10t3t2017 Los Angeles County Sanctioned for Withholding Use-of-Force Docunrents I Prison Legal News

Los Angeles County Sanctioned for

Withholding Use-of-F'orce Documents
Loaded on AUG- 25, zot6
Filed under: Police Misconduct (/search/?selected_facets=tags:Police%ozoMisconduct), Disclosure of Records (/search/?
selected_facets=tags:Discl osureYozooP/rzoRecords), Excessive Force (Police) (/search/?
selected facets=tags:ExcessiveTozoForce%ozo%"z8Police9Szg). Location: Ca-lifornia (/search/?selected-facets=locations:1476).

In July 20L2, United States Magistrate Judge Stephen Hillman ordered Los Angeles County to pay
$7,ooo in sanctions for opposing a motion to compel production of documents, without substantial
justification in a fed.eral case alleging unconstitr:tional use of force by counfv deputies.

After twice agreeing to lodge the requested documents with the court for in camera review, counsel for
the defendants then produced only some of the requested documents, forcing counsel for plaintiff
Jeremy Fogleman to file a motion to compel production of the documents.
Counsel for the defendants then compounded the problem by asserting boilerplate objections to the
motion to compel.
The Court found that the defendants acted in an "obstructionist" manner and that their oppostion to
the motion to compel was without substantial justification. Pursuant to Rule 37 of the Federal Rules
of Civil Procedure, it ordered the defendants to pay $7,ooo in sanctions to pay plaintiffs counsel for
the "unnecessary" time spent in filing the motion to compel.
The court also ord,ered the County to lodge with the Court "forthwith" all the documents in their
possession regarding complaints of force, retaliation, and dishonesty by the defendant deputies. See:
Fogleman u. County of Los Angeles, U.S. District Court (C.D. Cal.), case no. cv ro-6799-GAF (SHx),
Order on Plaintiffs Motion to Compel and Request for Sanctions, July 77,2012.

Related legal case

Fogleman v. County of Los Angeles

Year 2012

Cite U.S. District Court (C.D.Cal.), case no. cv to-6799-GAF (SHx)

Levcl District Court

Conclusion Bench \rerdict

0
FBI Former Number Two of Los Angeles Sheriffs Department Charged with Obstruct... Page I of 2
-

Lits Angeles Division

H{rc " Loi An{rbg ' PEr, Rllor$r - m15 . Fcrme. Nufib.i lsa oi L.s i alclt5 :ieriil s Depa.iil.ni Cha.g!-ii \!r.fL Oi,stilcliis Feoe€l jtvestigalion into

Foraer Nurrrber Tt+o of Los Arrgeles Shetlfs -L s: S l s-q-!eq Pi,v eiq !-L!ltl
Loe AngaL. Homo
Departrrrent Charged with Ohstrrcting federal Conl*ct Us
Investigation into Misconduct at C,ounty Jaile - Orreryielv
- Tenitoryruudsdiction

U,S, D€IErtrncnt of Jugtiee OEceof PubficAtrEim NffiandOutreacn W

Mrs a a o^1E (-zoz) sr4-zooTlTDD {2o2) Sr4-r888 - Pr€ss F.o4m l StorlE
- ln Your Community

.Absut Us
Paul Tanak4 56, who was the second in commmd of tle Le Angel,es Sherifs Departrent (LASD) md
- olrr Peopls E Capabili&s
rr'r'iliam Thonras Carry, 55, who oversaw internal criminal invstigations at the I"{SD, hare been
- \l/hd yrs6 hYdigsts
indicted on obtruction ofjustice charges for alegedly directing efiorts to quash a federal investigation - O$rPartnsrddps
imo corruptior and civil rights violatioos by sherifs &puties at two downtown iail complses. - Los Angeles F{istory

W.nbd by ths FBI - Lor Ang.hc

Jobr

deputies.

Itre ob$ruction ofjustice cax was annouaccd at a reHs conference this moming by Acting U*9-
n ?.
\
Attom€y Stephanie Yonekura for the Central District ofCalifornia and Assistant Director in Charge
David Bosdich for &e FBI's tas Angeles Field Office.

Tanaka and Carey are charged wiri conspiracyto obstruct justice md each is named itr otre count of
ohstructioa ofjustice, Carey is charged with two couts of making false declaratiom for perjuring
himsefflast 1an during tle trials of co-eonspintos.
Tanaka was the uo&rsheri{, the number ts"o in the IASD, until zor3 and he ral an ursuecesshtl
emluign for sherifrlastyear. Cacyleft IASD after reathingthe ralk of captain md heading the
Intemal Criminal Inve*igations Bureau.
Tanala and Careysurea&redthemselves to the FBI earlythis moming aad thetwo ms are expected
to be araiped on tle indicrment tht atemootr in US. District Courl

Accodingtotle iffioeng thetwo &feodaats were well awate of 'pmblem&puties'atthe jafls!

'altregations of tampaat abuse of inmates" and "insuficieot internal irtstigatioN" into deputy
misconduet. BBt agaifft thi6 backdop, Tanaka allegedly told deputies assiped to tkjails to Hork in a
'gm.y m' and that he thougbt that the IASD Iatemal Afrairs Bureau should he tetlitixd from +s
illestigators to just one.
The s.heoe to t}$art tbe federal irvestigation alegedly started when deprti€s in AIrSust 2011
recovered a mobile phonefrom an inmate in MCJ,linkedthe photretothe FBI atrd deteminedthat
tlre inmatewas an informantforthe FBI*'ho wascooperatingin a fuderai comrptiot civil righs
inrutigatiotl. The phone was ghen to the inmate b)' 3 corrupt depny, who subsequently pleaded guilty
to fedral bribery charges.

Alarmed by the ftderal investigatlm, membe m of the onspiraty, gtrided by Tanaka and Carsy, tmk
affirmative Bteps to hide the cooporator from tle FBI acd the U-S- Mmhals Service, whicb was
attempting to bring the inrate to t€stiry before a fed*al grand jury in response to al order issued by a
federal judge. Ite indictnent alkEes that m part ofthe conspiracy, rhe deputies altercd records to
make it aplm tiat the mpemtor had been relweil'Ihcy lhen rbmked the imate uder c
different na:re, moved him to s;ecure iocatiom, prdribited FBI access to the informmt and ttren lold
the cnoperator that he had been abandon€d by the FBI-

Over the ouue of several weeks, membex of the onspiracy allegedly attempted to otrtail an order
from a l,os Angeles Superior Court judge that would bave ompelled the FBI to turn owr in{ormtion
about its iDr.eEtigation to LASD. After the judge reftred to issue suc-h an order because he had no
jurisdiction orer the federal lsrr €r&rcement agency and wea thougl it was clear that the FBI m
pmperly acting in the courae of a lavful imrestigatio& Taraka ild Car€ry Bst to discuss having two
ggeaats appmach &e leacl FBI ese agfDt. Soon thereaft€a,lte sergmts colfronted the agent at her
resi;lence in e! odtempt to intimi&te her.lhe sergeants threatened the agent with arrest md later
reiterated ttrie threat to her supewisor, statilg tbeil tle agent's arrest was iminent.

'As the allegatiors &monstrate,&mta had a large mie in institutionalizinS cerlain ilega] behayior
within the sheriffs department," said Acting U,3. Attomey Yonekura- 'This case also fllustmts how
Iaclere who fosier and then try to hitle a corrupt sltuc, wil be hdd accou*able, jusd fike their
subordinates."

https://www.fbi.gov/losangeles/press-releaseY20l5/former-numbef-two-of-los-angeles-sher... 21312016
FBI
-
Former Number Two of Los Angeles Sheriffs Department Charged with Obstruct... Page 2 of 2 :: ..:.1

not to cooperate in the ftdeml investigation- Members ofthe conspimcy allegedly engrged in witness
r-mperiug by telting felLow deputia that rbe FBI rculd lie, t}rotu, mipulate ud blechrsil th@
to obtain infomation about the sheriffs deparEDert.

?s-
iio"lttY_Sggrylg!9:-Hotly*ood @p{r:
tfi"iGtrJn-dfifi6ffiTi:BhGffia;"d,ilt,
which minimized the value oftieir
said essista;ibiredoi itr Charge Bowdich. -nre public held
instead, theyspent theirtime md enerry setting a tone
oath and dishonored tle badgethey wore.'
<-
Ao indictment contains allegations that a &fendant has committed a sime. Every defen&nt is
presumed to be innocent until md nnless prwen guilty in court-

The conspiracy count carris a statutory maximum sentene offire )un in federal prison and the
obstruction of justice charges carry a maximum penalty of ten year. The two frlse declaration couts
against Carey each carry a potential pnalty of ftt years.

As a result of this iavestigation, a total of 21 defendants who held various ranla in the L.ASD haw been
charge4 indudi.e the deputy who took the bribe to smnesle the phone md seven o.conspiratos in
the scheme to obstruci justice (sq for example:
http://www justice. gov/usao/cac/Pressroory'20 14/ 161,html).
'ite investigation into corr':pdon, cilJ
r:.ghts ab,:res ard cbstrdcdon ofj'rshcc rclatcd to ths lrs
Angeles CouDtyjails is beirg conducied by the FBI.

This content hl< been reproduced from its original soure.

AmibilityieRulemkingiFEedomoflnfomtiotrActlr?alNoticesilJtalPolici6mdDirlairem;IJ*slPrimcyPolicyiUs&govlriyhiteEore
i:iil.3,,i ;: :n r:1t:cial siir
'tj
iire U.S. ,:,r, critnii:Ii. US. Dqxrtllst of Justie

@
https://www.fbi.gov/losangeles/press-releases /20l5lformer-number-two-of-los-angeles-sher... 2l3l2O 16
 Case 2:10-cv-06793-GAF-SH Docunient 178 Filed 1 U3Al12 Page 4 of 4 Page lD #:2349
LINKS:172
TINITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

CTVIL MINUTES - GENERAL

CaseNo. CV 10-06793 GAF (SHx) Date October 30,2012

Title Jeremy Fogleman v. County of Los Angeles et al

noJ lolerate ing@er Ied]U&$1]]glionin ltgiff B"gr'q_g{f".t t" ,r sheqlf

Baca mal.be deposed,.

III.
CONCLUSION

The motion is DENIED. The hearing on Defendants' motion presently scheduled for
November 5,2012 is hereby VACATED.

,l
IT IS SO ORDERED.

cv-90 (06/04) CIVIL N{INUTES - GENERAL Page 4 of4

 (l w,Anrw u CV 4D- 67 q yW6H4
Mgn)orandr:m o f Undercta

t. This Agreement shall be effective only upon a majority,rote of,(the Los Angeles Counry
Boarci oi- Sulxr-vrsors ("Bo.u,J") ratiFy-ing lhis Agi-ee n,e ii.. Ttcrc\Lnggiheijgjtdii;on(
to this Agree ment- Defendant Counry ol [.os Angeles ("Defendant") shall exercise
reasonable effort to have this Agreement ratified within 60 days- Failure to ratiS this
Agreement within 60 days shall not nullify this Agreement-

2. ntifl')
H:el.ffi{tg*ffiiJ":
"'""' r*r
@,,'ri*,eful"ltlJ95"/.otthispaymentisduetoSCverephysicalinjury
or severc physical illness. ,/<l
3. Each pBrly to bear their own attomeys' flees and costs-

4- PlaintiffshalI dismiss entire litigation and ail claims with prejudice within ten (10)
\
%*,a
5. Plaintiffto file notice of sefllement with Court immediately, anrC advise the Court of the
Seftlement Conference and the temrs oIthis Settlement- The parties shalljointly' requesl
the Court to stay proceedings until this Agreement can be fully *nrt.*o*i.d. 'l
6. Plaintiffand atl Defendms mutualty release one another to tlre exLent of the facts and
allegations of ttrc lawsuit and the parties' claims. Plaintiffshall also execute Defendsrt's
standard release agreement-

7. The parties are familiar witn Clffornia Civil Code Seaio n l542,and knowingly weive
that provision-

8. AII parties deny any wrongdoing or liability.

The Court shall retain to enforce this Agreemenl

Cour*y of t os Angeles

()r -_LL -\I

Date

l-aa-r3
Date
Attorney for Defend:rnt-s
 r I rPr -, , r rror r.Sw6re.vvuv ru

M Gmail Jeremy Fog leman < performa nceplusfwb@gma il.com>

Some other interesting news relevant to cr.u, 6 days ago the Feds subpeonaed the Lqs Angetes She dffi\ *1- , .,r,
dept in regards to the misconducd. Ihe:g.S5(including those named in my €se).y!!llqlnqjcred !y neL-4nl.l{ O
Jsgr. iitir-i.4'articies.iatirnes coiiti2O i'l'iiftaTit:;ji li:-,;iu-t(,J,i .i;-rir.s-:.iror.., lC12oil25- lfif l;f.
AiI6 we have retired Captain Bob Olmsted testifuing on my behalf. He vras captain of the jail while I was 'lY
there. This is a taste of whdt he has to say. i particularty tike the section "Donl feed the animals"
http://witnessla.com/lasdl20l2ladminlthe-sheriff-the-undersheriff-the-commanderl
Also the deputy that assaulted me was arrested for fighting at a department Christmas Party see attached
D.A. charge sheet. Here's the story http //www.nytinres.com/2011103124|us/24guards.html
Cunently this guy is washing cars for the Sheriffs after he was caught smuggling a knife to an inmate. See
below from Office of lndependent Revianrr 4n012 incident #23A24
oR t23024
Alr?{,rdon /S4oprls:

A deputy was alleged to have used excessive

force against an lnmate. Other inmates

witnessed the ficrce and it is alleged the "shotcallel'

in the dorm alkrwed the dorm to riot. A

very large riot ensued and several dorms and

co un g property were destroyed. Addit-ton a I ly,

during the investigation, a deputy found a knife

hidden in a barrack- Earlier in the day, a

depug had indicated his knife was missing. lt

is believed the found knife was the deputy's

and he had brought the knife into the facility

lof 3 3130/2018,6:58 Alvl

 rr!rPr./ / ru c. r -6w5rv.vvr r!
";i;;;;;,, -o'

against policy.
fdtudd
lf you're interested email me or call and we can talk more

Thank you,

Jeremy Fogleman

850-4614166

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Jeremy Fogleman <oerformanceplusfu b@gmail.com> Tue, Sep 18,2012 at 7:58 AM

To

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) 3/30/2018,6:58 AM
Former L.A. County sheriffs captain agrees to plead guilty in jail scandal - LA Times Page 4 of 4

L'A' jails sct &4?r4 gYe,L" !-1,,@

W
Indictment: 'tr4/hA!,feclgley top L.A' Couret5r sheriff s EXggg-dld lll:qgg M

Copyright CI 2016, Los Angeles Times

UPDATE
4:01 p.m.: This post was updated with cornments from Tanaka's attomey, H. Dean Steward.

This post was originally published at 3:12 p.m.

This article is related to: Crime, Trials and Arbitration, Law Enforcement
\

@
http://www.latimes.com/1ocal/lanodla-me-ln-former-top-sheriff-s-official-agreement-jail-s... 21312016
1B arrests in jail probe - latin'res 1/2 Page

. llack !o Original .r.rlicic

tB arrests in jail probe

Pr os e a rt o rs f n d' u i de s co p e qf il I eg o ! c oru]u c t' ir t S.h eritJ's I) ep t.

December ro,2or3 I Robert Faturechi andJack l,eonard

Federal authorities announced charges Monday against rB current and former Lm Angeles County sheriffls deputies accused of beating jail inmatc and
visitors, kying to intimidate an FBI agent and other crimes following an inrrestigation of cormption inside the nation's largest jail system-

Prosecutorssaidtieyfound,-@bydeputiesandtheirsupervisorst}atwent@ondmistreatinginmatestoactiveIyattemptingto
hiader an FBI investigation into jail misconduct-
.. .-
ForTheRecord "-
los Angeles Times Tiresday, June ro, 2ot4 Horne Editiou Main News Part A Page 4 News Desk r inches; 53 wor& T),pe of MateriaL Correction
SherilfsDepartnoeut An artide intleJune Z LAIEdra sectionabout'heobstruction of justice trial of six tm Angeles Sheriffs Degartrnentofflci:ts
misspelled the fir:t nrme of one of the defendants, Mariceta l-ong as Maricella- The misspeUing also occurred in articles Dec. 10, D€c- L7,May zo,May zB and
June 5-

T@ marked s_,"4t$reryf$€ritrs qfEqqb.ilgore ttran two deades *dgggglgjgotlglblow to a department

ttta@ racially biffi rs *;ffi t-a Uackgrounds and
".orrffi
:Lh=eI9q":5*.-_a_.Lq1"B&"_ekeF e y3sqlr* - in fact, they demonstrated behavior that had become ' LDgUlgEAnalke(UlIS. Atty. Andrc Jr. said in a
stet ffi ent considered th"o*tr- to-.5ii aiicve ihe law-il-' ' '
consid".ol thernselves
I

The indictrrents allege two assaults on inmates and ttrree on people who visited tlre jail They also indude elaims that deputies wrote false reports to justify
6ing force and conducted illegal arrests and searches ofjail visitors. ",

A sergeant who*uperryised &puties in the vlsiting area of l!{en's C-entral Jail was accused of encouraging violenead. rgprimandfng employees 'for not using
foreqon visitors .-. if the visitors had supposedly 'disrespected- jail deputies, according to an indicuner

In oae case, prmecutors say, an Austrian onsul official trying to visit aE ,5sai2rr inm:te was arresed and handcuffed even though she had committed no
crime and woutd harrc been immune frorn prosecution, tlre indictment said-

Sheriff l,ee Baca said at a ll{onterey Park news conference that he respected t}re findings of federal authorities but was saddened bv them. "Please know tlnt I
respect the criminal justiee system and no one is abore the law," Baca said.

Stilt he defended his agency, *yroE"S9.SX of our employees are on the right traclL... There is no institutional problem witlin the Sheriffs Department rvhen
it comes to cqqerting its€l'f
Baca's remarks came as his deputiis were being arraigned at t}e federal courthouse in downtown L-{- Sixteen appeared tn court, with at Ieast some handcuffed
a'ndctrainedatthewaisLSomepIeaded""r6iiiffipleasatalaterdate.Allwerereleasedonbond,aus.atilffi'ioffi.,.-.-
%
spotresman said. The two who did not appear are eryected to surrender in the future, he said-
-:-=i=.i..@---

In ali, 4
deputies, three sergeants alrd two lieutenants were charged- Among (he allegations are
civil rights violatiols. rgq_:"lg!eg!bgl9g3t9--Q. Ll1g!S3ti.o_1 rsglssrrr8.

I{onday's.ct4lxs q}a*.thg,}i tie Sheriffs Department has fuced sincc the late rg8os, rvhen 819!?ljlrl*glltiq:;_-accused deputies in an
e1itednirsandnroneyiaunderers.Bwtotheco,,viG6il*oiEIilthaltr^pdozendeputies.
The1atestirrdictmentsincIudeallegations,firstmadepublicbyTheTimes'againstadepr'rty.o**,o,..ro*,,
Deputy Bryan Bnrusting was the supewisor for a sheriffs rookie who graduated at the top of his recmit class but resigned after a fe1.,7 *eeks*itffi*ffi
rookie said Anuuting forced him and others to beat up a mentally ill inmate and then cover up their adions, according to interviews and law edorcement
records.

Sheriffs officials determined that no misconduct had or:curred. After TLre'Itmes' relxrrt, hou'ever, the rookie depury rras colryggn*ryg-
Federal prosetutors accrxed Brursting of assaulting inmates on two occasions and using deputies he trained to u.rite
.f+ej:peglg jg!€Ijgthe abuse.

Tlre'I'irnes- Actrcrding to the indictment, Bmnsting told a training deput-r,'that thel' nec'ded to teach a lesson to an inmate rvho had been disresor:ct{ul to
anoiirer.jaiier. Brunsting, iire trainee an<i a tirirci <iepug', Jason Bralurn, stnicii, liicke,j ana pepper,spraved the rn.ur,.tll9jll**n9"_!#g
{9
http://articles.latimes.com/printl2o13/dec/1afiaca1/la-me-sheriff-arrests-20131210 zfi/20i6
 Home >> Posts >> Govemment > This Article

LA Sheriff's 6-month prison plea

Posted Debbie L. Sklar on July 18, 2016 in Government 12,955 Views

SheriffLee Baca accepting the award for the 2013 Sheriff of the Year from the National
Sheriffs'Association onJune 23,2013. Photo courtesy of LASD

.Pisgraced former Los Angeles County SherifTlee Baca may face more than his hoped-for
maximum six months in prison after a federal judge Monday rejected a proposed plea deal and
sharply criticized Baca for his "gross abuse of the public's trust."

No sentencing decision was handed dowr.r and the hearing on Baca's conviction for_lying to
investieators-was continued until Aug. l.

U.S. District Judge Percy Anderson said a six-month sentence, the maximum under the rejected
plea deal between Baca and prosecutors, would "tivialize" Baca's role in setting in motion a
*i9":B"gtgg.o@inthejailsystemthatdid..substantialharm,,tothe
communrw-

"It's ong ltingto lie to an-assistant U.S. attorney," Anderson said at the conclusion of the 90-
minute hearing. '1$@glfor the chief law enforcement officer of Los Angeles County to ...
cover up abuse inI4en% ,Grtral Jail."
Former L.A. County sheriffs captain agrees to plead guilty in jail scandal - LA Times Page 1 of4
fxHBn"c"
LOCAL / L.A. Now lr%L
Former L.A. County sheriffs captain agrees
to plead guilty in jail scandal

Retired L.A. County Sheriffs Capt. William Thomas Carey leaves the Roybal federal courthouse in Los Angeles after
appearing for an arraignmenl on May 14. (Mel Melcon / Los Angeles Times)

By Cindy Chang and Joel Rubin . Contact Reporters

AUGUST 13, 2015,7:36 PM

retired Los Angeles County sheriffs captain has agreed to plead guilty to lying on the
stand and will cooperate with prosecutons, becoming the highest-ranking ofEcial to fall in
a jail scandal that has already resulted in seven convictions forpbst4qtig&a federal

investigation.

The plea agreement for retired Capt. William -Tom" &reywas filed in federal court Thursday and
could strengthen prosecutors' cap" against Paul Tanaka, the department's former No. z.

In May, both Tanaka and Carey were charged with glgl1gggry the federal investigation into excessive
force and cormption in the countyjails. Carey rt* ** with two counts of lying for
"h*g"d
statements he made in two trials of lower-ranking sheriffs officials.

htp://www.latimes.com.4ocal/lanodla-me-ln-former-top-sheriff-s-official-agreement-jail-s... 2/312016
Ex-LA Clounty tindersherifl, Captain Plead Not Guilty T'o Corruption Charges < CBS Lo... Page 1 of 4

Los Anseles SIGN l-..1P FOR hIEVJSLETTERS atss Lor;i Re!!.rd5 2 LoB ln iilegl5rer Search

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Ex-LA County Undersheriff, Captain Plead Not Guilty To Corruption Charges

May 14,2015 1 1:35 PM

Filed Under: Attonley, Corruptaoa, lndictsd, lndicfisnl, LA County Jaiis, LA County Und€ruheriff, Paul Tanaka, Shsritf's CaFtain Willia$ Tom Carey, su.rendered,
Tanaka, Tom Carey, william Thma. Carey, william Tm Carey

LISTEN LTYE S#l*.

FOLLOIY US Oil
,t

EI Siqn Uo for Newsletters

LOS ANGELES (CBSLA.com/AP) Former Los Angeles Coun$

-
Undersheriff Paul Tanaka and retired Sheriffs Captain William Thomas
Carey pleaded not guilty Thursday in U.S. District 9,"o."UI to charges of

Federal prosecutors believe the t*o-@

and abuse within the LA ffi
-gorruptio!
Ji,amr'n-ii Ali,ur,vj c\:ffiu $TYI, I$fi
"The sheriffs department was involved in this
,?=!91E !:-=id-1*:Lg*f,s*I9T!-.9| of the department,' Actins U s
"I}[fi1il$
tnl]nMtro

Attorney Stephanie Yonekura said '*[R[$$[s]

Tanaka, who has been th_e mayorrf Gardena since 2005 and retired from 1, *!e&"ia-Ozler k;:;,
the Sheriffs Department in 2013, y-a911O.!9!eO on chafges of o_b9-t1$9n
:!s.
cur.y y3-llo ll9,9t"l oj y3lgg: *uEgr.

http://losangeles.cbslo cal.carn/2015/05/14/forrner-la-county-undersheriff-paul-tanaka-indic... 5/3012016

 ufll0lr'c'
rfitud!
Paul Tanaka convicted in sheriffs jail
scandal
By Kevin Roderick lApril 6,2016 12:04 PM

jr

Paul Tanaka, the former Los Angeles County

frundersheriff who ran unsuccessfully for sherifflast year, was convicted today of,gonspt.acy 4g(_
obstruction ofjustice for interfering in fbderal
a investigation into the county jailS-IffiTe1iffied
erated less than two hours before convicting the former top law
y,w enforcement official- He faces up to 15 years in prison when sentenced June 20-

Slowly but surely, the legacy_bad cops of LA are over time beins weeded out and the sheritfs
department has been one of the Ygrg! abqsq@ql1g
-
hrough the decades. The
scandal in which the c:"rrntnal-atiffic",, s then-boss, Sheriff Lee Baca).final[
who was an inmate in the jails.
-gjt-Uglrig5kd was over trying to hide a fbderal informant
The conviction "[caps] a jail uUm" unA otrtrrction scandal that reached all the way to the top
echelons of the Sheriffs Departnaent," the LA Times' Joei Rubin rn'rites. "The conviction marks a
dramatic fall for a man who rapidly climbed the ranks of the Sheriff s Department, building a
reputation for being a tough, overbearing leader who inspired equal parts fear and respect. By the
time he retired in2013, Tanaka was the second-in-command, running the day-to-day operations
of the nation's largest sheriff s department and holdhg as much or more sway than his boss,
SheriffLee Baca."

Baca pleaded guilty in February to a bargained count of makir-rg a false statement to federal
investigators. He is expected to get no more than six months in jail-

From the LAT today:

AO
L

anaka faces maximum sentence for going to

trial, former prosecutor says

,T

Former Los Angeles County Undersheriff Paul Tanaka leaves US District Court in Los Angeles,
Tuesday, March 29,2016. File photo. (Hans Gutknecht/Los Angeles Daily News)

By Sarah Favot, Los Angeles Daily News

Posted: 04101116,8:30 PM PDT I Updated: on04l0l12016

0 Conments

Paul Tanaka'splligg3s former undersheriff of Los Angeles County could work against him
when it comesi6lf6lffiining his prison sentence, according to a former feder@3ffir

"Federal sentenci idelines advise that

ry Mr.
previously convi
who prosecuted
ns of public trust be punished more
could be

public corrgplion cpse_s, said in an interview.

which suggests that
1qqle slyglqly than the deputies, sergeants and lieutenants
federal prosecutor Joseph N. Akrotirianakis,
-_-- :- -:-- ,. -
---'- -
Tanaka faces a maximum of 15 years in federal prison when he is sentenced on June 20 after a
federal iury found
**-------l----:a-- @pb!!ryelgn qilUqlf-cq Wednesday.
 fuL^rry.fuu{
\P/M //o )1a

STF,PHF,N J HTI,T,MAN
DOCK.ET NO.

Case No. CV-10-6793 CAF

PROTECTIVE ORDER PROTECTIVE ORDER
JUDGES
GOOD CAUSE APPEARING TFIEREFCTRE, IT IS HEREBY ORDERED as follows:
STEPHEN J. HILLMAN

ADVOCATES
I GOOD CAUSE: PURPOSE AND SCOPE

LAW OFFICES OF DALE K. GALIPO Dalc K, Galipo Anomeys for Plaintiff HAROLD G. BECKS &
ASSOCIATES Huold C. Becks AttomEys for Dcfendants Plaintilf served a Request lor Productron of Documents to the County of Los Angeles

("COLA"); in response rhereto, COL,A is producrng documents deemed privileged and/or

ACTS confi dentral, specifi cal ly.
No Acts
(l) any and all docurnents pertarning to the rnternal investigation into t'larntrll-s'clarnrs of
X This ludgement does not cite any other record,
excessive force;

X This judgement tras not ben citcd yct.

(2) any and all documents included in the personnel [rles of Defendants Deputy Hernandez,

Deputy Nery, and Sergeant Edie that penain tor ,

(a) complaints or incidents involving use of force [including documents related to the investigation

FOGLEMAN V. . OF'LOS and outcome of the alleged use of lorcell

(b) complaints or incidents involving dishonesty, false reponing, or failing to report, Iincluding
n

documents related to the investigation and outcome of the alleged dishonesty, false reporting, or

failing reportl;
Text Highlighter
(c) complaints involving the handling ofdetainees [including documents related to the jnvestrgation
Bookmrk
PDF and outcome of the alleged handling of detainees]; and
Share
(d) repnmands relating to use offorce, dishonesty, lalse reporting, failing to report, or the handling

CaselQ"' of detainees;

29 Mt 2012 I UMTED STATES DISTRICT COTJRT CENTRA! DTSTRICT OF CALIFORMA

. Judgments
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t2 UNITED STATtrS DISTRICT COURT
L3 CENTRAL DISTRICT OF CALIFORNIA
14

15 JEREi\itY FOGLEMAN, Case No. CV-10-6793 GAF

l6 Plaintiffs, PROTBCTIVE ORDER

t7 vs.

iB COTINTY OF'LOS ANGELES, DEPUTY

HERNANDEZ, D EPUTY NERY,
t9 SERGEANT EDIE, and DOES 1
THROUGFI 20, inclusive,
20
De; f'endants.
2l
22

23

24

25

26
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l)ockets Jr-rsira
 Ntun'fa-s'
ftfufI-
1 PROTECTIVE ORDER
2 GOOD CAUSE APPEARING TI{EREFORE, IT IS I{EREBY
a
-) ORDERtrD as follows:
4 i. COOO CaUSA: PURPOSB aNn SCOPB -
5 Plaintiff served a Request for Production of Documents to the County of Los
6 Angeles ("COLA"); in response thereto, COLA is producing documents deemed
l privi leged and.ior confi dential, spec i fical ly :

B (1) any and all documents pertaining to the internal investigation into
9 Plaintiffs' claims of excessive fbrce;
10 (2) any and all documents included in the personnel files of Defendants
1l Depufy Hernande z,Deputy N"ry, and Sergeant Edie that pertain to: r*
L2 (a) complaints or incidents involving use of force [including documents
13 related to the investigation and outcome of the alleged use of force];
t4 (b) complaints or incidents involving dishonesty, false reporting, or
15 failing to report, [including documents related to the investigation and

t6 outcome of the alleged dishonesfy, false reporting, or failing to report];

l7 (c) complaints involving the handling of detainees Iincluding
1B documents related to the investigation and outcome of the alleged
19 handling of detainees]; and
20 (d) reprimands relating to use of force, dishonesty, false reporting,
2l failing to report, or the handling of detainees;
22 (3) internal affairs recorcis and documcnts perlaining to all allegations of use

Z) of force, dishonesty, false reporlir-tg, failing to repod, or the handling of detainees

24 against Defendants Depuly I'lernandcz, Deputy Nery, ar-rd Sergeant E,die, including
25 the documents related to tire internal investigation and outcome of these allegations.
26 Documents produced under these designations, as well as information
27 extracted therefrom, shafi be reletred to as "Confider-rtial htformation," and shall be
2B subject to this Protective Order.

_)_ C-ase No L-A C\,' l0-6791 CAI--SIlr

PRO IECTI\-/E ORDI]R
 tllttrr'm{
yyz{
,)
i L. DTIRATTON
2 The confidentialiry obligations imposed by this Protective Order shall remain
a
in effect e\,/en after the terrnination of this litigation, and shall not be lifted without
4 further order of this Court.
5 In the event that the case proceeds to trial, all of the Confidential Information
6 becomes public and will be presumptively available to all members of the public,

1 including the press, unless sufficient cause is shown in advance of trial to proceed
8 otherwise-
9 3. DESIGNATEDCONFIDENTIALINFORMATION
10 3.1. Each pafty or non-party that designates Confidential Information
11 for protection under this Protective Order shall ensure t*rt such
l2 designation is not over-broad, and applies only to those
13 materials, documents, items. or cornmunications (or portions
t4 thereof) for which such protection is warranted.
15 3.2. Information may qualiS, as Confidential Information only if it
l6 has not been made public.
aa
17 Confidential Information protected by this Protective Order must
18 be clearly designated prior to the disclosure or production of
19 such Confidential Inforn-ration, and must bear the notation of
20 "Confidential" on each page that contains Confidential
2t Information, provided that such notation does not obscure or
22 obliterate the document contents.
Z) 3.4. An inadvefient failure to designateci Confidential Information
)A does not waive the producing parly's right to secure protection

25 under this Protective Order. If the producing party discovers

26 after production of the Confidential Information that the

21 information is iacking the appropriate designation, the producing
1()
.L6 party must timely notiS/ the receiving party. who shall mgke

Casc No.. Lr\ CV ,o@oo,-Sl'l.r

PRO I t.,(,--ttVt: Oitt)t,R
 ilfi/Blr'//rr'
fns#
1 reasonable effort to ensure tl"rat the Confidential Information is

7 treated in accordance with the provisions of this Order.

J
) 4. TERMS AND CONDTU9.IIS Q-E UWTTQN
4 4.1. Under no circumstances sl-rall Confidential Information be used
5 in any proceeding other than the instant case or be disseminated,
6 in any form, except by order of this Cour1. Confidential
7 Information must be stored and maintained by the receiving
8 parfy at a location and in a secure manner that ensures tl-rat access

9 is limited to the person authorized under this Protective Order.

10 4.2. Confidential information and information derived therefrom may

not be disclosed in any form to anyone not covered undpr
t1 -t this
l2 protective order.
i3 4.3. Disclosure of Confidential Inlormation designated
t4 "Confidential" shall be limited to the personnel and/or
15 classification of persons listed below:
l6 4.3.1. Any Party to this action and that Par{'s counse[;
t7 4.3.2. staff and personnel ernployed by counsel for any party to
18 this action;
19 4.3.3. the Court and court personnel, in connection with this
20 litigation;
2l 4.3-4. during their depositions, witnesses who, from the face of
22 the document, appear to ltave previously authored or

23 received it: and

24 4.3.5. experts or consultants retained/consulted to work on this

25 case by couinsel lor any party to this action (so long as
26 each such experl ol consultant agrees, in writing, to be

27 bound by the terms of this Protective Order).

2B

('asc No. l-.,\ Cv l0-6791 GAt'-SHr

OT{DER
 txltflnrrueo

I 4.4. Confidential Information that a parfy intends to use in suppofi of

2 or in opposition to a pre-trial filing with the Court must be filed

-) in accordance with the Central District of,California l-ocal Rules

4 relating to under seal filings, including Local Rule 79-5.
5 Counsel intending to use Confidential Information must both (a)

6 submit unredacted documents containing Confidential

7 Information under seal and (b) file public versions of the same
B documents with the Confidentia-l Information redacted.

9 4.5. Except as set forth in paragraph 4.5. 1, counsel for any parly to
10 this action shall advise those individuals to whom disclosure of
11 Confidential Information is to be rnade of the contents of this
\
l2 Protective Order, and such counsel shall obtain the consent of
13 such individual that l-re or she will b,e bound by this Protective

l4 Order, prior to disclosure of Confidential Information. In the

i5 event such individual does not consent to be bound by this

16 Protective Order, no disclosure of Confider-rtial Information shall

l7 be made to that individual.

1B 4.5.1. The foregoing provision shall not apply to the disclosure

l9 of Confidential Information to the Courl or the Court's
20 staff.
2l 4.6. Any counsel, expeft, consuitant or investigator retained by
22 counsel for any pafly to this case shall not ref'er to Confidentiai
,.)
1a
Information in any other courl proceeding without further order
24 of this Court.
25 4.7. The parlies shall macle good laith eflorts to consent to the r"rse of
26 Confidential Information, ancl shalI meet and confer to discuss
2l redactions of particularly sensiLive inlorntation befbre making
1O
.L6 use thereof.
(9
5- Casc -\o.- 1..\ CV l0-679 ] CAF -SIIx
pno'r gcrrVc oRoLJ(-_
 tltgr'lual
tfra7fi?
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I 4.8. Nothing in this Order shall be construed as authorizing a parfy to
2 disobey a lawful subpoena issued in another action.

-) 5. CHALLENGES TO DESIGNATION OF CONFIDENTTAL

4 INFORMATION
5 5-1. Should apafty challenge the confidentiality of information so

6 designated, that party must do so in good faith, and shall confer

7 directly with counsel for the producing party.

C)
o 5-2. If the parties are unable to resolve the designation informally, the
9 parry challenging the designation may fi[e and serve a motion

10 under Civil Local Rules 37-1 and 37-2, including the Joint
Stipulation requirement (and in compliance with Civil
11
{cal
t2 Rule 79-5, if appticable), identifying the basis for the challenge.
13 The burden of persuasion in any such challenge proceeding shall

14 be on the party designating Confidential Information. The

I5 designation of the challenged information shall remain

1(t unchanged until the Court rules on the challenge.

t1 6. UNAUTHORIZED DISCLOSURE OF CONF'IDENTIAL

18 INFORMATION
l9 6.1. If a receiving party learns that it has disclosed Confidential
?.0 Information to any person or entity not zruthorized to receive
71 such information pursuant to this Protective Orcier, the rcceiving

22 party shall immediately (a) notifi the proclucing party of the

1l
_) unauthorized disclosure, inclucling irlerrti flcation o f' the pelSon or

24 entity to whom such unauthorizeci disclosLrre rvas made, (b)

?5 retrieve all copies of the Confidential Infbrrnation frorn the
26 unauthorized recipient, (c) inlorm the unauthorized recipient of
27 the terms of this Protective L)rder and request that thel'agree, it-t

rQ ,,r,riting, to be bor-rnd hereto. Should the Cor-u1 rleternrinc tlat the

u{)
- -,G- !l:l \ 1:\ !r \ io ":''\rir I sl {t
PttO I'[:Cl'l\1 l: OILDi]ti
 Nt/gr'hdd
ffryr-
I receiving party intentionally disctosed ConfidentiaI Information
2 to an unauthorized pafi, the Court rnay consider the imposition
a
-) of sanctions, including but not limited to monetary sanctions
4 and/or issue preclusion.
5 6.2. Under no circumstances shall the receiving parfy file in the
6 public record any Confidential Information, without written
7 permission from the producing party or an Order of this Court,
B and only upon timely written notice to all interested parties. The

9 parties shall made good faith efforts to consent to the use of

10 Confidential Information, and shall meet and confer to discuss
l1 redactions of particularly sensitive information. {
t2 7. RIGHT TO ASSERT OBJECTTONS
13 7.1. By the entry of this Protective Order, the parties are not waiving
l4 any rights that they might otherwise have to objecting to
15 disclosure or production of information on any ground not
t6 addressed herein. The parties do not waive any right to object to

l7 the use in evidence of the material covered by this Protective

iB Order.
t9
20 This Order may not be modified unless by written consent of the parties and
2l approval of the Court.
22 IT IS SO ORDERED.
^L)

24 DA'|ED: March 29,2012

25
fulr*;-
26
The Hon. STEPHEN J. HII-LMAN
Z/ United States Masistrate Judse
28

-7- _C:rsc
NcrL;\ (l\i l0-67q1 C;\L !!l\
PRO i-ECTIVL OI{DI-R
 NturTu*l
rrw
1 Annroved as to form atrd content:
2
a
DATED. Ma"rch 28.2012 LAW OFFICES OF DAI.E K GAI,IPO
4
By: lsl Dale K. Galipo
5
Dale K. Galipo
6 Attorneys for Plaintiff
7

8 DA fE.D: March 28,2012 I_IAROLD G. BECKS & ASSOCIA'|ES

10
By: lsl Harold G. Becks
1i Harold G. Becks ,t
Attorneys for Def'eridants
t2
13

l4
15

16

t1
18

L9

20
2l
22
L)

24
25

26
27
2B

a Ca>c N().. l-,\ ( \. i{l (r7!)-l C.\[ -Sl'lx

PROTECTIVE OIIDf]R
Former Los Angeles sheriffs officials charged in federal jail investig... http:/iwww.businessinsider.com/former-los-angeles-sheriffs-officials...

m
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5XNESS
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Former Los Angeles sheriffs officials

charged in federal jail investigation
BRIAN MELLEY ASSOCIATED PRESS
AP MAY 15, 2015,12.28 AM

JI

LA County Sheriff Deputies with rifles and shotguns keep watch outside of the Twin Towers Jail in
response to a unconfirmed sighting by a civilian employee of Christopher Dorner in Los Angeles,
California February 8, 2013.

REUTE RS/ Patrick Fallon

LOS ANGELES (AP)

- The case of the vanishing inmate at the I-os Angeles County jail nearly went all the way to
the top.

The former second-in-command of the nation's largd$t sheriffs department and a high-ranking official who was
supposed to investigate crimes by deputies surrendered Thursday on charges they hid an FBI jailhouse informant
to hinder a federal investigation into abuse by guards.

"The scheme to obstrgglig[gg!_o__&e-_eI9p_g-Eycjevel"f,the Sheriffs Department," Acting U.S. Attorney

StephanieYonaSrampantabr]seatthejai1,,.,dboth-,,*",.
aware that the internal investigations of that abuse were insufficient."

Forrner UndersheriffPaul Tanaka and former Capt. William Thomas Carey, both 56, pleaded not guilty in U.S.
District Court to charges of conspiracy and obstruction ofjustice.

The two are the highest-ranking officials charged in the investigation ofjailhouse corruption and abuse that

I of4 6130120167:27 AM
SheriffLee Baca's retirement: 'Very shocking and very surprising' - latimes Page 1 of3

Adverlisement

l'OU,{RE HERE: L{T Home - Collections '- I€s. Enforcement

Adverlisemsnt
SheriffLee Baca's retirement: Very shocking and very
JanuarT 07, 2014 By Kate Mather and Abby Sewell

Emril Share G+l 0 Tweei Rroommand 0

Sheriff I*e Baca's surprise decision to retire was met with shock and praise across Los Angeles County.

Baca announced Tuesday he will step down at the end of the montb The move come amid several
scandals in the Sheriffs Department and an ongoing federal investigation iato deputy abuse in thejails.

County Supewisor Gloria Molina, who had been Baea's most vocal critic on the board, said of the sheriffs
resignation: "It was very sbocking and very zurprising. It certainly caught me off guard."

Molina said she thougbt Baca had "trusted people a little more tlan he should."

FROM TtrEARCIII\/ES
"I think there was a second tier of management that had tremendous problems," she said. ,t.
Mils to go for LA. justice
lulg 6,2@A the sherifffor uot moving to crack down on pmblems in the department
reached crisis level: "It doesn't have to fall apart before we fix it, and unfortunately things were
Bae, Bmttotr Issue Pleas for More Fmals
apafi for a number ofyears."
Octobq 29, 2oog

Eccomc r Flower e Dozen...

$1e.99 $49S9 4 Hour Hand Delivery! Starting at $19.99
"BarGIooI lllfitef'
And live tbe life of a
farcus writer rruitbout
having to ro:cite a block-
buster nonie script or a
chae-t-topping booh. los Angeles Police Chief Charlie Beck told reporters Tuesday the decision to retire was 'very difficult" for
Baca, whom he called a'friend and mentor."
LEITil ilONC THE UI{IOil'E CRO{'II
of 'IOUT O
HtGHLY"Pfl f,ilTtRs,.. "People who are in aspects of leadership in law enforcement have to r€alize that sometimes you have to
do things that are in tle best interest of the organization above your own self-interest," Beck said. "And I
believe based on what ke has know about him, that this is why he did &is."
MORB STORIESI ABOUT

law Enforcement "He believed his department to be impeded from

doing itsjob. continued. "He's a great man, He'll be known as a
Beck
great sheriff- is an extremely difficultjob."
Gmetti
Ie Baca
Los Angeles Mayor Eric Garcetti echoed those sentiments, ealling Baca's decision "the right move for
himself and for his department."

Beckand Garcetti said the}, hoped Baca's successorwould be astrong partnerto the LAPD, someonewho

w
would work to reduce crime levels and focus on rcgional security.

They also emphasized the importancre of a sheriff who values transpareut policing. Garcetti said he would
lookfora"@nqq@t*nmuk"*tqth"Cgljtltrllionbjg 4qq4iq4gd
4,Y" tevet of qe cnq,nd llqce:sj/ste
Beckagreed,

"I look for somebody ttrat's collaborative. I look for ,nse of traneparerrt,
constitutional law enforcement and I look ," Becksaid. -Iheseare
the two biggest law enforcement to work together.'

http:llarticles.latimes.com/z0l4ljanl0TllocaVla-me-ln-sheriffs-bacas-retirement-very-shocki... 21312016
 L.A. County Sheriffs Department intends to hre seven deputies - latimes Page I of I

Eat:k to Original .r-niclc

-
L.A. County Sheriffs Department intends to fire seven deputies
='=*-":i ilffiTfiisiri?-riTfir.*.*
February o6, 2013 I By Robert Faturechi, los Angeles Times
Seven I-os Angeles County sheriffs deputies harc been notificd that the department inteDds to fire thcm for belonging to a secret law cnforcement clique ttrat
allegedly celebrated shootings and branded its members with matching tattoos, o{fcials said.

Tbe Times reported last year about tie existence of the clique, dubbed the Jump Out Boys, and the discovery of a pamphlet that described the group's creed,
which required aggressive policiug ar:d awarded tattoo modifications for Jrolice shootings.

The seven worked on an elite gang-enforcement team that patrols neighborhoods where violence is high. The team makes a priority of taking gum off the
street, officials said.

The Sheriffls Depa-rtmcnt has a long history of secrct cliques with members of the groups having reached high-raaking positions within the agency. Sheriff
ofEcials bave sought to cmck down on thc groups, fearing that they tamished the department's reputation and encouraged rmethical conduct.

In the casc of the Jurnp Gut Boys, sheriffs iavestigators did Dot uncover any criminal behavior. But, souces sai4 the group claslred with department policie.s
and image.

Their tattoos, for instance, depicted an oversize skull with

a wide, toothy grimace and glowing red eyes. A baldanna with ttre unit's acrotr,'rn is wrappcd
around the skull- A bony hand clasps a revolver. Smoke would be tattooed over Lhe gun's barrel for members who were involved in at least one shooting,
officials said-

One memlu, who spokc to The'fimes and requested anonymity, said the group pmmoted only hard work an<I bravery. He dismissed concerns about the {
group's tattoo, noting tlmt deputies throughout the department get matching tattoos. He said there was nothing sinister about their creed or conduct- The
deputy, who was oorified of the department's int€nt to terminate him, read The Times several passages from the pamphlet, wbich he said supported proactivc
policing.

"We are alpha dogs who think and act like the wolf, but neqer b€rome the nnolf," one passage state{ compa.rhg crinilnals to wolves. Another passage stated,
"We are not a.fraid to gct our hands dirtf without any disgrace, dishoaor or hesitation... sometimes (members) necd to do the things they don't rvant to in order
to get w*rere they want to bc."

DepartmeDt spokesman Steve r(4ritmore said starting the termination process shows that Sheriff [-ee Baca "does not take any of this lightly and wiil move
fomard with the appropriate action."

Investigators rvere lss concemed about tl€ tattms, ald more focused on the sxpected admiration tlrry showed for offim-involved shootings, which are
expected to be evcnls of Lrst resort. The dcprlty told The Times, bowcver, that investigators rwiewed their shootings and mests and found nothing unlanlirl.

"We get ca-lled a gang within the badge? It's un[air," he said. "People want to sayyou have a tattoo. So do fraternities. Go to Ya1e. Are they a gang?-... t]oy
Scouts have paiche and they have mision statemmls, and so do we'

"We do not glorily shootilgs," he mntinued- "What we do is cornmend and honop 1fu 5[66tings. I have to remember them becaure it cm happca any I ime, any
day. I don't want to forget them be<zuse I'm g]ad I'm alive."

If thc firings are upheld, it would be one of the largest tcnninations over one incideat in the department's history. In zou, the dcpartrnent fircd about half a
dozcndeputiesnhowerealsosaidtohavefonnedactique.'l'hosedeputiesworkcdonthethirdfoorofMen'sC,entral.iailandallegediylhreu,gang-likcttrce- (^
finger hand signs. Thcy rr'ere fircrl after they fought tu,o fellow deputies at an employee Christmas party and ailegcdly punclied a female cleput)r in tlre face. / -
/ln "-

cliques, specifically citing several of the groups including the "3ooo boys" and the Jump Out Boys- Al€rA l_f
When the parnphlet revealing tlre existencr: of the Jump Out Boys was initially found, ofEcials d.idn't know if the group was real. But eventua ttr, orr.*"^*!
!9.%*
came fonvard and named the others, according to an offrcial rvho askcd for anonymity bemrrse he was not authorized to speak to thc media- ,fffi
The sewen deputies can tig.lrt the deparLnrenl's decision io fire them.

r o b e r t Jaatr e chi(l I a t ir t es - co rn

fffS AngeleS Ginfe6 (hprildrt u o t(r Ins .\nrrttes 't'imcs Index blr Keyrvord I Index by Date I Privacy Policl' | 1'cnns of &:rr.ice

htl p://ar1ic lcs.lal irncs.corn/print /20 I -'r i 1'eh/06/loc6l/la-rne - jurr-rp-out-hor,.s-20 1 3 0? 07 5 /2?t?016