Aldama, Samuel May 16, 2018 - Cond

Atkinson-Baker Court Reporters
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1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
2 COUNTY OF LOS ANGELES, SOUTH DISTRICT
4 ANDREW TAYLOR, individually and )

as successor-in-interest to Donta )
5 Taylor; SHERRON OLIVER; CARL )
TODD, JR., a Minor; CARMEN TODD, )
6 a Minor; and CAMREN TODD, a Minor,)
by and through their Guardian Ad )
7 Litem SHERRON OLIVER, )
)
8 Plaintiff, )
)
9 vs. ) Case No.: TC028803
)
10 COUNTY OF LOS ANGELES; LOS )
ANGELES COUNTY SHERIFF'S )
11 DEPARTMENT; and DOES 1 through )
50, Inclusive, )
12 )
Defendants. )
13 __________________________________)
14
15
VIDEO DEPOSITION OF
16
SAMUEL ALDAMA
17
BEVERLY HILLS, CALIFORNIA
18
MAY 16, 2018
19
20
21 ATKINSON-BAKER, INC.
COURT REPORTERS
22 (800) 288-3376
www.depo.com
23
24 REPORTED BY: Lois Sarkisian, CSR No. 13707, RPR
25 FILE NO: AC052F6
Samuel Aldama
May 16, 2018
Page 1
www.depo.com
1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 1 INDEX

2 2
COUNTY OF LOS ANGELES, SOUTH DISTRICT 3 WITNESS: Samuel Aldama
3
4 EXAMINATION: PAGE
4 ANDREW TAYLOR, individually and )
5 By Mr. Sweeney 6,133
as successor-in-interest to Donta )
5 6 BY Mr. Day 128
Taylor; SHERRON OLIVER; CARL )
TODD, JR., a Minor; CARMEN TODD, ) 7
6 a Minor; and CAMREN TODD, a Minor,) 8
by and through their Guardian Ad ) 9
7 Litem SHERRON OLIVER, )
EXHIBITS
)
10
8 Plaintiff, )
11 FOR PLAINTIFFS
)
9 vs. ) Case No.: TC028803 12 NUMBER DESCRIPTION PAGE
) 13 1 Copy of Document No. 016-10848-2811-013, 87
10 COUNTY OF LOS ANGELES; LOS ) Interview of Deputy Samuel Aldama,
ANGELES COUNTY SHERIFF'S ) 14
11
Dated August 30, 2016, Bates stamped
DEPARTMENT; and DOES 1 through )
DEF 0052 through DEF 0054, 3 pages
50, Inclusive, )
12 15
)
Defendants. ) FOR DEFENDANTS:
13 __________________________________) 16
14
1 Copy of Bates stamped document DEF 0158 128
15
17 which includes a map, 1 page
16 Video deposition of Samuel Aldama taken on behalf
18
17 of Plaintiffs, at 315 South Beverly Drive, Suite 305,
18 19
Beverly Hills, California, commencing at 10:02 AM,
19 Wednesday, May 16, 2018, before Lois Sarkisian, 20
20 CSR No. 13707, RPR. 21
21 22
22
23
23
24
24
25 25
Page 2 Page 4
1 APPEARANCES 1 Beverly Hills, California, Wednesday, May 16, 2018, 10:02 AM
2
3 2 --oOo-- 10:02:36
FOR PLAINTIFFS:
4 THE SWEENEY FIRM 3 10:02:36
THE VIDEOGRAPHER: Good morning. I am Albert Salaz,
BY: JOHN E. SWEENEY, ESQ.
5 315 South Beverly Drive 4 your videographer. I represent Atkinson Baker in Glendale 10:02:47
Suite 305 5 10:02:52
6 California. I'm a notary public. I'm not financially
Beverly Hills, California 90212
(310) 277-9595 6 interested in this action nor a relative or employee of any 10:02:55
7 jes@thesweeneyfirm.com
8
7 attorney or any of the parties. 10:02:58
FOR PLAINTIFFS: 8 The date is May 16, 2018, and we are on the record 10:03:00
9
9 at 10:03 AM. This deposition is taking place at 315 South 10:03:04
GLICKMAN & GLICKMAN
10 BY: NICOLE E. HOIKKA, ESQ. 10 10:03:11
Beverly Drive, Suite 305, Beverly Hills, California, 90212;
9460 Wilshire Boulevard
11 Suite 330 11 case number TC 028803, case entitled Andrew Taylor et al., 10:03:16
Beverly Hills, California 90212 12
12 (310) 273-4040 versus County of Los Angeles. The deponent is deputy Samuel 10:03:24
neh@glickman-law.com 13 Aldama. This deposition is taking place -- or this 10:03:30
13
14 14 deposition is taken on behalf of the plaintiff. Your court 10:03:34
FOR DEFENDANTS: 15 reporter today is Lois Sarkisian from Atkinson Baker. 10:03:38
15
HAROLD G. BECKS & ASSOCIATES 16 Will counsel from both parties identify themselves. 10:03:46
16 BY: DOUGLAS L. DAY, ESQ. 17 MR. SWEENEY: John Sweeney for the plaintiffs. 10:03:51
3250 Wilshire Boulevard
17 Suite 708 18 MS. HOIKKA: Nicole Hoikka for the plaintiffs. 10:03:54
Los Angeles, California 90010
18 19 MR. DAY: Douglas Day on behalf of the Defendants. 10:03:56
(213) 385-9852
Dougday@beckslaw.com 20 THE VIDEOGRAPHER: Thank you. Will the court reporter 10:03:58
19
20 21 please administer the oath. 10:04:00
Also Present: 22 10:04:00
21 Samuel Aldama,
Albert Salaz, Videographer 23 having first been duly sworn, was 10:04:00
22
23 24 examined and testified as follows: 10:04:00
24 25 THE VIDEOGRAPHER: Please begin.
25
Page 3 Page 5
Samuel Aldama
May 16, 2018
2 (Pages 2 to 5)
www.depo.com
1 EXAMINATION 10:04:13 1 Q Okay. 10:06:56
2 BY MR. SWEENEY: 10:04:13 2 Do you understand the difference between a material 10:06:57
3 Q Thank you. Deputy, would you state and spell your 10:04:13 3 change and a non-material change? 10:07:01
4 name for the record. 10:04:16 4 A No, sir. 10:07:05
5 A Yes. Samuel Aldama, S-A-M-U-E-L A-L-D-A-M-A. 10:04:17 5 Q Okay. Let's say this were an automobile accident 10:07:07
6 Q My name is John Sweeney. I represent, along with 10:04:23 6 case, and you were charged with striking a pedestrian, and I 10:07:10
7 Nicole Hoikka, the plaintiffs in a lawsuit Andrew Taylor et 10:04:29 7 ask you at this deposition what color was the light when the 10:07:19
8 al., versus County of Los Angeles. You understand that is 10:04:37 8 pedestrian was walking in front of you, and you initially 10:07:23
9 what you are here for, correct? 10:04:40 9 said it was green for me to go or -- strike that -- it was 10:07:28
10 A Yes. 10:04:41 10 red for me to stop, but you thought about it and you thought 10:07:33
11 Q Have you ever had your deposition taken before? 10:04:42 11 you made a mistake and when you read over the transcript you 10:07:36
12 A No, sir. 10:04:47 12 changed it to green. That is a material change. Okay? 10:07:41
13 Q Have you had a chance to talk with your lawyer 10:04:49 13 A Yes, sir. 10:07:43
14 Mr. Day about the nature of these proceedings? 10:04:51 14 Q You have to answer my questions audibly, that is, 10:07:44
15 A Yes, sir. 10:04:55 15 out loud. You can't nod your head in the affirmative and 10:07:52
16 Q Okay. At the risk of repeating some of the things 10:04:56 16 shake your head in the negative as answers because, No. 1, 10:07:59
17 he probably already told you, I'm going to go over some 10:04:59 17 the court reporter may not be looking at you and she may not 10:08:04
18 ground rules so that we have it on the record that you are 10:05:02 18 be able to make a record and, No. 2, she is not authorized 10:08:09
19 informed of them and you understand them. Okay? 10:05:06 19 to interpret your gestures, a shake of a head, the shrug of 10:08:13
20 A Yes, sir. 10:05:09 20 a shoulders for I don't know, things like that. Okay? 10:08:17
21 Q First off, you've been placed under oath by a court 10:05:10 21 A Okay. 10:08:21
22 reporter. Even though we are in the informal confines of my 10:05:15 22 Q I'm going to be asking you questions about times, 10:08:22
23 office conference room, it is the same oath that you would 10:05:20 23 maybe distances, things like that. This incident took place 10:08:27
24 take in a court of law if a judge or the judge's clerk were 10:05:24 24 about two years ago; is that correct? A little under two 10:08:31
25 giving it. It attaches with it the duty to tell the truth 25 years ago; is that correct?
Page 6 Page 8
1 under penalty of perjury. 10:05:33 1 A Yes, sir. 10:08:37
2 Do you understand that? 10:05:35 2 Q All right. You may not know exactly what the 10:08:39
3 A Yes, I do. 10:05:36 3 distance was, or time may have eroded your memory a little 10:08:45
4 Q Do you understand what perjury is? 10:05:37 4 bit. It's my job to refresh your recollection. I don't 10:08:53
5 A Yes, I do. 10:05:39 5 want you to guess as to any question, okay, but I am 10:08:57
6 Q You understand that if you say that you don't know 10:05:40 6 entitled to your best estimate. Okay? I will do everything 10:09:03
7 the answer to one of my questions but you really do that is 10:05:45 7 I can, if you don't remember something, to refresh your 10:09:08
8 perjury. 10:05:51 8 recollection. Okay? 10:09:11
9 Do you understand that? 10:05:51 9 Do you understand the difference between a guess 10:09:17
10 A Yes, I do. 10:05:52 10 and an estimate? 10:09:19
11 Q Everything that is said here is being transcribed 10:05:56 11 A Yes. 10:09:20
12 and video recorded. Okay? You are going to get a chance to 10:06:01 12 Q Okay. 10:09:21
13 look over the transcription of this deposition in about less 10:06:05 13 Is there any reason why your deposition cannot go 10:09:26
14 than a month. Okay? It's going to be in booklet form. 10:06:11 14 forward today? 10:09:28
15 It's going to be sent to you. It reads like a script. 10:06:16 15 A No. 10:09:30
16 Everything that I say is transcribed, and anybody else here, 10:06:18 16 Q Have you had enough sleep so that your mind is 10:09:32
17 what they say is transcribed. 10:06:23 17 clear and you can give your best deposition today? 10:09:38
18 You are going to get a chance to read it over and 10:06:26 18 A Yes. 10:09:42
19 make any changes that you deem necessary and sign it under 10:06:30 19 Q Have you taken any type of medication, alcohol or 10:09:43
20 penalty of perjury, but let me warn you that if you make any 10:06:34 20 drugs that would impair your ability to give your best 10:09:49
21 material changes in your testimony between today's date and 10:06:39 21 testimony today? 10:09:54
22 the time that you read it over and sign it under penalty of 10:06:44 22 A No. 10:09:55
23 perjury that I or any other lawyer involved in this case can 10:06:47 23 Q Okay. 10:09:56
24 comment upon your change. Okay? 10:06:51 24 So let's start with your background. What is your 10:09:57
25 A Yes, sir. 25 highest level of education?
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Samuel Aldama
May 16, 2018
3 (Pages 6 to 9)
www.depo.com
1 A AS degree, sir. 10:10:06 1 Q So all the jobs that you had between Dominguez High 10:13:35
2 Q What does AS stand for? 10:10:09 2 School and the Academy were at Pep Boys and as a TA; is that 10:13:40
3 A Associates degree on automotive. 10:10:11 3 correct? 10:13:46
4 Q Where did you take that degree? 10:10:14 4 A Correct. 10:13:46
5 A I attended Los Angeles Trade Tech College. 10:10:18 5 Q You said you wanted to serve your community. 10:13:52
6 Q What year did you go to Los Angeles Trade Tech 10:10:25 6 That's why you became a police officer, correct? 10:13:59
7 College? 10:10:28 7 A That's correct. 10:14:02
8 A Estimating on 2005 to 2007. 10:10:31 8 Q Do you believe -- your community is the Compton 10:14:05
9 Q What city were you raised in? 10:10:44 9 community, correct? 10:14:08
10 A I was raised in the city of Compton and Lynwood. 10:10:48 10 A Yes. 10:14:09
11 Q What high school did you attend? 10:10:53 11 Q All right. Do you believe in your tenure as a 10:14:11
12 A I attended Dominguez High School in the city of 10:10:58 12 police officer you have honestly and with integrity served 10:14:15
13 Compton. 10:11:04 13 your community? 10:14:23
14 Q Did you graduate? 10:11:05 14 A I have. 10:14:25
15 A Yes. 10:11:06 15 Q All right. Have you had any military service? 10:14:29
16 Q What year did you graduate? 10:11:07 16 A No, sir. 10:14:33
17 A I graduated 2003. 10:11:09 17 Q 2007 you entered the Academy, correct, did you say? 10:14:38
18 Q 2002? 10:11:14 18 A That is correct. 10:14:43
19 A Three, sir. 10:11:15 19 Q Okay. What Academy did you attend? 10:14:44
20 Q Tell me all your jobs you had before you entered a 10:11:18 20 A Academy Class 367. 10:14:48
21 police Academy, between high school and the time that you 10:11:23 21 Q Los Angeles County Sheriff's, correct? 10:14:56
22 entered the Academy. 10:11:29 22 A That is correct, sir. 10:14:59
23 A My first job was working for the Los Angeles School 10:11:36 23 Q Did you ever apply to any other law enforcement 10:15:00
24 District assigned to Dominguez High School as a teacher 10:11:43 24 agency? 10:15:04
25 assistant for automotive. 25 A I did apply to, I believe, Orange County Sheriff's
Page 10 Page 12
1 10:11:51 1 Department as well. 10:15:12
Q For what?
2 10:11:51 2 Q Were you ever turned down by any law enforcement 10:15:13
A Automotive.
3 10:11:53 3 agency? When I say turned down, when you submitted an 10:15:18
Q Okay. What year was that job?
4 10:11:59 4 application they rejected you. 10:15:22
A It was in the year of 2006.
5 10:12:09 5 A No, sir. 10:15:26
Q How long did you have that job?
6 10:12:12 6 Q Did you receive an offer from the Orange County 10:15:29
A Approximately six, seven months.
7 10:12:17 7 Sheriff's Department? 10:15:32
Q So you are a TA for six or seven months, correct?
8 10:12:20 8 A No, sir. 10:15:33
A Correct.
9 10:12:20 9 Q Did you receive an offer from the Los Angeles 10:15:38
Q What was your next job?
10 10:12:23 10 County Sheriff's Department before you heard from the Orange 10:15:42
A I was also working a part-time job at a Pep Boys in
11 10:12:31 11 County Sheriff's Department? 10:15:47
the city of Huntington Park.
12 10:12:33 12 A Yes, I did. 10:15:50
Q The city of what?
13 10:12:34 13 Q Did you ever hear back from the Orange County 10:15:53
A Huntington Park.
14 10:12:36 14 Sheriff's Department? 10:15:57
Q How long did you work at Pep Boys?
15 10:12:39 15 A Not that I -- I don't remember that, sir, if I did 10:16:07
A I worked approximately five months.
16 10:12:45 16 or not. 10:16:11
Q What did you do after that?
17 10:12:47 17 Q Okay. Do you recall ever being rejected by them, 10:16:11
A When I was at work, I was also in the background
18 10:12:56 18 saying that the application that you submitted was rejected 10:16:14
checks for the Sheriff's Department.
19 10:12:59 19 or words to that effect? 10:16:21
Q What made you want to become a police officer?
20 10:13:05 20 A No. I was at the beginning stages of the 10:16:23
A To help my community make a change.
21 10:13:16 21 application. 10:16:26
Q What year did you enter the Academy?
22 10:13:24 22 Q Describe the beginning stages. What did you do? 10:16:27
MR. DAY: Entrance to the Academy, not graduate?
23 10:13:27 23 A It was the physical agility test, I believe, first 10:16:33
BY MR. SWEENEY:
24 10:13:28 24 and then -- 10:16:38
Q Enter the Academy.
25 A I entered the Academy on October 3rd of 2007. 25 Q But certainly you had to fill out some type of
Page 11 Page 13
Samuel Aldama
May 16, 2018
4 (Pages 10 to 13)
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1 paperwork before they gave you a physical agility test, 10:16:44 1 10:20:42
A Not that I know of, sir. It's been almost ten
2 correct? 10:16:47 2 10:20:45
years.
3 A That is correct. 10:16:49 3 10:20:45
Q There are more than 40, correct?
4 Q You did the physical agility test. Did you pass? 10:16:51 4 10:20:48
MR. DAY: If you know.
5 A Yes, I did. 10:16:55 5 10:20:50
THE WITNESS: I'm not sure.
6 Q Were you contacted by the Orange County Sheriff 10:16:59 6 10:20:51
BY MR. SWEENEY:
7 10:17:05
that you were to show up for another step, the next step to 7 Q Okay. Give me your best estimate of how many 10:20:51
8 becoming -- to entering the Academy? 10:17:09 8 10:20:57
learning domains there are.
9 A I was supposed to schedule an appointment for a 10:17:13 9 10:21:06
MR. DAY: Don't guess. If you have a basis for giving
10 written exam. However, I was contacted by the LA County 10:17:19 10 10:21:08
an answer.
11 Sheriff's Department, and I decided to go with them. 10:17:23 11 10:21:09
THE WITNESS: I don't remember.
12 Q So how long was your Academy training? 10:17:27 12 10:21:10
BY MR. SWEENEY:
13 A It was approximately five-months-and-a-half. 10:17:35 13 10:21:11
Q Was it more than 10?
14 Q What was your rank in the class at graduation? 10:17:42 14 10:21:12
A Yes.
15 A Just Deputy Sheriff, sir. 10:17:49 15 10:21:12
Q More than 20?
16 Q How many people were in the class? 10:17:54 16 10:21:15
A Yes.
17 A I believe it was 130 -- between 130 and 140 10:17:58 17 10:21:18
Q More than 30?
18 trainees. 10:18:12 18 10:21:23
A I'm not sure about that.
19 Q One -- I'm sorry. One admonition that I forgot to 10:18:14 19 10:21:24
Q Okay.
20 10:18:17
tell you, and I just broke it, is that two people cannot 20 You must take a test on each chapter or learning 10:21:26
21 speak at one time. So you have to wait for me to finish my 10:18:20 21 10:21:32
domain, isn't that true?
22 question before you give your response, and I did not accord 10:18:24 22 10:21:35
A That is true.
23 you the same courtesy, and I will in the future. I will not 10:18:28 23 10:21:37
Q Did you fail to pass any of those tests on the
24 talk over you because we have to have a clear record. Okay? 10:18:31 24 first try? 10:21:42
25 Does the Los Angeles County Sheriff's Academy rank 25 A Yes, I did.
Page 14 Page 16
1 each member with grades and like a valedictorian at the top 10:18:44 1 Q What learning domain did you fail? 10:21:48
2 and then so on down the line? 10:18:49 2 A It was the learning domain for crimes against 10:21:54
3 MR. DAY: Objection; calls for speculation. 10:18:53 3 children. 10:21:58
4 BY MR. SWEENEY: 10:18:55 4 Q Any other one? 10:22:00
5 Q If you know. 10:18:55 5 A No. 10:22:03
6 A What I know is they do the honor recruit which is 10:18:59 6 Q There is a learning domain on use of force, isn't 10:22:05
7 the highest in the Academy. 10:19:05 7 there? 10:22:10
8 Q Were you in that? 10:19:08 8 A I'm not sure. 10:22:15
9 A No, sir. 10:19:10 9 Q Were you taught about when you could or could not 10:22:18
10 Q Okay. How many are in the honor recruit category, 10:19:12 10 use force in the arrest of a citizen? 10:22:22
11 approximately? 10:19:18 11 MR. DAY: Are you asking now at the Academy? 10:22:27
12 A It is just one. 10:19:20 12 BY MR. SWEENEY: 10:22:29
13 Q Just one. Okay. 10:19:21 13 Q The Academy. 10:22:30
14 It's like the valedictorian in high school or 10:19:24 14 A Yes. 10:22:31
15 college, right? 10:19:27 15 Q All right. You recall learning that in your POST 10:22:33
16 A Yes. 10:19:28 16 training, correct? 10:22:38
17 Q You are POST trained in the Academy? 10:19:37 17 A Yes, sir. 10:22:41
18 A Correct, sir. 10:19:41 18 Q You passed it on your first try, correct? 10:22:42
19 Q What does POST stand for? 10:19:42 19 A Yes, sir. 10:22:46
20 A It stands for Police Officer -- Police Officer -- 10:19:45 20 Q That is the basis -- strike that. 10:22:47
21 I'm sorry. I had a blank. 10:20:24 21 That was the basis of your knowledge of when to use 10:22:51
22 Q That's okay. Did you pass all of your POST -- 10:20:28 22 and not to use force, correct? 10:22:58
23 strike that. 10:20:32 23 A Correct. 10:23:04
24 How many learning domains are there in POST, if you 10:20:32 24 Q Okay. 10:23:05
25 know? 25 You also had a learning domain about how to treat
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Samuel Aldama
May 16, 2018
5 (Pages 14 to 17)
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1 the public in general, correct; with decency, correct? Does 10:23:16 1 A It's for incidents and to let the department 10:26:13
2 that ring a bell? 10:23:21 2 members know what can you do or what can be accomplished. 10:26:20
3 A I'm not sure about the learning domain, but, yes, 10:23:23 3 Q Were you taught anything about the inherent dangers 10:26:26
4 we did. 10:23:27 4 of a foot pursuit both to the officer and to the arrestee? 10:26:30
5 Q What do you recall about that? 10:23:27 5 A Yes. 10:26:34
6 A Making contact with the community and responding to 10:23:29 6 Q Isn't it true that foot pursuits, a 10:26:43
7 calls and making contact with the citizens. 10:23:39 7 disproportionate amount of foot pursuits, end in some type 10:26:46
8 Q Okay. What did you learn about that? Should you 10:23:44 8 of injury or death to the suspect? 10:26:51
9 treat citizens with decency and respect? 10:23:47 9 A Can you repeat that question again, sir? 10:26:59
10 A Yes, sir; that's the goal. 10:23:53 10 Q Sure. Isn't it true that a large amount of injury 10:27:02
11 Q Have you always treated arrestees, people that 10:23:56 11 and/or death occurs to the suspect during a foot pursuit? 10:27:07
12 you've arrested, with decency and respect? 10:24:00 12 MR. DAY: Objection; no foundation, argumentative. 10:27:19
13 A Yes, I have. 10:24:04 13 BY MR. SWEENEY: 10:27:23
14 Q You are under oath. I'm going to ask that question 10:24:07 14 Q What were you taught about that? 10:27:23
15 again. Have you always treated arrestees with decency and 10:24:10 15 A Injuries don't happen all the time on foot 10:27:26
16 respect? 10:24:14 16 pursuits. 10:27:30
17 A Yes, I have. 10:24:16 17 Q They what? 10:27:30
18 Q Does Los Angeles County Sheriff's Department have a 10:24:27 18 A They don't happen all the time on foot pursuits. 10:27:31
19 policy on foot pursuits? 10:24:29 19 Q Right, right. But were you taught anything in the 10:27:33
20 A Yes, they do. 10:24:36 20 material that you reviewed on foot pursuits that they can be 10:27:37
21 Q Did you ever read it? 10:24:37 21 dangerous? 10:27:41
22 A I have. 10:24:40 22 A It's dangerous to the suspects and as well to the 10:27:45
23 Q Tell me what context you read it in. Did you 10:24:44 23 deputies, sir. 10:27:49
24 actually get a foot pursuit policy and read it cover to 10:24:47 24 Q Yes. You were taught that, correct? 10:27:50
25 cover, or were you given a class? Just how did you learn 25 A Correct.
Page 18 Page 20
1 about it? 10:24:55 1 Q Why? Do they explain why in your material they are 10:27:53
2 A We have a manual policy at the station that 10:24:56 2 dangerous? 10:27:58
3 everyone has access to, and we are reminded by our unit 10:25:04 3 A Yes. 10:28:06
4 commander to just read them; if there are any changes, to 10:25:09 4 Q Why? 10:28:09
5 note the changes. 10:25:14 5 A Because there are a lot of obstacles, areas, 10:28:16
6 Q Right. So you pretty much keep up on it since you 10:25:15 6 dangerous areas. 10:28:21
7 left the Academy, correct, what the policy is, correct? 10:25:19 7 Q What were you taught about if you have a partner, 10:28:23
8 A Correct. 10:25:23 8 not a single officer pursuit but if you are pursuing with a 10:28:29
9 MR. DAY: You are asking -- I'm sorry. You are asking 10:25:23 9 partner, about splitting with that partner? What do you 10:28:35
10 generally this policy or just policies? 10:25:26 10 know about that? 10:28:37
11 MR. SWEENEY: I'm sorry. What? 10:25:30 11 MR. DAY: Are you asking -- I'm sorry. 10:28:38
12 MR. DAY: You are asking generally this policy or 10:25:31 12 MR. SWEENEY: I'm sorry? 10:28:39
13 policies in general? 10:25:32 13 MR. DAY: I don't want to interrupt your question. 10:28:40
14 MR. SWEENEY: This policy, the foot pursuit policy. 10:25:32 14 MR. SWEENEY: I'm sorry. What? 10:28:42
15 THE WITNESS: Yes. 10:25:36 15 MR. DAY: I don't want to interrupt. I'm sorry if I 10:28:42
16 BY MR. SWEENEY: 10:25:39 16 interrupted your question. 10:28:46
17 Q Okay. You were familiar with it, the Los Angeles 10:25:40 17 BY MR. SWEENEY: 10:28:46
18 County Sheriff's Department's foot pursuit policy in the 10:25:47 18 Q The end of the question was in the year 2016. 10:28:46
19 year 2016, correct? 10:25:48 19 MR. DAY: Are you asking what he was taught at the 10:28:49
20 A Correct. 10:25:49 20 Academy? 10:28:52
21 Q Do you know why the Los Angeles County Sheriff's 10:25:54 21 MR. SWEENEY: No, no. 10:28:52
22 Department has a foot pursuit policy? 10:25:57 22 BY MR. SWEENEY: 10:28:54
23 MR. DAY: Objection; calls for speculation. 10:25:59 23 Q At the Academy or in your review of the foot 10:28:55
24 BY MR. SWEENEY: 10:26:01 24 pursuit policy that you talked about. 10:28:58
25 Q If you know. 25 MR. DAY: Well, objection; compound. If you understand,
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Samuel Aldama
May 16, 2018
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1 go ahead and answer, Deputy. 10:29:05 1 person? When can you do that, in general? 10:32:23
2 THE WITNESS: Can you repeat the question because now -- 10:29:07 2 A I'm not sure there is a policy of unholstering a 10:32:29
3 BY MR. SWEENEY: 10:29:09 3 weapon. 10:32:40
4 Q Sure. What were you taught about the splitting of 10:29:10 4 Q Okay. Can you unholster a weapon and point it at 10:32:40
5 pursuing officers during a foot pursuit? You know what 10:29:12 5 someone to intimidate them if they don't have any weapon on 10:32:46
6 splitting means? One officer goes one way and another 10:29:21 6 them? 10:32:51
7 officer goes the other way and you lose sight of each other 10:29:25 7 MR. DAY: Objection; incomplete hypothetical to a lay 10:33:02
8 so that you don't have each other's back, so to speak. Do 10:29:28 8 witness. You may answer. 10:33:05
9 you know -- 10:29:32 9 BY MR. SWEENEY: 10:33:06
10 A Yes. 10:29:33 10 Q In other words -- I'll withdraw that question. Let 10:33:06
11 Q What were you taught about that? 10:29:33 11 me ask this question. 10:33:08
12 A That it's dangerous when that happens. 10:29:39 12 Assuming the suspect was no threat to you, posed no 10:33:11
13 Q Yeah. Do they explain to you why it is dangerous? 10:29:44 13 threat, did not make any gestures towards you and had no 10:33:14
14 A Yes. 10:29:48 14 weapon, can you unholster your weapon and point it at him 10:33:17
15 Q What was the explanation? 10:29:49 15 just to intimidate him? 10:33:23
16 A Well, the partner splitting is you cannot assist 10:29:53 16 A No, sir. 10:33:31
17 your partner immediately. 10:29:59 17 Q That would be wrong, wouldn't it? 10:33:32
18 Q Also there is a possibility that your partner, you 10:30:01 18 MR. DAY: Objection; argumentative. 10:33:37
19 could be in each other's crossfire in case of the use of 10:30:07 19 THE WITNESS: Yes. 10:33:40
20 force with respect to handgun issues, correct? 10:30:16 20 BY MR. SWEENEY: 10:33:41
21 MR. DAY: Objection; no foundation, calls for 10:30:18 21 Q It would be in violation of Los Angeles County 10:33:41
22 speculation. 10:30:21 22 Sheriff's Department policy, wouldn't it? 10:33:45
23 THE WITNESS: It's possible. 10:30:22 23 MR. DAY: Objection; no foundation. 10:33:49
24 BY MR. SWEENEY: 10:30:23 24 THE WITNESS: I'm not sure if there is a policy on it. 10:33:53
25 Q Yeah. 25 ///
Page 22 Page 24
1 What is the Sheriff's Department policy with 10:30:26 1 BY MR. SWEENEY: 10:33:58
2 respect to losing communications with the command post 10:30:34 2 Q That would be a violation of all of your teachings 10:33:59
3 during a foot pursuit? 10:30:40 3 at POST and your training after you left the Academy, true? 10:34:02
4 A I'm not sure about the command post but the -- 10:30:45 4 A If there was a policy, it would be a violation, 10:34:11
5 Q CSS: What is CSS? 10:30:52 5 yes, sir. 10:34:15
6 A I'm not sure what CSS is. 10:30:55 6 Q And it would probably be just, speaking as a 10:34:16
7 Q Okay. 10:30:59 7 civilian, morally wrong to point a gun at someone for no 10:34:22
8 A I do know it's Sheriff's Communication Center, SCC. 10:31:01 8 reason, correct? 10:34:27
9 BY MR. SWEENEY: 10:31:09 9 A Correct. 10:34:32
10 Q Okay. All right. 10:31:10 10 Q What does color of authority mean to you? 10:34:34
11 So what is the policy, the Sheriff's Department 10:31:11 11 A Doing things that are wrong. 10:34:45
12 policy, if you lose communications with them? 10:31:14 12 Q Color of authority means doing things that are 10:34:54
13 MR. DAY: Are you asking if they lose communication? 10:31:19 13 wrong? That's what it means to you? 10:34:57
14 MR. SWEENEY: Yes. 10:31:22 14 A (Witness nods head up and down.) 10:35:01
15 THE WITNESS: You should terminate your foot pursuit 10:31:24 15 Q Okay. All right. 10:35:02
16 immediately. 10:31:26 16 Were you ever taught that when you are acting as a 10:35:07
17 BY MR. SWEENEY: 10:31:28 17 peace officer, you are doing things under the color of 10:35:13
18 Q Okay. 10:31:28 18 authority? Were you ever taught that? 10:35:17
19 When is the last time before January 2016 that you 10:31:34 19 A It doesn't -- 10:35:24
20 reviewed the Sheriff's Department foot pursuit policy? 10:31:38 20 Q I'm sorry? 10:35:26
21 A It was approximately a month, two months ago. 10:31:53 21 A It doesn't ring a bell in my -- 10:35:27
22 Q Two months before January of 2016? 10:31:58 22 Q Okay. Do you ever use your -- strike that. 10:35:34
23 A Oh, I'm sorry. I'm not sure. 10:32:01 23 Have you ever, from this day back to the time that 10:35:46
24 Q What is the Sheriff's Department's policy on when a 10:32:13 24 you graduated from the Academy, used your position as a 10:35:50
25 deputy can unholster his duty weapon and point it at a 25 peace officer to intimidate or scare someone that hasn't
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1 done anything? When I say hasn't done anything, has 10:36:03 1 A Yes. 10:39:53
2 committed no crime, is not suspected of committing any 10:36:08 2 Q Do you recall having an encounter with an 10:39:56
3 crime. 10:36:11 3 individual on Evers Street where eventually you had to use 10:39:58
4 A No. 10:36:12 4 force on him in 2016? 10:40:06
5 Q Have you ever -- strike that. 10:36:17 5 MR. DAY: Who is him? 10:40:08
6 Do you know what a Pitchess motion is? 10:36:19 6 MR. SWEENEY: Hmm? 10:40:10
7 A Yes. 10:36:23 7 MR. DAY: Who is him? 10:40:12
8 Q Okay. You are aware that my office brought a 10:36:25 8 BY MR. SWEENEY: 10:40:13
9 Pitchess motion in this case that we're here for, correct? 10:36:29 9 Q Him, on a male, in 2016. 10:40:13
10 A Correct. 10:36:36 10 A Yes. 10:40:20
11 Q By the way, these aren't trick questions. You know 10:36:40 11 Q Describe that male. 10:40:26
12 that there were complaints against you made by citizens that 10:36:51 12 A I can't -- I don't remember exactly how he looked 10:40:37
13 you had come into contact with. You know that, don't you? 10:36:56 13 like. 10:40:42
14 A Yes. 10:37:01 14 Q I'm not asking you -- Deputy, you know what I am 10:40:43
15 Q Were you ever disciplined by the Los Angeles County 10:37:06 15 talking about here. I am asking you about a general 10:40:47
16 Sheriff's Department as a result of an investigation into 10:37:08 16 description. Was he white, Caucasian? Yes, he was? 10:40:49
17 one of the complaints leveled against you? 10:37:14 17 A No. 10:40:56
18 MR. DAY: Well, I'm going to object. The background, 10:37:17 18 Q Okay. What race was he? 10:40:57
19 the Court in review of the -- your Pitchess motion, Counsel, 10:37:23 19 A African American. 10:40:59
20 only permitted disclosure of certain names regarding Deputy 10:37:28 20 Q Okay. You didn't use that term African American in 10:41:02
21 Aldama. 10:37:35 21 referring to him during that arrest of him, did you? 10:41:06
22 MR. SWEENEY: Okay. 10:37:35 22 A No. 10:41:16
23 MR. DAY: The Court did not allow any other disclosure 10:37:36 23 Q What is the most vile derogatory term that you can 10:41:21
24 of any information from Deputy Aldama 's personnel file or 10:37:39 24 think of in describing an African American? 10:41:26
25 any other information. So other than the names of those 25 MR. DAY: Are you asking in the abstract?
Page 26 Page 28
1 complainants or witnesses, I think that there is no other 10:37:53 1 BY MR. SWEENEY: 10:41:36
2 information from Deputy Aldama's file that you are permitted 10:37:55 2 Q In the abstract, yes. I'll make it more case 10:41:37
3 to inquire into. 10:37:58 3 specific. 10:41:42
4 MR. SWEENEY: So you are going to instruct him not to 10:37:59 4 A I'm not sure, sir. 10:41:44
5 answer. 10:38:01 5 Q Have you heard of the word nigger before? Yes or 10:41:46
6 MR. DAY: As to discipline, yes. 10:38:02 6 no. 10:41:53
7 MR. SWEENEY: Okay. 10:38:04 7 A Yes, I have. 10:41:54
8 BY MR. SWEENEY: 10:38:16 8 Q Have you ever used the word nigger in the course of 10:41:55
9 Q Do you recall an encounter during an arrest with a 10:38:17 9 arresting an African American male? 10:42:02
10 Sheldon Lockett in 2016? 10:38:23 10 A No, sir. 10:42:08
11 A It's possible. 10:38:38 11 Q Have you ever used that word in your life? 10:42:10
12 Q Were you ever contacted -- and I'm not going to ask 10:38:42 12 A No, sir. 10:42:17
13 you about any discipline -- were you ever contacted by your 10:38:45 13 Q The incident that you said you have a recollection 10:42:26
14 department to give your side to a complaint made by a 10:38:48 14 of on Evers, how did the contact with that person initially 10:42:29
15 Sheldon Lockett? 10:39:00 15 start? This is the 2016 incident. 10:42:43
16 A It's possible. I'm not sure, to be honest. 10:39:09 16 A I'm not sure that incident took place on 900 Evers. 10:42:58
17 Q Okay. 10:39:14 17 Q What is your recollection of where it took place, 10:43:01
18 In 2016, what was your assignment with the 10:39:16 18 200 Evers? 10:43:05
19 Sheriff's Department? 10:39:24 19 A Nearby, I'm guessing. 10:43:08
20 MR. DAY: You mean what station he was assigned to? 10:39:27 20 Q Okay. 10:43:10
21 MR. SWEENEY: Yes. 10:39:29 21 A Uh-huh. 10:43:11
22 THE WITNESS: I was assigned to Compton Station. 10:39:30 22 Q How did that -- you were with your partner Orrego, 10:43:12
23 BY MR. SWEENEY: 10:39:35 23 weren't you? 10:43:18
24 Q Is 900 North Evers Street within your jurisdiction, 10:39:38 24 A Yes. 10:43:25
25 patrolling jurisdiction, with the Compton Sheriff's Station? 25 Q Okay. How did that contact with the male black
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1 come about? 10:43:37 1 A I'm not sure, sir. 10:47:29
2 A I believe it was a call for service. 10:43:44 2 Q Okay. But you do recall a foot pursuit, correct? 10:47:32
3 Q From who? 10:43:49 3 A Correct. 10:47:37
4 A From a citizen. 10:43:55 4 Q You do recall chasing a male black, correct? 10:47:38
5 Q What was the call for service? 10:44:00 5 A Correct. 10:47:45
6 A I believe it was illegal shooting in the area. 10:44:07 6 Q You do recall arresting a male black, correct? 10:47:47
7 Q Illegal shooting in the area; is that right? 10:44:10 7 A Correct. 10:47:54
8 A Correct. 10:44:13 8 Q And you do recall using force on that male black, 10:47:54
9 Q And did you receive a dispatch call? 10:44:14 9 correct? 10:47:57
10 A I believe we were the assistant unit to a handling 10:44:24 10 A I'm not sure if I used force on him. 10:48:00
11 unit. 10:44:28 11 Q Did you touch that person? 10:48:09
12 Q But you were the first to arrive, correct? 10:44:31 12 A I was part of the arresting team. 10:48:15
13 A To that area, yes. 10:44:37 13 Q That wasn't my question, Deputy. Listen to my 10:48:17
14 Q Okay. So there was an actual radio call to your 10:44:42 14 question. Did you touch that person? 10:48:20
15 radio car that said we have a suspect who may have been 10:44:48 15 A What do you refer as touching, sir, like just 10:48:26
16 involved in a shooting, correct? 10:44:54 16 simple touch? 10:48:30
17 A I'm not sure if it was just like that. It was an 10:45:00 17 Q Touch means putting your hand on that person. I 10:48:31
18 illegal shooting call. 10:45:03 18 think you know what I mean. Did you touch that person? 10:48:34
19 Q Tell me how it was. I wasn't there. You were. 10:45:04 19 A I possibly did. 10:48:37
20 Tell me how it was. 10:45:07 20 Q Possibly? 10:48:39
21 A We were assisting handling unit on an illegal 10:45:12 21 A Yes, sir. 10:48:40
22 shooting call. 10:45:16 22 Q You don't know for sure whether or not you touched 10:48:42
23 Q Okay. 10:45:16 23 that person? 10:48:45
24 A Near the area. 10:45:17 24 MR. DAY: I think he answered your question, Counsel. 10:48:45
25 Q And obviously the dispatcher wants you to get the 25 MR. SWEENEY: What's that?
Page 30 Page 32
1 right person so they put out a description, correct? 10:45:23 1 MR. DAY: I think he answered your question. 10:48:49
2 A Didn't put out a description, just a, I believe, a 10:45:29 2 BY MR. SWEENEY: 10:48:50
3 vehicle description. 10:45:33 3 Q You don't know if you touched that person; is that 10:48:50
4 Q They didn't say the person is described as a male 10:45:38 4 right? 10:48:56
5 black, a female white or a male Hispanic; they didn't do 10:45:45 5 A I said I possibly did. 10:48:56
6 anything like that, correct? 10:45:54 6 Q Do you recall beating that person? 10:48:58
7 A I'm not sure if there was a description. 10:45:56 7 A No. 10:49:03
8 Q So that's all the information that you had, that 10:45:58 8 Q Do you recall hitting that person about his head? 10:49:04
9 there was a vehicle shooting, correct? 10:46:00 9 A No. 10:49:12
10 A Correct. 10:46:05 10 Q Did you see any of your fellow arresting team, as 10:49:15
11 Q Where was the location of the shooting? 10:46:08 11 you call them, hit that person in his head? 10:49:20
12 A It was in the area of Stanford Avenue, Cahita 10:46:14 12 A I don't recall. 10:49:25
13 Avenue and 148th which are a close-by area. 10:46:21 13 Q Did you see any injuries on that person after the 10:49:33
14 Q Did this incident eventually lead to a foot 10:46:29 14 arrest was effected? 10:49:36
15 pursuit? In other words, did you attempt to contact the 10:46:34 15 A Not that I could remember. 10:49:45
16 subject and that person took off running? 10:46:45 16 Q Did you see any injury to that person's eye? 10:49:47
17 A I don't think we're talking about the same incident 10:46:55 17 A Not that I could remember, sir. 10:50:02
18 here. 10:46:58 18 Q Did you have a baton with you during that pursuit? 10:50:04
19 Q Okay. That's why -- it's my job to narrow it down. 10:46:59 19 A No, sir. 10:50:09
20 Did you ever get into a foot pursuit in 2016 in the Compton 10:47:02 20 Q Did you have a collapsable baton, an ASP? Do you 10:50:12
21 area? 10:47:07 21 know what an ASP is, A-S-P? 10:50:16
22 A Yes. 10:47:09 22 A Yes, sir. 10:50:18
23 Q All right. What month was that? 10:47:11 23 Q Did you have an ASP? 10:50:19
24 A I'm not sure about what month. 10:47:19 24 A No, sir. 10:50:22
25 Q Give me your best estimate what month it was. 25 Q Did you have a PR-24?
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1 A Not on my person. 10:50:29 1 A He was in the front lawn of a house. 10:54:24
2 Q Did you see any officer in your arresting team with 10:50:30 2 Q He was what? 10:54:28
3 a PR-24? 10:50:36 3 A In the front lawn of a house. 10:54:28
4 A No, sir. 10:50:40 4 Q Just standing there? 10:54:30
5 Q Did you see anyone on your arresting team 10:50:40 5 A Standing with somebody else. 10:54:32
6 purposefully ram a PR-24 into the eye of this African 10:50:47 6 Q Okay. Who was that other person? Can you describe 10:54:34
7 American person? 10:50:53 7 that person? 10:54:38
8 A No, sir. 10:50:57 8 A It was also a male African American adult. 10:54:41
9 Q Did you ever use the term nigger in effecting this 10:51:00 9 Q Can you describe what the person that you 10:54:48
10 arrest that we're talking about now? 10:51:04 10 eventually arrested had on? 10:54:50
11 A No, sir. 10:51:08 11 A I don't remember what he had on. 10:54:56
12 Q Did you hear any of your arresting team refer to 10:51:10 12 Q Isn't it true that he had on work clothing from his 10:54:58
13 that person as a nigger? 10:51:15 13 job? 10:55:02
14 A No, sir. 10:51:20 14 A I'm not sure. 10:55:06
15 Q Did you ever hear your partner Orrego refer to that 10:51:20 15 Q Isn't it true that he had a back brace used by 10:55:08
16 person as a nigger? 10:51:26 16 those who lift in their jobs that was clearly marked with 10:55:12
17 A No, sir. 10:51:29 17 the store where he worked? Isn't that true? 10:55:19
18 Q Where did this pursuit start, the one we are 10:51:34 18 A I don't remember if he had a brace, a back brace. 10:55:23
19 talking about that ended up in the arrest of the person that 10:51:39 19 Q I'm sorry. What? 10:55:28
20 you may or may not have touched that you did not see any 10:51:45 20 A I don't remember if he had a back brace. 10:55:29
21 injuries on? 10:51:48 21 Q You do or don't? 10:55:31
22 A It started on Evers and Spruce Street. 10:51:51 22 A I don't. 10:55:32
23 Q Why were you chasing this person? 10:52:02 23 Q You don't. Okay. 10:55:37
24 A There was a call earlier of a shooting at a 10:52:10 24 How did you approach this person? 10:55:37
25 different location. 25 A Just a casual approach, sir.
Page 34 Page 36
1 Q At a different location? 10:52:20 1 Q Casual? 10:55:50
2 A At a different location. 10:52:22 2 A (Witness nods head up and down.) 10:55:51
3 Q How did you learn about this shooting? You heard 10:52:24 3 Q That means you pulled the car up and just got out 10:55:52
4 it on the radio? 10:52:27 4 to talk to him; is that correct? 10:55:57
5 A We heard it on the radio. 10:52:27 5 A That's correct. 10:55:59
6 Q How long before you actually contacted this black 10:52:30 6 Q Did you drive your car up to him in an aggressive 10:56:05
7 person did you hear this radio call about this shooting, two 10:52:39 7 manner? 10:56:09
8 hours, an hour, 20 minutes, 10 minutes? What was it? 10:52:43 8 A We were just simply driving around the area. 10:56:15
9 A Before the call you said? 10:52:48 9 Q What I mean by aggressive manner, fast and then 10:56:18
10 Q No. When did you -- how long before -- strike 10:52:50 10 sling the doors open before the car stopped? 10:56:28
11 that. 10:52:56 11 A I don't believe we did all that. 10:56:34
12 How long after the call did you see this person 10:52:56 12 Q Have you ever, in effecting an arrest, pulled the 10:56:42
13 that you eventually arrested? 10:53:00 13 car up to someone in an aggressive manner and slung the door 10:56:46
14 A I want to say within 45 minutes to an hour. 10:53:06 14 open and got out before the car stopped? 10:56:52
15 Q Did you receive a description from your dispatcher 10:53:21 15 A Before our car or their car? 10:57:02
16 of the person involved in this shooting? 10:53:26 16 Q Your car. 10:57:05
17 A Yes. 10:53:32 17 MR. DAY: Objection; irrelevant, immaterial. 10:57:07
18 Q What was the description? 10:53:34 18 THE WITNESS: I have done it. 10:57:13
19 A It was a male black adult, and I'm not sure about 10:53:43 19 BY MR. SWEENEY: 10:57:15
20 what was the clothing or anything like that. 10:53:47 20 Q You have? 10:57:15
21 Q Did the person that you eventually arrested match 10:53:51 21 A (Witness nods head up and down.) 10:57:16
22 the description that you got on the radio? 10:53:58 22 Q Did you do that in this case that we are talking 10:57:16
23 A Yes. 10:54:07 23 about? I'm talking about the guy that was standing on the 10:57:19
24 Q What was that person that you eventually arrested 10:54:13 24 lawn. Did you do that in this case? 10:57:23
25 doing when you first saw him? 25 A No.
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1 Q Did you immediately get out of the car with your 10:57:29 1 BY MR. SWEENEY: 11:00:49
2 guns drawn and point at that person? 10:57:33 2 Q The one with the skull. 11:00:49
3 A No. 10:57:41 3 A I got it when I was 18 years old. 11:00:52
4 Q Your partner was Orrego, correct? 10:57:42 4 Q Eighteen years old? 11:00:56
5 A Correct. 10:57:47 5 A Yes, sir. 11:00:58
6 Q Did you see Orrego jump out of the car with his gun 10:57:47 6 Q Do you have any tattoos on your legs? 11:01:00
7 pointed at this person? 10:57:51 7 A I do. 11:01:02
8 A No. 10:57:55 8 Q What tattoo? 11:01:03
9 Q Have you ever heard the term Jump Out Boys? 10:58:22 9 A Another skull. 11:01:05
10 A I heard of the term. 10:58:31 10 Q When did you get that? 11:01:09
11 Q Where have you heard that? 10:58:32 11 A I got it in 2016. 11:01:15
12 A Possibly on the news or something. I'm not sure. 10:58:44 12 Q Yeah. That skull, does it have any playing cards 11:01:20
13 Q What is your understanding of what a Jump Out Boy 10:58:52 13 next to it? 11:01:28
14 is? 10:58:54 14 A No, sir. 11:01:32
15 A I honestly didn't pay attention to that, so. 10:58:57 15 Q Do you have any playing cards tattooed to your 11:01:33
16 Q Well, you've heard that there was a -- possibly a 10:59:06 16 body? 11:01:38
17 clique. Do you know what a clique means, other than 10:59:12 17 A No, sir. 11:01:41
18 clicking your hand, the French spelling, Q-U E? Do you know 10:59:17 18 Q The skull that you had tattooed in 2016, describe 11:01:46
19 what a clique is? 10:59:22 19 it for me. 11:01:50
20 A Yes. 10:59:23 20 A It's a skull with a helmet. It has a helmet on it. 11:01:52
21 Q What is a clique? 10:59:24 21 Q Does it have a gun anywhere on it? 11:02:05
22 A A group. 10:59:26 22 A Yes, it does. 11:02:07
23 Q Yes. Have you ever heard of a Sheriff clique 10:59:28 23 Q Yeah. 11:02:08
24 called the Jump Out Boys? 10:59:34 24 A Uh-huh. 11:02:09
25 A I've heard about it. 25 Q Is there smoke coming out of the gun, Deputy?
Page 38 Page 40
1 10:59:43 1 A No. 11:02:15

Q You are a Jump Out Boy, aren't you?
2 10:59:46 2 Q May I see that? May I see that tattoo? 11:02:16
A No, sir.
3 Q Are you tattooed? 10:59:47 3 MR. DAY: You don't have to let him see the tattoo, 11:02:21
4 A Yes, sir. 10:59:52 4 Deputy. 11:02:25
5 Q Where are your tattoos? 10:59:54 5 MR. SWEENEY: I'm sorry. What? 11:02:25
6 A My arms. 10:59:57 6 MR. DAY: I said to the deputy he does not have to let 11:02:26
7 Q Describe your tattoos. 10:59:58 7 you see the tattoo. 11:02:28
8 MR. DAY: Objection; irrelevant. 11:00:02 8 BY MR. SWEENEY: Okay. Can you take a picture of it in the 11:02:30
9 MR. SWEENEY: I'm sorry? 11:00:04 9 bathroom and show it to me? 11:02:31
10 MR. DAY: Irrelevant. 11:00:06 10 MR. DAY: Again, he doesn't have to do that. 11:02:34
11 BY MR. SWEENEY: 11:00:08 11 BY MR. SWEENEY: 11:02:36
12 Q You can answer. 11:00:08 12 Q Why did you get that tattoo, Deputy? 11:02:36
13 A It's a St. Michael on my left arm. 11:00:10 13 A Because I wanted to get it, sir. 11:02:40
14 Q Uh-huh. 11:00:15 14 Q Why? 11:02:54
15 A And a skull on also my upper left arm. 11:00:15 15 MR. DAY: Asked and answered. 11:02:55
16 Q A skull? 11:00:21 16 BY MR. SWEENEY: 11:03:00
17 A Yes, sir. 11:00:22 17 11:03:00
Q Why?
18 Q Does the skull have red eyes? 11:00:22 18 11:03:01
A For working hard.
19 A No, sir. 11:00:26 19 11:03:03
Q For working hard.
20 Q Does it have any eyes? 11:00:27 20 11:03:06
A Yes, sir.
21 A No eyes. 11:00:37 21 11:03:08
Q For working hard where?
22 Q When did you get this tattoo? 11:00:39 22 11:03:12
A At Compton Station.
23 MR. DAY: Which one? 11:00:45 23 11:03:15
Q As a matter of fact, other deputies have that
24 MR. SWEENEY: Hmm? 11:00:47 24 11:03:18
tattoo also, don't they?
25 MR. DAY: Which one? 25 MR. DAY: Calls for speculation, no foundation.
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1 BY MR. SWEENEY: 11:03:22 1 A No. 11:06:30
2 Q If you know. I'm not asking you to speculate. You 11:03:23 2 Q What else does that tattoo have on it? 11:06:35
3 have seen that tattoo on other deputies, correct? 11:03:25 3 A It has flames. 11:06:47
4 A Yes. 11:03:30 4 Q Flames? 11:06:49
5 Q What does that signify? 11:03:32 5 A (Witness nods head up and down.) 11:06:49
6 MR. DAY: Calls for speculation. 11:03:38 6 Q What else? Describe it to me. 11:06:50
7 BY MR. SWEENEY: 11:03:41 7 A It's holding a rifle. 11:06:57
8 Q You can answer. 11:03:42 8 Q Holding a rifle? 11:07:02
9 A Just working hard, sir, at the station. 11:03:45 9 A Uh-huh. 11:07:03
10 Q You are a Jump Out Boy, aren't you? 11:03:51 10 Q The skull is holding a rifle? 11:07:05
11 MR. DAY: Argumentative. 11:03:53 11 A Correct. 11:07:11
12 THE WITNESS: No, sir. 11:03:55 12 Q Okay. What else? Is there any writing or 11:07:14
13 BY MR. SWEENEY: 11:03:57 13 lettering? 11:07:22
14 Q Is there a name given to the people who get that 11:03:57 14 A It says CPT on the helmet. 11:07:26
15 type of tattoo? 11:04:03 15 Q Okay. Stands for Compton? 11:07:32
16 A No, sir. 11:04:04 16 A Compton. 11:07:36
17 Q Describe the gun on the skull. Is it pointed 11:04:05 17 Q Have you ever known that tattoo to be associated 11:07:42
18 straight ahead? 11:04:10 18 with any clique? 11:07:45
19 A No, sir. 11:04:13 19 A No, sir. 11:07:50
20 Q What month did you get that tattoo? 11:04:15 20 Q Is there any flames coming out of the barrel of the 11:07:52
21 MR. DAY: If you recall. 11:04:33 21 gun? 11:08:01
22 THE WITNESS: It was in June. 11:04:43 22 A No, sir. 11:08:02
23 BY MR. SWEENEY: 11:04:46 23 Q Any smoke coming out of the barrel of the gun? 11:08:03
24 Q You are sure? 11:04:47 24 A No, sir. 11:08:09
25 A Yes, sir. 25 Q Are you a Viking?
Page 42 Page 44
1 Q June of 2016; is that right? 11:04:51 1 A No, sir. 11:08:14
2 A Yes, sir. 11:04:57 2 Q Are you a Caveman? 11:08:15
3 Q What kind of work did you have to do to get that 11:04:58 3 A No, sir. 11:08:19
4 tattoo? You said to work hard. What kind of work? 11:05:01 4 Q Do you belong to any clique within the Los Angeles 11:08:20
5 MR. DAY: Objection; no foundation, calls for 11:05:06 5 County Sheriff's Department? 11:08:23
6 speculation. 11:05:11 6 A No, sir. 11:08:26
7 THE WITNESS: Simple as just going in and working hard, 11:05:18 7 MR. DAY: Counsel, before we started off and we were off 11:08:32
8 take people to jail, answer calls. That type of work. 11:05:22 8 the record, I indicated to you that the deputy had a parking 11:08:35
9 BY MR. SWEENEY: 11:05:27 9 situation. 11:08:38
10 Q Does someone award you that tattoo? You can't just 11:05:27 10 MR. SWEENEY: Okay. 11:08:38
11 go out and get it, right? You have to be awarded that, 11:05:30 11 MR. DAY: Is this a convenient time -- 11:08:39
12 correct? 11:05:33 12 MR. SWEENEY: We'll take a break. 11:08:41
13 MR. DAY: No foundation, calls for speculation. 11:05:34 13 MR. DAY: Thank you. 11:08:42
14 THE WITNESS: You could get it. 11:05:41 14 THE VIDEOGRAPHER: We are going off the record. The 11:08:42
15 BY MR. SWEENEY: 11:05:43 15 time is 11:08 AM. 11:08:44
16 Q Somebody has to say that you deserve this tattoo, 11:05:44 16 (A break was taken in the proceedings.) 11:18:42
17 correct? 11:05:50 17 THE VIDEOGRAPHER: We are back on the record. The time 11:18:46
18 A Anyone can get a tattoo, sir. 11:05:55 18 is 11:18 AM. 11:18:54
19 Q Anyone can get it, a tattoo; I know. I can go out 11:05:58 19 BY MR. SWEENEY: 11:18:57
20 and get a tattoo. I know. I'm talking about that 11:06:03 20 Q Do you have any other tattoos, other than the ones 11:19:00
21 particular tattoo associated with the Sheriff's Department. 11:06:06 21 you already described, on your body? 11:19:04
22 Anyone can get that? A rookie can get that, or do you have 11:06:12 22 A No, sir. 11:19:07
23 to work your way up? 11:06:16 23 Q Just the three? 11:19:08
24 A Anyone could get it, sir. 11:06:21 24 A Yes, sir. 11:19:11
25 Q Does that tattoo have the numbers 998 on it? 25 Q What you originally described was just two. Where
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1 did you get that tattoo on your leg? 11:19:22 1 MR. DAY: Assumes facts not in evidence. 11:23:23
2 A In my house. 11:19:28 2 BY MR. SWEENEY: 11:23:25
3 Q Where? 11:19:34 3 Q What is St. Michael the patron saint of? 11:23:26
4 A My house. 11:19:35 4 A It is just a meaning for law enforcement. 11:23:31
5 Q Who tattooed you? 11:19:36 5 Q It is what? 11:23:34
6 A A guy. 11:19:42 6 A A meaning for law enforcement. 11:23:35
7 Q What guy? 11:19:46 7 Q A meaning for law enforcement throughout the 11:23:37
8 A I don't know his name. 11:19:55 8 country or just in Compton? 11:23:40
9 Q Was he a friend of yours? 11:20:00 9 A Throughout the country. 11:23:42
10 A No. 11:20:04 10 Q Can you describe the person who referred you to 11:23:45
11 Q Who referred him to you? 11:20:07 11 this tattoo artist? 11:23:48
12 A It was a friend at the station as well. 11:20:28 12 MR. DAY: We're now back to the third tattoo? 11:23:51
13 Q A friend at the station? 11:20:33 13 BY MR. SWEENEY: 11:23:53
14 A Yes, sir. 11:20:35 14 Q Yes, back to the third tattoo. 11:23:53
15 Q Okay. What friend at the station referred you? 11:20:35 15 A Describe the person? Male Hispanic. 11:24:05
16 A I'm trying to think of the name, sir. 11:20:39 16 BY MR. SWEENEY: 11:24:09
17 Q Did you have to pay for it? 11:21:04 17 Q Male Hispanic. Okay. Is it your testimony that 11:24:09
18 A Yes, sir. 11:21:10 18 you just took the word of a male Hispanic -- this guy is 11:24:16
19 Q Who paid for it? 11:21:12 19 going to tattoo you -- without checking, without knowing the 11:24:20
20 A I did. 11:21:15 20 male Hispanic any more than just a male Hispanic? 11:24:24
21 Q How did you pay him, credit card, check or cash? 11:21:18 21 A I'm sorry. Repeat that question one more time. 11:24:29
22 A Cash. 11:21:24 22 Q Sure. Sir, I warned you at the beginning that if 11:24:32
23 Q How much did it cost? 11:21:28 23 you know the answer to something and you don't tell me the 11:24:35
24 A Around 400. 11:21:37 24 answer to the question that I ask and you really know the 11:24:40
25 Q Where did you get your other tattoos? 25 answer that it is perjury. Okay?
Page 46 Page 48
1 A My first one I got it on, I believe, in the city of 11:21:55 1 A Okay. 11:24:46
2 Inglewood. 11:22:02 2 Q I'm going to ask you again. What is the name of 11:24:47
3 Q At a tattoo parlor? 11:22:02 3 the person who referred you to that tattoo artist? 11:24:50
4 A Yes. 11:22:06 4 A I don't know the name of the person, like I said, 11:25:03
5 Q The second one is at a tattoo parlor also? 11:22:07 5 sir. I'm trying to remember the name, sir. 11:25:06
6 A I'm sorry? 11:22:10 6 Q You are trying to remember the name. 11:25:17
7 Q The second one on your other arm, was that at a 11:22:11 7 A Yes, sir. 11:25:20
8 tattoo parlor? 11:22:15 8 Q Was it a superior? 11:25:21
9 A No. 11:22:17 9 A No, sir. 11:25:30
10 Q Where? 11:22:19 10 Q Isn't it true that you had to be recommended to 11:25:31
11 A It was at a -- also at a house. 11:22:21 11 have this tattoo and this tattoo artist shows up and puts it 11:25:35
12 Q At your house? 11:22:26 12 on? Isn't that true? 11:25:41
13 A No. 11:22:28 13 A I'm not sure about recommended. I don't know what 11:25:48
14 Q What year was the second one put on? 11:22:29 14 that -- 11:25:52
15 A I want to say around 2013. 11:22:37 15 Q You just can't go in and say, "Send me the shadowy 11:25:53
16 Q Okay. 11:22:50 16 tattoo artist to my house. I want that tattoo." Somebody 11:25:57
17 A 2014. 11:22:51 17 has to recommend that you get it, correct? 11:26:01
18 Q 2013? 11:22:52 18 MR. DAY: Objection; argumentative, asked and answered. 11:26:04
19 A 2013 or 2014. 11:22:54 19 THE WITNESS: No, sir. 11:26:11
20 Q Or 2014. Describe that tattoo once again. 11:22:55 20 BY MR. SWEENEY: 11:26:11
21 A It's a long piece on my left arm. 11:23:00 21 Q No, sir, what? 11:26:12
22 Q A what? 11:23:04 22 A It is not recommended. 11:26:13
23 A A long piece. It's a long tattoo of St. Michael. 11:23:05 23 Q But you said you had to earn it. Somebody has to 11:26:15
24 That's it. 11:23:16 24 feel that you have earned it, correct? 11:26:18
25 Q What's the purpose of having that tattoo? 25 A Yes, sir.
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1 Q Who felt that you earned it? 11:26:23 1 Q Just black ink? 11:29:54
2 A Our peers at the station. 11:26:27 2 A Correct. 11:29:55
3 Q What peers? Your peers? You don't know the name, 11:26:35 3 Q It would be a whole lot easier for you to show me 11:30:00
4 correct? 11:26:41 4 your tattoo or take a picture of it in the restroom and let 11:30:02
5 A Well, the deputies who work at the station. 11:26:42 5 me see it than me making a court order. The choice is 11:30:05
6 Q Okay. So there is some type of voting then, 11:26:45 6 yours. Do you want to show me? 11:30:09
7 correct? 11:26:49 7 MR. DAY: Not at this time. 11:30:17
8 MR. DAY: Objection; no foundation. 11:26:49 8 BY MR. SWEENEY: 11:30:23
9 THE WITNESS: No. 11:26:53 9 Q Are you going to follow the advice of your lawyer? 11:30:23
10 BY MR. SWEENEY: 11:26:54 10 A Yes, sir. 11:30:27
11 Q Well, if your peers recommend it, they have to 11:26:54 11 Q Okay. We're eventually going to get to the event 11:30:36
12 recommend it to somebody, and somebody makes a decision, 11:26:58 12 that I filed the lawsuit for, believe me. 11:30:39
13 correct? 11:27:02 13 MR. DAY: You will let us know what day that is? 11:30:41
14 A It's not recommended, sir. 11:27:10 14 MR. SWEENEY: Today. 11:30:44
15 Q But your peers -- you just testified that your 11:27:13 15 BY MR. SWEENEY: 11:30:46
16 peers recommend you, correct? 11:27:16 16 Q One other question on your tattoo. You are sure 11:30:54
17 A Our peers think something of hard work and 11:27:31 17 that you got it before the shooting of Donta Taylor? 11:31:00
18 dedication, sir, to the station. 11:27:39 18 A Yes, sir. 11:31:18
19 Q And they tell somebody that and that person sends 11:27:43 19 Q You mentioned earlier that there was another 11:31:19
20 this tattoo artist over to you? 11:27:47 20 incident where you chased someone because you got a radio 11:31:27
21 A They don't tell nobody. They just recommend me. 11:27:57 21 call, before we talked about the Sheldon Lockett chase. 11:31:35
22 Q Who do they recommend you to? 11:28:02 22 What was that person's name? 11:31:45
23 A Not recommend me. They just give me the -- a 11:28:06 23 A I'm not sure of the person's name, and I don't 11:31:49
24 contact information of the guy. 11:28:11 24 think there was a foot pursuit on that one. 11:31:55
25 Q Who gives you the contact information, your peers? 25 Q Okay. If I tell you the name, would it refresh
Page 50 Page 52
1 A Peers who have gotten tattoos by him. 11:28:20 1 your recollection? 11:32:02
2 Q Who have what? 11:28:25 2 A Possibly not, sir. 11:32:03
3 A Peers who have gotten tattoos. 11:28:26 3 Q Does the name Michael Thatcher mean anything to 11:32:06
4 Q Who have those same tattoos from Compton? 11:28:28 4 you? Does that ring a bell? 11:32:09
5 A Not the same tattoos; other tattoos. 11:28:32 5 A Yes, sir. 11:32:11
6 Q What other tattoos? 11:28:35 6 Q Tell me about that, the Michael Thatcher incident. 11:32:12
7 A Other random tattoos, sir. 11:28:41 7 What happened there? 11:32:17
8 Q How many tattoos have you seen like yours? 11:28:44 8 A Michael Thatcher, he is actually my captain at the 11:32:18
9 A A few. 11:28:53 9 station. 11:32:24
10 Q How many is a few? Is it more than 10? 11:28:57 10 Q Okay. 11:32:25
11 A Yes. 11:29:08 11 A That's -- 11:32:26
12 Q More than 20? 11:29:10 12 Q Okay. What did he complain against you for? 11:32:28
13 A No. 11:29:15 13 MR. DAY: Assumes facts not in evidence. 11:32:37
14 Q Pretty exclusive club then, correct? 11:29:18 14 BY MR. SWEENEY: 11:32:40
15 MR. DAY: Objection; argumentative. 11:29:20 15 Q What was your run-in with Michael Thatcher? 11:32:41
16 THE WITNESS: No. 11:29:25 16 MR. DAY: Assumes facts not in evidence. 11:32:44
17 BY MR. SWEENEY: 11:29:26 17 THE WITNESS: I'm not sure what that incident pertains 11:32:50
18 Q What do the flames symbolize on your tattoo? 11:29:27 18 to, sir. 11:32:52
19 A It's just a design around the skull. 11:29:35 19 BY MR. SWEENEY: 11:32:54
20 Q It's what? 11:29:41 20 Q Well, he filed a complaint against you. 11:32:55
21 A A design. 11:29:41 21 MR. DAY: Assumes facts not in evidence. 11:32:58
22 Q Around the skull? 11:29:42 22 BY MR. SWEENEY: 11:33:00
23 A Yes, sir. 11:29:43 23 Q Did you have any type of relationship that resulted 11:33:00
24 Q What color are the flames? 11:29:44 24 in an investigation with this -- by the Sheriff's 11:33:05
25 A There's no color in the flames. 25 Department, any incident with Mr. Thatcher?
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1 A No incident with Mr. Thatcher that I could 11:33:16 1 Q E? 11:37:39
2 remember. 11:33:23 2 A No, no E. 11:37:40
3 Q Okay. How does his name come up with respect to 11:33:24 3 Q Ivett Silva. 11:37:41
4 your name in an internal affairs investigation? 11:33:28 4 What is her date of birth? 11:37:45
5 MR. DAY: Objection; calls for speculation. Only if you 11:33:32 5 A 7/13/88. 11:37:49
6 know, Deputy. 11:33:39 6 Q Of what year? 11:37:54
7 THE WITNESS: I'm not sure what that incident pertains 11:33:41 7 A 1988. 11:37:55
8 to, like I said. 11:33:45 8 Q Okay. You live with her? 11:37:56
9 MR. DAY: Just so we're clear, Counsel, you are 11:33:47 9 A Yes, I do. 11:38:00
10 referring to a document served by the Fuentes firm. 11:33:50 10 Q When is the last time you have seen her? 11:38:05
11 MR. SWEENEY: I'm sorry. What? 11:33:55 11 A This morning. 11:38:10
12 MR. DAY: You are referring to a document served by the 11:33:56 12 Q You still live with her? 11:38:12
13 Fuentes Law Firm that identifies Captain Thatcher -- 11:33:59 13 A Yes, sir. 11:38:14
14 MR. SWEENEY: Yes. 11:34:07 14 Q Well, I suspect, Deputy, you are not telling me the 11:38:21
15 MR. DAY: As a complainant. 11:34:08 15 whole story because the judge who went over these records 11:38:25
16 MR. SWEENEY: Yes. 11:34:10 16 and decided to give me this information would not have given 11:38:30
17 MR. DAY: Okay. You have seen this before, Deputy? Let 11:34:11 17 me this information for you being loud. 11:38:33
18 me just make sure that is the right page. 11:34:18 18 What else is there? I'm going to find out so you 11:38:37
19 BY MR. SWEENEY: 11:34:50 19 might as well tell me now what else is involved in this 11:38:40
20 Q Do you know what that is all about? 11:34:51 20 domestic dispute. 11:38:47
21 A I don't know what incident that pertains to, but 11:34:56 21 A It was a domestic dispute. I had contact with law 11:38:50
22 it's not a use of force or anything. 11:35:00 22 enforcement. 11:38:58
23 Q General behavior: Do you know what he is talking 11:35:02 23 Q Okay. Did she accuse you of putting your hands on 11:38:59
24 about? 11:35:05 24 her in a non-amorous manner? In other words, did you hit 11:39:06
25 A I have an idea. I'm not sure if that's -- 25 her? Were you accused of hitting her?
Page 54 Page 56
1 11:35:20 1 A I don't know if I was accused. I haven't read the 11:39:20

Q What is the idea?
2 11:35:26 2 report, the initial report. I'm not sure what she said. 11:39:23
A Something I did not work related.
3 11:35:50 3 Q Did you hit her? 11:39:27
Q What was that?
4 11:35:52 4 A No, I didn't. 11:39:28
A What was that? I'm sorry.
5 11:35:55 5 Q Did she say that you hit her? 11:39:31
Q Yes.
6 11:35:56 6 MR. DAY: He said he hasn't read any -- 11:39:33
A It was an off-duty incident.
7 11:36:04 7 MR. SWEENEY: I'm not talking about a report. 11:39:35
Q What was the off-duty incident?
8 11:36:07 8 BY MR. SWEENEY: 11:39:37
A It was a domestic dispute.
9 11:36:20 9 Q Did Ivett say that you hit her? 11:39:37
Q With whom?
10 11:36:22 10 A I'm not sure what she said. 11:39:40
A With my domestic partner.
11 11:36:26 11 Q If you really know the answer -- I'm going to give 11:39:43
Q Who is your domestic partner?
12 A Ivett. 11:36:29 12 you the admonition again -- and you don't tell me the truth, 11:39:45
13 11:36:38 13 it's perjury. Did she accuse you of hitting her? 11:39:48
Q What is Ivett's last name?
14 11:36:40 14 A I'm not sure what she said. I wasn't at home at 11:39:57
A Silva, S-I-L-V-A.
15 11:36:44 15 the time. Well, I was at home but not inside the house. 11:40:00
Q Silva. What did Ms. Silva complain against you
16 11:36:57 16 Q When you were having this argument, did she accuse 11:40:04
about? What did she accuse you of?
17 11:37:19 17 you to your face, "You hit me," or say anything like that? 11:40:07
A Maybe of being loud. I'm not sure.
18 11:37:21 18 A No. 11:40:14
Q I'm sorry. What?
19 11:37:23 19 Q Did she call the police? 11:40:15
A Being loud.
20 11:37:23 20 A She did. 11:40:21
Q Being loud and that's it?
21 11:37:25 21 Q When was this incident, July of 2017? 11:40:26
A Possibly, sir, yeah.
22 11:37:29 22 A No, sir. 11:40:36
Q How do you spell Yvette, Y-V-E-T-T-E or --
23 11:37:36 23 Q When was the incident? 11:40:38
A I-V-E-T-T.
24 11:37:36 24 A It was in the month of February -- I'm not sure of 11:40:51
Q I-V-E-T-T?
25 A Correct. 25 the date -- 2017.
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1 Q Were you arrested? 11:41:02 1 A No, sir. 11:43:53
2 A No, sir. 11:41:05 2 Q Industry? 11:43:55
3 Q Were you detained? 11:41:06 3 A San Dimas Sheriff's Station. 11:43:56
4 A Yes, sir. 11:41:09 4 Q They didn't arrest you, correct? 11:44:09
5 Q What did the police officer tell you? Why did he 11:41:11 5 A No, sir. 11:44:12
6 tell you you were being detained? 11:41:14 6 Q Okay. 11:44:14
7 A Because there was a 911 call. 11:41:20 7 Real quickly back to the Sheldon Lockett case, real 11:44:17
8 Q A what? 11:41:23 8 briefly: The foot pursuit, do you know what precipitated 11:44:26
9 A A 911 call. 11:41:24 9 the foot pursuit? Tell me how it went down. 11:44:30
10 Q Did you -- do you know what was on that 911 tape? 11:41:25 10 A It was just contact with Lockett on Spruce and 11:44:40
11 A No, sir. 11:41:34 11 Evers. He took off running, I believe, eastbound on Spruce 11:44:48
12 Q Have you ever heard it? 11:41:34 12 and then northbound on Tijera and eventually westbound on 11:45:06
13 A No, sir. 11:41:36 13 Rosecrans. 11:45:15
14 Q Were you told what was on it? 11:41:37 14 Q You caught him, correct? 11:45:15
15 A No, sir. 11:41:40 15 MR. DAY: Are you saying he individually or just the 11:45:18
16 Q You were not told by Thatcher, Captain Thatcher, 11:41:40 16 deputies? 11:45:20
17 what was said on that 911 tape? 11:41:45 17 BY MR. SWEENEY: 11:45:20
18 A No, sir. 11:41:48 18 Q Your apprehension team. 11:45:21
19 Q Did Captain Thatcher tell you why he was 11:41:49 19 A After containment, yes, we did. 11:45:23
20 investigating you? 11:41:51 20 Q Okay. How did you know where to contain him? 11:45:25
21 A Yes, sir. 11:41:56 21 A Because I seen him, the block where he made a left 11:45:37
22 Q What did he say? 11:41:58 22 turn. 11:45:42
23 A For having law enforcement contact. 11:42:03 23 Q He was hiding behind a fence in a yard, correct? 11:45:43
24 Q Had you been drinking at the time of this incident 11:42:07 24 A He was hiding behind, like, a concrete wall or 11:45:47
25 in February of 2017? 25 something like that, to that effect.
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1 A Yes, sir. 11:42:12 1 Q You or a member of your apprehension team kicked in 11:45:59
2 Q Would you say that you had a problem with alcohol 11:42:14 2 a gate, correct? 11:46:04
3 at that time? 11:42:21 3 A No, not that I remember, sir. 11:46:08
4 A No. 11:42:30 4 Q Your apprehension team included a canine, correct? 11:46:13
5 Q Were you drunk at the time of this incident? 11:42:31 5 A I remember seeing one on the scene. 11:46:25
6 A I was intoxicated, yes. 11:42:37 6 Q But this was your handle, wasn't it? You know what 11:46:27
7 Q Have you ever seen your partner Deputy Orrego 11:42:41 7 the term handle means? 11:46:30
8 drunk? 11:42:48 8 A Yes, sir. 11:46:32
9 A I have seen him intoxicated. 11:42:52 9 Q This was your handle, wasn't it, you and Orrego? 11:46:32
10 Q Have you seen him drive a car while intoxicated? 11:42:54 10 A Yes, sir. 11:46:38
11 MR. DAY: Objection; irrelevant, immaterial. 11:43:00 11 Q Okay. So you were the first to get there to 11:46:39
12 BY MR. SWEENEY: 11:43:04 12 Mr. Lockett's person, correct? 11:46:44
13 Q You can answer. 11:43:04 13 A Correct. 11:46:47
14 A I've seen him drive a car. 11:43:11 14 Q Okay. Was it you or Orrego? 11:46:48
15 Q While intoxicated? 11:43:13 15 A I'm sorry. Of what? 11:46:54
16 A No. 11:43:15 16 Q Was it you or Orrego who first touched him? 11:46:55
17 Q After drinking, have you seen him drive a car? 11:43:18 17 A I'm not sure if we even touched him initially. 11:47:04
18 MR. DAY: Asked and answered. 11:43:22 18 Q Okay. Did he put his hands up, surrender 11:47:08
19 THE WITNESS: No. 11:43:24 19 peacefully? 11:47:12
20 BY MR. SWEENEY: 11:43:26 20 A Not that I could remember, sir. 11:47:14
21 Q What city did this incident occur with Ivett Silva? 11:43:28 21 Q Tell me how it went down. What do you remember? 11:47:16
22 A The city of Covina, sir. 11:43:34 22 A We got off of the car. 11:47:18
23 Q So the Sheriff's Department patrols that area? 11:43:38 23 Q We got what? 11:47:21
24 A Yes, sir. 11:43:44 24 A Me and my partner, Deputy Orrego, got off of our 11:47:22
25 Q What station, Covina? 25 patrol vehicle.
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1 Q Did you chase him in your patrol vehicle? 11:47:26 1 A I'm not sure what I did, sir, on that incident. 11:50:29
2 A When he took off running, yes. Not chase him. 11:47:28 2 Q You would have remembered if you struck him hard, 11:50:36
3 Q I'm sorry? 11:47:32 3 correct, because it would have been -- or was it such a 11:50:39
4 A We didn't chase. We were following from a distance 11:47:32 4 daily activity for you that they all blend together? 11:50:43
5 in my patrol car, yes. 11:47:37 5 MR. DAY: Objection; argumentative. 11:50:47
6 Q Okay. Who was the bookman? 11:47:39 6 BY MR. SWEENEY: 11:50:49
7 A I don't remember who was the bookman. 11:47:43 7 Q Do you recall striking him? 11:50:49
8 Q But you recall chasing him in your patrol car when 11:47:45 8 MR. DAY: Objection; asked and answered. 11:50:52
9 he took off running, correct? 11:47:50 9 THE WITNESS: I don't recall, sir. 11:50:53
10 A Correct. 11:47:52 10 BY MR. SWEENEY: 11:50:55
11 Q You didn't pursue him on foot, correct? 11:47:52 11 Q Could you have struck him? 11:50:55
12 A We did. 11:47:54 12 A Possibly. 11:50:59
13 Q What's that? 11:47:56 13 Q Could you have called him a nigger? 11:51:02
14 A We did. My partner Deputy Orrego did. 11:47:57 14 A No, sir. 11:51:06
15 Q Oh. So Orrego runs on foot and you pursue in the 11:48:01 15 Q What race is Ms. Silva? 11:51:13
16 car. 11:48:05 16 A Hispanic. 11:51:18
17 A Correct. 11:48:07 17 Q Did you ever see Mr. Lockett being tased? 11:51:31
18 Q You lost sight of Orrego, didn't you? 11:48:10 18 A I don't remember, sir, to be honest. 11:51:52
19 A No, sir. 11:48:15 19 Q Did you have a taser with you during that time? 11:51:55
20 Q You never lost sight of Orrego? 11:48:16 20 A I'm not sure if I had a taser, sir. 11:52:05
21 A No, sir. 11:48:19 21 Q Do you know how to use a taser? 11:52:08
22 Q Okay. You are sure? 11:48:20 22 A Yes, I do, sir. 11:52:10
23 A Not that I can remember. 11:48:24 23 Q Do you normally carry, in the course and scope of 11:52:12
24 Q Okay. How many blocks or feet or yards was this 11:48:26 24 your employment and your daily activities, carry a taser? 11:52:15
25 pursuit? 25 MR. DAY: In that time frame?
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1 A I believe just one block. 11:48:34 1 MR. SWEENEY: Yes. 11:52:24
2 Q Okay. And once you had it contained, you got out 11:48:36 2 THE WITNESS: I believe so. 11:52:26
3 of the car, you got out of the car? 11:48:43 3 BY MR. SWEENEY: 11:52:27
4 A Correct. 11:48:44 4 Q X-26? 11:52:29
5 Q You were there with Orrego before you made contact 11:48:45 5 A I believe so, sir. 11:52:31
6 with Mr. Lockett, correct? 11:48:50 6 Q Your testimony is you don't recall tasing him. 11:52:34
7 A When I arrived, I never made contact with 11:48:56 7 Strike that. 11:52:39
8 Mr. Lockett. 11:49:00 8 Can you say one way or the other whether or not 11:52:40
9 Q Who made contact with him? 11:49:02 9 that you tased him: I did not tase him, or yes, I did tase 11:52:45
10 A I'm not sure who made contact first. 11:49:13 10 him? Can you say that? 11:52:49
11 Q Did you ever put your hands-on him? I don't 11:49:20 11 A I don't remember what my involvement was on that 11:52:53
12 think -- I don't know. Did you answer that question? 11:49:23 12 one, sir. 11:52:58
13 A I said I don't remember putting hands on the 11:49:27 13 Q Do you recall Mr. Lockett having any injuries on 11:52:59
14 initial contact, sir. 11:49:31 14 his person after the arrest? 11:53:03
15 Q I'm not talking about not initial. Any time from 11:49:32 15 A I don't remember, sir. 11:53:09
16 that date until today's date, have you ever put your hands 11:49:36 16 Q Do you know what happened to the case after the 11:53:15
17 on Mr. Lockett? 11:49:40 17 arrest? 11:53:23
18 A I believe so. 11:49:44 18 A I don't know what happened after the -- with the 11:53:29
19 Q What did you do? Tell me the manner in which you 11:49:46 19 case. 11:53:31
20 put your hands on him. 11:49:54 20 Q After the arrest? 11:53:31
21 A I don't remember the whole incident, how it 11:50:00 21 A Yes, I don't. 11:53:32
22 happened, sir. 11:50:03 22 Q You never had any contact at all with the legal 11:53:33
23 Q Did you beat him? 11:50:07 23 system or your office regarding Sheldon Lockett after the 11:53:37
24 A No, sir. 11:50:10 24 arrest. Is that your testimony? 11:53:41
25 Q Did you hit him in any way? 25 A Not that I can remember, sir, no.
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1 Q Did you ever have to testify in court on this case? 11:53:57 1 someone and then lied about -- and filed a false police 11:56:26
2 When I say this case, the Sheldon Lockett case? 11:54:02 2 report, that would be very bad, wouldn't it, in the 11:56:32
3 A Not that I -- 11:54:13 3 abstract? 11:56:35
4 Q I'm sorry? 11:54:14 4 A Yes. 11:56:37
5 A Not that I can remember. I'm not sure. 11:54:15 5 Q Okay. 11:56:42
6 Q Do you know that he stayed in jail for eight months 11:54:17 6 So your testimony, and then I'll let this go after 11:56:51
7 as a result of your arresting him and then charges were 11:54:24 7 this question, your testimony is that you just walked up, 11:56:53
8 dropped? Did you know that? 11:54:29 8 got out of your car and walked up without your guns drawn to 11:56:58
9 A No, sir. 11:54:31 9 talk to him and he takes off running. Is that your 11:57:02
10 Q How do you feel about that, that someone stayed in 11:54:34 10 testimony? 11:57:04
11 jail for eight months charged with attempted murder and it 11:54:38 11 A That I could recall, yes, sir. 11:57:08
12 was the wrong person? How do you feel about that? 11:54:43 12 Q You wrote a police report, correct, after this 11:57:13
13 MR. DAY: Objection; irrelevant, immaterial. 11:54:46 13 incident? 11:57:16
14 BY MR. SWEENEY: 11:54:53 14 A I'm not sure if I wrote the police report, sir. 11:57:21
15 Q An innocent man in jail: How do you feel about 11:54:54 15 Q Did you give a statement to the detective? 11:57:25
16 that? 11:54:57 16 A It's possible. 11:57:33
17 MR. DAY: Same objection. 11:54:58 17 Q Or did you write an incident report? 11:57:34
18 BY MR. SWEENEY: 11:55:00 18 A It is possible, yes, sir. 11:57:37
19 Q You can answer. 11:55:00 19 Q Did you put in the incident report that Mr. Lockett 11:57:39
20 A I don't know why he was in jail that long if it 11:55:01 20 had a gun? 11:57:43
21 wasn't him then. 11:55:04 21 MR. DAY: Objection; calls for speculation. If you want 11:57:47
22 Q I'm sorry? 11:55:05 22 to show him the incident report. 11:57:49
23 A I don't know why he was in jail that long. 11:55:06 23 THE WITNESS: I'm not sure what I wrote on the report. 11:57:55
24 Q But eventually charges were dropped, and he was let 11:55:10 24 BY MR. SWEENEY: 11:57:59
25 go, but it was your arrest of him which set the ball in 25 Q Could you have put in there that he had a gun and
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1 motion for him to stay in jail for eight years on something 11:55:25 1 that's why you were chasing him? 11:58:02
2 he didn't do. How do you feel about that? 11:55:28 2 A Possibly, sir. 11:58:04
3 MR. DAY: First of all, it's eight months, not eight 11:55:31 3 Q Did you see him with a gun that day? 11:58:07
4 years and -- 11:55:33 4 A I don't recall, sir. 11:58:19
5 MR. SWEENEY: I'm sorry; eight months. 11:55:34 5 Q So if I have the police report, it's going to say 11:58:26
6 MR. DAY: It's still irrelevant, immaterial. 11:55:35 6 in there -- it's not going to make any mention in there that 11:58:31
7 BY MR. SWEENEY: 11:55:38 7 Sheldon Lockett possessed a gun that day, correct? 11:58:37
8 Q You can answer. 11:55:38 8 MR. DAY: Objection; argumentative, no foundation. 11:58:42
9 MR. DAY: Argumentative. 11:55:39 9 THE WITNESS: I'm not sure what the report is going to 11:58:46
10 MR. SWEENEY: I am sorry. What did you say, Mr. Day? 11:55:42 10 say, sir. 11:58:48
11 MR. DAY: Argumentative as well. 11:55:46 11 BY MR. SWEENEY: 11:58:51
12 MR. SWEENEY: Okay. 11:55:48 12 Q Let's put this report aside for a second and talk 11:58:52
13 BY MR. SWEENEY: 11:55:52 13 about your recollection of the event today. Did Sheldon 11:58:56
14 Q You have no feelings? 11:55:53 14 Lockett have a gun that day? Did you see him with a gun 11:59:01
15 MR. DAY: That's argumentative as well. You can answer, 11:55:55 15 before the chase? 11:59:08
16 Deputy, if you are able to. 11:55:57 16 A I don't remember, sir. 11:59:18
17 THE WITNESS: Well, I don't -- it's, I guess, bad. 11:56:00 17 Q Then why were you chasing him? 11:59:27
18 BY MR. SWEENEY: 11:56:08 18 A I don't recall the incident, sir. 11:59:47
19 Q It would be very bad to trump up -- do you know 11:56:08 19 Q Okay. 12:00:01
20 what trump means other than our president? To hold someone 11:56:11 20 Do you harbor any racial animus toward African 12:00:04
21 on trumped up charges, it would be very bad, correct? 11:56:15 21 Americans? 12:00:32
22 MR. DAY: Argumentative. 11:56:19 22 A Could you rephrase that question, sir? 12:00:32
23 THE WITNESS: Sure. 11:56:20 23 Q Do you know what animus means? Do you have any ill 12:00:34
24 BY MR. SWEENEY: 11:56:20 24 feelings toward African Americans in general? 12:00:41
25 Q If a police officer under color of authority beat 25 A Ill feelings? I'm not --
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1 Q I'm sorry? 12:01:00 1 ahead, Deputy. 12:22:21
2 A Could you repeat that question one more time, sir. 12:01:01 2 THE WITNESS: I just want to say I misunderstood the 12:22:22
3 Q Do you have any ill feelings in general against 12:01:03 3 question. I'm not -- I don't have any ill feelings. 12:22:24
4 African Americans? 12:01:06 4 BY MR. SWEENEY: 12:22:29
5 A I have feelings for African Americans, sir. 12:01:43 5 Q Okay. 12:22:30
6 Q What are your feelings? 12:01:56 6 Growing up, did you have any physical altercations 12:22:35
7 A They are just human beings, sir. 12:01:58 7 with African Americans in Compton? 12:22:39
8 Q Did you hear my question, sir? Do you have any ill 12:02:01 8 A No, sir. 12:22:41
9 feelings toward African Americans? 12:02:09 9 Q Do you know the name of an arrestee by the name of 12:22:43
10 A I do, sir. 12:02:24 10 Jeremiah Wilkerson? Does that ring a bell? 12:23:07
11 Q Okay. Tell me about your feelings. 12:02:31 11 A No, sir. Jeremiah Wilkerson, no. 12:23:17
12 A I grew up in the city of Compton, sir, mostly 12:02:34 12 Q Do you know about an incident between Orrego and 12:23:22
13 Hispanics, African Americans so I, you know, pretty much 12:02:46 13 Jeremiah Wilkerson where Mr. Wilkerson alleged that Deputy 12:23:25
14 grew up with everyone around. I'm not -- 12:02:50 14 Orrego used excessive force? 12:23:30
15 Q So what is the source of your ill feelings? 12:02:54 15 MR. DAY: Objection; calls for speculation. 12:23:37
16 MR. DAY: Counsel, I don't think the witness was done 12:02:57 16 THE WITNESS: No, sir. 12:23:39
17 with his answer. 12:02:59 17 MR. SWEENEY: This is a good place to take a break. I'm 12:23:39
18 MR. SWEENEY: I'm sorry? 12:03:00 18 ready to go into the Donta Taylor incident. 12:23:42
19 MR. DAY: I don't think the witness was done with his 12:03:01 19 MR. DAY: Okay. 12:23:46
20 answer. 12:03:03 20 MR. SWEENEY: Off the record. 12:23:47
21 BY MR. SWEENEY: 12:03:04 21 THE VIDEOGRAPHER: We're going off the record. The time 12:23:48
22 Q I'm just trying to -- I'll withdraw the question. 12:03:04 22 is 12:23 PM. 12:23:50
23 What is the source of your ill feelings toward 12:03:07 23 (A lunch break was taken at 12:23 PM 12:23:50
24 African Americans? 12:03:09 24 until 1:35 PM.) 13:31:46
25 A Like I said, sir, I grew up in the city of Compton, 25 THE VIDEOGRAPHER: We are back on the record. The time
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1 and I have no problems or anything with -- 12:03:25 1 is 1:31 PM. 13:31:48
2 Q You said you had ill feelings toward African 12:03:28 2 BY MR. SWEENEY: 13:31:49
3 Americans. What is the source? Have they done something to 12:03:31 3 Q Good afternoon, sir. 13:31:51
4 you? 12:03:34 4 A Good afternoon. 13:31:52
5 A No, I don't have any ill feelings. 12:03:34 5 Q On August 25, 2016, what was your assignment as a 13:31:56
6 Q Didn't he just say he had ill feelings? 12:03:37 6 Deputy Sheriff? 13:32:01
7 A I misunderstood the question then, sir. 12:03:42 7 A I was Deputy Sheriff assigned to Compton station. 13:32:02
8 Q Okay. Is there some racial animosity between 12:03:45 8 Q Any particular detail? 13:32:09
9 blacks and Hispanics in Compton? 12:03:51 9 A Yes, I was part of a summer team. 13:32:10
10 A No, sir. 12:03:53 10 Q What is a summer team? 13:32:14
11 Q Let's take a break. 12:03:58 11 A It's a team that is put together throughout the 13:32:16
12 THE VIDEOGRAPHER: We are going off the record. The 12:04:00 12 whole County. It is a 280W2, and it is just pretty much 13:32:25
13 time is 12:04 PM. 12:04:04 13 assigned to saturate the areas of Compton. 13:32:31
14 (A break was taken in the proceedings.) 12:04:09 14 Q For what purpose? 13:32:34
15 THE VIDEOGRAPHER: We're back on the record. The time 12:21:28 15 A For the high crime areas. 13:32:36
16 is 12:21 PM. 12:21:40 16 Q Okay. At some point you came into contact with an 13:32:43
17 MR. DAY: Counsel, before you go back to your 12:21:42 17 individual you came to know as Donta Taylor, correct? 13:32:47
18 questioning, Deputy Aldama wanted to make a comment about 12:21:46 18 A Correct. 13:32:56
19 your last -- the last couple of questions and his response. 12:21:52 19 Q What time did you first see him on that day? 13:32:57
20 MR. SWEENEY: Okay. Let me just put on the record that 12:21:54 20 A That was the only time I saw him. 13:33:00
21 Deputy Aldama has consulted with counsel, and after about a 12:22:00 21 Q I know, but what time was that? 13:33:02
22 15-minute break you have something new to say. Say it. 12:22:07 22 A Approximately 8:30 PM. 13:33:07
23 MR. DAY: Well, the 15-minute break had nothing to do 12:22:11 23 Q Tell me what the lighting conditions were. 13:33:12
24 with conference, the length of conference with counsel, 12:22:14 24 A Dark; it was dark already. 13:33:15
25 since I was also conferencing with you, Mr. Sweeney, but go 25 Q It was completely dark. It wasn't dusk, it was
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1 dark, correct? 13:33:23 1 to him? 13:36:32
2 A It was dark. 13:33:24 2 A He was walking -- he was walking northbound on 13:36:33
3 Q Okay. 13:33:25 3 Wilmington on the curb and he was holding his waistband. 13:36:42
4 Were you in a black and white? 13:33:27 4 Q And he was holding his waistband? 13:36:47
5 A Yes, sir. 13:33:30 5 A Yes. 13:36:49
6 Q You were with your partner Orrego, correct? 13:33:30 6 Q Can you demonstrate how he was holding his 13:36:50
7 A That's correct. 13:33:34 7 waistband? 13:36:53
8 Q Who was the bookman and who was the driver? 13:33:36 8 A Yes. 13:36:53
9 A I was the bookman, and Deputy Orrego was the 13:33:38 9 Q Can you stand up, please? Don't rip off your 13:36:53
10 driver. 13:33:42 10 microphone, but just stand up. 13:36:57
11 Q You were the bookman. Prior to that day, 13:33:42 11 A Going like that. 13:36:59
12 August 25, 2016, at 8:30, did you ever come in contact with 13:33:48 12 Q Indicating -- I know we have a film -- but for the 13:37:02
13 Donta Taylor before? 13:33:58 13 court reporter, you have your right hand on your right hip. 13:37:05
14 A No, sir. 13:33:59 14 A Right. 13:37:11
15 Q Had you ever seen him before? 13:34:00 15 Q The waist area. 13:37:12
16 A No, sir. 13:34:03 16 A Yes. 13:37:13
17 Q Did you know anything about him before that day? 13:34:05 17 Q All right. 13:37:14
18 A No, sir. 13:34:09 18 What type of shirt did he have on? 13:37:15
19 Q But you knew that the area in which he was walking 13:34:13 19 A He had a white shirt, t-shirt. 13:37:22
20 was a high crime area, correct? 13:34:19 20 Q Was it baggy, or was it tight fitting? What was 13:37:26
21 A Correct. 13:34:22 21 it? 13:37:29
22 Q Let's face it. All of Compton is a high crime 13:34:23 22 A It was baggy. 13:37:29
23 area; isn't that true? 13:34:25 23 Q Okay. What kind of pants did he have on? 13:37:33
24 A That in particular, sir. 13:34:27 24 A He had on some basketball short type. 13:37:37
25 Q Yeah. So in your mind you were looking for -- or 25 Q The kind with the elastic band?
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1 to saturate the area to suppress crime, correct? 13:34:43 1 A Something like that, yes. 13:37:44
2 A Correct. 13:34:47 2 Q Okay. Was it a thin elastic band, or do you know? 13:37:45
3 Q All right. Saturate the area means to patrol 13:34:48 3 A I'm not sure. 13:37:49
4 around in your car with a presence, correct? 13:34:51 4 Q You eventually searched him after he was down, 13:37:52
5 A Correct. 13:34:56 5 correct? 13:37:55
6 Q Okay. Where were you when you first noticed Donta 13:35:02 6 A Not myself, no. 13:37:55
7 Taylor? 13:35:07 7 Q Your partner? 13:37:58
8 MR. DAY: You mean in what part of Compton? 13:35:11 8 A Possibly, yeah. 13:37:59
9 BY MR. SWEENEY: 13:35:11 9 Q Possibly? You were there when he was -- because I 13:38:00
10 Q Yes. What street, what corner; where were you? 13:35:14 10 read your report -- when he fell, correct? 13:38:05
11 A We were on Wilmington, and we were just north of 13:35:19 11 A He fell. 13:38:08
12 Donta Taylor. 13:35:26 12 Q Yeah. So your partner -- you saw your partner go 13:38:08
13 Q Okay. What side of the street were you on? Were 13:35:29 13 over and search him, correct, looking for a gun? 13:38:13
14 you driving in the southbound lanes or the northbound lanes? 13:35:31 14 MR. DAY: Is there a question? 13:38:18
15 A We were driving southbound lanes in the No. 2 lane. 13:35:34 15 MR. SWEENEY: Huh? 13:38:20
16 Q The No. 2 lane: That's the lane closest to the 13:35:37 16 MR. DAY: Is there a question pending? 13:38:21
17 curb. 13:35:40 17 BY MR. SWEENEY: 13:38:22
18 A That's correct. 13:35:40 18 Q Yes. You saw your partner go over to touch him 13:38:23
19 Q How many feet, yards, blocks, were you from Donta 13:35:45 19 while searching for a gun, correct? 13:38:26
20 Taylor when you first noticed him? 13:35:50 20 A That I'm not sure about. 13:38:32
21 A I was possibly mid-block of Brazil and Arbutus when 13:36:04 21 Q Is your testimony that neither you or your partner 13:38:35
22 we first noticed him. 13:36:19 22 touched him when he was down? 13:38:39
23 Q How many feet or yards? 13:36:20 23 MR. DAY: That's a different question. 13:38:40
24 A I want to say 10 or 15 yards. 13:36:21 24 THE WITNESS: I believe it was a different deputy, sir. 13:38:42
25 Q Okay. What drew you to him? What drew your eyes 25 ///
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1 BY MR. SWEENEY: 13:38:45 1 Q At some point he takes off when you get out of the 13:41:23
2 Q A different deputy? 13:38:45 2 car? 13:41:26
3 A Yes. 13:38:47 3 A He pulls the gun first and then he takes off. 13:41:28
4 Q Okay. All right. I'll get to that. I just jumped 13:38:47 4 Q He pulled the gun, correct? 13:41:31
5 ahead. All right. 13:38:49 5 A Correct. 13:41:36
6 So what caused you to stop and question Mr. Taylor? 13:38:51 6 Q Where did he pull this gun from? 13:41:38
7 A Just because he was coming from the area where we 13:39:09 7 A From the waistband area. 13:41:42
8 get a lot of calls for service. I asked him a question. 13:39:13 8 Q Did he point it at you? 13:41:45
9 Q What crime had he committed at that point that you 13:39:19 9 A No. 13:41:47
10 saw? 13:39:24 10 Q So he pulls the gun. Can you describe the gun? 13:41:53
11 A None. 13:39:25 11 A It was a stainless steel firearm, handgun, and it 13:41:59
12 Q But you decided to stop him and question him 13:39:28 12 was semiautomatic. 13:42:06
13 anyway, correct? 13:39:31 13 Q Was it -- could you tell the brand? 13:42:09
14 A I stopped my vehicle. 13:39:33 14 A No, sir. 13:42:12
15 Q You were the bookman, right? 13:39:36 15 Q Could you tell -- you know a Glock looks a little 13:42:13
16 A Correct. 13:39:37 16 bit more square than other semiautomatics, correct? 13:42:18
17 Q But in spite of the fact that he had not committed 13:39:39 17 A Sort of, yes. 13:42:22
18 a crime or was not suspected of committing a crime by you, 13:39:42 18 Q You didn't describe that as a Glock-looking gun in 13:42:24
19 you stopped him anyway, correct? 13:39:45 19 your statement, did you? 13:42:27
20 MR. DAY: Objection; assumes facts not in evidence, 13:39:46 20 A No. At the time I saw silver, a stainless steel. 13:42:29
21 misstates the testimony. 13:39:49 21 Q Okay. 13:42:32
22 MR. SWEENEY: I'm asking him. 13:39:52 22 A That's it. 13:42:33
23 BY MR. SWEENEY: 13:39:52 23 Q Okay. You knew what a Glock looked like, didn't 13:42:34
24 Q In spite of him not having committed a crime in 13:39:56 24 you, at the time? 13:42:38
25 your mind you decided to stop him anyway, correct? 25 A I've seen a few.
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1 MR. DAY: Misstates the testimony. 13:40:04 1 Q Yeah. So you know that a Glock -- so a Glock, the 13:42:40
2 THE WITNESS: We stopped the vehicle and asked him a 13:40:07 2 slide and the barrel is a little bigger and more square, 13:42:43
3 question. 13:40:09 3 correct? 13:42:47
4 BY MR. SWEENEY: 13:40:10 4 A I've seen them a few times. I'm not a fan of 13:42:47
5 Q Okay. What was that question? 13:40:10 5 Glocks, but I've seen them. 13:42:50
6 A The question was if he was on probation or parole. 13:40:12 6 Q You know them. Come on, Deputy. You know what a 13:42:53
7 Q What was his answer? 13:40:18 7 Glock looks like. You are very familiar -- you are a police 13:42:55
8 A I'm not. 13:40:22 8 officer, correct? 13:42:58
9 Q What happened next? 13:40:27 9 A Yes. 13:42:59
10 A When I asked him a question, I simultaneously was 13:40:29 10 Q Did you ever describe that gun as a Glock to the 13:43:01
11 opening my door. 13:40:33 11 persons who interviewed you after the shooting? 13:43:06
12 Q I'm sorry. What? 13:40:34 12 A No, sir. 13:43:11
13 A I was simultaneously opening my patrol vehicle 13:40:35 13 Q Okay. 13:43:17
14 door. 13:40:39 14 Tell me everything. This is your chance to tell me 13:43:18
15 Q Why did you decide to get out? 13:40:39 15 every reason why you stopped him, every reason. Go on. The 13:43:24
16 A Due to the high crime area, I'd rather be out of 13:40:44 16 floor is yours. 13:43:30
17 the car than inside the car. 13:40:48 17 A We pulled alongside of him. We just asked him a 13:43:33
18 Q So he was free to go at that point because this was 13:40:51 18 question. I stepped out of the vehicle. 13:43:39
19 a consensual encounter, correct? 13:40:55 19 Q Yeah. But why did you do that? Every reason: 13:43:40
20 A It was just a question at that time, yes. 13:40:59 20 Tell me every reason up to that point. I'm not talking 13:43:45
21 Q Yes. It was a consensual encounter, correct? 13:41:01 21 about the point where you claim he pulled out a gun and took 13:43:47
22 A Correct. 13:41:05 22 off running. Up to that point when you saw him and stopped 13:43:51
23 Q You know from the law that a person is free to go 13:41:07 23 the car, tell me every reason why you decided to stop this 13:43:54
24 any time he chooses if the encounter is consensual, correct? 13:41:10 24 person. 13:43:58
25 A Correct. 25 A Due to the calls that we have received in the past
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1 of shootings in the area, that's why I asked him. That's 13:44:04 1 testimony. 13:46:49
2 why I stopped. 13:44:09 2 THE WITNESS: I have no ill feelings for black 13:46:50
3 Q Give me more. Any other reason? 13:44:10 3 Americans. I had no ill feelings. 13:46:55
4 A Murders in the area. 13:44:13 4 BY MR. SWEENEY: 13:46:59
5 Q Any other reason? 13:44:14 5 Q Okay. I'm not going to argue with you. 13:47:00
6 A Knowing that it's a Cedar Block Piru gang area. 13:44:20 6 Did the fact that Donta Taylor was African American 13:47:06
7 Q Any other reason? 13:44:25 7 have anything to do with you stopping him? 13:47:09
8 A Gunshot victims, calls for service of illegal 13:44:35 8 A No, sir. 13:47:12
9 shootings. 13:44:38 9 Q What if Mr. Day was walking along at the same time 13:47:21
10 Q So if I were to stop or walk in Compton at that 13:44:38 10 dressed like he's dressed right now; would you stop him? 13:47:27
11 time you would have stopped me? 13:44:43 11 A I will pull alongside of him, and I will have a 13:47:33
12 A I would do a consensual encounter. I would talk to 13:44:47 12 casual conversation with him. 13:47:36
13 you. 13:44:52 13 Q Would you ask him if he was on parole? 13:47:38
14 Q Yeah. I could represent to you that I've never 13:44:53 14 A Sure. 13:47:41
15 been involved in a murder. I've never shot anybody. Okay? 13:44:56 15 Q Oh, you would? 13:47:42
16 You would still stop me? 13:45:01 16 A Yes. 13:47:44
17 A I would have a casual conversation with you, sir. 13:45:03 17 Q You would ask him if he was on his parole 13:47:46
18 Q Okay. So what you do is you -- is it a true 13:45:05 18 because -- strike that. 13:47:50
19 statement to say that you throw a blanket over all African 13:45:09 19 You asked Donta Taylor whether or not he was on 13:47:51
20 American men in that area because of what you know about 13:45:13 20 parole because that would have given you a right to search 13:47:53
21 that area? Is that your testimony? 13:45:16 21 him without a warrant, correct, without any -- strike 13:47:57
22 MR. DAY: Misstates the testimony. 13:45:20 22 that -- without any reasonable suspicion that he committed a 13:48:02
23 BY MR. SWEENEY: 13:45:21 23 crime, correct? 13:48:05
24 Q Is that true? 13:45:21 24 A Correct. 13:48:07
25 A Not black -- not African Americans but there is 25 Q You were looking for a reason to stop Donta Taylor
Page 82 Page 84
1 also Hispanics there so I stop Hispanics as well. 13:45:27 1 and search him, weren't you? 13:48:12
2 Q But you know there are no Hispanic gang members 13:45:33 2 MR. DAY: Objection; argumentative. 13:48:14
3 along that particular stretch of Wilmington, don't you? 13:45:37 3 MR. SWEENEY: How is that argumentative? 13:48:17
4 A There's actually a few, sir. 13:45:43 4 BY MR. SWEENEY: 13:48:19
5 Q Isn't that area controlled by Piru? 13:45:46 5 Q Is that true? 13:48:19
6 A There's some blocks controlled by Pirus, and there 13:45:54 6 A There was other reasons. 13:48:20
7 are also Hispanic gang members. 13:45:57 7 Q What are the other -- I told you give me every 13:48:22
8 Q I'm talking about the block where he was walking. 13:46:00 8 reason. I gave you a chance. There are more reasons than 13:48:25
9 Is your testimony that that is controlled by a Hispanic 13:46:02 9 you articulated before? 13:48:28
10 gang? 13:46:07 10 A No; those particular reasons. 13:48:31
11 A No. It's controlled by Cedar Block Piru. 13:46:07 11 Q What's that? 13:48:33
12 Q Yeah. Okay. 13:46:11 12 A Those particular reasons that I explained before. 13:48:34
13 You've already testified that you had ill 13:46:13 13 Q So -- 13:48:37
14 feelings -- in spite of what you changed it to -- ill 13:46:17 14 MR. DAY: If you have other reasons, Deputy, that you've 13:48:37
15 feelings toward African Americans because you grew up in 13:46:21 15 thought of, you should tell counsel. 13:48:40
16 Compton. 13:46:25 16 BY MR. SWEENEY: 13:48:41
17 MR. DAY: Objection; misstates, mischaracterizes the 13:46:25 17 Q He already stated. Don't try to coach him at this 13:48:41
18 witness' testimony, argumentative. 13:46:30 18 point, Mr. Day. 13:48:45
19 MR. SWEENEY: The record speaks for itself, my friend. 13:46:30 19 MR. DAY: I am not coaching him. I am just telling him. 13:48:47
20 MR. DAY: Yes, it does. 13:46:33 20 MR. SWEENEY: You are coaching the witness. 13:48:47
21 BY MR. SWEENEY: 13:46:35 21 MR. DAY: Open book exam. 13:48:55
22 Q Did you have ill feelings for this particular black 13:46:35 22 BY MR. SWEENEY: 13:48:55
23 man when you stopped him to question him on August 25th, 13:46:38 23 Q Every black man that walks through that area, be it 13:48:56
24 2016, at or about 8:30? 13:46:44 24 a college student that you don't know, an NBA basketball 13:49:00
25 MR. DAY: Argumentative, misstates the witness' 25 player that you don't recognize that comes from that area,
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1 you would stop them just because they were in that area and 13:49:08 1 BY MR. SWEENEY: 13:52:29
2 question them, correct? 13:49:11 2 Q You went over this statement either yesterday or 13:52:30
3 A I will have a casual conversation with them if they 13:49:15 3 today, correct? 13:52:33
4 are in the area, yes, sir. 13:49:19 4 A Correct. 13:52:34
5 Q Was the conversation that you had with Donta Taylor 13:49:23 5 Q What other documents did you go over in preparation 13:52:36
6 as casual as a conversation that you had with Sheldon 13:49:26 6 for your deposition? 13:52:43
7 Lockett? That's the gentleman we talked about before. 13:49:33 7 A The homicide book. 13:52:46
8 Pretty much the same? 13:49:38 8 Q The murder book or the homicide book, correct? 13:52:48
9 A No, no. 13:49:41 9 A Correct. 13:52:51
10 Q What's the difference? 13:49:43 10 Q Okay. Did you go over your partner's statement? 13:52:53
11 A Well, I asked Mr. Taylor a question. 13:49:46 11 A I glanced through it, yeah. 13:52:56
12 Q Did you ask Mr. Lockett a question? 13:49:50 12 Q Okay. 13:52:58
13 A Not that I can recall, no. 13:49:53 13 So Exhibit 1 which is Bates-stamped 0052 13:53:00
14 Q Not that you could recall. He just took off 13:49:58 14 through 0054, okay, briefly glance at that and let me know 13:53:12
15 running without you asking him a question, Lockett? 13:50:01 15 whether or not that's the same statement that you went over 13:53:24
16 A I don't remember if I asked him a question, sir. 13:50:06 16 in preparation for this deposition. 13:53:27
17 Q So basically you approached them the same way, in a 13:50:10 17 Is that the same statement that you prepped for for 13:55:33
18 cordial manner, correct? 13:50:18 18 this deposition? 13:55:38
20 Q You approached -- is your testimony that you 13:50:29 20 Q Okay. Is everything in there true? 13:55:41
21 approached Donta Taylor in the same manner that you 13:50:32 21 A Yes, sir. 13:55:45
22 approached Sheldon Lockett? 13:50:36 22 Q Okay. You approached Donta Taylor from the front 13:55:47
23 MR. DAY: The question is vague. 13:50:41 23 instead of the back, correct, when you were driving since he 13:55:59
24 THE WITNESS: Almost the same; driving through, yes. 13:50:45 24 was on the west side of Wilmington and you were traveling 13:56:02
25 /// 25 southbound on Wilmington, correct?
Page 86 Page 88
2 Q Almost the same. Abracadabra. Okay. All right. 13:50:48 2 Q Okay. 13:56:31
3 That's just a little thing I use as a bookmark in the 13:50:57 3 Describe your -- what you had on your Sam Browne 13:56:35
4 transcript. There's a legend, and when I go to abracadabra 13:51:01 4 that evening. 13:56:41
5 it's a bookmark of something I might want to go back to, 13:51:07 5 A It was a nylon belt that I have. Going from the 13:56:45
6 that's all, just so you know. 13:51:10 6 middle to the left, I had a pouch, my magazine pouch with 13:56:56
7 Now, you gave a statement after the shooting to a 13:51:15 7 two magazines, radio. I also had a -- my expandible baton 13:57:02
8 superior, correct? 13:51:21 8 ring, handcuff case. I also had my weapon. I had my key 13:57:11
9 A I believe to the homicide detectives, yes. 13:51:24 9 holder, and I had my OC spray holder. 13:57:21
10 Q Yes. When was that given? 13:51:29 10 Q What kind of gun did you have? 13:57:26
11 A It was given on the -- a few hours after the 13:51:34 11 A I have the County issue M&P-9mm. 13:57:29
12 incident. 13:51:39 12 Q Smith & Wesson? 13:57:33
13 Q Okay. You talked to a lawyer before you gave your 13:51:40 13 A Smith & Wesson. 13:57:34
14 statement, correct? I'm not asking you what you said. I 13:51:44 14 Q Did it have a flashlight on it? 13:57:36
15 can't do that. But you talked to a lawyer, correct? 13:51:47 15 A Yes. 13:57:39
16 A Correct. 13:51:50 16 Q So you depress a button and a flashlight comes on? 13:57:39
17 Q I want to mark this first exhibit as Exhibit 1. Do 13:51:50 17 A Correct. 13:57:44
18 you have any stickers? 13:51:58 18 Q A very powerful flashlight, correct? 13:57:45
19 THE COURT REPORTER: I do. 13:52:11 19 A Yes. 13:57:49
20 MR. SWEENEY: Should I circle plaintiff? 13:52:14 20 Q Okay. 13:57:49
21 THE COURT REPORTER: You can. 13:52:28 21 A Yes. 13:57:50
22 MR. SWEENEY: Exhibit 1. 13:52:28 22 Q Did it have a laser on it? 13:57:50
23 (Plaintiff's Exhibit No. 1 was marked for 13:52:28 23 A No. 13:57:52
24 identification, a copy of which is attached 13:52:28 24 Q Just a flashlight? 13:57:52
25 hereto.) 25 A Just a flashlight.
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1 Q Do you ever carry a back-up weapon? 13:58:03 1 overhead light? 14:00:48
2 A Yes. 13:58:05 2 A There was overhead lights from businesses. 14:00:53
3 Q Did you have a back up weapon that night? 13:58:06 3 Q In front of what business did you stop Mr. Taylor? 14:00:57
4 A No. 13:58:09 4 A It was, I believe, a salon, a hair salon. 14:01:01
5 Q Where do you carry your back-up weapon? 13:58:10 5 Q Do you recall the name of the hair salon? You can 14:01:05
6 A On the opposite side of the main weapon. 13:58:12 6 refresh your recollection by looking at your report if that 14:01:09
7 Q Holster? 13:58:17 7 helps. 14:01:13
8 A Right-handed. 13:58:18 8 I know I read it somewhere. Maybe it's in your 14:01:48
9 Q Holstered? 13:58:19 9 partner's report. But it was in the -- Anyway, let me move 14:01:58
10 A Yes. 13:58:20 10 on. 14:02:01
11 Q What kind of weapon? 13:58:20 11 You were approaching Brazil Street when you noticed 14:02:02
12 A A pocket holster. 13:58:21 12 Mr. Taylor, correct? 14:02:07
13 Q A pocket holster. 13:58:23 13 A Correct. 14:02:09
14 A Yes. 13:58:23 14 Q Had Mr. Taylor walked north of Brazil street at 14:02:10
15 Q What kind, a revolver? 13:58:25 15 that time when you noticed him, or was he still south of 14:02:14
16 A It's a .38 Smith & Wesson revolver. 13:58:27 16 Brazil Street? 14:02:20
17 Q Air weight? 13:58:30 17 A No. He was north of Brazil Street. 14:02:21
18 A Yes. 13:58:31 18 Q Okay. How far north, two yards, 15 yards, 10 feet, 14:02:25
19 Q Hammerless? 13:58:33 19 15 feet? 14:02:32
20 A Yes. 13:58:34 20 A About 10, 15 feet north of Brazil. 14:02:34
21 Q I know a little bit about guns. 13:58:37 21 Q Okay. 14:02:37
22 You got out of the car first, correct? 13:58:43 22 So tell me every word that Donta Taylor spoke to 14:02:50
23 A Correct. 13:58:58 23 you. 14:02:56
24 Q Did you notice whether or not Deputy Orrego got out 13:59:00 24 A It was just the answer from the question I asked 14:03:01
25 of the car? 25 and --
Page 90 Page 92
1 A He got out of the car, yes. 13:59:11 1 Q Which was? 14:03:07
2 Q Okay. At the same time you did? 13:59:13 2 A Which was are you on probation or parole. 14:03:08
3 A Yes. 13:59:18 3 Q What did he say? 14:03:10
4 Q Where did he park the car, on a curb at an angle or 13:59:23 4 A No, I'm not. 14:03:11
5 parallel to the curb? 13:59:29 5 Q And then he took off? 14:03:12
6 A It was parallel to the curb, and we were still in 13:59:31 6 A When I asked the question, I was simultaneously 14:03:13
7 the No. 2 lane. 13:59:34 7 opening my door. 14:03:17
8 Q Stopped in the middle of the street. 13:59:36 8 Q Okay. When Mr. Taylor took off running, which 14:03:18
9 A A little bit off. 13:59:38 9 direction did he travel on Wilmington, north or south? 14:03:43
10 Q Okay. Did you have your lights on? Not your 13:59:40 10 A When he took off running, he went northbound on 14:03:48
11 headlights but the -- your overhead lights, the overhead 13:59:47 11 Wilmington. 14:03:52
12 lights? 13:59:54 12 Q Towards what street? 14:03:52
13 A I believe we did. 13:59:58 13 A Towards Arbutus Street. 14:03:53
14 Q How close did you make it to Mr. Taylor before, as 14:00:05 14 Q What direction did he go, left or right? 14:03:55
15 you said, he took off? 14:00:08 15 A On Arbutus he made a left turn which is westbound. 14:03:58
16 A Twenty-five, 30 yards, sir. 14:00:18 16 Q Okay. Did you pursue? 14:04:03
17 Q Twenty-five to 30 yards from him before he took 14:00:22 17 A I did. 14:04:07
18 off? 14:00:26 18 Q Okay. How quickly after he ran did you chase after 14:04:10
19 A I'm sorry. I misunderstood the question. 14:00:26 19 him, immediately; when he ran you ran? 14:04:14
20 Q Okay. 14:00:29 20 A Immediately, yes. 14:04:18
21 A Ten to 15 feet. 14:00:34 21 Q You left your partner, correct? 14:04:20
22 Q All right. 14:00:37 22 A My partner was right behind me. 14:04:23
23 What was -- it was dark, correct? 14:00:39 23 Q Okay. How do you know that? 14:04:25
24 A Correct. 14:00:43 24 A Because I could here him putting out radio traffic. 14:04:30
25 Q What was lighting up, if anything, Mr. Taylor; 25 Q Did you put out radio traffic?
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1 A At one point I did. 14:04:37 1 testimony? 14:07:11
2 Q Did you ask for the Patch? 14:04:39 2 A I have a gun -- my gun with me. 14:07:13
3 A No, I didn't. 14:04:43 3 Q That wasn't my question. My question is your 14:07:16
4 Q Do you know if your partner asked for the Patch? 14:04:44 4 testimony is that you were chasing balls out 20 yards after 14:07:19
5 A Yes. 14:04:48 5 someone with a gun, who has a gun, correct? 14:07:27
6 Q Did he? 14:04:50 6 A Correct. 14:07:31
7 A He did. 14:04:51 7 Q After he made that right, what street was that? 14:07:37
8 Q So you had an open mike to all units in the area, 14:04:53 8 There is no street; it's a dirt path? 14:07:43
9 correct, or he did? That's what the Patch means, right? 14:04:57 9 A Dirt path. 14:07:45
10 A That's correct. 14:05:02 10 Q Okay. Where did he go after that? 14:07:45
11 Q So he radioed in and said get me to Patch, correct? 14:05:03 11 A He went all the way to Poplar. 14:07:48
12 A Correct. 14:05:09 12 Q Poplar? 14:07:51
13 Q That's what you have to do to get on the Patch, 14:05:09 13 A Poplar, yes. 14:07:52
14 correct? 14:05:12 14 Q P-O-P-L-A R? 14:07:52
16 Q Was he communicating with command at all times, if 14:05:19 16 Q Okay. What did he do at Poplar? 14:07:55
17 you know? 14:05:25 17 A There is a footbridge that connects the wash so you 14:08:01
18 A Yes, he was communicating with them. 14:05:26 18 can go to the west side of the wash with that footbridge. 14:08:06
19 Q Okay. So we've gotten to the point where 14:05:29 19 Q Connects the east side to the west side. 14:08:10
20 Mr. Taylor made a left to go westbound on Arbutus, 14:05:32 20 A Correct. 14:08:12
21 A-R-B-U-T-U-S. Where did he go after that? 14:05:39 21 Q He goes across the wash? 14:08:12
22 A He continued westbound, westbound on Arbutus 14:05:42 22 A He did. 14:08:14
23 towards the wash. 14:05:49 23 Q When he reached the wash, how close were you? 14:08:16
24 Q Okay. Where did he go from there when he reached 14:05:51 24 A About 30 yards. 14:08:20
25 the wash? 25 Q Did he ever point the gun at you at this point?
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1 A From the dead-end he went into the dirt path and 14:05:56 1 A No. 14:08:36
2 then he went northbound on the dirt path. 14:05:59 2 Q Once he got to the other side, the west side of the 14:08:39
3 Q So was he on the east or west side of the wash when 14:06:03 3 wash, what did he do? 14:08:43
4 he hit the dirt path? 14:06:07 4 A He continued southbound on the dirt path on the 14:08:48
5 A When he hit the dirt path, he was on the east side 14:06:09 5 west side of the wash. 14:08:52
6 of the wash. 14:06:12 6 Q Okay. At some point, did you separate from your 14:08:55
7 Q This side of the wash. When I say this side, the 14:06:13 7 partner? 14:08:57
8 same side that Wilmington is on. 14:06:16 8 A Yes. 14:08:59
9 A Correct, the east side. 14:06:18 9 Q I'll get to that. 14:09:00
10 Q All right. That's a dead-end; that's where Arbutus 14:06:20 10 And you were chasing after him going southbound on 14:09:02
11 dead-ends? 14:06:24 11 the west side of the wash, dirt path, correct? 14:09:08
12 A Correct. 14:06:25 12 A I wasn't chasing him. 14:09:11
13 Q All right. What direction did he go after that? 14:06:26 13 Q Who was chasing him? 14:09:13
14 A He made a right turn which is northbound. 14:06:29 14 A No one. 14:09:14
15 Q How close were you when he was at that dead-end? 14:06:33 15 Q Okay. Why did you stop pursuing him? 14:09:16
16 How close were you behind him? 14:06:38 16 A Because we saw him go westbound on Arbutus and 14:09:26
17 A I want to say about 20 yards. 14:06:47 17 decided to do a mini containment within me and my partner. 14:09:31
18 Q About 20 yards? 14:06:49 18 Q Okay. So he gets to the other side of the wash and 14:09:38
19 A Yes. 14:06:50 19 goes down the dirt path on the west side of the wash. Where 14:09:41
20 Q Chasing after him, correct? 14:06:50 20 does he go after that? 14:09:46
21 A Correct. 14:06:52 21 A He makes a right turn west on Arbutus. 14:09:48
22 Q Okay. Did you have your gun out? 14:06:55 22 Q So Arbutus picks up again on the other side of the 14:09:53
23 A Yes. 14:06:59 23 wash, on the west side of the wash. 14:09:56
24 Q Your testimony is that you were chasing 20 yards in 14:07:02 24 A Correct. 14:09:58
25 back of a person with a gun in their hand. Is that your 25 Q Correct? It ends on the east side and picks back
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1 up on the west side on the other side of the wash, correct? 14:10:04 1 A No. 14:12:33
2 A Correct. 14:10:06 2 Q Okay. When is the next time you saw Donta Taylor? 14:12:35
3 Q So you decide to -- did you make this decision 14:10:08 3 A When I walked southbound on the dirt path. 14:12:41
4 yourself, or did you make it with your partner? 14:10:12 4 Q Okay. Where was he coming from? 14:12:47
5 A It was a decision within ourselves, both of us. 14:10:16 5 A He was coming from Arbutus. 14:12:50
6 Q Together. 14:10:20 6 Q Okay. Was he running? 14:12:56
7 A Correct. 14:10:20 7 A Yes. 14:12:58
8 Q You talked about this. 14:10:21 8 Q All right. Did you shoot at him at that point? 14:13:01
9 A Right there and then, yes. 14:10:23 9 A Yes. 14:13:04
10 Q Okay. What was that tactical decision? 14:10:27 10 Q How far away from you -- from him were you? Were 14:13:06
11 A It's a tactical decision -- 14:10:35 11 you still at Poplar and dirt path? 14:13:12
12 Q What was the decision? I just threw that word in, 14:10:37 12 A No. 14:13:14
13 tactical. 14:10:41 13 Q Where were you? 14:13:15
14 A It was a decision made to apprehend by containment 14:10:43 14 A I was about 25 feet north of Arbutus. 14:13:17
15 and to make sure that we had him within the containment. 14:10:48 15 Q How far south of Poplar? 14:13:31
16 Q Okay. So he made a right on Arbutus to go 14:10:51 16 A About 40 or 45 yards. 14:13:40
17 westbound on Arbutus on the other side of the wash, correct? 14:10:56 17 Q But your partner was still on Kemp and Poplar, 14:13:43
18 A Correct. 14:10:58 18 correct? 14:13:49
19 Q Where were you going to contain him? 14:11:00 19 A Correct. 14:13:50
20 A We were going to contain him in-between Kemp and 14:11:02 20 Q So you did separate at that point, correct? 14:13:51
21 Poplar. 14:11:09 21 A Correct. 14:13:56
22 Q So where did you go? 14:11:09 22 Q You couldn't see him, correct? 14:14:02
23 A I stayed on the dirt path and Poplar. 14:11:13 23 A No. 14:14:05
24 Q Is Poplar south or north of Arbutus? 14:11:16 24 Q I am correct; you could not see him? Yes, I am 14:14:07
25 A Poplar is going to be north of Arbutus. 25 correct?
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1 Q So he had to run past Poplar to get to Arbutus to 14:11:24 1 A Correct, I couldn't see him. 14:14:11
2 make that right, correct? 14:11:28 2 Q Okay. Isn't that a violation of the foot pursuit 14:14:13
3 A Well, the footbridge was Poplar so he ran through 14:11:30 3 policy? 14:14:17
4 there. 14:11:33 4 MR. DAY: If you know. 14:14:20
5 Q Okay. Where did your partner go? 14:11:34 5 THE WITNESS: Yes. 14:14:25
6 A He went on Poplar and Kemp. 14:11:38 6 BY MR. SWEENEY: 14:14:26
7 Q I'm sorry. Where did you go? 14:11:40 7 Q Okay. So Taylor, as you said, comes running back 14:14:37
8 A The dirt path and Poplar. 14:11:42 8 eastbound on Arbutus, correct? That's when you shot at him, 14:14:44
9 Q Okay. You lost -- you split at that point, 14:11:47 9 correct? 14:14:54
10 correct? 14:11:50 10 A Correct. 14:14:54
11 A Well, we were like 20 feet away. 14:11:51 11 Q How far away from him were you when you fired? 14:14:56
12 Q From each other? 14:11:55 12 A About 25 feet away, northbound. 14:15:00
13 A From each other. 14:11:56 13 Q Did you light him up with your flashlight? 14:15:03
14 Q Could you see him? 14:11:57 14 A I did. 14:15:08
15 A Yes. 14:11:58 15 Q Could you see him clearly? 14:15:10
16 Q And so Kemp is the north/south street just west of 14:11:59 16 A No. 14:15:14
17 the wash? 14:12:08 17 Q Did he have anything in his hand at that point? 14:15:18
18 A Correct. 14:12:10 18 A Yes. 14:15:24
19 Q So he went to Kemp and Poplar, right? 14:12:12 19 Q What did he have in his hand? 14:15:27
20 A Correct. 14:12:16 20 A He had a gun. 14:15:33
21 Q And you stayed at dirt path and Poplar, correct? 14:12:17 21 Q Did you hit him with your gunfire at that point? 14:15:35
22 A Correct. 14:12:20 22 A I wasn't sure at that point. 14:15:42
23 Q When is the next time you saw -- strike that. 14:12:23 23 Q Did he point his gun at you? 14:15:44
24 Were any shots fired up to this point when you made 14:12:27 24 A Yes, he did. 14:15:47
25 this plan and separated? 25 Q He pointed his gun at you at that point; is that
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1 right? 14:15:52 1 Q He fell down after you heard that -- strike that. 14:19:17
2 A Yes, he did. 14:15:52 2 Where did he fall down? 14:19:25
3 Q So did he fall at that point when you shot at him? 14:15:53 3 A On the dirt path. 14:19:27
4 A No. 14:15:59 4 Q Is it your understanding that -- strike that. 14:19:29
5 Q Did he pull the trigger and shoot at you? 14:16:00 5 What is your understanding as to what bullets hit 14:19:35
6 A No. 14:16:04 6 him, your gun -- your projectiles fired from your gun or 14:19:41
7 Q Where did Mr. Taylor -- what did Mr. Taylor do 14:16:13 7 your partner's? 14:19:46
8 after you shot at him? 14:16:18 8 MR. DAY: At that time or at the -- 14:19:47
9 A He went back westbound on Arbutus. 14:16:20 9 MR. SWEENEY: Later. 14:19:48
10 Q How many shots did you fire at him? 14:16:24 10 MR. DAY: So at any time. 14:19:49
11 A About 10 or 12 times. 14:16:26 11 MR. SWEENEY: At any time. 14:19:51
12 Q From 25 feet away; is that correct? Is that 14:16:37 12 BY MR. SWEENEY: 14:19:52
13 correct? 14:16:42 13 Q What is your understanding? 14:19:52
14 A Correct. 14:16:42 14 A I don't know how many -- I'm not sure. 14:19:55
15 Q How much -- how far east of any fencing along the 14:16:43 15 Q Whose bullets hit Donta Taylor, yours or your 14:20:00
16 wash at Arbutus was he? Was he at, like, in the middle of 14:16:58 16 partner's? 14:20:04
17 the dirt path, just peeked his head around the dirt path? 14:17:02 17 MR. DAY: Objection; calls for an expert opinion. 14:20:05
18 How was it? 14:17:06 18 BY MR. SWEENEY: 14:20:07
19 A I'm sorry. When he came around? 14:17:08 19 Q If you know. You read the murder book. 14:20:07
20 Q Yes. 14:17:11 20 A Possibly me, sir. 14:20:13
21 A He was more towards the chain-link fence at the 14:17:15 21 Q Okay. Did you -- was there a third shooting, 14:20:20
22 wash. 14:17:21 22 volley of shots? Before you answer that -- I'm sorry. How 14:20:25
23 Q Do you have any reason to believe that you hit him 14:17:44 23 many shots did you hear coming from your partner's gun? 14:20:29
24 with at least one of the ten rounds that you fired? 14:17:46 24 A When he was on Arbutus? 14:20:41
25 A Probably did, yeah. 25 Q Yes, when you heard that second volley of shots,
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1 Q What did he do after the initial volley of ten 14:18:01 1 yours being the first and your partner's being the second. 14:20:47
2 shots? 14:18:04 2 A When he was on Arbutus, it was about three to four. 14:20:55
3 A He went back westbound on Arbutus. 14:18:04 3 Q Okay. Did you discharge your gun a second time, a 14:20:58
4 Q Did you hear any gunshots after that? 14:18:07 4 second set of volleys after you initially shot the ten and 14:21:04
5 A Yes, I did. 14:18:12 5 then three seconds later you hear your partner shoot three 14:21:09
6 Q Could you tell where they were coming from? 14:18:14 6 or four times? Did you shoot a second set of volleys -- or 14:21:11
7 A Yes. They were coming from Arbutus. 14:18:21 7 a second volley of rounds? 14:21:16
8 Q You later found out that was your partner shooting, 14:18:25 8 A No, sir. 14:21:19
9 correct? 14:18:28 9 Q So then there was just -- do you know if your 14:21:20
10 A Correct. 14:18:28 10 partner shot a second volley of rounds? 14:21:22
11 Q Arbutus and Kemp? 14:18:29 11 A The initial contact he had with him, yes. 14:21:32
12 A I'm sorry? 14:18:32 12 Q So your first ten shots, that was the second volley 14:21:35
13 Q Were the shots coming from Arbutus and Kemp Street? 14:18:36 13 of rounds, correct? 14:21:39
14 A Possibly; close by, yes. 14:18:40 14 A Correct. 14:21:43
15 Q Okay. How long between the time you shot at him 14:18:46 15 Q Okay. So where was the first, if you know, volley 14:21:43
16 and the time you heard the other shots coming from what you 14:18:49 16 of rounds shot by your partner? What location was that? 14:21:45
17 later learned was your partner's gun? 14:18:51 17 A It was somewhere on Kemp, sir, between -- 14:21:51
18 A Seconds. 14:18:56 18 Q Somewhere what? 14:21:54
19 Q One second, two seconds, three seconds? 14:18:58 19 A The location of Kemp in-between Arbutus and Poplar. 14:21:56
20 A About three seconds. 14:19:02 20 Q And obviously he wasn't downed by those bullets 14:22:05
21 Q About three seconds. After that, did you see Donta 14:19:04 21 because he kept running, correct? 14:22:09
22 Taylor again? 14:19:07 22 A Correct. 14:22:11
23 A Yes. 14:19:09 23 Q All right. Do you know how many -- so you heard, 14:22:11
24 Q Where did you see him? 14:19:10 24 before you even shot, you heard a volley of rounds, correct? 14:22:14
25 A He fell down. 25 A Coming from that area, yes.
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1 Q Yes. So then you see him emerge from Arbutus and 14:22:23 1 A No. 14:25:08
2 you shoot, and then you hear about three seconds later more 14:22:25 2 Q Okay. Can you demonstrate how he had his hands out 14:25:15
3 shots, correct? 14:22:30 3 in front of him with something in it? Stand up, if you can. 14:25:18
4 A Correct. 14:22:30 4 MR. DAY: When they are on the dirt path? 14:25:23
5 Q All right. Let's focus in on your shots. Tell me 14:22:33 5 MR. SWEENEY: What is that? 14:25:26
6 every reason why you discharged your duty weapon that 14:22:43 6 MR. DAY: When they were on the dirt path. 14:25:27
7 evening. 14:22:47 7 MR. SWEENEY: Yes, right before he shot. 14:25:30
8 A After I heard the first volley of shots, Donta 14:22:50 8 THE WITNESS: Something like that. 14:25:31
9 Taylor came into the dirt path where I was at at full speed 14:22:59 9 BY MR. SWEENEY: 14:25:33
10 and his hands were at a chest level pointing at me so I shot 14:23:07 10 Q Like he had a gun, correct? 14:25:33
11 my weapon at him. 14:23:11 11 A Yes. 14:25:34
12 Q Did you notice anything in his hands? 14:23:14 12 Q That's when you shot 10 or 12 times -- 14:25:35
13 A I noticed he was holding something and -- 14:23:19 13 A Correct. 14:25:35
14 Q What was he holding? 14:23:24 14 Q Or 10 times? 14:25:37
15 MR. DAY: Counsel, he wasn't finished with his answer. 14:23:26 15 A Ten or 12 times. 14:25:38
16 BY MR. SWEENEY: 14:23:28 16 Q Ten to 12 times. 14:25:41
17 Q Sorry. Finish your answer. 14:23:29 17 How long was it between the time that you shot your 14:25:48
18 A I noticed he was holding something. He was 14:23:30 18 last shot did he fall? 14:25:50
19 pointing at me, and I shot at him. 14:23:33 19 A Five seconds. 14:26:03
20 Q Describe what he was holding. 14:23:37 20 Q Where did you aim? 14:26:06
21 A I didn't see it clearly. 14:23:42 21 A Center mass. 14:26:11
22 Q What do you think it was? 14:23:47 22 Q Pretty good shot, right, you? 14:26:14
23 A The gun. 14:23:51 23 A Hard if it's a moving target, yes. 14:26:18
24 Q Your flashlight was illuminated at that time? 14:23:53 24 Q I'm sorry. What? 14:26:20
25 A No. 25 A Hard if it's a moving target, yes.
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1 Q No? 14:23:58 1 Q But you are a pretty good shot, correct? You are 14:26:26
2 A No. 14:23:59 2 trained? 14:26:28
3 Q You had it at your disposal, though, the 14:24:02 3 A Yes. 14:26:28
4 flashlight, correct? 14:24:06 4 Q Was he darting from side to side, or was he coming 14:26:29
5 A I had a handheld flashlight, yes. 14:24:07 5 straight forward? 14:26:33
6 Q What was that? 14:24:09 6 A It was just straight forward. 14:26:35
7 A A handheld flashlight. 14:24:10 7 Q So the target wasn't moving that much because it 14:26:43
8 Q Did you have it illuminated? 14:24:11 8 was coming at you, correct? 14:26:47
9 A I was -- I possibly did because it was dark, yes. 14:24:14 9 MR. DAY: Objection; no foundation, calls for 14:26:49
10 Q Possibly? 14:24:20 10 speculation. 14:26:52
11 A Well, I was using it because it was dark, yes. 14:24:21 11 THE WITNESS: He was coming at me at one point, yes. 14:26:54
12 Q So you had it illuminated, correct? 14:24:25 12 BY MR. SWEENEY: 14:26:57
13 A Correct. 14:24:28 13 Q At the point where you fired, correct? 14:26:57
14 Q When you shot, you had the handheld flashlight in 14:24:28 14 A When I fired, and as I was firing he was going back 14:27:00
15 one hand and your gun in the other? 14:24:34 15 to Arbutus. 14:27:04
16 A No. 14:24:36 16 Q He was retreating from you when you fired; is that 14:27:06
17 Q Tell us how it went. 14:24:38 17 correct? 14:27:10
18 A As he is running eastbound on Arbutus. 14:24:42 18 A Correct. 14:27:10
19 Q Okay. 14:24:47 19 Q How long did it take between the time you perceived 14:27:16
20 A And now he's going northbound on the wash where I 14:24:48 20 danger -- Did you perceive danger -- strike that. 14:27:21
21 was at. I just saw him coming. I dropped my handheld 14:24:51 21 Did you perceive danger when he had his hands out 14:27:23
22 flashlight, and I just shot at him. 14:24:56 22 in front of him as you demonstrated? 14:27:26
23 Q When you had him -- did you have him lit up when he 14:24:59 23 A Yes. 14:27:30
24 turned that corner to come back on the dirt path to go 14:25:03 24 Q Is that why you fired? 14:27:30
25 northbound? 25 A Yes.
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1 Q Okay. Did you see him throw a gun away? 14:27:35 1 Q Did your partner say that he saw him throw it 14:31:06
2 A No, I didn't. 14:27:43 2 anywhere? 14:31:10
3 Q Did you see him throw any object away? 14:27:44 3 A Not that I remember, no. 14:31:11
4 A No, I didn't. 14:27:49 4 Q You told responding officers this story that you 14:31:13
5 Q Did you find any object around him that appeared to 14:27:52 5 just told us when they came? 14:31:22
6 be like the object you saw in his hand when you perceived 14:27:55 6 A Briefly, yes. 14:31:27
7 the danger and fired? 14:27:58 7 Q Do you know if they went looking for a gun? 14:31:29
8 A I'm sorry. Can you rephrase that? 14:28:04 8 A They went looking for a gun. 14:31:34
9 Q After he was downed, you approached him, correct? 14:28:10 9 Q So he had five seconds -- strike that. 14:31:38
10 A No. 14:28:15 10 He rid himself of the gun, correct, because you 14:31:46
11 Q Did your partner approach him? 14:28:17 11 never found a gun, correct? 14:31:51
12 A No. 14:28:23 12 A Correct. 14:31:52
13 Q How long did it take for backup to come after he 14:28:31 13 Q So he had five seconds to get rid of that gun, 14:31:53
14 was downed? 14:28:34 14 correct? 14:31:59
15 A Between 45 seconds to a minute. 14:28:43 15 MR. DAY: Misstates the witness' testimony. 14:32:00
16 Q Did you approach him to see if there was still a 14:28:47 16 BY MR. SWEENEY: 14:32:03
17 danger, if he still had a gun, in your mind? 14:28:52 17 Q Well, you said that you perceived the danger 14:32:03
18 A I know we were holding him at gunpoint. 14:28:57 18 because he had the gun out in front of him, you fire and 14:32:07
19 Q Did you ever touch him? 14:29:04 19 five seconds later he's back on the path falling down, 14:32:15
20 A No. 14:29:07 20 correct? Is that true? That's what you told me, right? 14:32:21
21 Q Did your partner ever touch him? 14:29:08 21 A Yes. 14:32:24
22 A Not that I remember. 14:29:11 22 Q And you didn't find any gun around him, correct? 14:32:26
23 Q Did you search in the area for a gun? 14:29:30 23 A Correct. 14:32:28
24 A Not me, sir. 14:29:37 24 Q And nobody found any gun around him, correct? 14:32:29
25 Q Do you know if your partner did? 25 A Correct.
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1 A No, sir. 14:29:42 1 Q So he had five seconds to get rid of this gun. 14:32:32
2 Q But you know someone from your department searched, 14:29:45 2 MR. DAY: Objection; misstates, mischaracterizes the 14:32:38
3 correct? 14:29:49 3 witness' testimony. 14:32:42
5 Q You read the murder book. You found that there was 14:29:50 5 Q Okay. Well, he had the gun or he had something in 14:32:43
6 no gun found, correct? 14:29:54 6 his hand, correct? 14:32:46
7 A Correct. 14:29:55 7 A An object, yes. 14:32:48
8 Q So he had an object, pointed it at you in the 14:30:00 8 Q Okay. So he had five seconds between the time you 14:32:49
9 stance that you just demonstrated five seconds before he was 14:30:04 9 shot your last shot and the time -- to get rid of whatever 14:32:53
10 downed, correct? 14:30:10 10 object was in his hand before he came back out and fell 14:32:58
11 A Could you repeat that question again? 14:30:15 11 down, correct? 14:33:02
12 Q Yes. He was downed five seconds after you shot 14:30:29 12 MR. DAY: Still the same objection; misstates and 14:33:03
13 your last shot, right? 14:30:35 13 mischaracterizes the witness' testimony. 14:33:06
15 Q And you shot because Mr. Taylor was in a position 14:30:39 15 Q You can answer. 14:33:08
16 holding his hands in front of him like he had a gun, 14:30:45 16 A I don't think he had five seconds. 14:33:14
17 correct? 14:30:48 17 Q What did he have; how much time in your best 14:33:18
18 A Correct. 14:30:48 18 estimation? 14:33:20
19 Q And you saw an object in his hand, correct? 14:30:49 19 A My opinion is he got rid of it somewhere else. 14:33:27
20 A Correct. 14:30:52 20 Q I'm sorry. What? 14:33:30
21 Q And you didn't see that object that you saw in his 14:30:55 21 A My opinion -- 14:33:32
22 hand anywhere around his body, did you? 14:30:58 22 Q I don't need your opinion. Objection. It's 14:33:33
23 A Not that I can remember. 14:31:02 23 irrelevant what your opinion is. 14:33:40
24 Q You didn't see him throw it anywhere, did you? 14:31:03 24 Between the time that you shot your last shot 14:33:41
25 A No. 25 because you were responding to a perceived threat, there is
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1 something in his hand, and the time that he came back out 14:33:49 1 Q Wounded? 14:36:09
2 into your view was five seconds, correct? 14:33:55 2 A I'm not sure. 14:36:10
3 A Correct. 14:33:57 3 Q He had something you said, right? 14:36:11
4 Q There was nothing in his hand when he fell, 14:34:08 4 A Something. I'm not sure what it was. 14:36:14
5 correct? 14:34:11 5 Q That is your testimony. You saw it with your own 14:36:16
6 MR. DAY: Are you asking if he fell in response to the 14:34:13 6 two eyes. You saw something in his hands when he was on the 14:36:22
7 shots fired by Deputy Aldama? 14:34:17 7 ground shot. Is that your testimony? 14:36:25
8 MR. SWEENEY: Yes. Fell down dead or wounded. 14:34:22 8 A Yes. 14:36:30
9 MR. DAY: Then the question is vague, vague as to when 14:34:26 9 Q By this time there was no danger to you, right, 14:36:33
10 he fell down. 14:34:28 10 because he was down. 14:36:36
11 Do you understand the question, Deputy? 14:34:31 11 MR. DAY: Objection; misstates, mischaracterizes the 14:36:38
12 THE WITNESS: Yes. He was holding something. Like I 14:34:32 12 witness' testimony. 14:36:41
13 said, we were holding him at gunpoint after that, so. 14:34:35 13 BY MR. SWEENEY: 14:36:41
14 BY MR. SWEENEY: 14:34:37 14 Q I'm asking the question. Was there any -- did you 14:36:42
15 Q He was holding something in his hand when he was 14:34:37 15 perceive any danger from this man who was mortally wounded 14:36:44
16 down? 14:34:40 16 on the ground moving around at that point? 14:36:47
17 A He had something. 14:34:40 17 MR. DAY: Objection; mischaracterizes the witness' 14:36:50
18 Q What was it? 14:34:42 18 testimony. 14:36:52
19 A I'm not sure what it was. 14:34:43 19 BY MR. SWEENEY: 14:36:53
20 Q Your testimony is you saw him with something in his 14:34:45 20 Q You can answer. 14:36:53
21 hand when he was on the ground shot; is that correct? 14:34:49 21 A He's still a danger until he's handcuffed. 14:36:54
22 A Oh, he was still moving. Mr. Taylor was still 14:34:54 22 Q So you took off running the opposite direction? 14:36:56
23 moving, yes. 14:34:57 23 A I didn't run. 14:37:01
24 Q Yes. You saw something in his hand at that point. 14:34:58 24 Q What did you do, Deputy? 14:37:03
25 A He was -- there was something in his hands. 25 A I took a couple of steps back, northbound, on the
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1 Q What was it? He was down, and you were looking at 14:35:12 1 dirt path. 14:37:13
2 him. Did you light him up at that point? 14:35:17 2 Q But you covered him, correct? 14:37:14
3 A We light him up from far away. 14:35:19 3 A Correct. 14:37:15
4 Q What was in his hand then, Deputy? 14:35:21 4 Q You lit him up with a flashlight, correct? 14:37:16
5 MR. DAY: Counsel, you are interrupting the witness. 14:35:24 5 A No. 14:37:18
6 MR. SWEENEY: I apologize. 14:35:26 6 Q Did anybody light him up with a flashlight? 14:37:18
7 BY MR. SWEENEY: 14:35:27 7 A I didn't see that. 14:37:22
8 Q What was in his hand? 14:35:27 8 Q About 45 seconds backup arrives? 14:37:25
9 A He had something. After he fell down, we retreated 14:35:29 9 A Approximately. 14:37:30
10 back. 14:35:35 10 Q Did you see any backup take anything out of his 14:37:31
11 Q What was it? 14:35:35 11 hand? 14:37:35
12 A I didn't see it that good. 14:35:36 12 A No. 14:37:37
13 Q Who retrieved it? 14:35:40 13 Q You read this murder book, correct? 14:37:41
14 A We retreated. We went back. 14:35:42 14 A I glanced through it, yes, sir. 14:37:44
15 Q Oh, you retreated. 14:35:44 15 Q You said you read it. That's what you told me. Do 14:37:46
16 A Yes, and we're holding him at gunpoint from a 14:35:46 16 you see anywhere in this murder book where someone took 14:37:49
17 distance. 14:35:50 17 something out of his hand after he was mortally wounded by 14:37:52
18 Q But something was in his hand when he was on the 14:35:50 18 you? 14:37:55
19 ground; is that correct? 14:35:52 19 A I glanced through some parts. I'm not sure what 14:37:59
20 A He was moving, yes, sir. 14:35:52 20 was there. 14:38:04
21 Q Do you speak English? I hate to jump down your 14:35:55 21 Q What was your understanding as to what was taken 14:38:04
22 throat. I didn't ask whether or not he was moving. I'm 14:36:00 22 out of his hand? You said something was in his hand. What 14:38:08
23 asking a specific question. What did he have in his hand 14:36:03 23 is your understanding of what was taken out of his hand 14:38:11
24 when he was on the ground -- 14:36:07 24 after you mortally wounded him? 14:38:14
25 A I'm not sure. 25 A I didn't ask, sir. We left the scene right away.
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1 Q Would it surprise you if I told you that nothing 14:38:33 1 roll-out team of the District Attorney's office? 14:40:43
2 was in his hands? That would surprise you? 14:38:36 2 A I heard of them, sir. 14:40:47
3 A I don't know. 14:38:50 3 Q What do you think they do? What does OIS stand 14:40:49
4 Q What's that? 14:38:52 4 for? 14:40:54
5 A I don't know what was recovered from his hands, 14:38:56 5 A I'm not sure, sir. 14:40:55
6 sir. 14:38:59 6 Q It stands for Officer Involved Shooting. Isn't it 14:40:56
7 Q I'm going to represent to you that nothing was 14:39:00 7 true that an experienced Deputy District Attorney rolls out 14:41:01
8 recovered from his hands. Okay? Does that surprise you? 14:39:02 8 to the scene of any police shooting? Isn't that true? You 14:41:06
9 A No. 14:39:09 9 know that. 14:41:09
10 Q No? That's because you are lying about something 14:39:12 10 A I know a lot of teams roll out. 14:41:11
11 being in his hands, correct? 14:39:17 11 Q Yes. Why do you think they roll out? 14:41:15
12 MR. DAY: Objection; argumentative, no foundation. 14:39:19 12 MR. DAY: Objection; calls for speculation. 14:41:17
14 Q You are not telling the truth -- 14:39:22 14 Q If you know. 14:41:19
15 MR. DAY: Same objection. 14:39:23 15 A To gather information, anything that has to do with 14:41:20
16 BY MR. SWEENEY: 14:39:24 16 this case. 14:41:26
17 Q About what was in his hands, about something being 14:39:24 17 Q Right. With an eye on prosecuting the shooter, 14:41:28
18 in his hands, correct? 14:39:28 18 correct? 14:41:32
19 A No. 14:39:30 19 MR. DAY: No foundation, argumentive. 14:41:33
20 Q You were telling the truth? 14:39:32 20 BY MR. SWEENEY: 14:41:35
21 A Yes, sir. 14:39:33 21 Q The District Attorney is a prosecuting agency, 14:41:37
22 Q You were not telling the truth because you knew 14:39:34 22 right? 14:41:39
23 that you were in a world of trouble, correct? 14:39:37 23 A Right; yes, sir. 14:41:40
24 MR. DAY: Objection; argumentative, no foundation. 14:39:40 24 Q Donta Taylor is dead, correct? They can't be 14:41:42
25 THE WITNESS: I'm telling the truth. 25 prosecuting him, right?
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2 Q You knew that you could be in a lot of trouble for 14:39:45 2 Q So they had to be looking at you, true? Yes? 14:41:48
3 taking another person's life; isn't that true? 14:39:48 3 MR. DAY: Assumes facts not in evidence. 14:41:54
4 MR. DAY: Objection; argumentative, no foundation, 14:39:52 4 THE WITNESS: Possibly. 14:41:56
5 immaterial. 14:39:54 5 BY MR. SWEENEY: 14:41:57
6 MR. SWEENEY: Okay. I'm sorry. What? 14:39:55 6 Q Possibly? Someone who shot and took somebody's 14:41:57
7 MR. DAY: Immaterial. 14:39:57 7 life, they look at the shooter. You know that, don't you? 14:42:02
8 BY MR. SWEENEY: 14:39:59 8 That was on your mind, wasn't it? 14:42:08
9 Q You knew that there was a possibility that you 14:40:00 9 MR. DAY: Argumentative. 14:42:10
10 could be charged with a crime, correct? 14:40:05 10 BY MR. SWEENEY: 14:42:12
11 MR. DAY: Same objection. 14:40:10 11 Q That was on your mind, wasn't it? 14:42:13
12 THE WITNESS: I'm telling you the truth, sir. 14:40:16 12 MR. DAY: Vague as to time. 14:42:15
13 BY MR. SWEENEY: 14:40:18 13 THE WITNESS: No. 14:42:16
14 Q That wasn't my question, Deputy. You knew that you 14:40:19 14 MR. DAY: Argumentive. 14:42:17
15 could be charged with a crime, correct? 14:40:22 15 BY MR. SWEENEY: 14:42:18
16 MR. DAY: When? 14:40:24 16 Q After the shooting, it was on your mind that you 14:42:18
17 MR. SWEENEY: You know when. 14:40:26 17 could be prosecuted, correct? 14:42:21
18 MR. DAY: No, I don't know when. Vague. 14:40:27 18 A No. 14:42:23
19 BY MR. SWEENEY: 14:40:29 19 Q No. It was on your mind, and that's why you made 14:42:26
20 Q After you shot and killed Donta Taylor. 14:40:29 20 up the story that there was something in his hand. Isn't 14:42:30
21 MR. DAY: Well, no foundation, calls for speculation, 14:40:34 21 that true? 14:42:34
22 vague as to time. 14:40:36 22 MR. DAY: Argumentative, no foundation, immaterial. 14:42:34
23 THE WITNESS: No, sir. 14:40:38 23 THE WITNESS: No. 14:42:37
25 Q You did not know that? Have you heard of the OIS 25 Q Because you know, you were trained, that the only
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1 time that you can use deadly force is if deadly force is 14:42:40 1 BY MR. SWEENEY: 14:45:07
2 threatened upon you or a third person, true? You know that, 14:42:46 2 Q I'm talking about you. 14:45:07
3 don't you? 14:42:50 3 A No, I did not. 14:45:09
4 A Yes. 14:42:51 4 Q You never saw Donta Taylor fire at you or your 14:45:37
5 Q You knew from your POST learning domain that you 14:42:53 5 partner that evening, did you? 14:45:41
6 could be charged with murder, possibly, not in this 14:42:57 6 MR. DAY: Objection; compound. 14:45:46
7 situation but if you shoot someone without justification, 14:43:02 7 THE WITNESS: He didn't fire at me. 14:45:50
8 correct? 14:43:06 8 BY MR. SWEENEY: 14:45:53
9 A Yes, sir. 14:43:07 9 Q Did you ever see him fire at your partner? 14:45:53
10 Q You don't want to go to prison, do you? Nobody 14:43:08 10 A No. 14:45:55
11 wants to go to prison, do they? 14:43:13 11 Q Your partner never told you that he took incoming, 14:45:57
12 MR. DAY: Objection; irrelevant, immaterial. 14:43:15 12 did he, from Donta Taylor, did he? 14:46:01
13 BY MR. SWEENEY: 14:43:17 13 A Not that I remember, no. 14:46:03
14 Q You didn't want to go to prison, did you? 14:43:17 14 Q Not that you remember. Come on, man. You know 14:46:04
15 MR. DAY: Same objection. 14:43:20 15 that your partner never told you that he had been shot at by 14:46:07
16 BY MR. SWEENEY: 14:43:23 16 Donta Taylor. You know that. 14:46:13
17 Q Yes or no. 14:43:23 17 A No, he didn't. 14:46:16
18 A No. 14:43:27 18 Q So why did you answer, "Not that I can remember?" 14:46:18
19 Q Were you ever out of radio contact with the command 14:43:39 19 A Not that I -- I would remember something like that. 14:46:20
20 center during this pursuit? 14:43:43 20 Q Your personal opinion -- I want your opinion now. 14:46:36
21 A There was a lot of radio traffic, sir, but we were 14:43:50 21 I didn't want your opinion before. Now I want your opinion. 14:46:42
22 in contact. 14:43:54 22 What happened to the gun? 14:46:46
23 Q I'm talking about you. Did you ever -- strike 14:43:55 23 A My opinion is he had plenty of chance and time to 14:46:55
24 that. 14:43:58 24 discard the weapon. 14:47:04
25 Did you have -- you said you had your handheld -- 25 Q Well --
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1 your radio mounted to your Sam Browne, right? 14:44:03 1 A During the pursuit. 14:47:11
2 A Correct. 14:44:06 2 Q Plenty of time. So he discarded it, correct? 14:47:14
3 Q Did you have one of those mikes that attaches to 14:44:07 3 A Correct. 14:47:15
4 your chest? 14:44:10 4 Q Five seconds before he falls on the ground dead, 14:47:21
5 A Yes. 14:44:11 5 you saw something in his hands and him pointing in a combat 14:47:24
6 Q Okay. Were you communicating through that? 14:44:12 6 stance, correct? 14:47:29
7 A I was communicating through that, yes. 14:44:17 7 A Correct. 14:47:30
8 Q Do you have to depress that to communicate, or can 14:44:20 8 Q Did you instruct the detectives or whoever was 14:47:35
9 you press a button and just you have an open Mike? 14:44:23 9 searching for the weapon to look in that area of Arbutus and 14:47:39
10 A Well, at the time it was open -- kind of like an 14:44:27 10 the wash for this gun? 14:47:46
11 open mike. 14:44:30 11 A Yes. 14:47:50
12 Q So there is a button you can press and you don't 14:44:31 12 Q So you believe you hit him with those 10 to 12 14:47:56
13 have to press it to talk and then take it off and then press 14:44:34 13 rounds, correct? 14:48:01
14 it to talk again? 14:44:38 14 A Correct. 14:48:02
15 A Oh, it has a little button so you can transmit, 14:44:39 15 Q So is it your belief that sometime between the time 14:48:05
16 yes. 14:44:43 16 that you hit him and the time that he came back out five 14:48:10
17 Q But it doesn't stay open at all times so what you 14:44:43 17 seconds later and fell dead or mortally wounded he hid that 14:48:15
18 had to do was you had to press the button to communicate, 14:44:46 18 gun; correct? 14:48:20
19 correct? 14:44:50 19 MR. DAY: Objection; misstates the witness' testimony. 14:48:24
21 Q You weren't doing that as you were chasing after 14:44:51 21 Q I'm asking. 14:48:27
22 Donta Taylor and shooting him, were you? 14:44:56 22 A My opinion is that he discarded it before that 14:48:35
23 MR. DAY: Objection; assumes facts not in evidence. 14:44:58 23 possibly. 14:48:40
24 THE WITNESS: After the shooting, my partner put out 14:45:04 24 Q You say he had an object in his hand, and no object 14:48:43
25 radio traffic. 25 was found around him, so, and you saw him -- you claim you
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1 saw him at the beginning of the chase with a gun so what 14:48:55 1 BY MR. SWEENEY: 15:05:34
2 else could it be when he pointed at you with something in 14:49:00 2 Q Are you aware of any witness, civilian witness, who 15:05:35
3 his hand? What else could it be? 14:49:03 3 saw Donta Taylor running with a gun? 15:05:38
4 A A gun, I believe. 14:49:07 4 A No, sir. 15:05:45
5 Q A gun, a gun. So it had to be -- so he had to get 14:49:10 5 Q Are you aware of any civilian witnesses who said 15:05:50
6 rid of it within five seconds in that confined area with 14:49:13 6 that they saw him running and he did not have a gun in his 15:05:52
7 your partner looking at him because he shot at him in the 14:49:20 7 hand? 15:05:56
8 opposite direction, correct? 14:49:23 8 A No, sir. 15:05:59
9 A On Arbutus. 14:49:25 9 MR. SWEENEY: Do you have anything else? 15:06:04
10 Q Yes. Okay. 14:49:29 10 MS. HOIKKA: No. 15:06:05
11 MR. SWEENEY: Let's take a quick break. 3:00 o'clock we 14:49:50 11 MR. SWEENEY: Nothing further. 15:06:06
12 will come back. Is that okay? 14:49:53 12 EXAMINATION 15:06:09
13 THE VIDEOGRAPHER: We're going off the record. The time 14:49:53 13 BY MR. DAY: 15:06:09
14 is 2:49 PM. 14:49:55 14 Q Deputy, I just have a couple of questions I would 15:06:10
15 (A break was taken in the proceedings.) 14:49:57 15 like to ask you to try to clear up some testimony you gave. 15:06:13
16 THE VIDEOGRAPHER: We are back on the record. The time 15:03:48 16 Let me have marked as Defendant's Exhibit 1 -- 15:06:20
17 is 3:04 PM. 15:04:06 17 Counsel, I don't have an extra copy, but it's in the 15:06:31
18 BY MR. SWEENEY: 15:04:09 18 homicide book. 15:06:35
19 Q I'm going to go back and ask you one question, a 15:04:09 19 MR. SWEENEY: What is that? 15:06:37
20 couple of questions, and then I'm finished after that. 15:04:12 20 MR. DAY: This is a map of the area. It is page 154 15:06:39
21 How many inches is your tattoo on your leg, how 15:04:16 21 from the homicide book bearing Bates stamp No. DEF0158. 15:06:41
22 many inches tall? 15:04:24 22 (Defendant's Exhibit No. 1 was marked for 15:06:41
23 A Five or six. 15:04:28 23 identification, a copy of which is attached 15:06:41
24 Q Five or six inches? 15:04:30 24 hereto.) 15:06:47
25 A (Witness nods head up and down.) 25 ///
Page 126 Page 128

1 Q Okay. How wide? 15:04:33 1 BY MR. DAY: 15:06:47
2 A Another five or six. 15:04:37 2 Q Deputy, you were being asked some questions about 15:06:48
3 Q Another five or six. Pretty big then. Where 15:04:38 3 the encounter you had with Mr. Taylor when you took shots at 15:06:52
4 exactly is it on your leg? Can you show us -- not by 15:04:42 4 him. Do you recall those questions? 15:06:57
5 pulling your pants up because your lawyer doesn't want us to 15:04:47 5 A Yes. 15:06:59
6 do that -- can you show us on your leg by just standing up 15:04:51 6 Q Okay. When you had the shot -- when you took the 15:07:02
7 and point to your pants where it is? 15:04:54 7 shot to Mr. Taylor, you said that you were facing him, he 15:07:04
8 A (Witness Complies.) 15:05:00 8 was facing you and this was on the dirt path, correct? 15:07:08
9 Q You can lift your leg up so the camera can see it. 15:05:04 9 A Correct. 15:07:12
10 A Here. 15:05:08 10 Q Okay. 15:07:15
11 Q Okay. On your right leg. 15:05:08 11 MR. SWEENEY: What Bates stamp is that? 15:07:15
12 A Yes, sir. 15:05:10 12 MR. DAY: Bates stamp DEF0158. 15:07:16
13 Q For the record, you pointed to the outside of your 15:05:11 13 MR. SWEENEY: C what? 15:07:20
14 calf muscle. 15:05:15 14 MR. DAY: DEF0158. 15:07:21
15 A Correct. 15:05:16 15 MR. SWEENEY: D-E-F? 15:07:24
16 Q On the side. 15:05:17 16 MR. DAY: Yes, sir; 0158. 15:07:24
17 A Correct. 15:05:18 17 MR. SWEENEY: Okay. 15:07:29
18 Q Is that correct? 15:05:18 18 MR. DAY: Okay. 15:07:30
19 A Correct. 15:05:22 19 BY MR. DAY: 15:07:31
20 Q Were you disciplined by the department after the 15:05:24 20 Q So that would be right about here on the dirt path, 15:07:32
21 Donta Taylor shooting for any reason? 15:05:27 21 correct? 15:07:36
22 MR. DAY: I'm going to object to the question. 15:05:29 22 A Correct. 15:07:36
23 MR. SWEENEY: Same objection? 15:05:30 23 Q Okay. Counsel asked you questions and said that -- 15:07:38
24 MR. DAY: Same objection. 15:05:32 24 in response to questions you said that you took 15:07:45
25 /// 25 approximately 10 to 12 shots at Mr. Taylor; is that correct?
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1 A That is correct. 15:07:51 1 Q Okay. When did you become aware that it was Deputy 15:09:36
2 Q Okay. What happened after you took those shots at 15:07:52 2 Orrego who took the shots? 15:09:44
3 Mr. Taylor? 15:07:56 3 A As soon as I heard him giving commands. 15:09:45
4 A He ran and went back westbound on Arbutus. 15:07:58 4 Q So you heard Deputy Orrego give commands. Were 15:09:48
5 Q Okay. So let me make it clear. When in response 15:08:01 5 those commands to Mr. Taylor? 15:09:52
6 to the shots that you took at Mr. Taylor, did he fall down? 15:08:04 6 A Commands to Mr. Taylor. 15:09:53
7 A No. 15:08:07 7 Q Okay. Do you recall what those commands were? 15:09:55
8 Q He didn't fall down? 15:08:07 8 A Let me see your hands. 15:09:59
9 A No. 15:08:09 9 Q Okay. Did you hear Mr. Taylor say anything in 15:10:00
10 Q Okay. So he ran -- he ran down the dirt path? 15:08:09 10 response? 15:10:03
11 A Down the dirt path. 15:08:13 11 A No. 15:10:03
12 Q Toward Arbutus? 15:08:15 12 Q Okay. And was there time that evening that you 15:10:04
13 A Towards Arbutus. 15:08:16 13 eventually went over to where Deputy Orrego was with 15:10:10
14 Q Okay. Did he turn then on Arbutus? 15:08:17 14 Mr. Taylor? 15:10:15
15 A Yes. 15:08:19 15 A Not that night, no. 15:10:17
16 Q Okay. So he turned westbound on Arbutus? 15:08:20 16 Q Okay. Why was it that you did not go over to that 15:10:19
17 A Westbound on Arbutus. 15:08:23 17 area on Arbutus? 15:10:21
18 Q Okay. Did you follow him? 15:08:25 18 A Because we were removed from the scene. 15:10:23
19 A No. 15:08:26 19 Q By whom? 15:10:25
20 Q You didn't follow him? 15:08:27 20 A By our sergeants. 15:10:26
21 A No. 15:08:28 21 Q Okay. So you had stayed on the dirt path until you 15:10:28
22 Q You stayed on the dirt path? 15:08:28 22 were removed by sergeants. 15:10:31
23 A Yes. 15:08:30 23 A Correct. 15:10:33
24 Q Okay. Could you see him turn on Arbutus? 15:08:34 24 Q Why were you removed by sergeants? 15:10:33
25 A Yes. 25 A That is protocol, yes.
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1 Q Okay. Could you see how far he turned if he went 15:08:38 1 Q Okay. When there is a shooting? 15:10:39
2 down on Arbutus or not, or was he out of your sight then? 15:08:42 2 A When there is a shooting, yes. 15:10:40
3 A He was out of my sight. 15:08:45 3 Q Okay. Later that evening -- let me strike that. 15:10:42
4 Q Okay. At the time, did you know what happened to 15:08:49 4 When were you first told by Deputy Orrego what had 15:10:45
5 him on Arbutus, or were you aware of anything that was 15:08:51 5 happened on Arbutus? 15:10:49
6 happening on Arbutus? 15:08:54 6 A After, after -- I believe after our interview with 15:10:51
7 A Well, I heard some shots. 15:08:56 7 homicide. 15:11:02
8 Q Okay. Do you know who was taking those shots? 15:08:58 8 Q Your respective interviews with homicide? 15:11:02
9 A It wasn't clear. 15:09:01 9 A Yes. 15:11:05
10 Q Okay. You don't know who was taking the shots. 15:09:03 10 Q Okay. Did Deputy Orrego tell you whether 15:11:06
11 A No. 15:09:05 11 Mr. Taylor ever made any verbal response to him, to the 15:11:27
12 Q Okay. That evening, did you later become aware of 15:09:05 12 verbal commands he gave him? 15:11:32
13 who took those shots? 15:09:08 13 A No, we didn't. 15:11:35
14 A Yes. 15:09:10 14 Q He never said anything? 15:11:37
15 Q Who took those shots? 15:09:11 15 A He never said anything to me. 15:11:38
16 A Orrego. 15:09:12 16 Q So any information you received in that regard 15:11:39
17 Q Your partner? 15:09:13 17 would have come from reading the homicide book? 15:11:42
18 A My partner, Deputy Orrego. 15:09:14 18 A Yes, it is. 15:11:46
19 Q After you heard those shots, did you make any 15:09:17 19 MR. DAY: Okay. I have no further questions. 15:11:47
20 movement toward Arbutus? 15:09:20 20 EXAMINATION 15:11:47
21 A No. 15:09:22 21 BY MR. SWEENEY: 15:11:48
22 Q Okay. You stayed where you were. 15:09:23 22 Q It remains that you heard Deputy Orrego's shots 15:11:48
23 A Yes. 15:09:24 23 three seconds after you had fired your shots, correct? 15:11:56
24 Q Okay. Do you recall how many shots you heard? 15:09:25 24 A Correct. 15:12:00
25 A About three or four. 25 Q And you saw Donta Taylor come back out Arbutus
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1 going eastbound and fall on the dirt path five seconds after 15:12:10
2 you fired your last shot, correct? 15:12:16
3 A Three seconds, yes, after Orrego shot, he fell 15:12:20
4 down. 15:12:33
5 Q Yes. Okay. No further questions. 15:12:33
6 MR. DAY: Okay. 15:12:36
7 MR. SWEENEY: Thank you. Do you have any questions? 15:12:37
8 MS. HOIKKA: No. 15:12:40
9 MR. SWEENEY: Okay. 15:12:41
10 I'll offer forth the following stipulation: That 15:12:42
11 the court reporter be relieved of her duty under the Code to 15:12:44
12 maintain control of the original transcript; 15:12:51
13 That she mail the original transcript to Mr. Day's 15:12:54
14 office where he can transmit it to the deponent who will 15:13:00
15 then read it over, make any changes he deems necessary, sign 15:13:07
16 it under penalty of perjury and return it to Mr. Day. 15:13:10
17 Mr. Day can maintain the original until the time of 15:13:18
18 trial when it is lodged in the court; 15:13:25
19 That Mr. Day can notify my office within 14 days of 15:13:31
20 the Deputy's signing of the transcript whether or not there 15:13:44
21 are any changes; 15:13:48
22 That if the original becomes unavailable either 15:13:56
23 through destruction, loss or otherwise, that a certified 15:14:04
24 copy can be used as if it were an original. 15:14:08
25 Let's set a time frame. He can read it over within
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1 two weeks of -- 15:14:17
2 MR. DAY: Our receipt? 15:14:21
3 MR. SWEENEY: Of your receipt. And then what did I say? 15:14:22
4 MR. DAY: You said 14 days after. 15:14:28
5 MR. SWEENEY: Fourteen more days to notify us of any 15:14:30
6 changes. 15:14:33
7 MR. DAY: So stipulated. 15:14:33
8 MR. SWEENEY: Thank you, Deputy, for coming. 15:14:35
9 THE VIDEOGRAPHER: This is the end of the video 15:14:39
10 deposition of Deputy Samuel Aldama. We are going off the 15:14:41
11 record. The time is 3:14 PM. 15:14:46
12 (The deposition was concluded at 3:14 PM.) 15:14:46
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A Angeles 1:2,10,10 2:2,10 arm 39:13,15 47:7,21 B 4:9 blocks 62:24 75:19 83:6
A-L-D-A-M-A 6:5 2:10 3:17 5:12 6:8 10:5 arms 39:6 back 13:13 22:8 25:23 body 40:16 45:21 111:22
A-R-B-U-T-U-S 94:21 10:6,23 12:21 13:9 arrest 17:10 27:9 28:21 36:15,18,20 45:17 book 85:21 88:7,8,8
A-S-P 33:21 14:25 18:18 19:17,21 33:14 34:10,19 37:12 48:12,14 60:7 71:15,17 104:19 111:5 117:13
ability 9:20 24:21 26:15 45:4 60:4 65:14,17,20,24 72:25 87:5 88:23 90:3 117:16 128:18,21
able 8:18 67:16 angle 91:4 66:25 95:25 97:25 101:7 133:17
abracadabra 87:2,4 animosity 71:8 arrested 18:12 35:13,21 102:9 103:3 107:24 booklet 7:14
abstract 28:25 29:2 68:3 animus 69:20,23 35:24 36:10 58:1 109:14 112:19 113:10 bookman 62:6,7 74:8,9
AC052F6 1:25 answer 7:7 8:14 16:10 arrestee 20:4 72:9 114:1 115:10,14 74:11 78:15
Academy 10:21,22 11:21 22:1 24:8 27:5 39:12 arrestees 18:11,15 116:25 125:16 126:12 bookmark 87:3,5
11:22,24,25 12:2,17,19 42:8 43:8 48:23,24,25 arresting 29:9 32:6,12 126:16,19 130:4 Boulevard 3:10,16
12:20 14:8,12,25 15:7 57:11 59:13 63:12 33:10 34:2,5,12 66:7 133:25 Boy 38:13 39:1 42:10
15:17 17:11,13 19:7 66:19 67:8,15 70:17,20 arrive 30:12 back-up 90:1,5 Boys 11:10,14 12:2 38:9
21:20,23 25:3,24 79:7 92:24 104:22 arrived 63:7 background 9:24 11:17 38:24
access 19:3 106:15,17 113:15 arrives 117:8 26:18 brace 36:15,18,18,20
accident 8:5 116:20 124:18 articulated 85:9 backup 110:13 117:8,10 brand 80:13
accomplished 20:2 answered 32:24 33:1 artist 48:11 49:3,11,16 bad 67:17,19,21 68:2 Brazil 75:21 92:11,14,16
accord 14:22 41:15 49:18 59:18 64:8 50:20 baggy 76:20,22 92:17,20
accuse 55:16 56:23 answers 8:16 aside 69:12 Baker 5:4,15 break 45:12,16 71:11,14
57:13,16 anybody 7:16 82:15 asked 41:15 49:18 59:18 ball 66:25 71:22,23 72:17,23
accused 56:25 57:1 117:6 64:8 78:8 79:2,10 balls 96:4 126:11,15
acting 25:16 anyway 78:13,19,25 92:9 81:17 82:1 84:19 86:11 band 76:25 77:2 briefly 60:8 88:14 112:6
action 5:6 apologize 115:6 86:16 92:24 93:6 94:4 barrel 44:20,23 81:2 broke 14:20
activities 64:24 appeared 110:5 129:2,23 basically 86:17 brought 26:8
activity 64:4 application 13:4,18,21 asking 8:22 17:11 19:9,9 basis 16:9 17:20,21 Browne 89:3 123:1
actual 30:14 apply 12:23,25 19:12 21:11,19 23:13 basketball 76:24 85:24 bullets 104:5,15 105:20
Ad 1:6 2:6 appointment 14:9 28:14,15,25 42:2 78:22 Bates 4:14,16 128:21 business 92:3
administer 5:21 apprehend 98:14 86:15 87:14 114:6 129:11,12 businesses 92:2
admonition 14:19 57:12 apprehension 60:18 115:23 116:14 125:21 Bates-stamped 88:13 button 89:16 123:9,12,15
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advice 52:9 approach 36:24,25 assigned 10:24 27:20,22 baton 33:18,20 89:7
affairs 54:4 110:11,16 73:7,13 bearing 128:21 C
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34:6 36:8 69:20,24 approaching 92:11 assistant 10:25 30:10 BECKS 3:15 calf 127:14
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afternoon 73:3,4 Arbutus 75:21 93:13,15 assumes 48:1 53:13,16 behalf 2:16 5:14,19 33:11 34:24 35:7,9,12
agency 12:24 13:3 94:20,22 95:10 97:16 53:21 78:20 121:3 behavior 54:23 52:21 57:19 58:7,9
120:21 97:21,22 98:16,17,24 123:23 beings 70:7 called 38:24 64:13
aggressive 37:6,9,13 98:25 99:1 100:5,14 Assuming 24:12 belief 125:15 calls 15:3 18:7 19:23
agility 13:23 14:1,4 101:8 102:9,16 103:3,7 Atkinson 5:4,15 believe 12:8,11,25 13:23 22:21 41:25 42:6 43:5
ago 8:24,25 23:21 103:11,13 104:24 ATKINSON-BAKER 1:21 14:17 30:2,6,10 31:2 43:8,13 54:5 68:21
ahead 22:1 42:18 72:1 105:2,19 106:1 107:18 attached 87:24 128:23 37:11 47:1 52:12 60:11 72:15 78:8 81:25 82:8
78:5 109:15 125:9 126:9 attaches 6:25 123:3 63:1,18 65:2,5 77:24 104:17 109:9 119:21
aim 108:20 130:4,12,13,14,16,17 attempt 31:15 87:9 91:13 92:4 102:23 120:12
Air 90:17 130:24 131:2,5,6,20 attempted 66:11 125:12 126:4 133:6 camera 127:9
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alcohol 9:19 59:2 31:13,21 37:8 59:23 attention 38:15 belong 45:4 captain 53:8 54:13 58:16
Aldama 1:16 2:16 4:3,13 74:19,20,23 75:1,3 attorney 5:7 120:7,21 belt 89:5 58:19
5:13,22 6:5 26:21,24 76:15 78:7 79:16 80:7 Attorney's 120:1 best 9:6,17,20 16:7 car 30:15 37:3,6,10,13
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Aldama's 27:2 85:23,25 86:1,4 94:8 August 4:14 73:5 74:12 Beverly 1:17 2:17,18 3:5 59:10,14,17 61:22 62:5
alleged 72:13 105:25 110:23 125:9 83:23 3:6,11 5:1,10,10 62:8,16 63:3,3 68:8
allow 26:23 126:6 128:20 132:17 authority 25:10,12,18 big 127:3 75:4 79:17,17 80:2
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29:9 34:7 36:8 82:20 argumentative 20:12 automotive 10:3,25 11:2 black 29:25 31:5 32:4,6,8 CARL 1:5 2:5
84:6 24:18 42:11 49:18 Avenue 31:12,13 35:6,19 52:1 74:4 CARMEN 1:5 2:5
Americans 69:21,24 51:15 64:5 67:9,11,15 award 43:10 82:25 83:22 84:2 85:23 carry 64:23,24 90:1,5
70:4,5,9,13,24 71:3 67:22 69:8 83:18,25 awarded 43:11 blacks 71:9 case 1:9 2:9 5:11,11 7:23
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Andrew 1:4 2:4 5:11 6:7 121:14 B block 60:21 63:1 82:6 cash 46:21,22
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casual 36:25 37:1 82:17 combat 125:5 context 18:23 country 48:8,9 85:14,18,19,21 86:23
84:12 86:3,6 come 26:13 30:1 54:3 continued 94:22 97:4 County 1:2,10,10 2:2,10 101:4 104:8,10,17
category 15:10 74:12 81:6 107:24 control 134:12 2:10 5:12 6:8 12:21,25 106:15 108:4,6 109:9
Caucasian 28:16 110:13 124:14 126:12 controlled 83:5,6,9,11 13:6,10,11,13 14:6,10 112:15 113:2,12 114:6
caught 60:14 133:17,25 convenient 45:11 14:25 18:18 19:18,21 114:9 115:5 116:11,17
caused 78:6 comes 85:25 89:16 conversation 82:17 24:21 26:15 45:5 73:12 118:12,15,24 119:4,7
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Cedar 82:6 83:11 coming 40:25 44:20,23 copy 4:13,16 87:24 couple 71:19 116:25 120:12,19 121:3,9,12
center 23:8 108:21 78:7 100:4,5 103:6,7 128:17,23 134:24 126:20 128:14 121:14,22 122:12,15
122:20 103:13,16 104:23 cordial 86:18 course 29:8 64:23 123:23 124:6 125:19
certain 26:20 105:25 107:21 109:4,8 corner 75:10 107:24 court 1:1,21 2:1 5:14,20 127:22,24 128:13,20
certainly 13:25 109:11 135:8 correct 6:9 8:24,25 11:7 6:21,24 8:17 26:19,23 129:1,12,14,16,18,19
certified 134:23 command 23:2,4 94:16 11:8 12:3,4,6,7,9,17,18 52:5 66:1 76:13 87:19 133:19 134:6,16,17,19
chain-link 102:21 122:19 12:21,22 14:2,3 15:18 87:21 134:11,18 135:2,4,7
chance 6:13 7:12,18 commander 19:4 16:3 17:16,18,22,23 courtesy 14:23 Day's 134:13
81:14 85:8 124:23 commands 132:3,4,5,6,7 18:1,1 19:7,7,8,19,20 cover 18:24,25 days 134:19 135:4,5
change 7:24 8:3,3,12 133:12 20:24,25 22:20 25:8,9 covered 117:2 dead 114:8 120:24 125:4
11:20 commencing 2:18 26:9,10 30:8,12,16 Covina 59:22,25 125:17
changed 8:12 83:14 comment 7:24 71:18 31:1,6,9,10 32:2,3,4,5 CPT 44:14 dead-end 95:1,10,15
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May 16, 2018
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May 16, 2018
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35:10,12 47:21,23,23 middle 89:6 91:8 102:16 nods 25:14 37:2,21 44:5 29:25 30:14,23 31:19 128:20
66:20,23 103:15 mike 94:8 123:9,11 126:25 32:2 36:6,23 41:8 pages 4:14
108:17 109:19 110:13 mikes 123:3 non-amorous 56:24 44:12,15 45:10 46:15 paid 46:19
look 7:13 121:7 125:9 military 12:15 non-material 8:3 47:16 48:17,25 49:1 pants 76:23 127:5,7
looked 28:12 80:23 mind 9:16 74:25 78:25 normally 64:23 50:6 52:11,25 53:10,12 paperwork 14:1
looking 8:17 74:25 77:13 110:17 121:8,11,16,19 north 27:24 75:11 92:14 54:3,17 56:8,23 60:6 parallel 91:5,6
84:25 92:6 112:7,8 mini 97:17 92:17,18,20 93:9 98:24 60:20 61:11,14,18 62:6 park 11:11,13 91:4
115:1 121:2 126:7 Minor 1:5,6,6 2:5,6,6 98:25 100:14 62:22,24 63:2 67:12 parking 45:8
looks 80:15 81:7 minute 110:15 north/south 99:16 68:5 69:19 70:11 71:8 parlor 47:3,5,8
Los 1:2,10,10 2:2,10,10 minutes 35:8,8,14 northbound 60:12 75:14 71:20 72:5,19 73:16 parole 79:6 84:13,17,20
3:17 5:12 6:8 10:5,6,23 mischaracterizes 83:17 76:2 93:10 95:2,14 74:3 75:6,13,25 76:23 93:2
12:21 13:9 14:25 18:18 113:2,13 116:11,17 101:12 107:20,25 77:2 78:4 79:5 80:21 part 32:12 73:9 75:8
19:17,21 24:21 26:15 misstates 78:21 79:1 116:25 80:23 81:13 82:15,18 part-time 11:10
45:4 82:22 83:17,25 112:15 notary 5:5 83:12 84:5 87:2,13 particular 43:21 73:8
lose 22:7 23:12,13 113:2,12 116:11 note 19:5 88:10,12,14,20,22 89:2 74:24 83:3,22 85:10,12
losing 23:2 125:19 notice 90:24 106:12 89:20 91:2,10,20 92:18 parties 5:7,16
loss 134:23 mistake 8:11 noticed 75:6,20,22 92:11 92:21 93:8,16,18,23 partner 21:7,9,9 22:16
lost 62:18,20 99:9 misunderstood 71:7 92:15 106:13,18 94:19,24 95:22 96:10 22:17,18 29:22 34:15
lot 21:5 52:3 78:8 119:2 72:2 91:19 notify 134:19 135:5 96:16 97:6,15,18 98:10 38:4 55:10,11 59:7
120:10 122:21 month 7:14 23:21 31:23 number 4:12 5:11 98:16 99:5,9 100:2,4,6 61:24 62:14 74:6 77:7
loud 8:15 55:17,19,20 31:24,25 42:20 57:24 numbers 43:25 101:2,7 103:15 104:21 77:12,12,18,21 93:21
56:17 months 11:6,7,15 23:21 nylon 89:5 105:3,15 107:19 108:2 93:22 94:4 97:7,17
lunch 72:23 23:22 66:6,11 67:3,5 110:1 113:5,8 118:8 98:4 99:5 100:17 103:8
lying 118:10 morally 25:7 O 119:6 123:6 126:10,12 105:5,10,16 110:11,21
Lynwood 10:10 morning 5:3 56:11 o'clock 126:11 127:1,11 129:6,10,17 110:25 112:1 123:24
mortally 116:15 117:17 oath 5:21 6:21,23 18:14 129:18,23 130:2,5,10 124:5,9,11,15 126:7
M 117:24 125:17 object 26:18 110:3,5,6 130:14,16,18,24 131:1 131:17,18
M&P-9mm 89:11 motion 26:6,9,19 67:1 111:8,19,21 113:7,10 131:4,8,10,12,22,24 partner's 88:10 92:9
magazine 89:6 mounted 123:1 125:24,24 127:22 132:1,7,9,12,16,21 103:17 104:7,16,23
magazines 89:7 move 92:9 objection 15:3 19:23 133:1,3,10,19 134:5,6 105:1
mail 134:13 movement 131:20 20:12 21:25 22:21 24:7 134:9 parts 117:19
main 90:6 moving 108:23,25 109:7 24:18,23 37:17 39:8 old 40:3,4 pass 14:4 15:22 16:23
maintain 134:12,17 114:22,23 115:20,22 43:5 49:18 50:8 51:15 OLIVER 1:5,7 2:5,7 passed 17:18
making 18:6,7 52:5 116:16 54:5 59:11 64:5,8 once 47:20 63:2 97:2 Patch 94:2,4,9,11,13
male 28:9,11 29:9,25 murder 66:11 82:15 88:8 66:13,17 68:21 69:8 ones 45:20 path 95:1,2,4,5 96:8,9
31:4,5 32:4,6,8 35:19 104:19 111:5 117:13 72:15 78:20 83:17 85:2 oOo-- 5:2 97:4,11,19 98:23 99:8
36:8 48:15,17,18,20,20 117:16 122:6 104:17 109:9 113:2,12 open 37:10,14 85:21 99:21 100:3,11 102:17
man 66:15 83:23 85:23 Murders 82:4 113:22 116:11,17 94:8 123:9,10,11,17 102:17 104:3 106:9
116:15 124:14 muscle 127:14 118:12,15,24 119:4,11 opening 79:11,13 93:7 107:24 108:4,6 112:19
manner 37:7,9,13 56:24 120:12 122:12,15 opinion 104:17 113:19 117:1 129:8,20 130:10
63:19 86:18,21 N 123:23 124:6 125:19 113:21,22,23 124:20 130:11,22 132:21
manual 19:2 N 3:1 4:1 127:23,24 124:20,21,21,23 134:1
map 4:17 128:20 name 6:4,6 42:14 46:8 obstacles 21:5 125:22 patrol 61:25 62:1,5,8
mark 87:17 46:16 49:2,4,5,6 50:3 obviously 30:25 105:20 opposite 90:6 116:22 75:3 79:13
marked 36:16 87:23 52:22,23,25 53:3 54:3 OC 89:9 126:8 patrolling 27:25
128:16,22 54:4 55:13 72:9,9 92:5 occur 59:21 Orange 12:25 13:6,10,13 patrols 59:23
mass 108:21 names 26:20,25 occurs 20:11 14:6 patron 48:3
match 35:21 narrow 31:19 October 11:25 order 52:5 pay 38:15 46:17,21
material 7:21 8:2,12 nature 6:14 off-duty 55:6,7 original 134:12,13,17,22 peace 25:17,25
20:20 21:1 NBA 85:24 offer 13:6,9 134:10 134:24 peacefully 61:19
matter 41:23 Near 30:24 office 6:23 26:8 65:23 originally 45:25 pedestrian 8:6,8
mean 25:10 27:20 32:18 Nearby 29:19 120:1 134:14,19 Orrego 29:22 34:15 38:4 peeked 102:17
37:9 53:3 75:8 necessary 7:19 134:15 officer 11:19 12:6,12 38:6 59:7 61:9,14,16 peers 50:2,3,3,11,15,16
meaning 48:4,6,7 need 113:22 15:20,20 20:4 21:8 61:24 62:14,15,18,20 50:17,25 51:1,3
means 22:6 25:12,13 negative 8:16 22:6,7 25:17,25 34:2 63:5 72:12,14 74:6,9 penalty 7:1,20,22 134:16
32:17 37:3 38:17 61:7 neh@glickman-law.com 58:5 67:25 81:8 120:6 90:24 131:16,18 132:2 pending 77:16
67:20 69:23 75:3 94:9 3:12 officers 22:5 112:4 132:4,13 133:4,10 people 14:16,20 18:11
medication 9:19 neither 77:21 Oh 23:23 62:15 84:15 134:3 42:14 43:8
member 15:1 61:1 never 62:20 63:7 65:22 114:22 115:15 123:15 Orrego's 133:22 Pep 11:10,14 12:2
members 20:2 83:2,7 82:14,15 112:11 124:4 OIS 119:25 120:3 other's 22:8,19 perceive 109:20,21
memory 9:3 124:11,15 133:14,15 okay 6:16,19 7:12,14,24 outside 127:13 116:15
Samuel Aldama
May 16, 2018
Page 6
www.depo.com
perceived 109:19 110:6 Poplar 96:11,12,13,16 puts 49:11 received 81:25 133:16 retreating 109:16
112:17 113:25 98:21,23,24,25 99:1,3 putting 32:17 56:23 recognize 85:25 retrieved 115:13
perjury 7:1,4,8,20,23 99:6,8,19,21 100:11,15 63:13 93:24 recollection 9:4,8 29:13 return 134:16
48:25 57:13 134:16 100:17 105:19 29:17 53:1 69:13 92:6 review 21:23 26:19
permitted 26:20 27:2 posed 24:12 Q recommend 49:17 50:11 reviewed 20:20 23:20
person 24:1 29:14 31:1,4 position 25:24 111:15 Q-U 38:18 50:12,16,21,22,23 revolver 90:15,16
31:16 32:11,14,17,18 possessed 69:7 question 9:5 14:22 18:14 recommended 49:10,13 rid 112:10,13 113:1,9,19
32:23 33:3,6,8,11,13 possibility 22:18 119:9 20:9 21:13,16,18 22:2 49:22 50:14 126:6
34:1,7,13,16,19,23 possible 22:23 27:11,16 24:10,11 32:13,14,24 record 5:8 6:4,18 8:18 rifle 44:7,8,10
35:7,12,16,21,24 36:6 68:16,18 33:1 48:21,24 52:16 14:24 45:8,14,17 71:12 right 9:2 12:11,15 15:15
36:7,9,24 38:2,7 48:10 possibly 32:19,20 33:5 63:12 68:7 69:22 70:2 71:15,20 72:20,21,25 17:15 19:6 20:19,19
48:15 49:3,4 50:19 38:12,16 53:2 55:21 70:8,22 71:7 72:3 83:19 126:13,16 23:10 25:15 30:7 31:1
61:12 65:14 66:12 64:12 69:2 75:21 77:8 77:14,16,23 78:6,8,12 127:13 135:11 31:23 33:4 43:1,11
79:23 81:24 95:25 77:9 103:14 104:20 79:3,5,6,10,20 81:18 recorded 7:12 54:18 75:3 76:13,13,14
122:2 107:9,10 121:4,6 122:6 83:23 86:2,11,12,15,16 records 56:15 76:17 78:4,5,15 84:10
person's 33:16 52:22,23 125:23 86:23 91:19 92:24 93:6 recovered 118:5,8 84:20 87:2 91:22 93:14
119:3 post 15:17,19,22,24 96:3,3 111:11 114:9,11 recruit 15:6,10 93:22 94:9 95:10,13,14
personal 124:20 17:15 23:2,4 25:3 115:23 116:14 119:14 red 8:10 39:18 96:7 97:21 98:9,16
personnel 26:24 122:5 126:19 127:22 refer 32:15 34:12,15 99:2,19 100:8 102:1
persons 81:11 pouch 89:6,6 questioning 71:18 referred 46:11,15 48:10 105:23 106:5 108:7,22
pertains 53:17 54:7,21 powerful 89:18 questions 7:7 8:14,22 49:3 111:13 112:20 116:3,9
physical 13:23 14:1,4 PR-24 33:25 34:3,6 26:11 71:19 126:20 referring 28:21 54:10,12 117:25 120:17,22,23
72:6 precipitated 60:8 128:14 129:2,4,23,24 refresh 9:4,7 52:25 92:6 120:25 123:1 127:11
picks 97:22,25 preparation 88:5,16 133:19 134:5,7 regard 133:16 129:20
picture 41:8 52:4 prepped 88:17 quick 126:11 regarding 26:20 65:23 Right-handed 90:8
piece 47:21,23 presence 75:4 quickly 60:7 93:18 rejected 13:4,17,18 ring 18:2 25:21 53:4
Piru 82:6 83:5,11 Present 3:20 related 55:2 72:10 89:8
Pirus 83:6 president 67:20 R relationship 53:23 rip 76:9
Pitchess 26:6,9,19 press 123:9,12,13,13,18 relative 5:6 risk 6:16
place 5:9,13 8:23 29:16 pretty 19:6 51:14 70:13 R 3:1 96:14 relieved 134:11 roll 120:10,11
29:17 72:17 73:12 86:8 108:22 race 28:18 64:15 remains 133:22 roll-out 120:1
placed 6:21 109:1 127:3 racial 69:20 71:8 remember 9:7 13:15 rolls 120:7
plaintiff 1:8 2:8 5:14 Prior 74:11 radio 30:14,15 35:4,5,7 16:11 28:12 33:15,17 rookie 43:22
87:20 prison 122:10,11,14 35:22 52:20 89:7 93:24 36:11,18,20 49:5,6 room 6:23
Plaintiff's 87:23 probably 6:17 25:6 93:25 122:19,21 123:1 54:2 61:3,5,20,21 62:7 Rosecrans 60:13
plaintiffs 2:17 3:3,8 4:11 102:25 123:25 62:23 63:13,21 64:18 rounds 102:24 105:7,10
5:17,18 6:7 probation 79:6 93:2 radioed 94:11 65:11,15,25 66:5 69:16 105:13,16,24 125:13
plan 99:25 problem 59:2 raised 10:9,10 86:16 110:22 111:23 RPR 1:24 2:20
player 85:25 problems 71:1 ram 34:6 112:3 124:13,14,18,19 rules 6:18
playing 40:12,15 proceedings 6:14 45:16 ran 93:18,19,19 99:3 remembered 64:2 run 99:1 116:23
please 5:21,25 76:9 71:14 126:15 130:4,10,10 reminded 19:3 run-in 53:15
plenty 124:23 125:2 projectiles 104:6 random 51:7 removed 132:18,22,24 running 31:16 60:11
PM 71:13,16 72:22,23,24 prosecuted 121:17 rank 14:14,25 repeat 20:9 22:2 48:21 62:2,9 68:9 81:22
73:1,22 126:14,17 prosecuting 120:17,21 reached 94:24 96:23 70:2 111:11 86:15 93:8,10 100:6
135:11,12 120:25 read 7:18,22 8:11 18:21 repeating 6:16 101:7 105:21 107:18
pocket 90:12,13 protocol 132:25 18:23,24 19:4 57:1,6 rephrase 69:22 110:8 116:22 128:3,6
point 23:25 24:4,14 25:7 public 5:5 18:1 77:10 92:8 104:19 report 57:2,2,7 68:2,12 runs 62:15
38:2 73:16 78:9 79:18 pull 80:6 84:11 102:5 111:5 117:13,15 68:14,17,19,22,23 69:5
80:1,8 81:20,21,22 pulled 37:3,12 80:4 134:15,25 69:9,12 77:10 92:6,9 S
85:18 94:1,19 96:25,25 81:17,21 reading 133:17 REPORTED 1:24
reads 7:15 s 3:1 4:9 26:24
97:6 99:9,24 100:8,20 pulling 127:5 reporter 5:15,20 6:22 S-A-M-U-E-L 6:5
101:17,21,22,23,25 pulls 80:3,10 ready 72:18 8:17 76:13 87:19,21
real 60:7,7 S-I-L-V-A 55:14
102:3 109:11,13 purpose 47:25 73:14 134:11 saint 48:3
114:24 115:2 116:16 purposefully 34:6 really 7:7 48:24 57:11 REPORTERS 1:21
reason 9:13 25:8 81:15 Salaz 3:21 5:3
127:7 pursue 62:11,15 93:16 represent 5:4 6:6 82:14 salon 92:4,4,5
pointed 38:7 42:17 pursuing 21:8 22:5 81:15,19,20,23 82:3,5 118:7
82:7 84:25 85:8 102:23 Sam 89:3 123:1
101:25 111:8 126:2 97:15 respect 18:9,12,16 22:20 Samuel 1:16 2:16 4:3,13
127:13 pursuit 18:24 19:14,18 106:6 127:21 23:2 54:3
reasonable 84:22 5:12,22 6:5 135:10
pointing 106:10,19 125:5 19:22 20:4,11 21:8,24 respective 133:8 San 60:3
police 10:21 11:19 12:6 22:5 23:3,15,20 31:15 reasons 85:6,8,10,12,14 responding 18:6 112:4
recall 13:17 17:15 18:5 Sarkisian 1:24 2:19 5:15
12:12 15:20,20 57:19 31:20 32:2 33:18 34:18 113:25 saturate 73:13 75:1,3
58:5 67:25 68:1,12,14 52:24 60:8,9 62:25 27:9 28:2 32:2,4,6,8 response 14:22 71:19
33:6,8,12 42:21 62:8 saw 35:25 73:20 77:12
69:5 81:7 120:8 101:2 122:20 125:1 114:6 129:24 130:5 77:18 78:10 80:20
policies 19:10,13 pursuits 18:19 20:6,7,16 64:7,9 65:6,13 68:11 132:10 133:11
69:4,18 86:13,14 92:5 81:22 97:16 99:23
policy 18:19,24 19:2,7,10 20:18,20 restroom 52:4 100:2 107:21 110:6
19:12,14,14,18,22 put 31:1,2 47:14 61:18 129:4 131:24 132:7 result 26:16 66:7
receipt 135:2,3 111:19,21 112:1
21:24 23:1,11,12,20,24 63:11,16,20 68:19,25 resulted 53:23 114:20,24 116:5,6
24:2,22,24 25:4 101:3 69:12 71:20 73:11 receive 13:6,9 30:9 retreated 115:9,14,15
35:15 124:4 125:5,25 126:1
93:25 123:24
Samuel Aldama
May 16, 2018
Page 7
www.depo.com
128:3,6 133:25 SHERRON 1:5,7 2:5,7 53:2,5,18 55:21 56:13 spoke 92:22 summer 73:9,10
saying 13:18 60:15 shirt 76:18,19 57:22 58:2,4,11,13,15 spray 89:9 superior 1:1 2:1 49:8
says 44:14 shoot 100:8 102:5 105:5 58:18,21 59:1,22,24 Spruce 34:22 60:10,11 87:8
scare 25:25 105:6 106:2 122:7 60:1,5 61:3,8,10,20 square 80:16 81:2 supposed 14:9
SCC 23:8 shooter 120:17 121:7 62:19,21 63:14,22,24 St 39:13 47:23 48:3 suppress 75:1
scene 61:5 117:25 120:8 shooting 30:6,7,16,18,22 64:1,9,14,18,20,22 stages 13:20,22 sure 16:5,18 17:8 18:3
132:18 31:9,11 34:24 35:3,7 65:5,12,15,25 66:9 stainless 80:11,20 20:10 22:4 23:4,6,23
schedule 14:9 35:16 52:17 81:11 87:7 68:11,14,18 69:2,4,10 stamp 128:21 129:11,12 24:2,24 27:16 29:4,16
school 10:11,12,21,23 103:8 104:21 120:6,8 69:16,18,22 70:2,5,7,8 stamped 4:14,16 30:17 31:7,24 32:1,10
10:24 12:2 15:14 121:16 123:22,24 70:10,12,25 71:7,10 stance 111:9 125:6 32:22 35:19 36:14
scope 64:23 127:21 133:1,2 72:8,11,16 73:3 74:5 stand 10:2 15:19 76:9,10 38:12 42:24 48:22
script 7:15 shootings 82:1,9 74:14,16,18,24 77:24 108:3 120:3 49:13 52:16,23 53:17
search 77:13 84:20 85:1 short 76:24 80:14 81:12 82:17 83:4 standing 36:4,5 37:23 54:7,18,25 55:17 57:2
110:23 shot 82:15 101:8 102:3,8 84:8 86:4,16 88:19,21 127:6 57:10,14,24 61:17
searched 77:4 111:2 103:15 105:4,10,16,24 91:16 96:15 104:20 stands 15:20 44:15 62:22 63:10 64:1,20
searching 77:19 125:9 106:10,19 107:14,22 105:8,17 110:24 111:1 120:6 66:5 67:23 68:14,23
second 47:5,7,14 69:12 108:7,12,17,18,22 115:20 117:14,25 Stanford 31:12 69:9 77:3,20 84:14
103:19 104:25 105:1,3 109:1 111:12,13,15 118:6,21 119:12,23 start 9:24 29:15 34:18 98:15 101:22 104:14
105:4,6,7,10,12 113:9,9,24,24 114:21 120:2,5,23 122:9,21 started 34:22 45:7 114:19 115:25 116:2,4
seconds 103:18,19,19 116:7 119:20 121:6 127:12 128:4,8 129:16 state 1:1 2:1 6:3 117:19 120:5
103:20,21 105:5 106:2 124:15 126:7 129:6,7 situation 45:9 122:7 stated 85:17 surprise 118:1,2,8
108:19 110:15 111:9 134:2,3 six 11:6,7 126:23,24 statement 68:15 80:19 surrender 61:18
111:12 112:9,13,19 shots 99:24 102:10 127:2,3 82:19 87:7,14 88:2,10 suspect 20:8,11 24:12
113:1,8,16 114:2 117:8 103:2,13,16 104:22,23 skull 39:15,16,18 40:2,9 88:15,17 30:15 56:14
125:4,17 126:6 133:23 104:25 105:12 106:3,5 40:12,18,20 42:17 station 19:2 27:20,22,25 suspected 26:2 78:18
134:1,3 106:8 114:7 129:3,25 44:10 51:19,22 41:22 42:9 46:12,13,15 suspects 20:22
see 33:10,13,16 34:2,5 130:2,6 131:7,8,10,13 sleep 9:16 50:2,5,18 53:9 59:25 suspicion 84:22
34:20 35:12 38:6 41:2 131:15,19,24 132:2 slide 81:2 60:3 73:7 Sweeney 3:4,4 4:5 5:17
41:2,3,7 52:5 64:17 133:22,23 sling 37:10 stay 67:1 123:17 5:17 6:2,6 11:23 15:4
69:3,14 73:19 99:14 shoulders 8:20 slung 37:13 stayed 66:6,10 98:23 16:6,12 17:12 19:11,14
100:22,24 101:1,15 show 14:7 41:9 52:3,6 Smith 89:12,13 90:16 99:21 130:22 131:22 19:16,24 20:13 21:12
103:21,24 106:1,21 68:22 127:4,6 smoke 40:25 44:23 132:21 21:14,17,21,22 22:3,24
110:1,3,16 111:21,24 shows 49:11 somebody 36:5 43:16 steel 80:11,20 23:9,14,17 24:9,20
115:12 117:7,10,16 shrug 8:19 49:16,23 50:12,12,19 step 14:7,7 25:1 26:22 27:4,7,8,21
124:9 127:9 130:24 side 27:14 75:13 88:24 somebody's 121:6 stepped 81:18 27:23 28:6,8 29:1
131:1 132:8 90:6 95:3,5,7,7,8,9 soon 132:3 steps 116:25 32:25 33:2 37:19 39:9
seeing 61:5 96:18,19,19 97:2,2,5 sorry 14:19 15:21 19:9 stickers 87:18 39:11,24 40:1 41:5,8
seen 42:3 51:8 54:17 97:11,18,19,22,23,25 19:11 21:11,12,14,15 stipulated 135:7 41:11,16 42:1,7,13,23
56:10 59:7,9,10,14,17 98:1,1,17 109:4,4 23:23 25:20 36:19 39:9 stipulation 134:10 43:9,15 45:10,12,19
60:21 74:15 80:25 81:4 127:16 41:5 47:6 48:21 54:11 stop 8:10 78:6,12,25 48:2,13,16 49:20 50:10
81:5 sight 22:7 62:18,20 55:4,18 61:15 62:3 81:23 82:10,16 83:1 51:17 52:8,14,15 53:14
semiautomatic 80:12 131:2,3 66:4,22 67:5,10 70:1 84:10,25 86:1 92:3 53:19,22 54:11,14,16
semiautomatics 80:16 sign 7:19,22 134:15 70:18 79:12 91:19 99:7 97:15 54:19 57:7,8 59:12,20
Send 49:15 signify 42:5 102:19 103:12 104:22 stopped 37:10,14 78:14 60:17 64:6,10 65:1,3
sends 50:19 signing 134:20 106:17 108:24 110:8 78:19 79:2 81:15,22 66:14,18 67:5,7,10,12
sent 7:15 Silva 55:14,15,15 56:3 113:20 119:6 82:2,11 83:23 91:8 67:13,18,24 68:24
separate 97:6 100:20 59:21 64:15 Sort 80:17 stopping 84:7 69:11 70:18,21 71:20
separated 99:25 silver 80:20 source 70:15,23 71:3 store 36:17 71:25 72:4,17,20 73:2
sergeants 132:20,22,24 simple 32:16 43:7 south 1:2 2:2,17 3:5 5:9 story 56:15 112:4 121:20 75:9 77:15,17 78:1,22
serve 12:5 simply 37:8 92:15 93:9 98:24 straight 42:18 109:5,6 78:23 79:4 82:23 83:19
served 12:12 54:10,12 simultaneously 79:10,13 100:15 street 27:24 28:3 34:22 83:21 84:4 85:3,4,16
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Samuel Aldama
May 16, 2018
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Samuel Aldama
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Samuel Aldama
May 16, 2018

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Atkinson-Baker Court Reporters

1 SUPERIOR COURT OF THE STATE OF CALIFORNIA

2 COUNTY OF LOS ANGELES, SOUTH DISTRICT

4 ANDREW TAYLOR, individually and )

24 REPORTED BY: Lois Sarkisian, CSR No. 13707, RPR

25 FILE NO: AC052F6

1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 1 INDEX

1 EXAMINATION 10:04:13 1 Q Okay. 10:06:56

4 name for the record. 10:04:16 4 A No, sir. 10:07:05

8 perjury. 10:05:51 8 recollection. Okay? 10:09:11

10 A Yes, I do. 10:05:52 10 and an estimate? 10:09:19

11 Q Everything that is said here is being transcribed 10:05:56 11 A Yes. 10:09:20

25 A Yes, sir. 25 highest level of education?

3 A Associates degree on automotive. 10:10:11 3 correct? 10:13:46

4 Q Where did you take that degree? 10:10:14 4 A Correct. 10:13:46

7 College? 10:10:28 7 A That's correct. 10:14:02

13 Compton. 10:11:04 13 your community? 10:14:23

14 Q Did you graduate? 10:11:05 14 A I have. 10:14:25

16 Q What year did you graduate? 10:11:07 16 A No, sir. 10:14:33

18 Q 2002? 10:11:14 18 A That is correct. 10:14:43

22 entered the Academy. 10:11:29 22 A That is correct, sir. 10:14:59

24 District assigned to Dominguez High School as a teacher 10:11:43 24 agency? 10:15:04

3 MR. DAY: Objection; calls for speculation. 10:18:53 3 children. 10:21:58

4 BY MR. SWEENEY: 10:18:55 4 Q Any other one? 10:22:00

5 Q If you know. 10:18:55 5 A No. 10:22:03

7 the highest in the Academy. 10:19:05 7 there? 10:22:10

8 Q Were you in that? 10:19:08 8 A I'm not sure. 10:22:15

12 A It is just one. 10:19:20 12 BY MR. SWEENEY: 10:22:29

13 Q Just one. Okay. 10:19:21 13 Q The Academy. 10:22:30

14 It's like the valedictorian in high school or 10:19:24 14 A Yes. 10:22:31

16 A Yes. 10:19:28 16 training, correct? 10:22:38

19 Q What does POST stand for? 10:19:42 19 A Yes, sir. 10:22:46

23 strike that. 10:20:32 23 A Correct. 10:23:04

25 know? 25 You also had a learning domain about how to treat

5 Q What do you recall about that? 10:23:27 5 A Yes. 10:26:34

13 A Yes, I have. 10:24:04 13 BY MR. SWEENEY: 10:27:23

16 respect? 10:24:14 16 pursuits. 10:27:30

17 A Yes, I have. 10:24:16 17 Q They what? 10:27:30

21 Q Did you ever read it? 10:24:37 21 dangerous? 10:27:41

2 A We have a manual policy at the station that 10:24:56 2 dangerous? 10:27:58

16 BY MR. SWEENEY: 10:25:39 16 interrupted your question. 10:28:46

20 A Correct. 10:25:49 20 Academy? 10:28:52

22 Department has a foot pursuit policy? 10:25:57 22 BY MR. SWEENEY: 10:28:54

25 Q If you know. 25 MR. DAY: Well, objection; compound. If you understand,

3 BY MR. SWEENEY: 10:29:09 3 weapon. 10:32:40

9 you know -- 10:29:32 9 BY MR. SWEENEY: 10:33:06

15 Q What was the explanation? 10:29:49 15 just to intimidate him? 10:33:23

22 speculation. 10:30:21 22 Sheriff's Department policy, wouldn't it? 10:33:45

5 Q CSS: What is CSS? 10:30:52 5 yes, sir. 10:34:15

9 BY MR. SWEENEY: 10:31:09 9 A Correct. 10:34:32

18 Q Okay. 10:31:28 18 authority? Were you ever taught that? 10:35:17

4 A No. 10:36:12 4 force on him in 2016? 10:40:06

7 A Yes. 10:36:23 7 MR. DAY: Who is him? 10:40:12

10 A Correct. 10:36:36 10 A Yes. 10:40:20

17 one of the complaints leveled against you? 10:37:14 17 A No. 10:40:56

22 MR. SWEENEY: Okay. 10:37:35 22 A No. 10:41:16

3 to inquire into. 10:37:58 3 specific. 10:41:42

6 MR. DAY: As to discipline, yes. 10:38:02 6 no. 10:41:53

7 MR. SWEENEY: Okay. 10:38:04 7 A Yes, I have. 10:41:54

10 Sheldon Lockett in 2016? 10:38:23 10 A No, sir. 10:42:08

15 Sheldon Lockett? 10:39:00 15 start? This is the 2016 incident. 10:42:43

17 Q Okay. 10:39:14 17 Q What is your recollection of where it took place, 10:43:01

19 Sheriff's Department? 10:39:24 19 A Nearby, I'm guessing. 10:43:08