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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-CV-61029-RAR

LATOYA RATLIEFF, 

Plaintiff,

v.

CITY OF FORT LAUDERDALE, 

FLORIDA, et al., 

Defendants.

____________________________________/

JOINT DISCOVERY STATUS REPORT

Pursuant to the Court’s Order (DE 111), the Parties (Cristafaro, Dietrich, 

Greenlaw, Figueras, MacDoughall, Ratlieff, and Ramos) file this Joint Discovery 

Status Report (JSR):

REQUEST FOR INTERROGATORIES

Request No. 1: Identity specific video footage by time stamp, including BWC 

footage or undercover footage, supporting any contention of violence at the 

corner of SE 2nd Street and SE 1st Ave on May 31, 2020, during the following 

time periods: 

a. From 6:51pm ET to 6:52 pm ET 

b. From 6:52 pm ET to 6:59 pm ET 

c. From 7:00 pm ET to 7:01:25 pm ET 

d. From 7:01pm ET to 7:07:30 pm ET 

Response from Cristafaro, Dietrich, Greenlaw, Figueras, MacDoughall: 

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Defendant objects to Plaintiff's interrogatories 1 and 2 as seeking mental 

impressions of counsel and legal defense strategy. Additionally, Defendant 

objects as overly broad, unduly burdensome, irrelevant to and not 

proportionate to the discovery needs or issues in this case. In order to respond 

to these interrogatories, Defendant and his attorneys would have to jointly 

review hours and hours of body worn camera footage (“BWC”)(over days) of 

approximately 40 different officers, social media and news footage, and cell 

phone video to locate any such portions that capture footage at SE 2nd Street 

and SE 1st Avenue, and further assess whether those portions depicted certain 

acts at very specific times outlined in the interrogatory questions. Plaintiff is in 

possession of all BWC footage, news and social media videos and video 

produced by the City of Fort Lauderdale in its discovery responses. The content 

of the videos speak for themselves and having an individual defendant spend 

an inordinate amount of time to give commentary on what can be seen by any 

viewer is unreasonable.

Response from Ramos:

Defendant, Ramos, objects to Plaintiff's interrogatories 1 and 2 as

overbroad, unduly burdensome and as both disproportional and

irrelevant to the discovery needs or issues in this case. In order to

respond to these interrogatories, Officer Ramos and his attorneys

would have to jointly review tens of hours of body worn camera footage

(over days) of approximately 40 different officers to locate any

portions, no matter how brief, that capture footage at SE 2nd Street

and SE 1st Avenue, and further assess whether those portions depicted

certain acts at very specific times outlined in the interrogatory

questions. This serves no valid purpose as Ramos is not contending

that he discharged his weapon in the direction of Plaintiff in response

to general numerous violent acts of others, but instead in direct

response to a specific violent act: a rioter located in close proximity to

Plaintiff throwing a metal canister at police officers. That specific

violent act is depicted on the Rose body camera video and was shown

at Plaintiff's deposition and attached as an exhibit. Ramos, at the time,

was under orders from his supervisors to utilize less-lethal rounds at

violent offenders, and that is precisely what he did in this instance,

unfortunately striking Plaintiff (who was moving and stepped down off

a curb) instead of the violent offender. To the extent Plaintiff's

attorneys desired for Ramos to comment on any specific video, they

could have presented it to him at his deposition, as Ramos' attorney did

when deposing Plaintiff. The content of the videos speak for themselves

and having an individual defendant spend this inordinate amount of

time to give commentary on what can be seen by any viewer is

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unreasonable. Moreover, the City has produced the body camera of

Officer Rose, which depicts the violent offender and the subject

incident.

Movant’s Position:

The police reports, 

Internal Affairs 

Statements, and now 

discovery depositions are 

rife with allegations of 

violence by 

demonstrators at the 

corner of SE Second 

Street and SE First 

Avenue during the Fort 

Lauderdale May 31, 

20220, George Floyd 

protests. The testimonial 

evidence about the 

timeline of this purported 

“violence” is vague. 

During the City’s 30(b)(6) 

testimony, its corporate 

representative identified 

the specific video footage 

supporting any claims of 

violence during these 

time periods. The City did 

not object. This 

interrogatory, in effect, 

gives the individual 

defendants the

opportunity to provide a 

different answer, identify 

other video footage, or 

stand by their employer’s 

Opponent’s Position:

Defendant Ramos

In this action relief is 

sought against

Defendant Ramos for a 

single act. Specifically, it 

is alleged that Defendant 

Ramos fired a kinetic 

impact projectile which 

struck Plaintiff Ratlieff in 

the face causing her 

injury. (ECF 102 at 

¶¶130-138) Defendant 

Ramos has testified that, 

and video and audio 

evidence corroborates 

that he was instructed by 

supervisors to fire kinetic 

impact projectiles as 

persons who were 

attacking the police by 

throwing objects at them. 

Defendant Ramos has 

identified for Plaintiff’s 

counsel video/audio 

evidence which shows 

that a person threw a 

teargas canister at the 

police and that Ramos 

attempted to strike the 

attacker with a kinetic 

impact projectile which 

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articulation of what the 

physical video evidence 

shows.

Plaintiff tendered these 

contention interrogatories 

near the close of 

discovery (and after the 

City already identified 

specific video footage 

supporting any 

contention of violence at 

the corner of SE Second 

Street during these 

times). Given that this is 

the close of discovery, 

there is no burden in 

asking the individual 

defendants to identify any 

video evidence supporting 

their contentions of 

violence during the above 

time periods.

unfortunately struck 

Plaintiff Ratlieff as she 

moved in front of the 

attacker. Defendant 

Ramos does not assert 

that he fired the kinetic 

impact projectile because 

of any other generalized 

violence which was 

occurring at the location. 

Defendant Ramos has 

identified the audio and 

video evidence which 

does relate to his actions. 

Defendant Ramos’s 

interpretation of video 

evidence which is 

available to Plaintiffs 

counsel is not relevant to 

the claims or defenses 

which relate to him, and 

it would be unduly 

burdensome for 

Defendant Ramos to 

spend dozens of hours 

reviewing the video 

evidence which is not in 

any way pertinent to the 

claims asserted against 

him. The request is not 

relevant, is unduly 

burdensome, is not 

proportional to the 

issues in the case and no 

authority exists to 

support requiring 

Defendant Ramos to 

engage in the 

unnecessary exercise 

requested by Plaintiff’s 

counsel.

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Response from NonRamos individual 

Defendants: 

As the Defendants stated in 

their objections, in order to 

respond to these 

interrogatories, each of 

these Defendants and his 

attorneys would have to 

jointly review hours and 

hours of body worn camera 

footage (“BWC”)(over days) 

of approximately 40 

different officers, social 

media and news footage, 

and cell phone video to 

locate any such portions 

that capture footage at SE 

2nd Street and SE 1st 

Avenue, and further assess 

whether those portions 

depicted certain acts at 

very specific times outlined 

in the interrogatory 

questions. Plaintiff is in 

possession of all case 

supplement reports 

reflecting the observations 

of Defendants on scene, in 

addition to BWC footage, 

news and social media 

videos and video produced 

by the City of Fort 

Lauderdale in its discovery 

responses. The content of 

the videos speak for 

themselves and having an 

individual defendant spend 

an inordinate amount of 

time to give commentary on 

what can be seen by any 

viewer is unreasonable. 

Additionally, both Douglas 

MacDoughall and Steven 

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Greenlaw were not even at 

the scene of the incident as 

they were in the Command 

Center at the police station 

and would not have firsthand accounts of any 

actions of the agitators. 

Finally, Plaintiff’s 

interrogatory seeks the 

legal defense strategy that 

would be employed by 

reviewing any video footage 

for the purpose of 

responding to the inquiry. 

Request No. 2: Identify all documents, videos, and evidence of any kind, which 

supports your contention of civilian violence toward officers at the corner of SE 

2nd Street and SE 1st Ave on May 31, 2020, during the following time periods:

a. From 6:51pm ET to 6:52 pm ET

b. From 6:52 pm ET to 6:59 pm ET

c. From 7:00 pm ET to 7:01:25 pm ET

d. From 7:01pm ET to 7:07:30 pm ET. 

Response: (a. – d.). See Response No. 1.

Movant’s Position:

Same

Opponent’s Position:

Defendant Ramos

Same

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