion (1)suit (1)Suite (4)summarizing (1)summary (1)summer (2)

Sunday (4)superintendent (9)superiors (3)supervision (2)supervisor (12)support (2)supposed (15)supposedly (1)sure (50)surrounding (1)survival (1)suspend (3)suspended (2)suspending (1)swear (1)swearing (1)swirling (1)switch (11)switched (1)sworn (4)system (8)systems (1)

< T >table (1)tabled (1)tables (1)tail (1)tainted (2)take (32)Taken (17)talk (16)talked (35)talking (36)talks (2)Tappen (3)technically (2)teenagers (3)Teens, (1)tell (48)telling (16)tells (2)ten (7)ten-plus (1)termed (1)termination (1)testified (5)testify (1)testimony (21)text (2)

texting (1)texts (1)Thank (17)Thanks (3)that, (1)theirs (1)them, (1)them.' (1)thereto (1)

< ' >'They (1)

< T >thicker (2)thin (1)thing (21)things (37)think (61)thinking (1)third (7)this, (1)Thomas (9)Thomas's (1)thorough (2)thought (16)thoughts (1)Three (30)till (9)time (140)times (10)time-wise (1)Tina (10)title (1)Today (57)today's (7)toggle (1)token (1)told (104)told, (1)top (5)topic (5)topically (1)topics (2)toss (2)Total (1)totally (5)touch (1)town (5)Tracy (2)

traffic (4)tragic (1)train (1)training (7)trait (1)transcribed (1)transcript (3)transcription (1)transported (1)Traurig (1)trays (1)triggered (1)trip (2)true (19)truth (3)truthful (2)try (7)trying (25)Tuesday (5)turn (5)turned (18)turning (2)twice (5)two (42)type (7)Typed (4)typed-out (1)typed-up (1)typewriting (1)Typewritten (3)typically (1)

Uh-huh (41)unaware (1)uncomfortable (1)unconditional (2)Undated (1)underlining (1)underneath (1)understand (39)understanding (35)understood (2)undertake (1)undertook (1)undivided (2)Unfortunately (1)unhappy (1)uninvited (1)union (3)

union-sponsored (1)unit (2)UNITED (2)universe (1)unlocked (2)UNLV (6)unofficial (1)up, (1)update (2)updated (6)uphold (1)upper (1)upset (2)use-of-force (5)usually (1)utilize (1)

< V >Vegas (9)VEHICLE (1)verbal (1)verbally (2)verify (1)version (2)versus (2)victim (2)Video (16)videographed (8)VIDEOGRAPHER (15)Videographers (1)Videotape (1)view (2)violated (2)violation (1)violations (6)Violence (2)violent (1)Virginia (1)visit (2)visited (1)vs (1)

< W >wait (10)waited (2)waiting (1)walked (2)walking (2)

Wamsley (37)Wamsley's (20)want (49)wanted (15)wants (1)watch (3)watching (1)water (1)way (17)

< ' >'we (1)

< W >Wednesday (4)Week (12)weekend (2)weeks (7)week's (1)Well (68)went (25)we're (26)were, (1)We've (8)what'd (2)when's (3)where'd (2)WHEREOF (1)whichever (1)wife (4)William (4)Williams (1)wish (1)WITNESS (33)word (3)words (3)work (14)worked (4)working (3)workplace (2)works (3)write (6)writing (3)written (13)wrong (4)wrongdoing (10)wrote (13)

< Y >Yeah (63)

year (4)years (10)Yep (1)Yes, (1)York (7)

< Z >Zeddies (1)Zuniga (15)Zuniga's (3)

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