COPY FILED

COMMO N P L E AS C OURTS
HAMILTON COUNTY
COST DE SK

IN THE COURT OF COMM JN PLEAS SEP 21 2020

HAMILTON COUNTY,! HIO AFTAB PUREVAL
M.R, a Cincinnati Police Officer Case No. ~00~5 A 9 (.9-ERK OF COURTS

V.
Plaintiff; Juclg Shanahan

Ju.lie Niesen, el: al. FIRS 'AFfi'IDAVIT or

Defonclants.

State of Ohio )
)ss:
County of Hamilton )

M.R., being duly cautioned and sworn, hereby sta ·es the following is true and accurate
to the best of his personal knowledge and belief:

:I.. I am a resident of Hamilton County, . hio and a sworn member of the

Cincinnati Police Department.

2.

3. I am a Cincinnati police officm· and have l een assigned to the Dist: 4·. Violent
Crime Squad, the Gang Unit and the SWAT team.

4•. In those assignrnent:s, r have been involvec in t:he investiga Uon and arrest of
violent criminals, gang members and drug traffickers.

S. For my own safety and the safety of my fan ily, I have taken steps to maintain

confidentiality regarding my personal iclenti(ying information such as rny birth name,

residence address, social security numbc~r, date of birth,

 6. On June 24, 2020 during an open for 1m before lhe Budget and Finance

Conunil:1:ee, I was assigned t:o City Hall to provide police ·ervices inc:luding crowd control and
security for City Council's chambers.

'7. During the hearing, the hallway outside c 1.111cil's chambc)rs was occupied by a

loud, unruly crowd of people that were anti-police an I urging City Council to clefund the
policc1.

n. The noise level in the hallway

I
made spoke ·1 communication at conversational
volume difficult or impossible.

9. One of the people in the crowd asked me ~ibout the status of another police

officer that had just left the scene and I responded that ti e officer was "okay" by holding up
my hand touching- my thumb and index finger.

10. People in the crowd claimed that my "oka. gesture was a "white power" or
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"white supremacist" hand signal intended to intimidate pc ople.

1.1.. I am not a racist or a white supremacist and I y hand gesture was not intended
to be a "white power" gesture.

l2. The Defonclant:s individually, or in concert: ith others, through their actions

have violated my protected privacy interests by portray ng me in a false light:, publicly

disseminating my private personal identifying inforrnat:ion, nd/or threatening to publish my

private-) personal identifying information.

1.3. On June :?.!5, 2020 Julie Nic~sen ("Niesen"] pul· lished a post on a social media '.

platform, in which she portrayed me falsely as a "white supr 'macist." (Bee Exhibit l.)

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 11-. On June 25, 2020 James Noe published a hlse post: on a social media platform

in which he refel"t'ed to me as a limp .. clicked POS [piece of' shit] and claimed that I was flashing

l:lw "white power :;yrnbols to Black speakers." (See Exhil· it 2.)

:1.S. Noe has threatened to publicize Plaintiff's · ersonal identifying iuformat:ion in

his social media posts. (Exhibit 2.)

l6. On June 2S, 2020 Terhas White filed a cc mplaint: against: me with Citizen's

Complaint Authority (CCA) and has published social rnec ia posts falsely portraying rne as a

white supremacist piece of shit:. (See Exhibit 3.)

17. On June 25, 2020 Alissa Gilley filed a cor 1plaint: agr.1inst me with Citizen's

Complaint Authority (CCA). (See Exhibit: 4-.)

10. These false complaints can he used against n e as evidence of improper motive

or intent in the event that I am involved in a use of force 01 critical incident.

19. Friends of Bones has published social media J ost:s about me t:hat: are false. (See
l.ixhihit: 5.)

20. The public dissemination of my personal id 'nti[:'ying information will cause

irT'tiparable harm because it: enclangc~rs rny personal safety <' nd lhe safety of my farnily.

21.. There are violent: felons that: I've arrested that would use rny personal
inforrnaUon to harm me and rny family.

22. Public di8semination of my private infonnat on or branding me as a racist:

and/or white supremacist would make it impossible to do m job.

23. It would be irnpossible for me t:o find other e 11ployrnent: if the social media

posls that portray me as a racist or white suprernacist rerrn. in publicly available on social
,neclia.

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 24. These accusations have harmed my reputa ·Jon anct the well -- being and peace
ofrnincl ofmy entire family.

FURTl·[lm I\FPJANT SAYETI-I NAUGll'J'.

CERTIFICATE Qf§lm.vxc •

I hereby certify that a true and accurate copy of the f 1·egoing was served upon

Defendants or counsel of rnc:orct with the Complaint: on thL 22"t clay of July 2020

L'llZqc!1w , G..m--1:e,1.w._(L/J ______ ___________

Zachary G ttesman (00586'/-5)

4..