UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION

- - -

Karl Shaw,

Plaintiff,

vs. Case No. 2:18-cv-483

City of Columbus, et al.,

Defendants.

- - -

Deposition of Karl D. Shaw, Plaintiff

herein, called by the Defendants under the

applicable Federal Rules of Civil Procedure, taken

before me, Jane M. Ferrante, a Notary Public in and

for the State of Ohio, pursuant to notice, at the

offices of Columbus City Attorney Zach Klein,

77 North Front Street, Columbus, Ohio, on Monday,

July 1, 2019, at 9:03 a.m.

- - -

JANE M. FERRANTE

REGISTERED MERIT REPORTER

7089 VIOLET VEIL COURT

DUBLIN, OHIO 43016

(614) 733-0158

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JANE M. FERRANTE, RMR (614) 733-0158

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APPEARANCES:

Mr. Frederick M. Gittes

The Gittes Law Group

723 Oak Street

Columbus, Ohio 43205

Mr. Sean L. Walton, Jr.

Walton & Brown, LLP

395 East Broad Street

Columbus, Ohio 43215

On behalf of the Plaintiff.

Mr. Richard N. Coglianese

Columbus Assistant City Attorney

77 North Front Street

Columbus, Ohio 43215

On behalf of the Defendants.

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I N D E X

Examination Page

By Mr. Coglianese 5

By Mr. Gittes 144

By Mr. Coglianese 150

E X H I B I T S

Exhibits Page

13 E-Mail chain 2-9-2015 -

2-10-2015

119

29 Letter of Agreement 121

14 E-Mail chain 2-25-2015 124

28 Assignment Abolishment 125

16 E-Mail 4-7-2015 141

18 Text Messages 142

19 -

22

Job Applications 153

23-24 Job Applications 154

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JANE M. FERRANTE, RMR (614) 733-0158

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Monday Morning Session,

July 1, 2019.

- - -

STIPULATIONS

It is stipulated by and among counsel for the

respective parties that the deposition of Karl D.

Shaw, Plaintiff herein, called by the Defendants

under the applicable Federal Rules of Civil

Procedure, may be taken at this time and reduced to

writing in stenotype by the Notary, whose notes

thereafter may be transcribed out of the presence

of the witness; and that proof of the official

character and qualification of the Notary is

waived.

- - -

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JANE M. FERRANTE, RMR (614) 733-0158

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KARL D. SHAW

being by me first duly sworn, as hereinafter

certified, deposes and says as follows:

EXAMINATION

By Mr. Coglianese:

Q. Good morning, Mr. Shaw.

A. Good morning.

Q. We met several times, but I am going to

go ahead just for purposes of the record and

introduce myself. My name is Rich Coglianese, and

I'm an attorney at the City Attorney's office. I

am representing the defendants in the case that you

filed against the City of Columbus.

As you know, we are here this morning to

take your deposition. And I know you have sat

through the depositions in this case at least, so I

know you are familiar with the way these happen.

A. Yes.

Q. Just to make sure, though, that you and

I are on the same page I just want to go over a

couple things with you.

A. Okay.

Q. First thing is -- and you are doing it

so far, so that's great. But it's very important

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JANE M. FERRANTE, RMR (614) 733-0158

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for you to answer verbally. If the answer is yes,

please say, "yes." Don't shake your head. If it's

no, please say, "no." And along that same line,

"uh-huh" and "huh-uh" sound really, really similar,

so just to make sure that we have got a clean

record, I am going to ask you to answer verbally.

Okay?

A. Yes.

Q. Perfect.

The other thing is -- and we are going

to do it because it's just normal conversation, but

I will do my best to try not to interrupt your

answers. I am going to ask you to do the same with

my questions. It just makes it difficult for Jane

to take everything down if we are both talking at

the same time.

A. Okay.

Q. If I do interrupt you please tell me.

It's not my intention at all to interrupt any

answer you want to give. So if I do happen to

interrupt you just say, Hey, you interrupted me.

And, please, then, I'll let you continue with your

answer. Okay?

A. Okay.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Generally speaking, I try to ask clear

questions and they are usually clear in my mind but

unfortunately lots of times the only person to whom

they are clear is me. So if you don't understand

what I'm asking, if it's confusing, please tell me.

I'm not here to try and trick you or anything. I

really just want to hear what you have to say. But

if I do ask a question that you are not sure of, I

would ask that you tell me, and I'm happy to

repeat, rephrase, restate, define, whatever it is

that would clear the question up. Is that okay?

A. Yes.

Q. And along that line, if you do answer a

question I'm going to assume that you understood

it. Is that fair?

A. Yes.

Q. We are going to be here for a little

while at least today, so these are not endurance

contests, as you know. If you need a break at any

time please tell me. We can do that. The only

thing that I would ask is that if there is a

question pending that you answer the question

before we take a break. Is that fair?

A. Yes.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. And again, as you heard your lawyers

tell all of the witnesses, I will tell you the same

thing. This is not a memory test. A lot of what

we are talking about is going to have happened

four, five, six years ago. So if you don't

remember, that's fine. Just tell me that. If over

the course of the deposition something jogs your

memory about something that we've talked about

please tell me. We can go back and talk about

anything that we've talked about previously. Is

that fair?

A. Yes.

Q. And then the final set of the

preliminary matters. Are you aware of any reason

that you cannot answer my questions truthfully,

honestly and to the best of your ability today?

A. No.

Q. So would you please go ahead and state

your name for the record?

A. Karl Douglas Shaw.

Q. And Mr. Shaw, where are you employed?

A. With the City of Columbus Division of

Police.

Q. How long have you been at CPD?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. 26 years.

Q. What is your current assignment?

A. High school resource officer at East

High School.

Q. How long have you been the resource

officer at East?

A. Four years.

Q. Generally speaking, what are your --

what is your role as a resource officer? What do

you do most days?

A. Most days -- basically, I talk a lot

with the kids. I enforce criminal violations.

That's pretty much it.

Q. Do you do -- are you part of any task

force or anything else with CPD or right now is

your job simply the school resource officer?

A. Right now it's just high school resource

officer.

Q. Do you have any opportunities for

overtime as a high school resource officer?

A. No.

Q. What about special duty?

A. Yes.

Q. How frequently do you do special duty?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. I work home football games and some of

the home basketball games, and I will work the

school graduation.

Q. Are you eligible to do special duty for

things outside of your jobs? For example, I know

that there are officers that will do special duty

for 5K races or half marathon or things like that

or work at Giant Eagle or apartment buildings. Are

you eligible to do any of those special duties?

A. Yes.

Q. Do you ever sign up for those?

A. No.

Q. Any particular reason why not?

A. Most of the jobs don't fit into my

schedule. I have joint custody with two of my

boys, so that's the reason why I don't do -- work

special.

Q. And what are your normal hours at East

High School?

A. 7:00 a.m. to 3:00 p.m.

Q. And is that Monday through Friday

usually?

A. Yes.

Q. What was your assignment before East

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JANE M. FERRANTE, RMR (614) 733-0158

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High School?

A. It was second shift patrol on -- I think

zone -- on 1 Precinct.

Q. Which zone was that in?

A. Zone 1.

Q. How long did you work Zone 1 Precinct 1

in patrol?

A. I never worked it.

Q. And why not?

A. I was admin to that job, and then I had

knee replacement.

Q. For purposes of the record what does it

mean when you say you were "admin to the job"?

A. It means that I was assigned that job by

the chief of police.

Q. And that would have been Chief Jacobs?

A. Yes.

Q. Do you know why Chief Jacobs assigned

you to that position?

A. Because my -- my job prior to that was

abolished.

Q. And that was the position that you held

in SRB, is that right?

A. Yes, sir.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. How long were you listed as admin for

Zone 1 Precinct 1?

A. Until sometime at the beginning of July.

Q. Do you remember which year that was?

2015? Does that sound --

A. I want to say it may have been 2015.

Q. Okay. How long were you in SRB?

A. To my best recollection, it may have

been about two years.

Q. So what would that have been? Like '13

through '15?

A. Yes.

Q. And what did you do at SRB?

A. I was on one of the enforcement teams.

Q. What does that mean?

A. Enforcement teams did various jobs that

they were tasked by the city. Working street

drugs, working burglars, following rape suspects.

That's about -- did other things, but I can't

recall all of them at this moment.

Q. My understanding is there were several

different units or teams inside of SRB. Is that

correct?

A. Yes.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Who was on your team, if you recall?

A. I mean it was Larry Wilson, Whitney

Lancaster, Eric Cornett, myself, Brett Bodel, James

Mathis, Richard Moore. And that's all I can recall

at this point.

Q. And did the six or so folks that you

worked with have the same type of general

responsibilities?

A. No.

Q. What -- how did the team divide out

responsibilities, if you remember?

A. We were allowed to kind of work or pick

our own cases or our own subjects that we wanted to

go after.

Q. And did you pick any particular types of

cases to go after?

A. Yes.

Q. What was your main area of focus?

A. Drugs and prostitution out of area

hotels up there at 161 and Morse Road.

Q. How did you end up deciding to

concentrate on that?

A. I was in a zone meeting -- and am pretty

sure it was Zone 1. And there was a city attorney

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JANE M. FERRANTE, RMR (614) 733-0158

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at the meeting, Bill Spurlazza complaining that --

about the prostitution and drugs at some of the

hotels up there. And after the meeting I went to

him and informed him I knew of a way to work those

hotels.

Q. So what did you end up doing when you

were doing the hotel investigation?

A. I started buying drugs from the area

hotels.

Q. What was the ultimate conclusion of the

investigation that you were doing with the hotels

up there?

A. What do you mean, "ultimate conclusion"?

Q. What ended up happening with the

investigation? You know, did people get charged?

Convicted?

A. Initially what happened was nuisance

abatements were made on five of the hotels.

Q. Okay.

A. And a few of them were boarded up for

over a year. Two of them to this day are still

boarded up. Then I came up with another plan

because I was in the human trafficking task force

because a lot of the prostitutes were working for

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JANE M. FERRANTE, RMR (614) 733-0158

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certain people that I -- that I knew.

I did some research on how -- what it

would take to do a RICO case. And then we started

looking at these drug buys and some of the

prostitution as RICO cases.

Q. Was a RICO case ever brought as a result

of these investigations?

A. Several.

Q. Did any of them result in convictions?

A. To my knowledge today, because I was

removed from the project and never was able to see

it through completion -- all the ones that I put

together led to convictions.

Q. And do you recall what any of the

defendants' names were?

A. One was Donald Fegan -- Fagan. And I

don't know the spelling on that. And his -- his

girlfriend. I can't recall her name.

One that comes to mind because it was

just recent was Bobby Smith, aka Jamaican Brick,

just received 15 years.

And there is another one, Sherman

Tanner. But I don't know where that one is or if

he took a plea.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Okay.

A. And there is one more that I can't think

of the defendant's name right now.

Q. Okay.

MR. GITTES: Can we go off the record

for a second?

(Discussion off the record.)

MR. GITTES: So the parties agree that

disclosures about Officer Shaw's role in particular

individuals' prosecutions will be sealed. We will

get an order together to protect that.

MR. COGLIANESE: Yeah. That's okay.

Q. What were some of the investigations

that the folks that you had worked with when you

were at CPD -- what areas did they try to

concentrate in?

A. They pretty much concentrated on areas

that they were good at. Some people were good at

tracking down wanted felons, so that's what they

primarily worked. Some were good -- they worked a

lot with burglary, following burglary suspects. So

some people would do that. Some people were good

at working drugs, so they did that.

Q. Okay. Who was your sergeant when you

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JANE M. FERRANTE, RMR (614) 733-0158

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were in SRB?

A. Sergeant Doug Williams.

Q. What was Sergeant Williams like as a

supervisor?

A. I liked him because he allowed you to

work. And if you had a good idea or a good plan he

was behind you and let you -- let you work it.

Q. So how would it work? You had said that

you went to a zone meeting with Bill Spurlazza and

Bill was talking about the hotels up in the 161

corridor.

How would it work that you would then

get the approval to start doing investigations into

those hotels?

A. There was a sheet that you fill out and

it identifies locations and targets that you want

to work and the reason why. And you just -- you

submit it through the chain.

Q. So you would submit it to Sergeant

Williams and he would send it up?

A. Yes.

Q. Do you recall who Sergeant Williams'

lieutenant was at that time?

A. It was Lieutenant Kimmerling.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Did you have much interaction with

Lieutenant Kimmerling at that time?

A. Yes.

Q. What was your relationship like with

him?

A. I felt it was good. A fair

relationship.

Q. Any issues that you had with Lieutenant

Kimmerling?

A. No. He always supported me.

Q. Okay. And the same would be true about

Sergeant Williams?

A. Yes.

Q. Do you recall the commander that

Lieutenant Kimmerling reported to at that time?

A. It was Commander Cameron -- no, not

Cameron. It was Curmode.

Q. And did you have much interaction with

her?

A. No.

Q. Did you have any issues with her as a

commander?

A. No.

Q. If I'm keeping time frames right in my

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JANE M. FERRANTE, RMR (614) 733-0158

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head, it sounds like you were in SRB probably from

about '13 through '15. Is that right?

A. I think so.

Q. Thereabouts?

A. Right.

Q. What did you do before SRB?

A. Before SRB I was in narcotics.

Q. How long were you in narcotics?

A. I want to say it was around maybe

three-and-a-half years.

Q. And what was your role in narcotics?

A. When I first got there it was working --

working drugs, working narcotics. And then it kind

of evolved.

Q. What did it evolve into?

A. Into human trafficking.

Q. Were you on any task forces when you

were in SRB?

A. Yes.

Q. What task forces were you on?

A. The human trafficking task force.

Q. Did that carry over from your time in

narcotics or was that new?

A. Actually, I was one of the -- one of the

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JANE M. FERRANTE, RMR (614) 733-0158

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original members of the task force. The task force

got started because of work that I was doing, and

the AG's office had saw that and saw that there was

a need for a task force. And it was started.

Q. And I don't need the individual names of

the task forces, but do you recall who the

employers were? Which agencies were members of the

task force?

A. CPD was the lead.

Q. Okay.

A. And then there was one ICE agent.

Q. Okay. Besides CPD and ICE, was anybody

else involved?

A. At one point before I left there was a

BCI agent.

Q. Who did you work with when you were in

narcotics as fellow officers?

A. To my knowledge today -- because it had

changed because some people came, some people left.

Walt Miller was one. Neil Young. It's either Mark

or Mike Johnson. I can't remember which one. C.J.

Joyce was another one.

Q. And who was your sergeant when you were

there?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. I had two.

Q. Okay.

A. When I first got there it was John

Warren. And then it -- then he retired and it was

Sergeant Piccinnini.

MR. GITTES: Can you spell that one?

THE WITNESS: I can't spell that one.

MR. COGLIANESE: Go off the record.

(Discussion off the record.)

MR. COGLIANESE: Back on.

Q. What was Sergeant Warren like as a

sergeant? Let me ask it this way. Did you have

any issues with him when he was your sergeant?

A. Never had any issues.

Q. What about Piccinnini?

A. Never had any issues.

Q. They both treated you fairly?

A. Yes.

Q. Did they both report up to the same

lieutenant? Do you recall?

A. Once again, because of people retiring I

think there might have been two lieutenants.

Q. Do you recall who they might have been?

A. First one would have been Lieutenant

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JANE M. FERRANTE, RMR (614) 733-0158

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Hawkins. And I'm not sure of his first name.

Q. Okay.

A. And then the second one may have been

Lieutenant Casner. The first name is Troy.

Q. Okay. Did you have any issues with

Lieutenant Hawkins?

A. Never.

Q. What about Lieutenant Casner?

A. Never.

Q. And did they both treat you fairly?

A. Yes.

Q. So again, if I'm doing my math

correctly, which is sometimes a big "if," it looks

like you probably got to narcotics maybe 2010, give

or take? Does that sound about right to you?

A. I think so.

Q. Where did you -- what was your

assignment before narcotics?

A. Vice.

Q. And how long were you in vice?

A. Roughly about three years.

Q. What was your primary responsibility

when you were there?

A. Street prostitution and boot joints,

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JANE M. FERRANTE, RMR (614) 733-0158

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illegal liquor establishments.

Q. Do you recall who your sergeant was when

you were in vice?

A. First one was Sergeant Oliverio.

Q. Okay.

A. He left, and then it was Sergeant -- I

can't think of it offhand. It will come to me.

Q. Okay. Did you have any issues with

Sergeant Oliverio when he was your sergeant while

you were in vice?

A. Never.

Q. What about the other sergeant whose name

you can't remember right now?

A. Never.

Q. Again, if I'm doing math right, it looks

like you probably got to vice somewhere around

2007. Does that sound about right?

A. No.

Q. When do you think you would have gotten

there?

A. I think your dates are off. I think I

may have gotten there around 2004.

Q. Okay. But that would have been the

assignment that you had before narcotics?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. Yes.

Q. Okay. What did you do before vice?

A. I was in sexual abuse squad.

Q. Do you recall how long you would have

been there?

A. Six months.

Q. Why such a short assignment?

A. I took a temp job in vice and I never

went back. Then I finally got a full-time job in

vice.

Q. How do temp jobs work at CPD?

A. They are posted in the daily bulletin,

and you bid on them by seniority.

Q. So that would be, if I recall

everything, that would be like a 60-day assignment?

Is that the way that works, or --

A. Yeah. I think some of them are 60 days.

Some of them may even be a max of like a six-month

temp.

Q. Okay. What did you do when you were on

the sexual abuse squad?

A. Investigate rape cases.

Q. Do you recall who your sergeant was when

you were there?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. I want to say it was Sergeant Clark.

Q. Did you have any issues with Sergeant

Clark?

A. None.

Q. Do you recall what you did before the

sexual abuse squad?

A. Yes.

Q. What was that?

A. I was administratively assigned to 11

Precinct on first shift.

Q. How long was that administrative

assignment?

A. I'm not sure. I never filled it.

Q. Okay. Do you recall why you were

administratively assigned to 11 Precinct?

A. Yes. My -- my assignment was abolished.

Q. And what was the job that was abolished

at that time?

A. D.A.R.E.

Q. How many officers were -- had their

positions abolished as a result of that, if you

recall? And a round number is fine.

A. Eight to ten.

Q. Okay. Do you recall what the

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JANE M. FERRANTE, RMR (614) 733-0158

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department's rationale was for abolishing those

assignments?

A. I think it may have been shortage of

officers, wanted to use officers in other areas.

Q. Do you recall who the chief was at that

point?

A. It was Chief Jackson.

Q. So the best you can, kind of -- could

you explain to me what happens when positions are

abolished at CPD? How that goes about? How it

affects the officers that have the positions

abolished?

A. You get a written notice that your job

was abolished. And I think it gives you 70 days to

find a position, or you get administratively

assigned into a job.

Q. Okay. And so if during that 70-day

period you don't have a job, you don't find a job,

that's when the chief would put you someplace

through the administrative assignment?

A. Yes.

Q. And so that's what happened to you as a

result of the D.A.R.E. abolishment?

A. Yes.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. How long did it take you to find the

sexual abuse squad position after being posted into

the administrative assignment for 11 Precinct, if

you recall?

A. It was about eight to nine months.

Q. Do you recall who your sergeant was in

11 Precinct?

A. No, 'cause I never worked a day in that

assignment.

Q. So then help me out. You were assigned

there, but what were you doing? Because you said

it had been about eight to nine months. So I am

just trying to figure out --

A. I was in a charity football game, police

against the sheriffs.

Q. Okay.

A. And I tore my ACL, PCL and MCL and had a

dislocated kneecap.

Q. Ouch.

A. So that eight to nine months was me

having two surgeries and recovery.

Q. Okay. So while you were -- did you

attempt to apply for any positions during the time

that you were out on -- it sounds like medical

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JANE M. FERRANTE, RMR (614) 733-0158

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leave because of the knee issues?

A. No.

Q. Why not?

A. Because I would have never been able to

fill it. Once you take a job you have to fill that

job I think within 30 days or you forfeit.

Q. Okay.

A. So I didn't know when I was coming back

to full duty.

Q. And that's a general rule over at CPD

that you have got to be able to fill a job within a

certain number of days after you take it. Is that

correct?

A. Yes.

Q. To your understanding?

A. That's my understanding.

Q. Okay. How long were you at the position

or the assignment at D.A.R.E., if you recall?

A. Oh, I was there two different occasions.

There was a break in the time that I was in

D.A.R.E. for 112 days.

Q. What was the reason for the break?

A. I had taken a community liaison job in

SRB.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. What did you do as a community liaison

at SRB?

A. Attended community meetings, addressed

complaints that the citizens had on the precinct

that I was assigned.

Q. Do you recall who your sergeant was the

second time you were at D.A.R.E.?

A. Both times it was Sergeant Roundtree.

Q. Roundtree?

A. Yes.

Q. What was Sergeant Roundtree like as a

supervisor?

A. Fair. Always treated me good. Never

had an issue.

Q. Why did you decide to take the SRB

community liaison position?

A. Try something different.

Q. What did you think of it?

A. Didn't like it, so I went back to

D.A.R.E.

Q. What was it that you didn't like?

A. I liked dealing with the people, but

it's too political. Didn't want to get involved.

Q. What do you mean by, "too political"?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. I think there was certain things that

were going on with certain housing programs being

put in, and I didn't think some of that was fair,

so I went back to D.A.R.E.

Q. Do you recall which housing programs you

would have been dealing with at SRB at that time as

the --

A. No, not offhand. It was something that

they were trying to implement down there with

vacant properties, abandoned properties.

Q. So it would have been, I guess,

providing police services or investigations?

A. No.

Q. Okay.

A. It was -- what they were trying to do is

putting housing in where people could rent to own.

And I think after a certain period then you could

purchase the house. But the issue was they didn't

have to sell you that house after you rented it.

Q. Okay. Was this the city that was

renting the houses, or do you recall?

A. I'm not sure.

Q. Okay. One of the names that has come up

in this case has been Officer Wes Sorell. How do

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JANE M. FERRANTE, RMR (614) 733-0158

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you know -- do you know Officer Sorell?

A. Yes, I know him.

Q. How do you know him?

A. We were in the same academy class

together.

Q. Which class was that?

A. I'm not sure exactly. It was either

82nd or 83rd.

Q. What year did you graduate?

A. It would have been in '93. We started

in November of '92.

Q. Why did you decide to go to the police

academy?

A. I needed a job, and I wanted out of the

military.

Q. How long did you serve?

A. Seven-and-a-half years.

Q. Which branch?

A. In the Navy.

Q. Where were you stationed?

A. Before I got out?

Q. Yes.

A. I was with 1st Marine Recon at Camp

Pendleton.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Honorable discharge?

A. Yes.

Q. Where did you go to high school?

A. In Akron, Ohio.

Q. What drew you to Columbus?

A. There was an individual that I was

stationed with at 1st Recon Battalion that was from

Columbus, and he got me an application and we both

applied for the police department.

Q. Did this person get into the department?

A. Yes.

Q. Who was it?

A. It was -- you asked me too fast. He's

in squad now. I can't -- if I think of it I'll let

you know.

Q. That's fair. And you said he still

works for CPD as well?

A. Yes. Rob Vass.

Q. What was your time like at the academy?

A. Fun because it didn't bother me.

Q. Any issues that you had?

A. No, none.

Q. You said that you knew Officer Sorell

through your academy class, your graduating class.

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JANE M. FERRANTE, RMR (614) 733-0158

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Did you ever have an assignment with him?

A. The only assignment would have been the

enforcement job because he was assigned to the team

but never worked. He didn't come back to work for

the team until it was being disbanded.

Q. When was that?

A. It would have been the fall of 2014.

Q. What's your relationship like with

Officer Sorell?

A. Really didn't have one until the Eric

Moore investigation came out.

Q. Would you describe Officer Sorell as a

friend? Acquaintance?

A. Acquaintance.

Q. One of the other names -- and you just

brought him up -- is Sergeant Moore. When did you

first -- have you ever worked for Sergeant Moore?

Let me ask it that way.

A. Never worked directly for him.

Q. How do you know Sergeant Moore?

A. He was in SRB the same time I was there.

Q. That would have been around '13 to '15?

A. Yes, sir.

Q. So he would have been the sergeant for a

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JANE M. FERRANTE, RMR (614) 733-0158

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different group? Is that --

A. Yes.

Q. Okay. Was that the first time you had

met him, or do you recall if you had worked -- you

know, if you had known him before showing up at

SRB?

A. I probably have seen him around

different places, but not until I came to SRB

enforcement.

Q. What was -- did you have a working

relationship with him?

A. What do you mean by "working

relationship"?

Q. Did you work with him at all? I know he

was the sergeant on a different team, but would you

work with him at all?

A. No.

Q. Would you need to interact with him at

the office for any reason?

A. Yes.

Q. Why would you need to interact with

Sergeant Moore?

A. He was in charge of like surveillance

equipment; GPSs, binoculars, cameras, listening

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JANE M. FERRANTE, RMR (614) 733-0158

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devices.

Q. How was his job different than --

actually, let me go back a little bit. You said

that the sergeant that you worked for when you were

at SRB was Sergeant -- I am sorry?

A. Doug Williams.

Q. How was Sergeant Moore's responsibility

different than Sergeant Williams' responsibility,

if you know?

A. I don't know.

Q. So would you go to Sergeant Williams if

you needed equipment, or would you go to Sergeant

Moore?

A. No. I think Sergeant Moore's job

description was more of like an admin; whereas

Sergeant Williams was in charge of people, as a way

to put it.

Q. So I just want to make sure I am clear

on what you are saying. And if this is wrong, tell

me. But what I am picturing from your answer up to

this point as far as the differences there are if

you have personnel issues or if you are talking

about investigations, things like that, you would

go through Sergeant Williams. If you had office

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JANE M. FERRANTE, RMR (614) 733-0158

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issues, needing equipment or needing supplies,

things like that, you would go through Sergeant

Moore? Is that --

A. Yes.

Q. Okay. Did you have any issues with

Sergeant Moore?

A. Yes.

Q. What were your issues with Sergeant

Moore?

A. Trying to get equipment.

Q. Any other issues that you had with

Sergeant Moore?

A. Yes. Later on when -- after he left SRB

enforcement.

Q. Okay. Let's -- and we will come back to

that. Let's kind of break it up into while he was

at SRB and then after he was at SRB. So while he

was at SRB, issues you had with him were trying to

get equipment?

A. Yes.

Q. Was there anything else?

A. That was it.

Q. Okay. Describe what you mean by,

"trying to get equipment."

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JANE M. FERRANTE, RMR (614) 733-0158

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A. I would go down there, maybe wanting a

camera. And he was like, Well, you have to take

this class or you have to sit here for a

presentation. We have to teach you how to use the

camera, when I already knew how to use the camera.

I knew how to use every device down there because I

used it in narcotics. I used it on the human

trafficking task force. It became an issue where I

just didn't feel I wanted to be bothered with

trying to get equipment that is down there, so I

had other avenues in order to get my own equipment.

Q. Okay. Do you recall when Sergeant Moore

would have left SRB?

A. Sometime in the summer of 2015.

Q. Do you know why you had trouble getting

equipment from Sergeant Moore?

A. Found out later it was because he had an

issue with black officers.

Q. What about at that time?

A. Couldn't explain why.

Q. I just want to make sure that the record

is clear. And so what I am talking about is from

the time that you and Sergeant Moore were there --

2013 to '15 is the time frame we are looking at --

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JANE M. FERRANTE, RMR (614) 733-0158

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you said that he left SRB in the summer of 2015?

A. Yes.

Q. During that period of time did you know

why you had issues getting equipment from Sergeant

Moore?

A. Because he didn't like black officers.

Q. Why do you say that?

A. Statements that Wes Sorell had made.

Q. So Wes Sorell told you that he didn't

like African-American officers?

A. Yes. I think he wrote a letter stating

it.

Q. Did he write that letter to you?

A. No.

Q. So how did you find out from Officer

Sorell that Sergeant Moore did not like

African-American officers?

A. I can't tell you exactly 'cause I can't

remember. But it was known. It was talked about

in the office.

Q. During that period of time -- and again,

I want to focus on the '13 to '15 time period --

A. Okay.

Q. -- did you ever have any firsthand

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JANE M. FERRANTE, RMR (614) 733-0158

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knowledge that Sergeant Moore did not like

African-American officers?

A. Yes. It would have been in probably the

spring of 2015.

Q. What was your firsthand knowledge at

that time?

A. There was an issue about a wanted felon

that Officer Cornett was looking for, and I don't

know all the particulars. But he sent an e-mail up

through the chain of command and comments were made

by Sergeant Moore that if Doug Williams would have

put him in his place, none of this would have been

happening.

Q. Were you on that e-mail chain?

A. No.

Q. So let me then define some things just

so that way you and I are on the same page, okay?

A. Okay.

Q. When I say, "firsthand knowledge" what I

mean by that is that you are a direct witness. You

were in the room when somebody said something. You

were copied -- you received an e-mail directly from

Sergeant Moore.

Do you have -- with that definition of

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JANE M. FERRANTE, RMR (614) 733-0158

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firsthand knowledge, okay, do you have any

firsthand knowledge of the 2013 to '15 time period

that Sergeant Moore did not like African-American

officers?

A. So let me -- let me try to clarify it

for myself. So you are saying if someone that was

a party to it came and told me, that that doesn't

count? Or do you want to know?

Q. Well, I will talk to you about those

down the road. What I am talking about is things

that you as an individual directly witnessed. Not

what somebody told you.

MR. GITTES: Just to clarify. While --

you are talking about the 2013 to 2015 period?

MR. COGLIANESE: Yes.

Q. During the time period of 2013 to 2015

things that you personally witnessed. So you

personally heard, you personally observed. Not

that somebody showed you an e-mail or forwarded you

an e-mail or told you that they heard somebody say

something.

A. The people that received that e-mail.

Q. I understand. And I'll talk to you

about that later.

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JANE M. FERRANTE, RMR (614) 733-0158

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A. Okay.

Q. But what I am trying to do is find out

from you, 2013 to 2015, based on what I told you

personal knowledge is, direct interaction where you

witnessed it, where you saw it, where you heard it,

did you have any direct knowledge, any direct

personal interaction that would -- would support --

A. I would have to say that e-mail.

Q. That e-mail -- okay. That e-mail was

not -- you did not receive that e-mail, correct?

MR. GITTES: Could we take a short

break? I think I can help you with this.

MR. COGLIANESE: I just --

MR. GITTES: Because I don't think there

is a problem with your question.

MR. COGLIANESE: I understand.

THE WITNESS: It's probably me.

MR. GITTES: I think you are --

Q. And just before we take a break, you did

not receive that e-mail directly from Sergeant

Williams?

A. Correct.

MR. COGLIANESE: Let's take a break.

(Recess taken.)

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JANE M. FERRANTE, RMR (614) 733-0158

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MR. COGLIANESE: We are back on the

record.

Q. So Officer Shaw, before the break we

were kind of talking about the 2013 to 2015 time

period. And my question was: If you had any

firsthand knowledge about Sergeant Moore not liking

African-American officers.

And so I am going to ask: Do you have

any firsthand knowledge, direct knowledge, of

Sergeant Moore not liking African-American officers

in that 2013 to 2015 time period?

MR. GITTES: As you defined it.

MR. COGLIANESE: As I defined it.

A. No.

Q. Okay. You had said before we took a

break that you had issues with him getting you

various types of equipment. And one of the

examples that you gave me was a camera.

Do you know if other officers had that

same -- those same issues with him? Getting

various equipment?

A. To my knowledge, I don't -- I don't

know.

Q. Okay.

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JANE M. FERRANTE, RMR (614) 733-0158

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A. I can only speak for myself.

Q. You also said that you had an

alternative method to be able to obtain the

equipment that you needed. What was that method?

A. Because I was on the human trafficking

task force I had credentials through ICE, and they

would allow me to still come over. Even though I

wasn't on a task force I still held the credentials

and they would allow me to come over and sign out

equipment.

Q. So were you ultimately able to get all

the equipment that you needed through that

alternative route in the '13 to '15 time period?

A. Yes. And I even went out and purchased

my own camera.

Q. So again, I want to focus on the '13

through '15 time period. Did you ever inform your

supervisor that you were having issues getting

equipment from Sergeant Moore?

A. I can't recall specific -- but I -- I

may have because he knew where I was getting my

other equipment from.

Q. Do you recall to the extent that -- it's

one of those questions that sounded coherent in my

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JANE M. FERRANTE, RMR (614) 733-0158

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head. During that time period you said you may

have informed Sergeant Williams?

A. Yes.

Q. Do you recall what you may have -- what

you might have talked to Sergeant Williams about?

A. Mainly talked about trying to work the

hotels and get that completed. That was really my

main task at that time.

Q. Okay. And what about issues that you

had with Sergeant Moore and getting equipment? Do

you recall any conversations that you would have

had there?

A. We may have had conversations, but I

can't recall exactly what was said.

Q. Yeah. And I understand that. We are

looking at eight years ago.

Just to the extent generally you have

any recollections?

A. We talked about a lot of different

topics dealing with Sergeant Moore.

Q. What all did you talk about with

Sergeant Williams relative to Sergeant Moore?

A. We talked about the e-mail that

triggered a lot of this where Eric Moore stated

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JANE M. FERRANTE, RMR (614) 733-0158

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that if Sergeant Williams would have put Officer

Cornett in his place we wouldn't be having these

issues.

Q. Okay. Anything else?

A. We talked about Wes Sorell's statements

that were made about Sergeant Eric Moore.

Q. Anything else?

A. Not that I can recall at this moment.

Q. So let's go back then. As I had said, I

wanted to kind of break it down into the 2013 to

'15 time period while Sergeant Moore was there, and

then once he left. Okay?

A. Okay.

Q. You said that you had talked to Sergeant

Williams about Moore's e-mail relative to Cornett.

Was that -- was Sergeant Moore still there when

that e-mail was sent, or had he left?

A. I want to say he was still there, to my

knowledge.

Q. Okay. What about Wes Sorell's

statements about Moore? Was Sergeant Moore still

there, or had he left?

A. I'm not sure. I think he was -- he was

still there.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Do you recall how many times you had

conversations with Wes Sorell about Sergeant

Moore's comments?

A. I can recall one.

Q. Do you think that was the only time, or

do you think there were more?

A. I want to say it was two because we

talked about setting up the main conversation.

Q. Okay. So to the best of your

recollection can you tell me when that first

conversation with Wes would have occurred?

A. I'm not sure if it was late spring,

early summer.

Q. That would have been 2015?

A. Yes.

Q. What do you recall Wes Sorell telling

you?

A. To my best recollection, he talked about

the comments that he made, the derogatory comments

he made about black officers being lazy, calling

them monkeys, threatening to fight or threatening

to harm them. He stated that this was common

amongst him, and that he got to the point where he

could no longer accept it because of his religious

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JANE M. FERRANTE, RMR (614) 733-0158

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beliefs.

Q. Do you recall anything else Officer

Sorell told you in that first conversation?

A. The comments I just made was the second

one.

Q. Oh, okay.

A. That was the second conversation.

Q. I apologize.

A. The first one, what we did was set up a

day to meet over lunch. That was the first time we

spoke.

Q. Okay. So tell me about that first

conversation. Did Officer -- what did Officer

Sorell tell you?

A. I can't recall.

Q. Was it something along the lines of,

Hey, Karl, I just want to have lunch with you, or

was it more than that?

A. It was more than that. He said he

just -- he wanted to talk to us.

Q. It was you, Officer Sorell. And you

said "he wanted to talk to us," so I assume that

there were other people?

A. It was one other person. It was Officer

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JANE M. FERRANTE, RMR (614) 733-0158

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Whitney Lancaster.

Q. Okay. So during that first conversation

when Sorell told you he wanted to talk to you and

Officer Lancaster, did you ask him any questions or

say anything during that conversation that you

remember?

A. No, I can't remember -- I don't

remember.

Q. What about Officer Lancaster? Do you

remember him saying anything during that

conversation?

A. No.

Q. Where was that? Do you recall where

that conversation took place?

A. The first one or the second one?

Q. The first.

A. The first one would have been in the SRB

office.

Q. And do you recall if anybody else was in

the office with the three of you when you had that

conversation?

A. I'm not sure.

Q. Okay. Anything else at all about that

conversation that you remember that you have not

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JANE M. FERRANTE, RMR (614) 733-0158

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told me?

A. The first one?

Q. Yes.

A. No.

Q. Let's move over to the second

conversation which if I have taken notes

correctly --

A. Okay.

Q. -- it seems like Officer Sorell said

that Sergeant Moore was referring to

African-Americans as lazy, as monkeys, he

threatened to fight or harm them, that it was a

common occurrence, that it got to the point that he

no longer could accept -- and by "he," it was

Officer Sorell -- could no longer accept those

comments because of his religious beliefs? Is that

accurate as far as your recollection of that

conversation?

A. Yes. And he also stated that there was

more things that he hasn't told anyone, and that if

asked the right questions, he would tell -- he

would tell it all.

Q. Do you recall when this second

conversation occurred?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. I can't recall. And it was at a BW-3s

on High -- on South High Street. The person that

would probably know the exact date would probably

be Sergeant Decker.

Q. You had a conversation with Sergeant

Decker about this conversation?

A. Yes. And plus, I gave him a receipt for

what I ate that day.

Q. Okay. Was this conversation you,

Officer Lancaster and Officer Sorell? This second

conversation that we have been talking about?

A. Yes.

Q. Anybody else in that conversation

besides the three of you?

A. No.

Q. What did you do when Officer Sorell told

you these comments that Sergeant Moore was making?

A. I told him he needed to be honest and he

needed to tell the truth.

Q. What else did you say?

A. I can't recall, but just -- but I told

him that.

Q. What about Officer Lancaster? What did

he say?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. I can't remember anything that he --

that he -- he may have not said anything. He may

have just listened because that's what we pretty

much did was listen to Sorell.

Q. What did -- did Officer Sorell say

anything else during the course of that

conversation?

A. I can't recall at this minute.

Q. What did you do with the information

that Officer Sorell gave you?

A. I may have talked to Sergeant Williams,

but I'm pretty sure at this point it was already

common knowledge through the chain of command.

Q. Why do you believe it was common

knowledge?

A. Because I -- if I had my -- if I am

recalling this right, it was right about the same

time he wrote that letter through the chain of

command.

Q. And by, "he," you mean Sorell?

A. Yes. Sorell did.

Q. You did not independently report those

comments to the chain of command --

A. No.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. -- at that time?

A. No.

Q. Why not?

A. Because I think at that time the chain

of command already knew.

Q. Did you independently report those

comments to any Equal Employment Opportunity

officials either at CPD or in the City of Columbus?

A. No.

Q. Why not?

A. I didn't even know who to report that

to.

Q. Have you had training on equal

employment matters while you have been a member of

the Columbus Police Department?

A. Now I have.

Q. When was the last time you had EEO

training?

A. Maybe a year ago.

Q. What about prior to that?

A. Can't recall.

Q. Are you able to access directives from

the -- of the Columbus Division of Police?

A. Yes.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. And during this time period were you

able to access directives at that time?

A. Yes.

Q. All directives, as far as you know?

A. The ones that I'm entitled to, yes.

Q. Okay. Did you ask Officer Sorell what

he meant by, "if people asked the right questions

he would tell all"?

A. Yes.

Q. What did he tell you?

A. Nothing.

Q. Did you have any impression in that

meeting what he might have been talking about?

A. No.

Q. You previously mentioned the e-mail in

which Moore stated that if Williams put Cornett in

his place they wouldn't be having these issues.

How did you come across that e-mail?

A. The e-mail was an e-mail that Officer

Cornett sent complaining about a 50A that he was

asked to go get. There was some type of hidden

agenda in having him go get this 50A. He sent an

e-mail through the chain of command because he

found out people were looking at what he was doing

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JANE M. FERRANTE, RMR (614) 733-0158

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and that he informed the chain of command that

because of these hidden agendas he wasn't going to

go after this 50A. The comments that --

Q. What's -- I am sorry. I was going to

say just for clarification, what's a 50A?

A. A wanted felon.

Q. Sorry. Didn't mean to interrupt.

Sorry. Go ahead.

A. Those comments came from Eric Moore to

Wes Sorell, and I think Scott Watkins down in their

-- the equipment room.

Q. So to the best of your understanding the

e-mail that you are speaking of was an e-mail that

Officer Cornett wrote attributing comments that he

heard from Sorell and Watkins to Moore? Is that

correct?

A. State it again.

Q. To the best of your understanding this

e-mail that we have been talking about was an

e-mail that Officer Cornett wrote. Is that

correct?

A. Yes.

Q. And Officer Cornett was relating a story

that he was told by either Sorell or Watkins saying

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JANE M. FERRANTE, RMR (614) 733-0158

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what they heard -- one of those two individuals

heard Sergeant Moore say? Is that --

A. Correct. And there may have been one

other officer that heard it.

Q. Okay. So at least as far as your

understanding, Officer Cornett -- using that

definition that we used earlier about firsthand

knowledge, Officer Cornett did not have firsthand

knowledge of these comments, to the best of your

understanding. Is that correct?

A. Correct.

Q. How did you come across that e-mail?

A. Officer Cornett was on my same

enforcement team, and we worked a lot together

daily. He told me about the e-mail he sent up and

the reason why he wasn't going after the wanted

felon.

Q. What happened to Officer -- did anything

happen to Officer Cornett for not going after that

wanted felon, as far as you know?

A. Nothing.

Q. Do you know what happened as a result of

that e-mail being sent? Was anything done? If you

know.

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JANE M. FERRANTE, RMR (614) 733-0158

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A. To him sending that?

Q. Let's start there.

A. No.

Q. Do you know if anything -- any of the

allegations in that e-mail were investigated?

A. They weren't investigated. And I think

that's the reason why Sergeant Moore got upset and

said that if they would have put him in his place

then we wouldn't be having this problem.

Q. They were or were not? I am sorry?

A. The e-mail that Officer Cornett sent was

never investigated.

Q. Okay.

A. I think that's the reason why Sergeant

Moore got upset and made the comments that if

Sergeant Williams would have put him in his place

then we wouldn't be having these issues.

Q. Okay. Do you believe that the

statements that were attributed to Sergeant Moore

about Sergeant Williams putting Officer Cornett in

his place were racially motivated?

A. Yes.

Q. Why?

A. Being how it was raised and how blacks

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JANE M. FERRANTE, RMR (614) 733-0158

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have been treated in history, you always refer to

putting blacks in their place. And I find that

racially motivated.

Q. To your recollection did the e-mail say

"putting blacks into their place" or did it say

"putting Cornett into his place," to your

recollection?

A. It was -- it was never put in an e-mail.

You are saying that was in an e-mail. It was never

in an e-mail.

Q. Okay. I apologize. Let me -- let's

back up and I'll try and clean everything up.

So Moore's comment specifically -- Moore

never wrote those in an e-mail, correct?

A. Correct.

Q. Cornett wrote an e-mail after being told

of the comments by Sorell or Watkins, correct?

A. No.

Q. Correct?

A. Wrong.

Q. Okay. What happened?

A. And a lot of it is starting to come back

to me now. There was a wanted felon out of a case

that they wanted found.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Okay.

A. And I don't know why they just didn't go

look for him themselves.

Q. Who is the "they," if you recall?

A. Somehow Officer Jeremy Ehrenborg got

involved.

Q. Okay.

A. Because I think -- I want to say he was

also looking to talk to this person. So someone

came to Officer Cornett -- Cornett and asked him if

he could find this person. So he went through old

police reports and he started looking at addresses

where this person may be residing. I want to even

say that he went so far as to get a court order to

ping his cell phone.

Q. "He," being Cornett or Eric Moore?

A. Officer Cornett --

Q. Okay.

A. -- was pinging his phone. Somehow other

people were getting into -- because it was -- it

was a Sprint phone. And what you do is you send

the court order to Sprint and then they set up the

ping and you are sent on a map or you can get on

the computer and find out where the phone is

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JANE M. FERRANTE, RMR (614) 733-0158

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located. He was doing that. But other people were

doing -- going back and looking at his ping map and

going out too.

Q. Okay.

A. So that's when he become upset saying

that you asked me to do this, but yet other people

are out there running around trying to catch this

guy. And that's when he said there is some type of

hidden agenda -- and he didn't know what -- why.

So he didn't want any parts of that.

Q. Okay. So the "he" that did not want any

parts of hidden agenda was Cornett?

A. Officer Cornett.

Q. Who put the e-mail together that you are

talking about? Do you recall?

A. Officer Cornett put the e-mail together.

Q. Okay.

A. I want to say he sent it to Sergeant

Williams and he sent it to Lieutenant Kimmerling.

Q. And we've talked about the reasons why

you thought that the statements attributed to Moore

in that e-mail were racially motivated. Were there

any other reasons besides what you have told me

that you thought that those comments that were

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JANE M. FERRANTE, RMR (614) 733-0158

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attributed to Moore in that e-mail were racially

motivated?

A. You are getting the facts messed up

again.

Q. Okay. Help me out.

A. Sergeant Moore never put that in an

e-mail.

Q. I understand that.

A. But you are saying those statements were

made in an e-mail.

Q. You are saying Cornett -- so the e-mail

I am talking about is the e-mail that Cornett sent.

A. Correct. Explaining the reasons why he

wasn't going --

MR. GITTES: Could I?

MR. COGLIANESE: Go ahead.

MR. GITTES: Could I try to help?

MR. COGLIANESE: Yes. Go ahead.

MR. GITTES: I think you are being

asked: Were there any other reasons you believe

the statement attributed to Moore about putting

Cornett in his place would be racist, besides the

fact -- you know, put in place historically as you

have explained? Other things? Any other things

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JANE M. FERRANTE, RMR (614) 733-0158

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that make you think that, as you have testified

here?

MR. COGLIANESE: Thank you. That was

much clearer than I could have asked it. I'll give

you the rest of the depo if you want, Fred.

MR. GITTES: I want to be as efficient

on both sides.

MR. COGLIANESE: We do.

A. The only other things are the comments

he made before about referring to blacks as monkeys

and apes.

Q. Okay. Any other reasons?

A. Not that I can recall right now.

Q. Okay. Now, did Officer Cornett show you

the e-mail that he put together? Did he send it to

you? Did he just tell you about it? How did you

learn about it?

A. He told me about it.

Q. What do you recall him telling you?

A. He was upset because he felt like he was

being put in the middle of something, and he didn't

know why.

Q. What was your response when he told you

this? To him?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. I can't remember.

Q. Did you advise him to do anything?

A. No, I don't think so.

Q. Why not?

A. He had done it. He excused himself from

that situation.

Q. So did you report any of the information

that Officer Cornett gave you to your chain of

command?

A. No, I didn't.

Q. Why not?

A. Officer Cornett did.

Q. Did you report it to anybody in the City

of Columbus?

A. No.

Q. Why not?

A. Officer Cornett sent it and had talks

with the chain of command about it.

Q. What did Officer Cornett tell you about

his talks with the chain of command?

A. I can't recall.

Q. Besides these two incidences that we

have talked about, any other issues with Sergeant

Moore that you had?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. What time frame do you want to use?

Q. So we have already talked about 2013 to

'15 and I think you have said at that point there

was nothing more?

A. Okay.

Q. Is that correct? I just want to make

sure. I am not trying to --

A. To my knowledge.

Q. Yes. So he leaves.

A. Okay.

Q. Anything -- any issues that you had with

Sergeant Moore when he left SRB?

A. Yes.

Q. What are they?

A. Trying to get a job in narcotics.

Q. Anything else?

A. Trying to get another job in narcotics.

Q. Anything else?

A. Yeah. Statements that he made about my

hotel case.

Q. "He," being who?

A. Sergeant Eric Moore.

Q. Anything else?

A. Nothing that I can remember right now.

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JANE M. FERRANTE, RMR (614) 733-0158

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Maybe later something will.

Q. And that's fair. And I'll give you an

opportunity to. When we finish up I'm going to --

and if I don't, holler at me. But I will ask you

if there is anything else when we finish up.

So at least as of right now the best

that you can recall, issues that you have had with

Sergeant Moore from the time he left SRB were

trying to get a job in narcotics, trying to get a

second job in narcotics, and making statements

about your hotel case. And there may be others,

but right now you can't remember.

So let's -- go ahead. You look like you

are going to say something.

A. Yeah. There was one other narcotics job

I think when he first went over there.

Q. Okay. Anything else come to mind?

A. No.

Q. Okay. So three narcotics jobs and a

statement about a hotel case. Just for simplicity

let's start with the hotel case.

A. Okay.

Q. What did he say about the hotel case

that you thought --

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JANE M. FERRANTE, RMR (614) 733-0158

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A. He had told people in SRB that -- one of

them was Officer Richard Moore, Lieutenant

Echenrode -- that the cases I was working on would

never go anywhere. That it was a waste of time.

Q. You did not hear Sergeant Moore make

those statements, did you?

A. No.

Q. How did you learn about them?

A. Through Officer Richard Moore.

Q. What did Officer Richard Moore tell you?

A. That Sergeant Eric Moore was going

around bad-mouthing me, saying that my cases

wouldn't go anywhere.

Q. Did he tell you anything else?

A. Not that I can remember right now.

Q. Do you know why Sergeant Moore would

have made those comments about your hotel case?

Your hotel cases?

A. With all the facts and everything that

was said because I considered him to be a racist.

Q. Do you have any firsthand knowledge as

to why he said that? Again, going back to the

definition that we used earlier, do you have any

firsthand knowledge as to why Sergeant Moore would

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JANE M. FERRANTE, RMR (614) 733-0158

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have said that about your hotel cases?

A. No.

Q. Do you know if he made comments about

other individuals' investigations at that time?

A. No.

Q. You've told me all of the reasons why

you believe Sergeant Moore to be a racist?

MR. GITTES: Are you asking him to tell

you?

Q. I am asking if -- Officer Shaw, if you

have told me all of the reasons why you believe

Sergeant Moore to be a racist?

A. I -- you want -- I gave you a list.

Q. And I am asking you: Is that all of it?

A. Those are some of the ones that come to

mind right now.

Q. Okay. Anything else?

A. No.

Q. Okay. And I know the time frame on this

is probably all going to run together, but to the

best that you can do, you have said three jobs in

narcotics. To the best of your recollection can

you run me through what happened with those

positions? If it's easier for you to do job by

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JANE M. FERRANTE, RMR (614) 733-0158

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job, great. If it's just easier to kind of free

form and talk generally, that's fine.

A. The first job would have been on his

team when he first got there. There was an

opening. And I bid on it. And it got down to me.

Q. And "his" team is Sergeant Moore?

A. Yes. Sergeant Moore. I think it was

Investigative C.

Q. Okay.

A. I received a phone call from an officer,

and I can't recall his name right now. But he

really wanted that job. So I -- I passed on it.

John -- his name is John Whittaker.

Q. Okay.

A. He was already in narcotics, but he

wanted to move to that -- to that team.

Q. Okay.

A. So I passed on it so it would get down

to him.

Q. Okay. Anything else you remember about

that first job? And I'll come back and ask more

questions. But --

A. Not that I can remember.

Q. Have you worked with John Whittaker

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JANE M. FERRANTE, RMR (614) 733-0158

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before?

A. Yes.

Q. When did you work with -- I assume it's

Officer Whittaker?

A. Yeah. He's -- or detective.

Q. Okay.

A. It would have been when he first came on

the police department. And it would have been

maybe late -- early 90's.

Q. Okay. Do you recall what Officer

Whitaker's race is?

A. White.

Q. So I just want to make sure that I

understand kind of what was going on. You had

posted for this position?

A. Yes.

Q. And at least to the best of your

knowledge the seniority list had gotten to you. Is

that correct?

A. Yes.

Q. And you were offered the position?

A. No. He contacted me --

Q. "He," being Mr. Whittaker?

A. Mr. Whittaker.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Okay.

A. And I informed the sarge that I was

passing on it.

Q. Which sergeant was that?

A. Sergeant Moore.

Q. How did you inform Sergeant Moore?

Telephone? E-mail? Don't remember?

A. Don't remember.

Q. You said that he -- that "he," being

Officer Whittaker, had already been in narcotics

but he wanted to switch teams?

A. Yes.

Q. Did he tell you why he wanted to switch

teams?

A. I knew him and Sergeant Moore were

friends.

Q. So you voluntarily chose to pass on that

job because Officer Whittaker asked you to. Is

that --

A. Yes.

Q. Okay. Anything else about that first

posting that you haven't told me that you recall?

A. No. That's it.

Q. That's it, okay.

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JANE M. FERRANTE, RMR (614) 733-0158

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Then you said there was a second

narcotics job?

A. Yeah. Actually, there were two posted

at the same time.

Q. Okay.

A. So those two were two that were posted.

Q. Okay.

A. Eventually -- and then eventually one

was canceled and then re-posted.

Q. So the one that was canceled was the one

that went to Officer Ehrenborg, is that right? To

the best of your recollection?

A. Yes.

Q. Officer Whittaker, however, was allowed

to stay in that position? Do you know?

A. Yeah.

Q. Okay.

A. Yes.

Q. What do you recall about the second

posting at that same time, the one that went to

Officer Ehrenborg?

A. It was posted. I think I received an

e-mail from Sergeant Moore stating that I would

have to interview for that job, and that Lieutenant

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JANE M. FERRANTE, RMR (614) 733-0158

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Brust would -- and Commander Cameron would be

conducting that interview.

Q. Okay. Was that for the Ehrenborg job or

was that for both of them, if you recall?

A. It would have been for both of them.

Q. Okay. Previous to your posting for

these narcotics positions had you ever been

interviewed for a position at CPD outside of

applying to the academy?

A. No.

Q. Had you ever heard of officers being

interviewed for postings?

A. No.

Q. Do you know why Sergeant Moore told you

that you needed to be interviewed?

A. I can't recall him giving me a reason

why.

Q. You can't recall him telling you why?

A. Right.

Q. Okay. Did you have any speculation as

to why Sergeant Moore told you you needed to be

interviewed for the job?

A. No, but found out after the fact.

Q. So at that period of time -- I just want

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JANE M. FERRANTE, RMR (614) 733-0158

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to make sure that we are clear. At that period of

time you did not have any supposition, but later on

you came to a conclusion. Is that fair?

A. It wasn't a conclusion. It was that he

was given an order not to talk to or deal with me

and Officer Whitney Lancaster.

Q. And how did you learn that?

A. Through this --

Q. Through the litigation?

A. Through the litigation.

Q. Okay. When Sergeant Moore told you that

you needed to interview with Lieutenant Brust and

Commander Cameron, what did you do?

A. I'm not sure. Through that same e-mail

chain we set up a time and date when I was coming

over to narcotics to interview for it.

Q. Okay. Tell me about the interview.

A. On that day of the interview I received

a text message from Detective Heidi Malone stating

to me that Eric Moore and Commander Cameron are

running around the office trying to figure out a

way to stop me from getting that narcotics job.

Q. How do you know Officer Heidi Malone?

A. I had worked previously with her in vice

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JANE M. FERRANTE, RMR (614) 733-0158

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for the entire time that I was in vice.

Q. Did you talk to her about the text

message? Call her? Anything else? Have any other

conversations with Officer Malone about the text

message?

A. I may have texted back, Okay. But I

talked to her when I came into the office.

Q. Tell me about the conversation that you

had with her.

A. It was brief. She just pretty much

reiterated what she put in the text, that they were

trying to stop me from getting the job.

Q. Did she tell you why they were trying to

stop you from getting the job?

A. No, I can't remember the --

Q. Just generally. I know you are not

going to remember actual specific words.

A. It was something because Cameron didn't

want me there because of something that happened or

I did when I was there before.

MR. GITTES: Rich, would you mind if I

just take a short break and heat up some coffee?

MR. COGLIANESE: We can take a break.

(Recess taken.)

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JANE M. FERRANTE, RMR (614) 733-0158

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MR. COGLIANESE: We are back on the

record.

Q. Officer Shaw, before we broke we were

just starting to talk about the interview that you

had with Lieutenant Brust and Commander Cameron.

A. Yes.

Q. Tell me what you remember about that.

Well, actually, let me strike that. Let me back up

even a little bit further.

We were talking about Heidi Malone?

A. Yes.

Q. And Officer Malone. What do you recall

her telling you when you got in there?

A. Pretty much the same, what she put into

the text message that they were trying to figure

out a way of me not getting that job.

Q. Did she tell you why they were trying to

figure out a way to keep you from getting the job?

A. Something to deal with me being there

before.

Q. Did she tell you anything else?

A. Not that I can recall.

Q. Do you recall what you told her?

A. I may have told her, thank you. But

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JANE M. FERRANTE, RMR (614) 733-0158

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other than that --

Q. Nothing substantive that you recall?

A. No.

Q. When you say you "being there before,"

what does that mean?

A. I was in narcotics before.

Q. And we had talked about that.

A. That time frame.

Q. Okay. Was there anything about your

time in narcotics previously that you are aware of

that would have Lieutenant Brust not want you back

in narcotics?

A. No.

Q. What about Commander Cameron? Is there

anything in your time period previously being in

narcotics that you think would make Commander

Cameron not want you in narcotics?

A. It was nothing I did. It was what he

did.

Q. What did Commander Cameron do?

A. He put a list out of officers that he

felt was not performing or doing their job.

Q. Did he explain to you, I assume, that

you were one of the people on the list that he

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JANE M. FERRANTE, RMR (614) 733-0158

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thought was not doing his job?

A. Yes.

Q. Do you recall who the other officers

were on that list?

A. No.

Q. Did -- do you know why Commander Cameron

would have put you on that list?

A. No.

Q. Do you have any supposition why

Commander Cameron would have put you on that list?

A. He said I did absolutely zero work for

two years.

Q. Did Commander Cameron tell you how he

came to that conclusion?

A. Something about EARS.

Q. I assume that's an acronym?

A. EARS is an acronym for -- for a form

that you fill out. Like if you execute a search

warrant you would fill this out notifying everybody

that you did a search warrant.

Q. Oh, okay. That's much better than --

A. Yes.

Q. During the period that you were in

narcotics that he was talking about did you fill

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JANE M. FERRANTE, RMR (614) 733-0158

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those reports out?

A. Yes.

Q. Do you know why they did not make it

into the report that he had?

A. Didn't look properly. He was told he

was wrong by Lieutenant Lang.

Q. How do you know Lieutenant Lang told

Commander Cameron that he was wrong?

A. I was there.

Q. Okay. Describe that conversation the

best you recall it.

A. Lieutenant Lang came to me first,

stating that my name was on this list. And we both

couldn't understand why. At that time frame I was

on the human trafficking task force, and Lieutenant

Lang who was also the lieutenant in vice, was also

the commander of that human trafficking task force.

Q. Okay. So what did Lieutenant Lang tell

you when he came to talk to you? Just that your

name was on the list?

A. That he knew I did work. We just

executed a search warrant on a human traffic. We

were -- we couldn't understand it.

Q. Okay.

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JANE M. FERRANTE, RMR (614) 733-0158

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A. So he went to him, commander, and showed

him things that I have done and things that I have

put together in the last two years. But my name

still stayed on the list.

Q. And you went with Lieutenant Lang when

he went to speak with Commander Cameron?

A. No.

Q. Okay.

A. He went separate. But me and Lang had

conversations before he approached the commander

trying to have my name taken off that list.

Q. Okay. And then maybe I misunderstood.

A. I may have -- may be my fault.

Q. No. That's fine. I just wanted to be

clear for the record because I thought you had said

that you and Lang went and talked to Cameron.

You talked to Lang and then Lang talked

to Cameron?

A. Yes.

Q. Okay. After Lang talked to Cameron I

assume he came back and spoke with you. Is that

correct?

A. Yes.

Q. Do you recall what Lang told you at that

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JANE M. FERRANTE, RMR (614) 733-0158

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point?

A. I'm not sure 'cause I can't remember.

It's been so long ago. At some point Cameron

removed me from the human trafficking task force,

and I can't remember if it was before or after

this.

Q. "This," being the interview for the

investigator's position or "this" being the time

that Lang and Cameron talked?

A. I thought the question was about --

Q. Maybe it's easier -- because I think I

misunderstood the time frames that you were talking

about. You said that at some point Cameron removed

you from the human trafficking task force?

A. Right. But I thought the initial

question was dealing with Cameron.

Q. It was.

A. And about what was said in the

interview.

Q. Why don't we start over so that way you

and I are both on the same page?

A. Okay.

Q. So when you were in narcotics the first

time Cameron had you down as -- for a person on the

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JANE M. FERRANTE, RMR (614) 733-0158

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list who wasn't doing any work?

A. Yes.

Q. And so when you found out about it you

and Lieutenant Lang spoke?

A. Yes.

Q. Then Lieutenant Lang went and spoke to

Cameron?

A. Yes.

Q. You were not present for that

conversation?

A. Correct.

Q. Okay. And then Lieutenant Lang reported

back to you about the conversation he had with

Cameron?

A. Yes.

Q. What do you recall Lang telling you

about the conversation he and Cameron had?

A. That there was nothing more I could do

because I was working. I was trying to put

together cases. So what I wound up doing was

giving him another list of four or five people that

we could probably go after for human trafficking,

and we executed a couple more search warrants.

Q. Do you know why Cameron never corrected

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JANE M. FERRANTE, RMR (614) 733-0158

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that list?

A. No.

Q. Do you have any supposition as to why

Cameron never corrected that list?

A. To -- now after things have been said, I

think he was being racist.

Q. Why do you think that?

A. Comments he made during the interview

almost mirror what comments that Eric Moore stated.

Q. And what comments were they that he

made?

A. Blacks being lazy, blacks not wanting to

work. Not having high ethics. Not being -- being

able to be trusted.

Q. What else did he say during the

interview?

A. He brought up something about Rampart,

California, which I didn't even know what that was

until I left and I Googled it.

Q. What else did he say?

A. During the interview he brought up

that -- the EARS thing again. And I told him in

the interview I could dispute every fact on that

list because I did do work. The work I was doing

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JANE M. FERRANTE, RMR (614) 733-0158

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-- I mean led up to us getting the human

trafficking task force. I was doing search

warrants. One of the search warrants I wrote -- I

had was the case that was the very first case for

the human trafficking task force.

Q. What else do you recall him saying?

A. He questioned me not being able to do

police reports or put them in the proper data

bases, one of them being ACSIS. And I was sent to

the trainer's school as a trainer.

Q. What else do you recall him saying?

A. I think they -- they asked me if I could

work for Eric Moore, and I told them, yes. At the

end I informed them that I was still interested in

the job.

Q. What else do you recall?

A. All right. Now that's all I can recall.

Q. Okay. And so I just wanted to make sure

that I understood as far as this was an interview

for both the position that went to Ehrenborg and

the position that went to -- my notes are --

MR. GITTES: Whittaker.

Q. -- Whittaker?

MR. COGLIANESE: Thank you.

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JANE M. FERRANTE, RMR (614) 733-0158

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A. No. The Whittaker one was totally

separate.

Q. I thought -- okay. Go ahead. I am

sorry.

A. These two were posted after Whittaker

took his job. Like months. Two months. That

would have been like in August of 2015.

Q. Okay. So --

A. These two were posted in the fall.

Q. Okay. I'm sorry. I thought that when

we were talking previously there were two positions

posted at the time that Whittaker took the

position?

A. No.

Q. Okay. So it was just the Whittaker

position?

A. Just the one when he took it.

Q. You were not interviewed for that

position?

A. No.

Q. Is that right?

But you passed seniority-wise to allow

Officer Whittaker to take the job?

A. Yes.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Were you -- had SRB been abolished at

that point in time?

MR. GITTES: Which point? I am sorry.

I am confused.

MR. COGLIANESE: Oh, I am sorry.

Q. When Whittaker was filling his position

had SRB been abolished?

A. No.

Q. Did you have an understanding that SRB

was going to be abolished at that time?

A. No.

Q. When did you first learn that SRB might

be abolished?

A. In the fall, I think. I can't remember

the exact time. It was being talked about, but we

-- I don't think we officially got notification.

Q. So when do you recall it first being

talked about? Would that have been fall of '14?

A. It would have been fall of '15.

Q. Fall of '15, okay. And then you

officially got notification sometime after that?

A. Yes.

Q. You said that Commander Cameron during

the interview with you and Lieutenant Brust said

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JANE M. FERRANTE, RMR (614) 733-0158

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blacks are lazy?

MR. GITTES: Objection.

A. That Cameron said that?

Q. Yes.

A. No. I said --

MR. GITTES: Can we go off the record

because I want to avoid confusion.

(Discussion off the record.)

MR. COGLIANESE: Let's go back on.

Q. We are back on the record. Let me for

purposes of making sure the record is clear -- and

I completely understand your answer. And Officer,

please, I never want to put words in your mouth.

Today is for you to testify.

A. Okay.

Q. So you show up for the interview?

A. Yes.

Q. What do you recall Cameron and Brust

telling you as you are being interviewed?

A. First I got there and Brust brings me

back into the conference room.

Q. Okay.

A. And he tells me he doesn't understand

why we are doing this, why they are interviewing me

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JANE M. FERRANTE, RMR (614) 733-0158

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for a job that goes strictly by seniority.

Q. Uh-huh.

A. I may have told him that I -- I mean I

can work for Eric Moore. I can work for anybody,

can get along. And then that's when I think

Cameron comes in and we start the interview.

Q. Okay. What do you recall that Commander

Cameron said during the interview?

A. Something that he has reservations about

me coming back to narcotics since I was there

before. And then he brings up the fact that in the

two-year span I did absolutely zero work. Never

documented my work. Wasn't putting things into the

proper data bases.

Q. Okay.

A. And I told him I dispute everything he

just said.

Q. Okay. Anything else that you remember

Commander Cameron saying during that interview?

A. Just the fact he brought up -- what --

he doesn't -- he didn't want what happened in

Rampart, California to happen here because it would

bring down the -- something to the effect it would

bring down the division or bring down the narcotics

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JANE M. FERRANTE, RMR (614) 733-0158

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bureau.

Q. Okay. Anything else that you remember

him saying?

A. Not -- not now, I can't.

Q. What do you remember Lieutenant Brust

saying during the interview?

A. Besides our brief conversation before

Cameron came in?

Q. Yes.

A. Nothing.

Q. So we had previously talked about

whether or not Cameron's statistics with you during

your previous time in narcotics were correct. And

I just want to make sure that I understand. During

this interview when he raised that issue, you let

him know that you disagreed. Is that correct?

A. Correct.

Q. Okay. What was his reaction to you

disagreeing with him on those statistics during the

interview?

A. He had a piece of paper on the desk with

the names and the zeroes by everybody's names.

When I confronted him on it and said I can prove

him wrong he takes that back and says, Well, we are

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JANE M. FERRANTE, RMR (614) 733-0158

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not going to go into this right now.

Q. Okay. Anything else you remember about

talking about those statistics?

A. No.

Q. Okay. And then you said he mentioned

Rampart, California?

A. Yes.

Q. And I just want to make sure it's clear.

At that period in time you did not know anything

about Rampart, California. Is that correct?

A. Correct.

Q. You said you ultimately went out and

Googled Rampart?

A. Yes.

Q. What did you learn through Googling?

A. Rampart, California is -- like our

precincts are numbered. Theirs, I guess, have

names. And it was a precinct in California where

officers were, I guess, shooting people, planting

dope, stealing guns, selling guns. It was just

corrupt.

Q. In fact, ultimately the United States

Department of Justice ended up entering into a

consent decree with the Los Angeles Police

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JANE M. FERRANTE, RMR (614) 733-0158

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Department. Is that correct?

A. Yes.

Q. And that was as a result of all of the

behaviors at Rampart?

A. Yes.

Q. Is it your understanding that both

African-American and Caucasian officers were

participating in the, shall we say, illicit

activity?

A. I'm not -- I'm not sure. It was

probably both.

Q. Okay. But you don't know one way or the

other?

A. I don't know one way or the other.

Q. Okay. Anything else that you recall

about the interview with Brust and Cameron that we

have not spoken about?

A. I can't recall at this time.

Q. Okay. You believe that at this period

of time that you would be able to work with

Sergeant Moore. Is that right? By this period of

time? I mean when you were interviewing with Brust

and Cameron?

A. Yes.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Has that position ever changed?

A. Yes.

MR. GITTES: Sorry. I think you two are

understanding each other. I don't want to get in

the way. Go ahead.

MR. COGLIANESE: Thanks.

Q. When did you come to the conclusion that

you were not able to work for Sergeant Moore?

A. When I was shown a text message.

Q. Do you recall what the text message was?

A. Something to the effect that I better

not take the narcotics job, that he didn't expect

this from -- meaning Richard Moore, but he would

expect this from the brothers.

Q. Who showed you the text message? Do you

recall?

A. Officer John Evans.

Q. Did Officer Evans tell you why he showed

you the text message?

A. Probably because he didn't want me to

take that job and something happen to me.

Q. What was your reaction when you saw it?

The text message?

A. Anger. Fear.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. What did you do?

A. Talked to family. Decided it might be

time to put a security system on my home. It's --

sometimes -- I mean it's hard because you go

through a lot of different emotions. Someone

doesn't like you because of the color of your skin,

it's not about you being able to do the job. He

just doesn't like you because of the color of your

skin.

Q. So you said you talked to family and you

put a security system on your home. Did you do

anything else after reviewing that text message?

A. I tried talking to him to forward me or

give someone a copy of the e-mail -- I mean the

text message. He told me he wouldn't delete it.

That if I ever needed it, then he would save it.

Q. Did you do anything else?

A. I probably -- I can't -- probably talked

to people about it. I know I talked to Sergeant

Williams about it. I talked to Officer Richard

Moore about it. I talked to Officer Cornett about

it. And it may have been a couple more.

Q. Anything else?

A. No, not right now.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. What do you recall talking to Sergeant

Williams about? Just --

A. We talked about -- because he was

friends with John Evans, and he was going to try to

talk to John Evans about him giving him the text

message.

Q. Do you know if Sergeant Williams did

talk to John Evans?

A. I think he did.

Q. Do you recall if Sergeant Williams

talked to you after he spoke with Officer Evans?

A. He may have because John Evans never --

the only person he gave the text message to was

Sergeant Decker in internal affairs.

Q. Okay. Do you recall anything else about

your conversations with Sergeant Williams that you

haven't told me about the text message?

A. No, I can't recall.

Q. Okay. You said you spoke with Richard

Moore about the texts message. What do you recall

about those -- well, first off, how many

conversations did you have with Officer Moore?

A. A few. I don't know the exact numbers.

Q. More than -- more or less than ten?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. Yeah. Less than ten.

Q. Okay. Less than five?

A. Probably -- maybe five or less.

Q. Okay. What do you recall about the

conversations with Officer Moore about the text

message?

A. He stated it wasn't him that complained

about Eric Moore or him complaining about the way

the job was filled.

Q. And that was the job that went to

Officer Ehrenborg, is that right?

A. Yes.

Q. Do you recall anything else about your

conversations with Officer Moore about the text

message?

A. Did I have conversations with Eric

Moore?

Q. Richard Moore. I am sorry. You said --

we were talking about your conversations with

Richard Moore, and you just said that it wasn't him

that complained about the way the job was filled.

I am just trying to figure out if there was

anything else.

A. I think that was it.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Okay. What about Officer Cornett? What

do you recall -- well, first off, how many

conversations do you recall having with Officer

Cornett about the text message?

A. Probably just a few.

Q. And again, if you can ballpark? Five or

less? Ten or less?

A. About that?

Q. About that text message.

A. About that text, probably five -- five

or less.

Q. What do you recall about those

conversations?

A. It upset him because he was already

going through the hard time with the threats. And

it pretty much confirmed to him that these threats

were real.

Q. What threats were -- was Officer Cornett

going through at that time?

A. Eric -- that Eric Moore threatened or

said that he should take them out back and do

physical harm to him. Another thing that was

brought up was that Eric Moore had made a statement

that he could have his job in two weeks if he

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JANE M. FERRANTE, RMR (614) 733-0158

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wanted to.

Q. Okay. Any other threats that you were

aware of that Officer Cornett was dealing with at

that time?

A. Nothing comes to mind at this time.

Q. How did you learn that Sergeant Moore

had threatened to take Officer Cornett out back and

do him physical harm?

A. That came from Sorell.

Q. Officer Sorell told you that?

A. No. He told Sergeant Williams and

Cornett that.

Q. Okay. And then Officer Cornett told you

that Officer Sorell told him that?

A. Yes.

Q. Do you recall when? The approximate

time frame of that?

A. No.

Q. Anything else that you recall about that

threat that we haven't talked about?

A. The threat on the text or the threat

that he made toward Cornett?

Q. The threat that he made toward Cornett.

A. No.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. I am sorry. No?

A. No, I can't recall.

Q. Okay. And then you said Eric Moore

threatened Cornett that he could have his job in

two weeks if he wanted to. What do you know about

that?

A. That sounds like a threat that he could

have him fired.

Q. I assume that you did not hear Sergeant

Moore make that threat. Is that correct?

A. Correct.

Q. Officer Cornett informed you of that?

Or how did you learn about that?

A. Actually, that part came from Officer

John Evans. The same one that had the text

message.

Q. When did Officer Evans tell you about

the threat on Cornett's job?

A. He went to Sergeant Williams and Officer

Cornett after he had -- after he heard it.

Q. Do you recall when that was? Month/

year, or season/year?

A. It would have been around the same time

frame as Sorell came -- it was after Sorell came

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JANE M. FERRANTE, RMR (614) 733-0158

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forward.

Q. Okay. So timing-wise I want to make

sure that I am kind of clear where we are at on the

timeline. You were informed to show up for an

interview with Brust and Cameron. And as you are

going to the interview you got the text from Heidi

Malone. You go and you have the conversation with

Brust and Cameron. You learned of the text that

Moore sent about better not take the job.

Is that when you turned the job down?

Or what happened once you -- once you learned of

that text?

A. Once I learned of the text is when I

contacted Lieutenant Brust.

Q. Okay. And why did you -- what did you

tell Lieutenant Brust when you contacted him?

A. Through the e-mail I think I put in

there that I still was interested in the job but I

needed to meet with him first before making a final

decision.

Q. Okay. And did you ultimately meet with

Lieutenant Brust?

A. Yes.

Q. Tell me about the meeting to the best of

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JANE M. FERRANTE, RMR (614) 733-0158

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your recollection.

A. He made a comment that he doesn't

understand why all this was happening, that he

considered Cameron a bully, and didn't understand

why he was doing this to me. I told him that

Sergeant Moore had made a threat that I better not

take the job. And he said that he would try to

protect me, but he wouldn't be around me all the

time to protect me.

So I told him, then I'm going to have to

pass at this time on that job.

Q. In your role as a police officer have

you ever filed charges against an individual for

threats that they have made? Criminal charges?

A. Yes.

Q. Did you file criminal charges against

Sergeant Moore for the threats that he made?

A. No.

Q. Why not?

A. It was going -- it was being

investigated by internal affairs. I gave internal

affairs all the information that I had, thinking

that the police department, internal affairs, the

chief, the higher-ups, would take those facts and

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JANE M. FERRANTE, RMR (614) 733-0158

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do something with them.

Q. Any other reasons why you didn't file

criminal charges against Sergeant Moore for the

threats?

A. That's it.

Q. At that period in time did you have the

authority to file criminal charges against Sergeant

Moore for the threats he made?

A. Maybe if I had a copy of the text

message, which I never was given but Sergeant

Decker was given. He could have filed charges.

Q. My question was: Could you have filed?

Did you have the ability to file?

MR. GITTES: Objection. Go ahead.

A. It would have been a better case if I

had a copy of the text message.

Q. I understand it may have been a better

case. But my question was: Could you have?

MR. GITTES: Objection. Go ahead and

answer.

A. I may have been able to. I'm not sure.

Q. Okay. To the best of your

understanding, explain to me what your obligation

is as a member of the Columbus Division of Police

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JANE M. FERRANTE, RMR (614) 733-0158

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if you find out criminal activity has occurred.

What are you obligated to do?

A. To report it or take action.

Q. What kind of reports are you obligated

to engage in? You said you have got a couple of

obligations, to report or to take action?

A. Right.

Q. What are the reports that you are

talking about?

A. It all depends on the circumstances, the

situations. There are different types of reports

that you would take. What type of reports are you

talking about? Or what -- what instances are you

talking about?

Q. Well, you said you have got an

obligation to report at certain times. What kind

of reports are you obligated to make? That's what

I am trying to find out. Just -- I am talking like

30,000-foot view here. You find out a criminal

action has occurred. You said one of your

obligation may be to report?

A. Right.

Q. What would those reports be? To whom

would they be made? What would you do?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. We have a PremierOne system that you put

all your police reports in. And it's routed --

depending on the title that you give that police

report, it's routed to that bureau. Since I'm not

a detective and I'm just -- take, for example, I'm

a high school resource officer. Most of the

reports that I take are assaults or disorderly

conducts. So when I put those in the system they

go into PremierOne. If it's an assault or maybe if

I had a robbery, another kid robs another, then

that gets routed to the robbery.

Q. Okay. So what if you learn as a school

resource officer that Student A makes a threat

against Student B that you believe might be

something that Student A could engage in. What

would you do with that?

A. It all depends on what is said. Is it a

threat of violence? Then that becomes -- it could

be simple assault or it could be a menacing, making

threats. If I have facts to back that up I make a

police report and I issue a summons. I never

arrest kids. I always issue summons.

Q. Okay. You recorded the conversation

that you had with Lieutenant Brust, correct?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. Correct.

Q. Why did you do that?

A. To protect myself and to make sure that

it's not his word against my word, that I had

documentation of everything that was said.

Q. Did you tell Lieutenant Brust you were

recording it?

A. No.

Q. Why not?

A. Didn't have to. Law.

Q. When did you make the decision to record

Lieutenant Brust?

A. To make sure I document everything.

Q. When? Not "why." When?

A. When?

Q. Not "why." When?

A. After recording the Cameron interview I

decided then anytime I go into a meeting I'm

recording it. I needed proof. And that was a way

of getting proof.

Q. When did you first -- and I don't want

to know what. But when did you first speak to a

lawyer about your employment at the Columbus

Division of Police?

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JANE M. FERRANTE, RMR (614) 733-0158

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MR. GITTES: Objection.

MR. COGLIANESE: I just want time. I

don't want conversations.

MR. GITTES: Don't -- you can answer

that question.

Q. Just when?

A. When?

Q. Yes.

A. Probably was the start of August with

Eric Moore. I can't remember the exact date.

Q. So sometime around August 2014?

A. It would have been '15.

Q. August 2015?

A. Yes.

Q. So it would have been before or after

the conversation with Lieutenant Brust that you

recorded?

A. Yes.

Q. Before or after? I am sorry.

A. It was before Lieutenant Brust.

Q. How many conversations have you taped

since you -- yeah. Let me strike that. How many

conversations at the Columbus Division of Police

that you have been involved in have you taped?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. Dealing with this or through my entire

career?

Q. Dealing with this.

A. All the ones that I have turned over.

It's probably, maybe, ten or under.

Q. Were there any conversations that you

initially taped that you then deleted the

tape-recording, the audio recording?

A. Yeah. There was one.

Q. What was that?

A. This was way before the Eric Moore

thing.

Q. What was it?

A. It was a conversation I was told by the

safety director to meet with Cameron and the people

in the human trafficking task force about the

hotels.

Q. And that would have been Director

Speaks?

A. Yes.

Q. Why did you record Director Speaks?

A. I didn't -- he wasn't in the meeting.

When I went over to narcotics to sit down with

Cameron Kimmerling and Sergeant Chrysler I recorded

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JANE M. FERRANTE, RMR (614) 733-0158

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it.

Q. Why did you decide to record that

meeting?

A. Because I knew Cameron was going to be

there and there was going to be some issues. They

were having issues with me putting together RICO

cases on human trafficking and drugs.

Q. Why did you decide to erase that

recording?

A. I thought I was saving it. And I hit

"delete" by accident. And I couldn't get it back.

MR. COGLIANESE: Let's go off the record

for a minute.

(Discussion off the record.)

(Lunch recess taken.)

- - -

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JANE M. FERRANTE, RMR (614) 733-0158

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Monday Afternoon Session,

July 1, 2019.

- - -

EXAMINATION (Continued)

By Mr. Coglianese:

MR. COGLIANESE: We are back on the

record after a lunch break.

Q. Officer Shaw, I just kind of want to

continue where we were talking about -- I believe

it was you speaking with Lieutenant Brust about

turning the position down.

A. Okay.

Q. So did Lieutenant Brust ever ask you why

you felt as though you needed protection?

A. No.

Q. Did you ever explain to Lieutenant Brust

why you felt you needed protection?

A. No.

Q. Why not?

A. I explained to him that he threatened or

that I better not take -- take that job, and that's

what I explained to him. He's the one that brought

up that he couldn't -- he would try to protect me,

but he couldn't be around me all the time.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. What could Lieutenant Brust have told

you that would have made you decide to take the job

at that point?

A. One of them could have been taking it

more serious, could have removed him from -- from

that job.

Q. Anything else that he could have done?

A. Maybe he could have said, Well, I'm

going to go back and talk to the chain of command,

get their inputs, and get back -- don't turn it

down today. Let me see what I can do on my end.

Q. Anything else he could have done?

A. Those few things are what comes to mind

right now.

Q. Was Lieutenant Brust in your chain of

command at the time you spoke with him, or was he

in the chain of command that you would have been

moving into had you taken the job?

A. He would have been in the chain of

command that I would have been moving into if I

would have taken the job.

Q. Did you speak with your chain of command

about the text that Sergeant Moore sent about you

better not take the job?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. No.

Q. Why not?

A. At that -- I think at that point I

really didn't have a chain of command because my 70

days was already up, and they gave me a little bit

extra time to try to find a job. I can't recall

why I didn't.

Q. Well, even if the 70 days were up you

still would have had a chain of command to report

through, correct?

A. It was changing day-to-day because I

think a lot of people had already left. Like the

lieutenant, I think, was already -- Lieutenant

Echenrode was already on the way out. So I was

answering to a brand new lieutenant.

Q. And who was the lieutenant that you were

answering to?

A. I think it was -- first name is Scott.

I can't -- it will come to me and I'll let you

know.

Q. Okay. But he was still serving as your

lieutenant at that time, correct?

A. Yeah. Because Echenrode had, I think,

already left.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. So if you received an order from a

lieutenant it would have been the person who filled

in for Lieutenant Echenrode?

A. It was Lieutenant Barthalow.

Q. Barthalow?

A. Yes. Barthalow.

Q. Okay. And he would have been the

lieutenant that would have given you instructions

or orders if you needed to receive them from

lieutenants, right?

A. Yes.

Q. And if you needed to make a report to a

lieutenant at that time that would have been the

lieutenant that you would have reported to,

correct?

A. He was the only person I reported to. I

didn't have a sergeant at that time.

Q. So was there any reason that you didn't

report those comments to him?

A. No, there is no reason why I didn't.

Q. Okay. So you turned the job down this

time after the conversation that you had with

Lieutenant Brust, is that correct?

A. Yes.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Do you know who ultimately filled that

position that time?

A. I want to say it was Ernie Rice.

Q. What is Mr. Rice's race?

A. White.

Q. Do you know what number he was on the

seniority roster?

A. Not offhand. I know he was behind me as

far as seniority.

Q. Do you know what number you were on the

seniority roster for that position?

A. No, I can't recall.

Q. And was there another position that you

had attempted to get in narcotics after this?

A. Yes.

Q. Did you interview for it?

A. No, didn't interview for it.

Q. What happened with filling of that

position?

A. An officer from INE left his team and

took the INC job.

Q. Who was that officer?

A. It's Dave Allen -- or he also goes by

Mike Allen.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. What is Mr. Allen's race?

A. White.

Q. Did you speak with Mr. Allen about why

he transferred from INE to INC?

A. No.

Q. Do you know why he did that?

A. No. Because I don't.

Q. Was that similar to -- I forget who you

told me --

MR. GITTES: Whittaker.

MR. COGLIANESE: Thank you.

Q. Was that similar to Mr. Whittaker's

transfer from one to another?

A. No. It was different.

Q. How was it different?

A. Because Mike Allen was on the DEA task

force.

Q. What makes that different?

A. Because basically he should have -- he

shouldn't even have had an assignment in narcotics.

He should have had to give up his assignment. He

shouldn't have dual assignments. Because one of

the stipulations to be on a task force, you have to

give up your assignment. So he -- he was on the

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JANE M. FERRANTE, RMR (614) 733-0158

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DEA task force. Never reported to anybody in

narcotics. So him switching teams didn't affect

him one bit.

Q. Do you know why he decided to switch

teams?

A. No.

Q. Did you file a grievance over him

switching teams?

A. No.

Q. Why not?

A. I talked to F.O.P., and it was my

choice. I went a -- I did it a different way. I

went to internal affairs and talked to people in

internal affairs.

Q. Why did you not file a grievance with

the F.O.P. over it?

A. Because I didn't know the facts and the

reasoning why he took it. But there should have

been no reason for him to be able to take it

because he was already on a task force. Him taking

that job had no effect on him because he wasn't

going to work on that team because he wasn't even

working on his present team. Because he was

attached to a task force.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Do you know when the task force -- do

you know when he was no longer attached to a task

force?

A. He is still on that task force. To my

knowledge as of today he is still on that task

force.

Q. So I guess if it would have no effect

and you said that he should not have even been

allowed to post for the position since he was on

the task force, why would you not grieve that?

A. I probably should have because basically

that -- that was used to block me from taking the

job. But he had -- yes, he had more seniority.

And they allowed that because he had more

seniority. But that move right there was to block

me from taking that or getting that job.

Q. How do you --

A. Because I was next in line.

Q. How do you know it was done to block

you?

A. Him taking that job. He was never, ever

going to work on that team.

Q. Okay.

A. So basically you are giving -- you are

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JANE M. FERRANTE, RMR (614) 733-0158

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giving him that job to fill in name only because

he's not going to do any work or work around that

team because he's on a task force.

Q. But what I'm trying to figure out is:

What facts do you attribute to his motivation that

he was doing that to block you?

A. I know he was friends with Eric Moore.

Q. Okay. Anything else?

A. No.

Q. Did he tell you why he took the job?

A. That -- never talked to him about it.

Q. Did Sergeant Moore tell you why he took

the job?

A. No.

Q. Did anybody tell you why Mr. Allen took

the job?

A. No.

Q. So outside of him being friends with

Sergeant Moore do you have any other reasons as to

why he would have done that?

A. My take on everything was to block me

from taking that job.

Q. I just want to make sure I understand

all the reasons why you have reached that

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JANE M. FERRANTE, RMR (614) 733-0158

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conclusion. And what you have told me is that he's

friends with Sergeant Moore. If there was anything

else?

A. And Sergeant Moore did not want me to be

on his team.

Q. Anything else?

A. Not that I can recall at this moment.

Q. So previously you told me that the

reason that you didn't take the job when you talked

to Lieutenant Brust was because he couldn't assure

you that you would be protected. What changed from

the time you talked to Lieutenant Brust when he

told you you couldn't be protected to this position

that now all of a sudden you wanted to take the

job?

A. My 70 days was up and I had to find an

assignment. And if I didn't find a good

assignment, what they were trying to do was put me

back into patrol on second shift with Tuesdays/

Wednesdays off. And it -- I look at it now, it's

different from when I lost my D.A.R.E. job and

D.A.R.E. was abolished. They gave me a first shift

job. Here to me it seems like they are trying to

punish me with my years and my seniority time, they

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JANE M. FERRANTE, RMR (614) 733-0158

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are going to give me a second shift job with

Tuesdays/Wednesdays off, and I needed to find

something because of my kids and joint custody that

I can have time with my kids.

Q. How -- strike that.

What first shift jobs were open when

they assigned you to second shift?

A. I have no clue. The jobs that -- the

lists that they gave me were all second shift jobs

with like Tuesday/Wednesday, Wednesday/Thursday

off.

Q. So you don't know one way or the other

if there was a first shift available at that time,

correct?

A. It wasn't offered to me.

Q. So you would not know if there was?

A. I would not.

Q. Okay. What -- strike that.

You did not believe -- is it correct

that you did not believe that your safety was in

question if you would have taken the job that Mr.

Allen ultimately took?

A. In those kind of jobs your safety is

always at risk because of what you do.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. From Sergeant Moore? And I apologize.

That was a bad question. From Sergeant Moore?

A. Yes, still. But everybody knew about

it.

Q. Didn't everybody know about it when you

talked to Lieutenant Brust?

A. No, because after the fact we find out

when I informed Lieutenant Brust that he -- that

Eric Moore didn't want me taking that narcotics job

he never went back and told anyone. He kept that

to himself.

Q. How do you know he didn't tell anyone?

A. I think in his deposition he testified

to that.

Q. You didn't know that at the time,

though, did you?

A. No.

Q. And you didn't know that at the time

that you said you did, in fact, want the job that

Mr. Allen ultimately took, correct?

A. What was the question again?

Q. So you said that the reason that you

thought that you would be okay was because

everybody knew about it.

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JANE M. FERRANTE, RMR (614) 733-0158

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And so what I'm saying is -- and you

told me that you knew that Lieutenant Brust didn't

say anything because you heard him deposed a couple

of months ago.

At that period of time, however, you

would not have know that. Correct?

A. But I knew Lieutenant Brust knew about

it because I told him. And he said he would try to

protect me, but he couldn't be around me all the

time. So even if I would have taken it, he still

could have tried to protect me from him even while

I worked for him.

Q. And the only thing that changed was the

fact that your 70 days had come up and gone,

correct?

A. Yeah. That's the big one because I

needed to find something that fit with my kids.

That is important to me.

Q. You talked to Lieutenant Brust in early

February of 2015, right? About the job that you

ultimately turned down?

A. Yes.

What was the date again?

Q. Early February 2015?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. Yes.

Q. And then in late February of 2015 that

was when the Allen position was ultimately filled,

right?

MR. GITTES: Could you say that again?

A. I think you have your dates wrong. I

think it would have been '16, right? Not '15.

Q. I am going to show you what I have

marked as Exhibit 13.

(Exhibit No. 13, E-Mail chain 2-9-2015 - 2-10-2015,

marked.)

MR. GITTES: Is this a new one?

MR. COGLIANESE: Yeah. I am doing

numbers myself here.

MR. GITTES: Okay.

Q. You can keep that. Do you recognize

what I have handed to you as Exhibit 13?

A. Yes.

Q. Could you identify it for the record?

A. It's an e-mail.

Q. It's an e-mail chain between you and

Lieutenant Brust?

A. Yes.

Q. And it is dated -- the earliest e-mail

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JANE M. FERRANTE, RMR (614) 733-0158

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on here is dated February 9, 2015. Is that

correct?

A. Yes.

Q. And so this is the position that we have

been talking about that you ultimately turned down.

Is that right?

A. Yes.

Q. So does that refresh your recollection

that it was 2015?

A. Yes.

Q. Okay. And then my follow-up question to

you was: The Allen position was actually filled in

late February 2015. Correct?

A. Correct.

Q. So if the 70 days is the motivating

factor one way or the other and you are only

looking at a difference of a couple of weeks, why

was it such a requirement in later February that it

wasn't a motivating factor for you in early

February?

A. I think during this time I also put in

for other jobs, one of them being the freeway job

which was third shift. And I could do any third

shift hours. And that job had Sunday/Monday off.

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JANE M. FERRANTE, RMR (614) 733-0158

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So that gave me one weekend day. So there was --

that was another option. But that option fell

through also.

Q. Why did that option fall through?

A. From the time frame that the job was

posted to the time it was supposed to be filled and

started, I think it was a large gap. I had told

the Sergeant that I would take that job. By the

time he turned the paperwork in, there was only

going to be a week that I would be on the job and I

had already had a knee replacement scheduled. So

when they found out I was having a knee replacement

they canceled the job.

Q. You ultimately reached a grievance

settlement with your union in order to fill a

freeway job. Is that correct?

A. For me to fill it or someone else to

fill it?

Q. For you to fill it.

A. I never filled it -- or the job was

never -- the job was never filled.

Q. I am going to hand you what I previously

marked as Exhibit 29.

(Exhibit No. 29, Letter of Agreement, marked.)

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. And it's a front and back. Do you

recognize that?

A. Yes.

Q. Can you identify it for the record,

please?

A. It's a letter for -- agreement.

Q. And it is a letter of agreement between

you, the Fraternal Order of Police and the

Department of Public Safety, correct?

A. Correct.

Q. So it talks about Job Vacancy 313774

traffic freeway?

A. Yes.

Q. Explain to me what that position was,

please.

A. It's a freeway patrol job on third

shift, and the hours were 9:30 P to 5:30 A with

Sunday/Monday off.

Q. So you were allowed to fill that job

while you were off. Is that right?

A. I was never allowed to fill the job.

The reason why we agreed -- this even came about is

because I had a grievance.

Q. What was your grievance?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. That that freeway job I should have been

allowed to take, work that week and then mark off,

have my knee surgery, and when I healed up be

allowed to come back and fill that job.

Q. Okay. So CPD did not let you do that.

Right?

A. Correct.

Q. So you filed a grievance over that?

A. I went to the F.O.P. Instead of filing

a grievance this was agreed upon.

Q. And you were one of the signees. Is

that correct?

A. Yes.

Q. So on the back page on the second page

of this over "Karl Shaw," that's your signature?

A. Yes.

Q. And so you were transferred to the

patrol job as a result of this letter of agreement?

A. Correct. On first shift, with weekends

off.

Q. Okay.

A. Which I never filled.

Q. What was your regular assignment at that

point in time? And this was signed in April of

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JANE M. FERRANTE, RMR (614) 733-0158

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'15.

A. At this time? It was going to be that

second shift patrol job on Zone 1.

Q. Okay.

(Exhibit No. 14, E-Mail chain 2-25-2015, marked.)

Q. I am going to hand you what I previously

marked as Deposition Exhibit 14. And I am going to

ask you to go ahead and identify that for the

record, please. If you can identify Exhibit 14 for

the record?

A. It's an e-mail chain between myself and

Lieutenant Brust.

Q. Okay. And the one that I want to focus

on is the e-mail that you sent to Lieutenant Brust

on February 25, where you say, "Lieutenant, if the

job gets down to me this time I'm taking it."

That was the job that Dave Allen

ultimately filled, is that right?

A. Yes.

Q. Going way back to the beginning of when

we started talking today, do you know why the

Columbus Division of Police ended up abolishing the

SRB unit?

A. Only from conversation I had with F.O.P.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. What did the F.O.P. tell you?

A. That it was because of the racial issues

in the enforcement.

Q. Did the F.O.P. tell you how they came to

that conclusion?

A. Can't recall.

Q. Who at the F.O.P. told you that?

A. Mark Fester.

Q. When did you have that conversation?

A. Twice. First time was when we were

waiting for my first interview with Sergeant Decker

in internal affairs.

Q. Okay. When was the next time?

A. It would have been at the F.O.P. office,

but I can't remember the date. But it was -- it

was after the interview with Sergeant Decker the

first time.

(Exhibit No. 28, Assignment Abolishment, marked.)

Q. I am going to hand you what I have

marked as Exhibit 28, and ask you to identify that

for the record, please?

A. It's an --

MR. GITTES: Wait a second. Let me look

at it. Okay.

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JANE M. FERRANTE, RMR (614) 733-0158

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MR. COGLIANESE: Is it okay for him to

answer?

MR. GITTES: Yeah. Go ahead. It is.

A. It's an assignment abolishment letter.

Q. And you received this -- it's a letter

from Chief Jacobs to you dated December 20, 2014,

is that right?

A. Yes.

Q. And you did receive this?

A. Yes.

Q. So was this the official notification

that you received that SRB was going to be

abolished?

A. Yes.

Q. And you had until, it looks like,

March 1, 2015 to find a new assignment, is that

right?

A. Yes -- you said March 17?

Q. March 1, 2015. I apologize.

A. Yes.

Q. So we have kind of chatted a lot about

various comments that you heard that Sergeant Moore

was making and issues with filling the position in

the narcotics unit.

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JANE M. FERRANTE, RMR (614) 733-0158

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Any other issues that you believe

besides what we have talked about today that were

discriminatory against you on the basis of your

race?

A. State it again.

Q. Sure. So you brought a discrimination

against the Columbus Police Department for race

discrimination?

A. Yes.

Q. And what I said is: You and I have

spent a good portion of today talking about various

comments that people told you Sergeant Moore made,

text messages that he sent, positions in the

investigative unit and in the narcotics unit.

Anything else that you believe was racially

discriminatory against you besides the stuff we

have talked about so far?

A. One thing that was alarming is that he

was questioned by ATF for ordering a lightning link

to make his rifle fully automatic.

Q. Okay.

A. You want just things that happened out

of this case or that have happened in the past?

Q. Well, what I am trying to find out is

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JANE M. FERRANTE, RMR (614) 733-0158

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everything that's happened that you believe is

discriminatory. So the stuff we have talked about

today. You have told me the lightning link. Is

there anything else?

A. When I first came on the department, did

seven-and-a-half years in the Navy, was trained to

dive. I put in for the dive team on three

different occasions. The first time they told me

my qualifications were not good enough, even though

I was trained in the military and held a Navy dive

card.

I felt that was discriminatory because I

was black. I'm a good swimmer. I even hold

records in the Police and Fire Olympics. I swam in

college. But I wasn't even allowed to even get in

the pool to demonstrate how proficient I was.

Q. Okay. Anything else?

A. Those things are what comes to mind

right now.

Q. So when did you apply for the dive team?

A. It would have been right after I got out

of the police academy. I hadn't been out of the

military just a little bit over a year.

Q. Okay. So we are looking early to mid

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JANE M. FERRANTE, RMR (614) 733-0158

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90's?

A. Yes.

Q. Okay. The ATF lightning link scenario.

Again, you had no firsthand knowledge about any of

that. Correct?

A. Correct.

Q. And again, just to be clear, firsthand

knowledge the way I defined it to you earlier?

A. Right.

Q. Okay. How did you learn about the

lightning link?

A. Detective Jerry Orak came to my office

and sat down with me.

Q. And where does Detective -- did you say

Orak?

A. Yes.

Q. Where does Detective Orak work?

A. He is on the ATF task force.

Q. So he's a member of CPD?

A. Yes.

Q. And he's on ATF task force. What do you

recall him telling you?

A. That he was sitting in the office when

Eric Moore and the -- and a representative from the

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JANE M. FERRANTE, RMR (614) 733-0158

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F.O.P., which was -- now he's the F.O.P.

president -- Farrell -- came to ATF because they

wanted to talk to him. I guess what had happened

was they got a list --

Q. And I apologize. "Him" being Moore?

A. Yes.

Q. Okay.

A. ATF received a list of people that had

ordered this lightning link from China. And I

guess they were told to go out and investigate the

people that were on the list.

Q. Okay. When did you have this

conversation? Do you recall? Maybe for purposes

of trying to at least get time frames --

A. Late February.

Q. Of '15?

A. Yeah. Sometime maybe beginning of

March.

Q. Okay. So it was about the time that the

postings were going up, the positions that you were

talking about in narcotics?

A. Narcotics, freeway, yes.

Q. Okay. So did Detective Orak tell you

why he was having that conversation with you?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. He thought that I needed to know.

Q. Did he tell you why?

A. Not that I can recall.

Q. What makes you think -- you said he

thought that you needed to know. What makes you

reach that conclusion?

A. Because he probably knew that Eric Moore

was under investigation for racial comments,

threats. And like I told internal affairs, now he

has a mechanism to carry out his threats.

Q. Detective Orak never told you why he was

speaking to you about this. Is that correct?

A. Not that I can recall or -- the exact

reason why he would come to me and share that with

me.

Q. So you are just speculating as to why he

was talking to you about it. Is that fair?

A. I'm speculating that he thought that was

serious enough for me to know and me to make a

decision on what I was going to do with that

information.

Q. But he never -- that's just your

speculation --

A. Yes.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. -- as to why he told you that, correct?

A. Yes.

Q. You said that he now had a way to carry

out threats.

Now, Sergeant Moore has a service

weapon, I would assume. Is that --

A. Yes.

Q. A lightning link would not fit on a

service weapon, would it?

A. No. But it would fit on his AR 15.

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

What is the difference between Sergeant Moore being

armed with a weapon at work versus ordering a

lightning link? How does that make it any

different?

A. I want to say it's been testified about

that he has sometimes brought his AR 15 and had it

stored in his office.

Q. What did you know at that time when

Detective Orak told you about the lightning link?

Did you know anything at all about Sergeant Moore

having an AR 15 at that point?

A. I want to say, yes.

Q. How would you know that?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. Through Sorell and through Orak.

Q. So --

A. Because I think --

Q. No. Go ahead. I didn't mean to cut you

off.

A. It was brought up when he went into --

when he went into ATF. I think they knew he -- he

owned an AR 15.

Q. So it's your understanding that when

Detective Orak talked to you in March or

thereabouts of 2015 he knew that Sergeant Moore had

an AR 15?

A. Yes.

Q. And it is your recollection that he

would have told you that at that point?

A. Yes.

Q. It's your recollection or it's your

understanding that Officer Sorell knew about

Sergeant Moore's AR 15 in March of 2015?

A. Yes. And before.

Q. How would -- what did Officer Sorell

tell you about Moore's AR 15?

A. It was known that he kept his personal

AR 15 in his office.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Who knew it?

A. It would have been Sorell, Watkins and

people that frequently hung out in that office.

Like Larry Wilson. John Evans.

Q. How do you know that they knew that?

Did they tell you that?

A. I would have to go back and look at some

of -- some of the other previous -- I think it was

brought up in the internal affairs investigation.

Q. So you would have known about it through

reading the IA investigation?

A. No. By people talking about it. By

common knowledge of conversations held in the

office.

Q. Right. And I am asking who would have

told you that?

A. The names that I just rattled off.

Q. All of them would have told you that?

A. I'm not sure for certain, but there were

conversations that took place about him having his

AR 15 at work.

Q. Any other reasons that you would have

believed that Sergeant Moore was capable of acting

on threats with an AR 15 against you?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. There is -- there is no telling what

someone would do or if someone was put in a

situation, fired or he's had a history of being

aggressive or being violent, always wanting to

fight. There is nothing -- most of these mass

shootings, it's people out of the blue that you

would say, I would never expect that from him.

Anybody is capable of anything if they are put in a

situation they feel like they have no way out.

That -- that -- ordering that gave him a way to

shoot mass people.

Q. Why didn't you file a criminal charge

against Sergeant Moore for ordering a lightning

link?

A. I'm not the federal government. That

was ATF's job.

Q. Do you know if that's a violation of

Ohio law?

A. It's a violation of federal law. That's

the reason why they were working their way down

this list that they were given of people that

ordered the lightning link.

Q. And what I am asking you is: Do you

know if a lightning link is also a violation of

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JANE M. FERRANTE, RMR (614) 733-0158

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Ohio law?

A. No, I don't.

Q. Did you file a complaint with ATF about

Sergeant Moore and his lightning link?

A. No.

Q. Why not?

A. I went to internal affairs and reported

it to Sergeant Decker.

Q. Why did you not file a complaint with

ATF?

A. I'm not sure if I was the right person

to go and file that complaint. What I do know is

that they -- ATF was investigating it. And one of

the things that I can remember -- other things that

Jerry Orak told me was that they had him ordering

it. They had his signature on the paperwork when

it was delivered. But they were not going to

pursue it because they gave him the benefit of the

doubt because he told them that, yes, he did order

it, but he never took possession. But they had a

signature of his taking possession. But they

weren't going to go after him out of common

courtesy because he was a police officer.

Q. You never saw his signature?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. No. I'm going what -- what Jerry Orak

informed me.

Q. And you never saw any order that he

would have made?

A. No.

Q. Did you file a complaint with the U.S.

Attorney for the Southern District of Ohio over the

ordering of the lightning link?

A. No.

Q. Why not?

A. The proof of him doing this I did not

have. So I could not pursue charges or anything to

evidence that I did not possess and did not see. I

can report it to people, which is what I did. But

I couldn't take action.

Q. Any other things that you have had

happen to you at the Columbus Division of Police

outside of what we've talked about today that you

believe are racially discriminatory?

A. Not that I can recall at this time.

Q. Anything else than what we have talked

about today that you believe are retaliatory while

you have been working at CPD?

A. Yes.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. What else?

A. Commander Cameron.

Q. What about Commander Cameron?

A. The comments that he made and the

e-mails that he sent out complaining about my work

or complaining that I didn't know what I was doing

or I haven't had proper training to do human

trafficking cases. Those were -- that's all -- it

was a lie. I've -- FBI sent me to training in

Boston for a week. I knew how to put these cases

together. But for some reason he did not want me

working those cases.

Q. Why do you believe it was retaliatory?

What -- let me just leave it there. Go ahead. Why

do you believe it was retaliatory?

A. Because you -- you put comments out

saying that I never did any work, but, yet, I can

prove you wrong. And you never take those

statements back. But, yet, you will go to the

chain of command and still tell those lies.

Q. That was stuff that he talked about the

first time that you worked with him in narcotics,

right?

A. And it continued all the way through

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JANE M. FERRANTE, RMR (614) 733-0158

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this case.

Q. So what was he retaliating against you

for? What did you do that you believe he was

retaliating against you for?

A. Maybe because I spoke up. I filed a

complaint.

Q. When did you file a complaint?

A. I'm not sure of the exact date when I

filed it. But they all knew I had spoken to

internal affairs and expressed that I thought what

was going on was racially motivated.

Q. So the action that he was taking -- I

just want to make sure I understand time frames.

The action that he was taking after you filed the

complaint, you believe he was taking that in

retaliation for you filing a complaint. Is that

what your testimony is?

A. Yes.

Q. So to the extent -- I apologize. You

look like you want to say something. Go ahead.

A. No. Go ahead.

Q. Please.

MR. GITTES: If you are done, you are

done.

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JANE M. FERRANTE, RMR (614) 733-0158

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THE WITNESS: I'm done.

Q. I didn't mean to cut you off. And like

I say, I am here to hear what you've got to say.

Those conversations didn't start

occurring until sometime the fall of 2014. Is that

right? That you had with internal affairs?

A. Yes.

Q. Okay. So anything that Cameron said

about you prior to that would not have been

retaliatory. Would you agree with that?

A. But it was still -- to me it was still

discrimination. Now that -- now that -- you take

all the facts that have come out in this case, I

can say the way he was treating me when I was in

narcotics, that was -- that's discrimination. He

had a bias for some reason toward me. And you

would have to ask him that. But to me it -- it

seemed racial.

Q. You don't know why he had a bias against

you, do you?

A. No.

Q. Okay. And you didn't report it at that

time, did you?

A. No. That was the reason why I left

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JANE M. FERRANTE, RMR (614) 733-0158

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narcotics.

Q. Anything else that you believe was

either discriminatory or retaliatory that we've not

talked about today?

A. Well, the text message. Again, that was

-- that was retaliatory.

Q. And that's what I said. Besides what

we've talked about?

A. No, nothing that comes to mind at this

moment right now.

Q. Who is Jack Harris?

A. Jack Harris was the lieutenant in charge

of freeway.

(Exhibit No. 16, E-Mail 4-7-2015, marked.)

Q. I am going to hand you what I previously

marked as -- I will do it this way -- what I

previously marked as Deposition Exhibit 16, and ask

you to take a look at that and identify it for the

record, please.

A. It's an e-mail chain between myself and

Lieutenant John Harris.

Q. And it says, Please give me a call when

you have a moment."

Do you recall what this was about?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. Yes.

Q. What was it about?

A. He felt bad that I wasn't allowed to

take the freeway job because they had already given

me my cruiser, my freeway car. And then they --

sarge cancels the job on me.

Q. Did they ever tell you why they canceled

the job?

A. They gave the excuse because I was

having the knee surgery.

Q. What did Lieutenant Harris say when you

-- I am going to assume you did give him a call?

A. Yes, I called him.

Q. What did he tell you?

A. That he was sorry that this happened and

for me there is other jobs to put in for.

Q. Anything else?

A. Not that I can recall.

(Exhibit No. 18, Text Messages, marked.)

Q. I am just trying to do some clean-up

here. I am going to hand you what I previously

marked as 18 and ask you to identify that for the

record.

A. This is the text message between me and

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JANE M. FERRANTE, RMR (614) 733-0158

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Heidi Malone.

Q. Okay. And this is the text message that

we talked about earlier?

A. Yes.

Q. Any other situations that happened

besides what we have talked about that you believe

were discriminatory or retaliatory?

A. Not that I can recall at this moment.

Q. Anything else that we've talked about

today that you think you need to either fill in

more or correct? Anything else?

A. No.

MR. COGLIANESE: No. Okay. At this

point, Officer Shaw, I do want to thank you. We

are done.

MR. GITTES: We are not done. I want to

talk to him. I want to see whether I want to ask

him any follow-up questions.

MR. COGLIANESE: Okay.

MR. GITTES: Can we use the conference

room?

(Recess taken.)

- - -

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JANE M. FERRANTE, RMR (614) 733-0158

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EXAMINATION

By Mr. Gittes:

Q. Officer Shaw, I just want to ask you

about two topics.

Do you recall what assignment that

Officer Allen had before he went to the task force?

A. Yes.

Q. And what was that?

A. It was Investigative Team C.

Q. Do you know whether he left

Investigative C to go to the task force?

A. Yes.

Q. Okay. And was Sergeant Moore the

sergeant of Investigative C in narcotics at the

time that he left?

A. No, he wasn't.

Q. At the time that he bid on the position

that you have been asked about a lot today, the

second opening that -- Investigative E, I believe?

Right?

A. Yes.

Q. And was sergeant Moore there or am I

confusing the units?

A. No, Sergeant Moore wasn't there.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Okay.

A. They --

Q. Explain the timing in terms of where

Sergeant Moore was and when Officer -- Detective

Allen left and came back.

A. Dave Allen originally started on

Investigative C. The time he was on Investigative

C he went to the DEA task force. It was a point

while he was on the task force that he went to

Investigative E. Then that job that I put in for,

he left Investigative C -- I mean E --

Investigative E and went back to Investigative C

when Eric Moore was there.

Q. By the way, had he bid on the job he --

I just want to get the timing clear here on this

record. At the point in time that you met with

Lieutenant Brust and indicated in your meeting that

you no longer were going to take the job --

A. Okay.

Q. -- that meeting that has been discussed

today?

A. Yes.

Q. Had the job been filled? It was still

open basically?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. It was still open.

Q. Had Allen bid on it, to your knowledge?

If you don't know, tell us.

A. I'm confused.

Q. I am sorry. I am asking about the wrong

job, right?

A. Yes.

Q. At the point that you were having that

discussion was the job still open?

MR. COGLIANESE: Objection. Which job

are you talking about?

MR. GITTES: I am sorry.

A. Are you talking about the one that I

discussed with Lieutenant Brust?

Q. Yes.

A. Yes, that job was still open.

Q. Okay. And by the time you e-mailed back

to Brust -- I believe it's an exhibit here -- about

-- let's see if I can find which one it is -- I'm

trying to understand that between the time you met

with Lieutenant Brust and had the conversation that

you were questioned about today and the time you

sent Defendant's Exhibit 14 to Lieutenant Brust

whether the first -- the first job that you were

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JANE M. FERRANTE, RMR (614) 733-0158

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discussing with him had been filled.

A. That one had been filled.

Q. Okay. And do you know how much before

you sent this e-mail on the 25th?

For the record, I am talking about

February 25, 2015, reflected in Defendant's

Exhibit 14.

A. It would have been filled right after I

passed on it.

Q. Okay. And at that moment in time were

you totally out of time when you talked to Brust?

A. I think I would have been totally out of

time come March 1st.

Q. Okay. So at the time you were having

that conversation with Lieutenant Brust you still

had some time?

A. I still had some time.

Q. At the time you were talking to Brust --

and just for the record because I know -- including

me -- we get confused. Were there -- were there

three job openings that this case concerns, or two?

MR. COGLIANESE: Objection.

A. It was two jobs.

Q. Okay. And is it -- just for the record,

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JANE M. FERRANTE, RMR (614) 733-0158

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the first job had initially gone through a process

and your chain had recommended Officer Ehrenborg,

right?

A. Correct.

Q. For the position?

A. For the position.

Q. And then because of the action of the

chief that same job was re-opened for decision?

A. Yes.

MR. COGLIANESE: Objection.

Q. Okay. So -- and that job was what job?

Which job? Do you remember?

A. I don't remember because each job is

given an assignment number. Both of them initially

were posted at the same time.

Q. Okay.

A. Ehrenborg got one, and then that left

one still open.

Q. Okay.

A. They were going to give it to Ehrenborg.

The chief stopped it. So that meant the two jobs

were still open.

Q. The person who took what you have

referred to as the first job, ultimately took it --

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JANE M. FERRANTE, RMR (614) 733-0158

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A. Yes.

Q. -- did he have more or less seniority

than you?

A. He had less.

Q. When that first job was first -- when

Ehrenborg was first recommended for that position

in the beginning by the chain of command did you

have more or less seniority than him?

A. I had more.

Q. Had you -- as of the time you learned

that Ehrenborg had been recommended for the

position had you withdrawn your request to be given

the job?

A. Never turned that job down.

Q. Had you personally communicated to

Lieutenant Brust and to Commander Cameron that you

would take that job?

MR. COGLIANESE: Objection.

A. I told them I was still interested in

that job.

Q. In light of Rich's objection, let me ask

it a different way.

What is the last thing you said to

Commander Cameron and Lieutenant Brust as you left

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JANE M. FERRANTE, RMR (614) 733-0158

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the interview?

A. That I was still interested in that job.

Q. Have you ever been given an explanation

or even heard an explanation of why Ehrenborg was

still recommended and not you after that interview?

A. Never.

Q. Okay. The only other thing I want to

ask about is related to the lightning link.

Is it your understanding that a

lightning link device is legal or illegal?

A. It's illegal.

Q. Is there -- is it also illegal for a

Columbus Police Officer to have and obtain -- have

or obtain such a device?

MR. COGLIANESE: Objection.

A. Illegal.

MR. GITTES: That's all I have.

FURTHER EXAMINATION

By Mr. Coglianese:

Q. Sir, you told Fred that Allen started on

C initially -- Investigative C initially. Is that

right?

A. Yes.

Q. And then while he was on C he joined the

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JANE M. FERRANTE, RMR (614) 733-0158

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DEA task force. Is that correct?

A. Correct.

Q. So while he was off and doing the DEA

work he switched to E?

A. Correct.

Q. And then -- and he was continuing simply

to do the DEA task force work?

A. Correct.

Q. And then while on the DEA task force

work he switched back to C?

A. Correct.

Q. So Allen sounds like he's got a history

of switching positions while on the DEA task force.

Is that correct?

A. There is years in between the switching.

Q. I understand that, but that wasn't my

question.

My question was: Allen has a history of

switching between investigative units while on the

DEA task force. Is that correct?

A. Yes.

Q. Are you maintaining that when Allen went

from C to E while he was on the DEA task force that

he did that for racially discriminatory reasons?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. I'm not sure.

Q. You don't know why he went from C to E.

Is that correct?

A. Correct.

Q. Okay. I want to clear up because I

think I am now more confused than I was earlier

about all of the positions. So I thought we had

been talking about four jobs. And let me explain

to you how I am getting the four.

A. Okay.

Q. We are getting to the job that you admit

you turned down. We are talking -- and that went

to --

A. Ernie Rice.

Q. -- Ernie Rice. So let's call that Job

1.

A. Okay.

Q. Job 2 went to Ehrenborg. Is that right?

That was ultimately canceled by the chief?

A. Correct.

Q. Job 3 was the position that went -- that

you were offered and turned down after you talked

to Lieutenant Brust?

A. That's the job Ernie Rice took.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. Now I'm really confused because --

MR. GITTES: Rich, just so you know

that's why I am trying to get this clarified

because I'm -- I think there is confusion about

this. Maybe you have the answer in your book

there.

MR. COGLIANESE: Let's do it this way.

(Exhibit Nos. 19 - 22, Job Applications, marked.)

Q. I am going to give you multiple

exhibits. Just bear with me, okay?

MR. GITTES: Have these been previously

marked?

MR. COGLIANESE: They have been

previously marked. We will introduce them. But

let me do it this way because I think it's going to

be easiest.

MR. GITTES: Okay.

MR. COGLIANESE: So here is 19. Here is

20. Here is 21. And here is 22.

Q. And just for the record, all of these

are two-sided copies. So I'll give you a second to

take a look at them and then, Officer, when you are

done looking at them I am going to ask you to

identify for the record what we are looking at.

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JANE M. FERRANTE, RMR (614) 733-0158

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Are you ready?

A. Yeah. I can probably explain it so

everybody understands.

Q. Okay. But before you do that, let's

just start 19 through 22 are applications that you

submitted for the narcotics position -- for

narcotics positions, is that correct?

A. Correct.

Q. Okay. So go ahead. You said you can

explain it so everybody understands it?

A. Yeah. I think I got it now. And I can

explain it.

You are seeing four jobs. But actually

there are only two.

MR. COGLIANESE: And I apologize. I

don't mean to do this, but let me give you 23 also.

And actually, while we are doing this let me also

give you 24. Then I am done at that point. I

promise.

(Exhibit Nos. 23-24, Job Applications, marked.)

Q. Okay. And I don't know if that changes

anything that you were about to say.

A. Okay. These two --

Q. 23 and 24?

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JANE M. FERRANTE, RMR (614) 733-0158

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A. Yes. 24 ran 23 are from 2018, not from

this time frame.

Q. Okay. Who was the sergeant in charge in

2018 when you submitted that application?

A. I don't know who it is now. It's not --

it's not Moore because he had already been fired

and come back in 2018, and he just holds an admin

job there now.

Q. Okay.

A. So these jobs were in 2018.

Q. Okay.

A. These --

MR. GITTES: Again, for the record,

Exhibits 23 and 24 is what you just talked about?

THE WITNESS: Yes.

MR. GITTES: Okay.

A. Which I didn't get those jobs because of

seniority.

Q. Okay.

A. These jobs --

Q. You are looking at 19?

A. 19, 20, 21 and 22.

Q. Uh-huh.

A. 19 and 22 are the same job. Look at the

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JANE M. FERRANTE, RMR (614) 733-0158

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assignment numbers on those jobs. They were posted

at two different times, but it's the exact same

assignment.

Q. So it's not --

A. The confusion is that they canceled them

and then re-posted them, the two jobs. That's

where the confusion is coming.

Q. So 19 was posted. You applied?

A. Yes.

Q. Was this the job that went to Allen?

19?

A. We would have to go back and look at

what his assignment number is, and that will tell

you.

Q. Well, let's flip to the back page on

each of them because that -- that gives us the

seniority groups. Okay?

And so the only one that I see Allen on

is 19.

A. Yes.

Q. So it would stand to reason -- you would

have no reason to dispute that 19 was the job that

went to Allen?

A. Yes. You can also go by the effective

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JANE M. FERRANTE, RMR (614) 733-0158

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date. It would have been March of 2015.

Q. Okay. And he was ahead of you on the

seniority roster?

A. Yes.

Q. So then that leaves us with 20, 21 and

22. And you have -- you had said earlier that you

passed on an initial job. Would that have been 20

that you passed on?

A. See, the assignment number for 19 and 22

are the same. The assignment is 7220607 --

Q. Okay.

A. -- on 19. And on 22 the assignment

number is 7220607. So --

Q. Except the problem is 22 has an

effective date of 1-4-2015. 19 has an effective

date of 3-1-2015?

A. Right. These two are the same.

Q. You have got to use numbers as you are

pointing.

A. 21 and 20 are the same assignment

numbers.

Q. Okay.

A. If you look at Exhibit 21 and 22 they

were filed at the same time. So --

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. With different closing dates?

A. Yes.

Q. One is 12-17, one is 6-16 the next year?

A. The two initial jobs had to be -- they

were -- what? Canceled and then re-posted.

Q. I thought you said --

A. But I thought -- now I'm confused

because I thought one job stayed open and then that

was the one they closed was the one I thought

Jeremy took or they were going to give Jeremy. So

that left one job open, and the chief canceled

Jeremy's job. Remember --

Q. Right.

A. Retired Deputy Chief Gray says what they

did was the job that Jeremy took, they canceled to

stop any grievance. And then re -- that job was

re-posted. And that's -- that's Exhibit 19 and

Exhibit 22. That's that second job. But that job

was also re-posted twice. There were only two

vacancies on that team. But because of all this,

that job was canceled and re-posted.

Q. So then I want to -- you told me

initially that you passed on the position in order

to allow -- I forget what the gentleman's name was.

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JANE M. FERRANTE, RMR (614) 733-0158

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MR. GITTES: Can we go off the record?

Can we just talk for a second? It's up to you.

MR. COGLIANESE: Actually, just give me

a second here.

(Witness and counsel confer.)

MR. COGLIANESE: Let's go off the

record.

(Discussion off the record.)

Q. So you had previously testified that you

got a call from Officer John Whittaker and because

of that you decided to pass to allow Officer

Whittaker to take the job?

A. And that job was before these jobs.

Q. When was that job posted?

A. Like the summer. That summer. That one

took effect like July, August. He was -- when

these jobs were posted he was already on INC.

Q. So that was before you were told that

SRB was being abolished. Is that right?

MR. GITTES: Objection. Go ahead.

A. This was --

Q. The Whittaker posting.

A. Yes.

Q. The job that you passed for Whittaker.

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JANE M. FERRANTE, RMR (614) 733-0158

160

A. That was before -- before SRB was talked

about being abolished.

Q. And Moore was the sergeant in charge of

that position. Is that right?

A. That was right around the time he left

SRB that summer and went to narcotics.

Q. And then there was the Ehrenborg job.

Was that the next one?

A. Yes.

Q. So which one is that?

A. I'm not sure because you don't have a

full printout. It may have been -- the only one

that his name comes up on is these two jobs.

Q. And give me exhibit numbers. 19 and 22?

A. They are going to be 19 and 22, which

are the same jobs, just posted different times.

Q. Okay. Then the next job. Is it your

testimony that the next job is the job that you

talked to Brust about? After they canceled the

Ehrenborg position?

A. Yes.

Q. And that's when you then declined that

position? Is that right?

A. Correct.

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JANE M. FERRANTE, RMR (614) 733-0158

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Q. And then the next position would have

been the end of February when you told Brust that

this time you were not going to turn it down. Is

that right?

A. Correct.

Q. And that would have been Exhibit 14, if

the job opens -- "If the job gets down to me this

time I'm taking it"?

A. Yes.

MR. COGLIANESE: Okay. I think it's

clear as mud. I don't have anything further. Did

you want to --

MR. GITTES: No. I have nothing

further. I am afraid to ask anything further now.

MR. COGLIANESE: Officer Shaw, I do want

to thank you for taking the time and coming over

here today and talking to us.

(Discussion off the record.)

MR. GITTES: Yes, we will sign.

(Signature not waived.)

(Deposition concluded at 2:00 p.m.)

- - -

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JANE M. FERRANTE, RMR (614) 733-0158

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AFFIDAVIT

State of Ohio:

SS:

County of _____________:

I, Karl D. Shaw, do hereby certify

that I have read the foregoing transcript of my

deposition given on Monday, July 1, 2019; that

together with the correction page attached hereto

noting changes in form or substance, if any, it is

true and correct.

_______________________

Karl D. Shaw

I do hereby certify that the

foregoing transcript of the deposition of Karl D.

Shaw was submitted to the witness for reading and

signing; that after he had stated to the

undersigned Notary Public that he had read and

examined his deposition, he signed the same in my

presence on the ______ day of ___________, 20___.

_____________________

Notary Public, State of

Ohio

My commission expires:

- - -

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JANE M. FERRANTE, RMR (614) 733-0158

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CERTIFICATE

State of Ohio:

SS:

County of Union:

I, Jane M. Ferrante, a Notary Public in

and for the State of Ohio, certify that the within

named Karl D. Shaw was by me duly sworn to testify

to the whole truth in the cause aforesaid, that the

testimony was taken down by me in the presence of

said witness, afterwards transcribed by computer;

that the foregoing is a true and correct transcript

of the testimony given by said witness taken at the

time and place in the foregoing caption specified

and was completed without adjournment.

I do certify that I am not a relative,

employee or attorney of any of the parties, or of

any attorney or counsel employed by the parties, or

financially interested in the action.

IN WITNESS WHEREOF, I have hereunto set my

hand and affixed my seal of office at Dublin, Ohio,

on this 15th day of July 2019.

My commission expires

October 17, 2021 Jane M. Ferrante

Registered Merit Reporter

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'

'13 [6] - 12:10, 19:2,

33:22, 38:22, 43:13,

43:16

'14 [1] - 84:18

'15 [16] - 12:11, 19:2,

33:22, 37:24, 38:22,

40:2, 43:13, 43:17,

45:11, 63:3, 84:19,

84:20, 103:12,

119:7, 124:1, 130:16

'16 [1] - 119:7

'92 [1] - 31:11

'93 [1] - 31:10

1

1 [15] - 1:19, 4:2, 11:3,

11:5, 11:6, 12:2,

13:24, 106:2, 124:3,

126:16, 126:19,

152:16, 162:7

1-4-2015 [1] - 157:15

11 [4] - 25:9, 25:15,

27:3, 27:7

112 [1] - 28:21

119 [1] - 3:8

12-17 [1] - 158:3

121 [1] - 3:9

124 [1] - 3:9

125 [1] - 3:10

13 [4] - 3:8, 119:9,

119:10, 119:17

14 [7] - 3:9, 124:5,

124:7, 124:9,

146:23, 147:7, 161:6

141 [1] - 3:10

142 [1] - 3:11

144 [1] - 3:4

15 [11] - 15:21, 132:10,

132:17, 132:22,

133:8, 133:12,

133:19, 133:22,

133:24, 134:21,

134:24

150 [1] - 3:4

153 [1] - 3:11

154 [1] - 3:12

16 [3] - 3:10, 141:14,

141:17

161 [2] - 13:20, 17:10

17 [1] - 126:18

18 [3] - 3:11, 142:19,

142:22

19 [17] - 3:11, 153:8,

153:18, 154:5,

155:21, 155:22,

155:24, 156:8,

156:11, 156:19,

156:22, 157:9,

157:12, 157:15,

158:17, 160:14,

160:15

1st [3] - 31:23, 32:7,

147:13

2

2 [1] - 152:18

2-10-2015 [2] - 3:8,

119:10

2-25-2015 [2] - 3:9,

124:5

2-9-2015 [2] - 3:8,

119:10

20 [6] - 126:6, 153:19,

155:22, 157:5,

157:7, 157:20

2004 [1] - 23:22

2007 [1] - 23:17

2010 [1] - 22:14

2013 [9] - 37:24, 40:2,

40:14, 40:16, 41:3,

42:4, 42:11, 45:10,

63:2

2014 [4] - 33:7,

103:11, 126:6, 140:5

2015 [25] - 12:5, 12:6,

37:14, 38:1, 39:4,

40:14, 40:16, 41:3,

42:4, 42:11, 46:14,

83:7, 103:13,

118:20, 118:24,

119:2, 120:1, 120:9,

120:13, 126:16,

126:19, 133:11,

133:19, 147:6, 157:1

2018 [4] - 155:1,

155:4, 155:7, 155:10

2019 [4] - 1:19, 4:2,

106:2, 162:7

20___ [1] - 162:19

21 [5] - 153:19,

155:22, 157:5,

157:20, 157:23

22 [14] - 3:12, 153:8,

153:19, 154:5,

155:22, 155:24,

157:6, 157:9,

157:12, 157:14,

157:23, 158:18,

160:14, 160:15

23 [4] - 154:16,

154:24, 155:1,

155:14

23-24 [2] - 3:12,

154:20

24 [4] - 154:18,

154:24, 155:1,

155:14

25 [2] - 124:15, 147:6

25th [1] - 147:4

26 [1] - 9:1

28 [3] - 3:10, 125:18,

125:20

29 [3] - 3:9, 121:23,

121:24

2:00 [1] - 161:21

2:18-cv-483 [1] - 1:8

3

3 [1] - 152:21

3-1-2015 [1] - 157:16

30 [1] - 28:6

30,000-foot [1] -

100:19

313774 [1] - 122:11

395 [1] - 2:5

3:00 [1] - 10:20

4

4-7-2015 [2] - 3:10,

141:14

43016 [1] - 1:23

43205 [1] - 2:3

43215 [2] - 2:6, 2:9

5

5 [1] - 3:3

50A [4] - 53:20, 53:22,

54:3, 54:5

5:30 [1] - 122:17

5K [1] - 10:7

6

6-16 [1] - 158:3

60 [1] - 24:17

60-day [1] - 24:15

614 [1] - 1:23

7

70 [6] - 26:14, 108:4,

108:8, 115:16,

118:14, 120:15

70-day [1] - 26:17

7089 [1] - 1:22

7220607 [2] - 157:10,

157:13

723 [1] - 2:3

733-0158 [1] - 1:23

77 [2] - 1:18, 2:9

7:00 [1] - 10:20

8

82nd [1] - 31:8

83rd [1] - 31:8

9

9 [1] - 120:1

90's [2] - 68:9, 129:1

9:03 [1] - 1:19

9:30 [1] - 122:17

A

a.m [2] - 1:19, 10:20

abandoned [1] - 30:10

abatements [1] -

14:18

ability [2] - 8:16, 99:13

able [14] - 15:11, 28:4,

28:11, 43:3, 43:11,

52:22, 53:2, 81:14,

82:7, 89:20, 90:8,

91:7, 99:21, 112:19

abolished [15] - 11:21,

25:16, 25:17, 25:21,

26:10, 26:12, 26:14,

84:1, 84:7, 84:10,

84:13, 115:22,

126:13, 159:19,

160:2

abolishing [2] - 26:1,

124:22

Abolishment [2] -

3:10, 125:18

abolishment [2] -

26:23, 126:4

absolutely [2] - 76:11,

86:12

abuse [4] - 24:3,

24:21, 25:6, 27:2

academy [6] - 31:4,

31:13, 32:19, 32:24,

71:9, 128:22

accept [3] - 46:24,

49:14, 49:15

access [2] - 52:22,

53:2

accident [1] - 105:11

accurate [1] - 49:17

ACL [1] - 27:17

acquaintance [2] -

33:13, 33:14

acronym [2] - 76:16,

76:17

ACSIS [1] - 82:9

acting [1] - 134:23

action [7] - 100:3,

100:6, 100:20,

137:15, 139:12,

139:14, 148:7

activity [2] - 89:9,

100:1

actual [1] - 73:17

addressed [1] - 29:3

addresses [1] - 58:12

1

admin [5] - 11:10,

11:13, 12:1, 35:15,

155:7

administrative [3] -

25:11, 26:20, 27:3

administratively[3] -

25:9, 25:15, 26:15

admit [1] - 152:11

advise [1] - 62:2

affairs [12] - 92:14,

98:21, 98:22, 98:23,

112:13, 112:14,

125:12, 131:9,

134:9, 136:7,

139:10, 140:6

affect [1] - 112:2

affects [1] - 26:11

AFFIDAVIT[1] - 162:1

afraid [1] - 161:14

African [8] - 38:10,

38:17, 39:2, 40:3,

42:7, 42:10, 49:11,

89:7

African-American[7]

- 38:10, 38:17, 39:2,

40:3, 42:7, 42:10,

89:7

African-Americans [1]

- 49:11

Afternoon [1] - 106:1

AG's [1] - 20:3

agencies [1] - 20:7

agenda [3] - 53:22,

59:9, 59:12

agendas [1] - 54:2

agent [2] - 20:11,

20:15

aggressive [1] - 135:4

ago [5] - 8:5, 44:16,

52:19, 79:3, 118:4

agree [2] - 16:8,

140:10

agreed [2] - 122:22,

123:10

Agreement[2] - 3:9,

121:24

agreement [3] - 122:6,

122:7, 123:18

ahead [19] - 5:9, 8:18,

54:8, 60:16, 60:18,

64:13, 83:3, 90:5,

99:14, 99:19, 124:8,

126:3, 133:4,

138:14, 139:20,

139:21, 154:9,

157:2, 159:20

aka [1] - 15:20

Akron [1] - 32:4

al [1] - 1:9

alarming [1] - 127:18

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 164 of 177 PAGEID #: 2323
allegations [1] - 56:5

Allen [21] - 110:23,

110:24, 111:3,

111:16, 114:15,

116:22, 117:20,

119:3, 120:12,

124:17, 144:6,

145:5, 145:6, 146:2,

150:20, 151:12,

151:18, 151:22,

156:10, 156:18,

156:23

Allen's [1] - 111:1

allow [5] - 43:7, 43:9,

83:22, 158:24,

159:11

allowed [11] - 13:12,

17:5, 70:14, 113:9,

113:14, 122:19,

122:21, 123:2,

123:4, 128:15, 142:3

almost [1] - 81:9

alternative [2] - 43:3,

43:13

American[7] - 38:10,

38:17, 39:2, 40:3,

42:7, 42:10, 89:7

Americans [1] - 49:11

Angeles [1] - 88:24

anger[1] - 90:24

answer[14] - 6:1, 6:6,

6:20, 6:23, 7:13,

7:22, 8:15, 35:20,

85:12, 99:20, 103:4,

126:2, 153:5

answering [2] -

108:15, 108:17

answers [1] - 6:13

anytime [1] - 102:18

apartment [1] - 10:8

apes [1] - 61:11

apologize [7] - 47:8,

57:11, 117:1,

126:19, 130:5,

139:19, 154:15

APPEARANCES[1] -

2:1

applicable [2] - 1:14,

4:8

application [2] - 32:8,

155:4

applications [1] -

154:5

Applications [4] -

3:11, 3:12, 153:8,

154:20

applied [2] - 32:9,

156:8

apply [2] - 27:23,

128:20

applying [1] - 71:9

approached [1] -

78:10

approval [1] - 17:13

approximate [1] -

95:16

April [1] - 123:24

AR [10] - 132:10,

132:17, 132:22,

133:8, 133:12,

133:19, 133:22,

133:24, 134:21,

134:24

area [3] - 13:18, 13:19,

14:8

areas [3] - 16:15,

16:17, 26:4

armed [1] - 132:13

arrest [1] - 101:22

assault [2] - 101:9,

101:19

assaults [1] - 101:7

assigned [9] - 11:14,

11:18, 25:9, 25:15,

26:16, 27:10, 29:5,

33:3, 116:7

Assignment[2] - 3:10,

125:18

assignment [31] - 9:2,

10:24, 22:18, 23:24,

24:7, 24:15, 25:12,

25:16, 26:20, 27:3,

27:9, 28:18, 33:1,

33:2, 111:20,

111:21, 111:24,

115:17, 115:18,

123:23, 126:4,

126:16, 144:5,

148:14, 156:1,

156:3, 156:13,

157:9, 157:10,

157:12, 157:20

assignments [2] -

26:2, 111:22

Assistant[1] - 2:8

assume [9] - 7:14,

47:22, 68:3, 75:23,

76:16, 78:21, 96:9,

132:6, 142:12

assure [1] - 115:10

ate [1] - 50:8

ATF [10] - 127:19,

129:3, 129:18,

129:21, 130:2,

130:8, 133:7, 136:3,

136:10, 136:13

ATF's [1] - 135:16

attached [3] - 112:24,

113:2, 162:8

attempt [1] - 27:23

attempted [1] - 110:14

attended [1] - 29:3

Attorney[3] - 1:17,

2:8, 137:7

attorney [2] - 5:11,

13:24

Attorney's [1] - 5:11

attribute [1] - 114:5

attributed [4] - 56:19,

59:21, 60:1, 60:21

attributing [1] - 54:14

audio [1] - 104:8

August [5] - 83:7,

103:9, 103:11,

103:13, 159:16

authority [1] - 99:7

automatic [1] - 127:20

available [1] - 116:13

avenues [1] - 37:11

avoid [1] - 85:7

aware [3] - 8:14,

75:10, 95:3

B

bad [3] - 65:12, 117:2,

142:3

bad-mouthing [1] -

65:12

ballpark [1] - 94:6

Barthalow [3] - 109:4,

109:5, 109:6

based [1] - 41:3

bases [2] - 82:9, 86:14

basis [1] - 127:3

basketball [1] - 10:2

Battalion [1] - 32:7

BCI [1] - 20:15

bear[1] - 153:10

became [1] - 37:8

become [1] - 59:5

becomes [1] - 101:18

beginning [4] - 12:3,

124:20, 130:17,

149:7

behalf [2] - 2:7, 2:10

behaviors [1] - 89:4

behind [2] - 17:7,

110:8

beliefs [2] - 47:1,

49:16

benefit [1] - 136:18

best [17] - 6:12, 8:16,

12:8, 26:8, 46:9,

46:18, 54:12, 54:18,

55:9, 64:6, 66:21,

66:22, 68:17, 70:12,

77:11, 97:24, 99:22

better[8] - 76:21,

90:11, 97:9, 98:6,

99:15, 99:17,

106:21, 107:24

between [9] - 119:21,

122:7, 124:11,

132:12, 141:20,

142:24, 146:20,

151:15, 151:19

bias [2] - 140:16,

140:19

bid [5] - 24:13, 67:5,

144:17, 145:14,

146:2

big [2] - 22:13, 118:16

Bill [3] - 14:1, 17:9,

17:10

binoculars [1] - 34:24

bit [5] - 35:3, 74:9,

108:5, 112:3, 128:23

black [4] - 37:18, 38:6,

46:20, 128:13

blacks [7] - 56:24,

57:2, 57:5, 61:10,

81:12, 85:1

block [5] - 113:12,

113:15, 113:19,

114:6, 114:21

blue [1] - 135:6

boarded [2] - 14:20,

14:22

Bobby [1] - 15:20

Bodel [1] - 13:3

book [1] - 153:5

boot [1] - 22:24

Boston [1] - 138:10

bother [1] - 32:20

bothered [1] - 37:9

boys [1] - 10:16

branch [1] - 31:18

brand [1] - 108:15

break [14] - 7:19, 7:23,

28:20, 28:22, 36:16,

41:12, 41:19, 41:23,

42:3, 42:16, 45:10,

73:22, 73:23, 106:7

Brett [1] - 13:3

Brick [1] - 15:20

brief [2] - 73:10, 87:7

bring [3] - 86:23,

86:24

brings [2] - 85:20,

86:11

Broad [1] - 2:5

broke [1] - 74:3

brothers [1] - 90:14

brought [11] - 15:6,

33:16, 81:17, 81:21,

86:20, 94:23,

106:22, 127:6,

132:17, 133:6, 134:9

Brown [1] - 2:5

2

Brust [49] - 71:1,

72:12, 74:5, 75:11,

84:24, 85:18, 85:20,

87:5, 89:16, 89:22,

97:5, 97:8, 97:14,

97:16, 97:22,

101:24, 102:6,

102:12, 103:16,

103:20, 106:10,

106:13, 106:16,

107:1, 107:15,

109:23, 115:10,

115:12, 117:6,

117:8, 118:2, 118:7,

118:19, 119:22,

124:12, 124:14,

145:17, 146:14,

146:18, 146:21,

146:23, 147:11,

147:15, 147:18,

149:16, 149:24,

152:23, 160:19,

161:2

buildings [1] - 10:8

bulletin [1] - 24:12

bully [1] - 98:4

bureau [2] - 87:1,

101:4

burglars [1] - 12:18

burglary [2] - 16:21

buying [1] - 14:8

buys [1] - 15:4

BW-3s [1] - 50:1

C

C.J [1] - 20:21

California [6] - 81:18,

86:22, 88:6, 88:10,

88:16, 88:18

camera [5] - 37:2,

37:5, 42:18, 43:15

cameras [1] - 34:24

Cameron [49] - 18:16,

18:17, 71:1, 72:13,

72:20, 73:18, 74:5,

75:14, 75:17, 75:20,

76:6, 76:10, 76:13,

77:8, 78:6, 78:16,

78:18, 78:20, 79:3,

79:9, 79:13, 79:16,

79:24, 80:7, 80:14,

80:17, 80:24, 81:4,

84:23, 85:3, 85:18,

86:6, 86:8, 86:19,

87:8, 89:16, 89:23,

97:5, 97:8, 98:4,

102:17, 104:15,

104:24, 105:4,

138:2, 138:3, 140:8,

149:16, 149:24

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 165 of 177 PAGEID #: 2324
Cameron's [1] - 87:12

Camp [1] - 31:23

canceled [11] - 70:9,

70:10, 121:13,

142:7, 152:19,

156:5, 158:5,

158:11, 158:15,

158:21, 160:19

cancels [1] - 142:6

cannot [1] - 8:15

capable [2] - 134:23,

135:8

car[1] - 142:5

card [1] - 128:11

career[1] - 104:2

carry [3] - 19:22,

131:10, 132:3

case [20] - 5:12, 5:16,

15:3, 15:6, 30:24,

57:23, 63:20, 64:11,

64:20, 64:21, 64:23,

65:17, 82:4, 99:15,

99:18, 127:23,

139:1, 140:13,

147:21

Case [1] - 1:8

cases [13] - 13:13,

13:16, 15:5, 24:22,

65:3, 65:12, 65:18,

66:1, 80:20, 105:7,

138:8, 138:10,

138:12

Casner[2] - 22:4, 22:8

catch [1] - 59:7

Caucasian [1] - 89:7

cell [1] - 58:15

certain [7] - 15:1,

28:12, 30:1, 30:2,

30:17, 100:16,

134:19

certified [1] - 5:3

certify [2] - 162:5,

162:13

chain [30] - 3:8, 3:9,

17:18, 39:10, 39:14,

51:13, 51:18, 51:23,

52:4, 53:23, 54:1,

62:8, 62:18, 62:20,

72:15, 107:9,

107:15, 107:17,

107:19, 107:22,

108:4, 108:9,

119:10, 119:21,

124:5, 124:11,

138:20, 141:20,

148:2, 149:7

changed [4] - 20:19,

90:1, 115:11, 118:13

changes [2] - 154:21,

162:9

changing [1] - 108:11

character[1] - 4:13

charge [6] - 34:23,

35:16, 135:12,

141:12, 155:3, 160:3

charged [1] - 14:15

charges [7] - 98:13,

98:14, 98:16, 99:3,

99:7, 99:11, 137:12

charity [1] - 27:14

chatted [1] - 126:21

chief [8] - 11:15, 26:5,

26:19, 98:24, 148:8,

148:21, 152:19,

158:11

Chief [5] - 11:16,

11:18, 26:7, 126:6,

158:14

China [1] - 130:9

choice [1] - 112:12

chose [1] - 69:17

Chrysler[1] - 104:24

circumstances [1] -

100:10

citizens [1] - 29:4

city [3] - 12:17, 13:24,

30:20

City [8] - 1:9, 1:17,

2:8, 5:11, 5:13, 8:22,

52:8, 62:13

Civil [2] - 1:14, 4:8

clarification [1] - 54:5

clarified [1] - 153:3

clarify [2] - 40:5, 40:13

Clark [2] - 25:1, 25:3

class [5] - 31:4, 31:6,

32:24, 37:3

clean [3] - 6:5, 57:12,

142:20

clean-up [1] - 142:20

clear[15] - 7:1, 7:2,

7:4, 7:11, 35:18,

37:22, 72:1, 78:15,

85:11, 88:8, 97:3,

129:7, 145:15,

152:5, 161:11

clearer[1] - 61:4

closed [1] - 158:9

closing [1] - 158:1

clue [1] - 116:8

coffee [1] - 73:22

Coglianese [7] - 2:8,

3:3, 3:4, 5:5, 5:10,

106:5, 150:19

COGLIANESE [40] -

16:12, 21:8, 21:10,

40:15, 41:13, 41:16,

41:23, 42:1, 42:13,

60:16, 60:18, 61:3,

61:8, 73:23, 74:1,

82:24, 84:5, 85:9,

90:6, 103:2, 105:12,

106:6, 111:11,

119:13, 126:1,

143:13, 143:19,

146:10, 147:22,

148:10, 149:18,

150:15, 153:7,

153:13, 153:18,

154:15, 159:3,

159:6, 161:10,

161:15

coherent [1] - 43:24

college [1] - 128:15

color [2] - 91:6, 91:8

Columbus [22] - 1:9,

1:17, 1:18, 2:3, 2:6,

2:8, 2:9, 5:13, 8:22,

32:5, 32:8, 52:8,

52:15, 52:23, 62:14,

99:24, 102:23,

103:23, 124:22,

127:7, 137:17,

150:13

coming [5] - 28:8,

72:15, 86:10, 156:7,

161:16

command [19] - 39:10,

51:13, 51:19, 51:23,

52:5, 53:23, 54:1,

62:9, 62:18, 62:20,

107:9, 107:16,

107:17, 107:20,

107:22, 108:4,

108:9, 138:20, 149:7

commander[5] -

18:14, 18:22, 77:17,

78:1, 78:10

Commander[20] -

18:16, 71:1, 72:13,

72:20, 74:5, 75:14,

75:16, 75:20, 76:6,

76:10, 76:13, 77:8,

78:6, 84:23, 86:7,

86:19, 138:2, 138:3,

149:16, 149:24

comment [2] - 57:13,

98:2

comments [28] -

39:10, 46:3, 46:19,

47:4, 49:16, 50:17,

51:23, 52:7, 54:3,

54:9, 54:14, 55:9,

56:15, 57:17, 59:24,

61:9, 65:17, 66:3,

81:8, 81:9, 81:10,

109:19, 126:22,

127:12, 131:8,

138:4, 138:16

commission [1] -

162:22

common [6] - 46:22,

49:13, 51:13, 51:14,

134:13, 136:22

communicated [1] -

149:15

community [4] -

28:23, 29:1, 29:3,

29:16

complained [2] - 93:7,

93:21

complaining [5] -

14:1, 53:20, 93:8,

138:5, 138:6

complaint [8] - 136:3,

136:9, 136:12,

137:6, 139:6, 139:7,

139:15, 139:16

complaints [1] - 29:4

completed [1] - 44:7

completely [1] - 85:12

completion [1] - 15:12

computer[1] - 58:24

concentrate [2] -

13:22, 16:16

concentrated [1] -

16:17

concerns [1] - 147:21

concluded [1] -

161:21

conclusion [9] -

14:10, 14:13, 72:3,

72:4, 76:14, 90:7,

115:1, 125:5, 131:6

conducting [1] - 71:2

conducts [1] - 101:8

confer[1] - 159:5

conference [2] -

85:21, 143:20

confirmed [1] - 94:16

confronted [1] - 87:23

confused [6] - 84:4,

146:4, 147:20,

152:6, 153:1, 158:7

confusing [2] - 7:5,

144:23

confusion [4] - 85:7,

153:4, 156:5, 156:7

consent [1] - 88:24

considered [2] -

65:20, 98:4

contacted [3] - 68:22,

97:14, 97:16

contests [1] - 7:19

continue [2] - 6:22,

106:9

continued [1] - 138:24

Continued [1] - 106:4

continuing [1] - 151:6

conversation [38] -

3

6:11, 46:8, 46:11,

47:3, 47:7, 47:13,

48:2, 48:5, 48:11,

48:14, 48:21, 48:24,

49:6, 49:18, 49:24,

50:5, 50:6, 50:9,

50:11, 50:13, 51:7,

73:8, 77:10, 80:10,

80:13, 80:17, 87:7,

97:7, 101:23,

103:16, 104:14,

109:22, 124:24,

125:9, 130:13,

130:24, 146:21,

147:15

conversations [20] -

44:11, 44:13, 46:2,

73:4, 78:10, 92:16,

92:22, 93:5, 93:14,

93:16, 93:19, 94:3,

94:13, 103:3,

103:21, 103:23,

104:6, 134:13,

134:20, 140:4

convicted [1] - 14:16

convictions [2] - 15:9,

15:13

copied [1] - 39:22

copies [1] - 153:21

copy [3] - 91:14, 99:9,

99:16

Cornett [45] - 13:3,

39:8, 45:2, 45:15,

53:16, 53:20, 54:14,

54:20, 54:23, 55:6,

55:8, 55:13, 55:19,

56:11, 56:20, 57:6,

57:16, 58:10, 58:16,

58:17, 59:12, 59:13,

59:16, 60:11, 60:12,

60:22, 61:14, 62:8,

62:12, 62:17, 62:19,

91:21, 94:1, 94:4,

94:18, 95:3, 95:7,

95:12, 95:13, 95:22,

95:23, 96:4, 96:12,

96:20

Cornett's [1] - 96:18

correct [67] - 12:23,

28:13, 41:10, 41:22,

54:16, 54:21, 55:3,

55:10, 55:11, 57:14,

57:15, 57:17, 57:19,

60:13, 63:6, 68:19,

78:22, 80:11, 87:13,

87:16, 87:17, 88:10,

88:11, 89:1, 96:10,

96:11, 101:24,

102:1, 108:10,

108:22, 109:15,

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 166 of 177 PAGEID #: 2325
109:23, 116:14,

116:19, 117:20,

118:6, 118:15,

120:2, 120:13,

120:14, 121:16,

122:9, 122:10,

123:7, 123:12,

123:19, 129:5,

129:6, 131:12,

132:1, 143:11,

148:4, 151:1, 151:2,

151:5, 151:8,

151:11, 151:14,

151:20, 152:3,

152:4, 152:20,

154:7, 154:8,

160:24, 161:5,

162:10

corrected [2] - 80:24,

81:4

correction [1] - 162:8

correctly [2] - 22:13,

49:7

corridor[1] - 17:11

corrupt [1] - 88:21

counsel [2] - 4:5,

159:5

count [1] - 40:8

County [1] - 162:4

couple [6] - 5:21,

80:23, 91:22, 100:5,

118:3, 120:17

course [2] - 8:7, 51:6

court [2] - 58:14,

58:22

COURT [2] - 1:2, 1:22

courtesy [1] - 136:23

CPD [14] - 8:24, 9:15,

16:15, 20:9, 20:12,

24:11, 26:10, 28:10,

32:17, 52:8, 71:8,

123:5, 129:19,

137:23

credentials [2] - 43:6,

43:8

criminal [8] - 9:12,

98:14, 98:16, 99:3,

99:7, 100:1, 100:19,

135:12

cruiser[1] - 142:5

Curmode [1] - 18:17

current [1] - 9:2

custody [2] - 10:15,

116:3

cut [2] - 133:4, 140:2

D

D.A.R.E [9] - 25:19,

26:23, 28:18, 28:21,

29:7, 29:20, 30:4,

115:21, 115:22

daily [2] - 24:12, 55:15

data [2] - 82:8, 86:14

date [9] - 50:3, 72:15,

103:10, 118:23,

125:15, 139:8,

157:1, 157:15,

157:16

dated [3] - 119:24,

120:1, 126:6

dates [3] - 23:21,

119:6, 158:1

Dave [3] - 110:23,

124:17, 145:6

day-to-day [1] -

108:11

days [12] - 9:10, 9:11,

24:17, 26:14, 28:6,

28:12, 28:21, 108:5,

108:8, 115:16,

118:14, 120:15

DEA [10] - 111:16,

112:1, 145:8, 151:1,

151:3, 151:7, 151:9,

151:13, 151:20,

151:23

deal [2] - 72:5, 74:19

dealing [7] - 29:22,

30:6, 44:20, 79:16,

95:3, 104:1, 104:3

December[1] - 126:6

decide [5] - 29:15,

31:12, 105:2, 105:8,

107:2

decided [4] - 91:2,

102:18, 112:4,

159:11

deciding [1] - 13:21

decision [4] - 97:20,

102:11, 131:20,

148:8

Decker[7] - 50:4,

50:6, 92:14, 99:11,

125:11, 125:16,

136:8

declined [1] - 160:22

decree [1] - 88:24

Defendant's [2] -

146:23, 147:6

defendant's [1] - 16:3

Defendants [4] - 1:10,

1:13, 2:10, 4:7

defendants [1] - 5:12

defendants' [1] -

15:15

define [2] - 7:10,

39:16

defined [3] - 42:12,

42:13, 129:8

definition [3] - 39:24,

55:7, 65:23

delete [2] - 91:15,

105:11

deleted [1] - 104:7

delivered [1] - 136:17

demonstrate [1] -

128:16

Department [5] -

52:15, 88:23, 89:1,

122:9, 127:7

department [5] - 32:9,

32:10, 68:8, 98:23,

128:5

department's [1] -

26:1

depo [1] - 61:5

deposed [1] - 118:3

deposes [1] - 5:3

Deposition [4] - 1:12,

124:7, 141:17,

161:21

deposition [7] - 4:6,

5:15, 8:7, 117:13,

162:7, 162:14,

162:18

depositions [1] - 5:16

Deputy [1] - 158:14

derogatory [1] - 46:19

describe [3] - 33:12,

36:23, 77:10

description [1] - 35:15

desk [1] - 87:21

detective [3] - 68:5,

101:5, 129:12

Detective [8] - 72:19,

129:14, 129:17,

130:23, 131:11,

132:20, 133:10,

145:4

device [3] - 37:6,

150:10, 150:14

devices [1] - 35:1

difference [2] -

120:17, 132:12

differences [1] - 35:21

different [22] - 12:22,

28:19, 29:17, 34:1,

34:8, 34:15, 35:2,

35:8, 44:19, 91:5,

100:11, 111:14,

111:15, 111:18,

112:12, 115:21,

128:8, 132:15,

149:22, 156:2,

158:1, 160:16

difficult [1] - 6:14

direct [5] - 39:20,

41:4, 41:6, 42:9

directives [3] - 52:22,

53:2, 53:4

directly [4] - 33:19,

39:22, 40:11, 41:20

director[1] - 104:15

Director[2] - 104:18,

104:21

disagreed [1] - 87:16

disagreeing [1] -

87:19

disbanded [1] - 33:5

discharge [1] - 32:1

disclosures [1] - 16:9

discrimination [4] -

127:6, 127:8,

140:12, 140:15

discriminatory [8] -

127:3, 127:16,

128:2, 128:12,

137:19, 141:3,

143:7, 151:24

discussed [2] -

145:20, 146:14

discussing [1] - 147:1

Discussion [6] - 16:7,

21:9, 85:8, 105:14,

159:8, 161:18

discussion [1] - 146:9

dislocated [1] - 27:18

disorderly [1] - 101:7

dispute [3] - 81:23,

86:16, 156:22

District [1] - 137:7

DISTRICT [2] - 1:2, 1:3

dive [4] - 128:7,

128:10, 128:20

divide [1] - 13:10

Division [7] - 8:22,

52:23, 99:24,

102:24, 103:23,

124:22, 137:17

DIVISION [1] - 1:4

division [1] - 86:24

document [1] - 102:13

documentation [1] -

102:5

documented [1] -

86:13

Donald [1] - 15:16

done [14] - 55:23,

62:5, 78:2, 107:7,

107:12, 113:19,

114:20, 139:23,

139:24, 140:1,

143:15, 143:16,

153:23, 154:18

dope [1] - 88:20

doubt [1] - 136:19

Doug [3] - 17:2, 35:6,

39:11

Douglas [1] - 8:20

down [30] - 6:15,

4

16:19, 30:9, 37:1,

37:6, 37:10, 40:10,

45:10, 54:10, 67:5,

67:18, 79:24, 86:23,

86:24, 97:10,

104:23, 106:11,

107:11, 109:21,

118:21, 120:5,

124:16, 129:13,

135:20, 149:14,

152:12, 152:22,

161:3, 161:7

drew [1] - 32:5

drug [1] - 15:4

drugs [7] - 12:18,

13:19, 14:2, 14:8,

16:23, 19:13, 105:7

dual [1] - 111:22

DUBLIN [1] - 1:23

duly [1] - 5:2

during [23] - 26:17,

27:23, 38:3, 38:21,

40:16, 44:1, 48:2,

48:5, 48:10, 51:6,

53:1, 76:23, 81:8,

81:15, 81:21, 84:23,

86:8, 86:19, 87:6,

87:12, 87:14, 87:19,

120:21

duties [1] - 10:9

duty [5] - 9:22, 9:24,

10:4, 10:6, 28:9

E

E-Mail [6] - 3:8, 3:9,

3:10, 119:10, 124:5,

141:14

e-mail [55] - 39:9,

39:14, 39:22, 40:19,

40:20, 40:22, 41:8,

41:9, 41:10, 41:20,

44:23, 45:15, 45:17,

53:15, 53:18, 53:19,

53:23, 54:13, 54:19,

54:20, 55:12, 55:15,

55:23, 56:5, 56:11,

57:4, 57:8, 57:9,

57:10, 57:14, 57:16,

59:14, 59:16, 59:22,

60:1, 60:7, 60:10,

60:11, 60:12, 61:15,

69:7, 70:23, 72:14,

91:14, 97:17,

119:20, 119:21,

119:24, 124:11,

124:14, 141:20,

147:4

e-mailed [1] - 146:17

e-mails [1] - 138:5

Eagle [1] - 10:8

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 167 of 177 PAGEID #: 2326
earliest [1] - 119:24

early [6] - 46:13, 68:9,

118:19, 118:24,

120:19, 128:24

EARS[3] - 76:15,

76:17, 81:22

easier[3] - 66:24,

67:1, 79:11

easiest [1] - 153:16

East [5] - 2:5, 9:3, 9:6,

10:18, 10:24

EASTERN[1] - 1:4

Echenrode [4] - 65:3,

108:14, 108:23,

109:3

EEO [1] - 52:17

effect [5] - 86:23,

90:11, 112:21,

113:7, 159:16

effective [3] - 156:24,

157:15

efficient [1] - 61:6

Ehrenborg [15] - 58:5,

70:11, 70:21, 71:3,

82:20, 93:11, 148:2,

148:17, 148:20,

149:6, 149:11,

150:4, 152:18,

160:7, 160:20

eight [5] - 25:23, 27:5,

27:12, 27:20, 44:16

either[6] - 20:20,

31:7, 52:8, 54:24,

141:3, 143:10

eligible [2] - 10:4, 10:9

emotions [1] - 91:5

employed [1] - 8:21

employers [1] - 20:7

Employment[1] - 52:7

employment[2] -

52:14, 102:23

end [5] - 13:21, 14:6,

82:14, 107:11, 161:2

ended [3] - 14:14,

88:23, 124:22

endurance [1] - 7:18

enforce [1] - 9:12

enforcement [7] -

12:14, 12:16, 33:3,

34:9, 36:14, 55:14,

125:3

engage [2] - 100:5,

101:15

entering [1] - 88:23

entire [2] - 73:1, 104:1

entitled [1] - 53:5

Equal [1] - 52:7

equal [1] - 52:13

equipment [19] -

34:24, 35:12, 36:1,

36:10, 36:19, 36:24,

37:10, 37:11, 37:16,

38:4, 42:17, 42:21,

43:4, 43:10, 43:12,

43:19, 43:22, 44:10,

54:11

erase [1] - 105:8

Eric [25] - 13:3, 33:10,

44:24, 45:6, 54:9,

58:16, 63:22, 65:11,

72:20, 81:9, 82:13,

86:4, 93:8, 93:16,

94:20, 94:23, 96:3,

103:10, 104:11,

114:7, 117:9,

129:24, 131:7,

145:13

Ernie [4] - 110:3,

152:14, 152:15,

152:24

establishments [1] -

23:1

et [1] - 1:9

ethics [1] - 81:13

Evans [10] - 90:17,

90:18, 92:4, 92:5,

92:8, 92:11, 92:12,

96:15, 96:17, 134:4

eventually [2] - 70:8

evidence [1] - 137:13

evolve [1] - 19:15

evolved [1] - 19:14

exact [7] - 50:3, 84:15,

92:23, 103:10,

131:13, 139:8, 156:2

exactly [3] - 31:7,

38:18, 44:14

EXAMINATION[4] -

5:4, 106:4, 144:1,

150:18

Examination [1] - 3:2

examined [1] - 162:18

example [2] - 10:5,

101:5

examples [1] - 42:18

except [1] - 157:14

excuse [1] - 142:9

excused [1] - 62:5

execute [1] - 76:18

executed [2] - 77:22,

80:23

exhibit [2] - 146:18,

160:14

Exhibit [21] - 119:9,

119:10, 119:17,

121:23, 121:24,

124:5, 124:7, 124:9,

125:18, 125:20,

141:14, 141:17,

142:19, 146:23,

147:7, 153:8,

154:20, 157:23,

158:17, 158:18,

161:6

Exhibits [2] - 3:7,

155:14

exhibits [1] - 153:10

expect [3] - 90:12,

90:14, 135:7

expires [1] - 162:22

explain [11] - 26:9,

37:20, 75:23, 99:23,

106:16, 122:14,

145:3, 152:8, 154:2,

154:10, 154:12

explained [3] - 60:24,

106:20, 106:22

explaining [1] - 60:13

explanation [2] -

150:3, 150:4

expressed [1] -

139:10

extent [3] - 43:23,

44:17, 139:19

extra [1] - 108:6

F

F.O.P [10] - 112:11,

112:16, 123:9,

124:24, 125:1,

125:4, 125:7,

125:14, 130:1

fact [9] - 60:23, 71:23,

81:23, 86:11, 86:20,

88:22, 117:7,

117:19, 118:14

factor[2] - 120:16,

120:19

facts [7] - 60:3, 65:19,

98:24, 101:20,

112:17, 114:5,

140:13

Fagan [1] - 15:16

fair[10] - 7:15, 7:23,

8:11, 18:6, 29:13,

30:3, 32:16, 64:2,

72:3, 131:17

fairly [2] - 21:17, 22:10

fall [8] - 33:7, 83:9,

84:14, 84:18, 84:19,

84:20, 121:4, 140:5

familiar[1] - 5:17

family [2] - 91:2, 91:10

far[10] - 5:24, 35:21,

49:17, 53:4, 55:5,

55:20, 58:14, 82:19,

110:9, 127:17

Farrell [1] - 130:2

fast [1] - 32:13

fault [1] - 78:13

FBI [1] - 138:9

fear[1] - 90:24

February [11] -

118:20, 118:24,

119:2, 120:1,

120:13, 120:18,

120:20, 124:15,

130:15, 147:6, 161:2

Federal [2] - 1:14, 4:8

federal [2] - 135:15,

135:19

Fegan [1] - 15:16

fell [1] - 121:2

fellow [1] - 20:17

felon [5] - 39:7, 54:6,

55:17, 55:20, 57:23

felons [1] - 16:19

felt [7] - 18:6, 61:20,

75:22, 106:14,

106:17, 128:12,

142:3

Ferrante [1] - 1:15

FERRANTE[1] - 1:21

Fester[1] - 125:8

few [4] - 14:20, 92:23,

94:5, 107:13

fight [3] - 46:21,

49:12, 135:5

figure [7] - 27:13,

72:21, 74:15, 74:18,

93:22, 114:4, 132:11

file [12] - 98:16, 99:2,

99:7, 99:13, 112:7,

112:15, 135:12,

136:3, 136:9,

136:12, 137:6, 139:7

filed [9] - 5:13, 98:13,

99:11, 99:12, 123:8,

139:5, 139:9,

139:14, 157:24

filing [2] - 123:9,

139:16

fill [16] - 17:15, 28:5,

28:11, 76:18, 76:19,

76:24, 114:1,

121:15, 121:17,

121:18, 121:19,

122:19, 122:21,

123:4, 143:10

filled [16] - 25:13,

93:9, 93:21, 109:2,

110:1, 119:3,

120:12, 121:6,

121:20, 121:21,

123:22, 124:18,

145:23, 147:1,

147:2, 147:8

filling [3] - 84:6,

110:18, 126:23

5

final [2] - 8:13, 97:19

finally [1] - 24:9

fine [4] - 8:6, 25:22,

67:2, 78:14

finish [2] - 64:3, 64:5

Fire [1] - 128:14

fired [3] - 96:8, 135:3,

155:6

first [56] - 5:2, 5:23,

19:12, 21:3, 21:24,

22:1, 22:4, 23:4,

25:10, 33:17, 34:3,

46:10, 47:3, 47:9,

47:10, 47:12, 48:2,

48:15, 48:16, 48:17,

49:2, 64:16, 67:3,

67:4, 67:21, 68:7,

69:21, 77:12, 79:23,

82:4, 84:12, 84:17,

85:20, 92:21, 94:2,

97:19, 102:21,

102:22, 108:18,

115:22, 116:6,

116:13, 123:19,

125:10, 125:11,

125:17, 128:5,

128:8, 138:22,

146:24, 148:1,

148:24, 149:5, 149:6

firsthand [13] - 38:24,

39:5, 39:19, 40:1,

40:2, 42:6, 42:9,

55:7, 55:8, 65:21,

65:24, 129:4, 129:7

fit [4] - 10:14, 118:17,

132:8, 132:10

five [8] - 8:5, 14:18,

80:21, 93:2, 93:3,

94:6, 94:10

flip [1] - 156:15

focus [4] - 13:18,

38:22, 43:16, 124:13

folks [2] - 13:6, 16:14

follow [2] - 120:11,

143:18

follow-up [2] - 120:11,

143:18

following [2] - 12:18,

16:21

follows [1] - 5:3

football [2] - 10:1,

27:14

force [40] - 9:15,

14:23, 19:21, 20:1,

20:4, 20:8, 37:8,

43:6, 43:8, 77:15,

77:17, 79:4, 79:14,

82:2, 82:5, 104:16,

111:17, 111:23,

112:1, 112:20,

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 168 of 177 PAGEID #: 2327
112:24, 113:1,

113:3, 113:4, 113:6,

113:10, 114:3,

129:18, 129:21,

144:6, 144:11,

145:8, 145:9, 151:1,

151:7, 151:9,

151:13, 151:20,

151:23

forces [3] - 19:17,

19:20, 20:6

foregoing [2] - 162:6,

162:14

forfeit [1] - 28:6

forget [2] - 111:8,

158:24

form [3] - 67:2, 76:17,

162:9

forward [2] - 91:13,

97:1

forwarded [1] - 40:19

four [6] - 8:5, 9:7,

80:21, 152:8, 152:9,

154:13

frame [9] - 37:24,

63:1, 66:19, 75:8,

77:14, 95:17, 96:24,

121:5, 155:2

frames [4] - 18:24,

79:12, 130:14,

139:13

Fraternal [1] - 122:8

Fred [2] - 61:5, 150:20

Frederick [1] - 2:2

free [1] - 67:1

freeway [9] - 120:22,

121:16, 122:12,

122:16, 123:1,

130:22, 141:13,

142:4, 142:5

frequently [2] - 9:24,

134:3

Friday [1] - 10:21

friend [1] - 33:13

friends [5] - 69:16,

92:4, 114:7, 114:18,

115:2

Front [2] - 1:18, 2:9

front [1] - 122:1

full [3] - 24:9, 28:9,

160:12

full-time [1] - 24:9

fully [1] - 127:20

fun [1] - 32:20

FURTHER [1] - 150:18

G

game [1] - 27:14

games [2] - 10:1, 10:2

gap [1] - 121:7

general [2] - 13:7,

28:10

generally [5] - 7:1,

9:8, 44:17, 67:2,

73:16

gentleman's [1] -

158:24

Giant [1] - 10:8

girlfriend [1] - 15:18

Gittes [4] - 2:2, 2:2,

3:4, 144:2

GITTES [43] - 16:5,

16:8, 21:6, 40:13,

41:11, 41:14, 41:18,

42:12, 60:15, 60:17,

60:19, 61:6, 66:8,

73:21, 82:22, 84:3,

85:2, 85:6, 90:3,

99:14, 99:19, 103:1,

103:4, 111:10,

119:5, 119:12,

119:15, 125:23,

126:3, 139:23,

143:16, 143:20,

146:12, 150:17,

153:2, 153:11,

153:17, 155:13,

155:16, 159:1,

159:20, 161:13,

161:19

given [10] - 72:5,

99:10, 99:11, 109:8,

135:21, 142:4,

148:14, 149:12,

150:3, 162:7

Googled [2] - 81:19,

88:13

Googling [1] - 88:15

government[1] -

135:15

GPSs [1] - 34:24

graduate [1] - 31:9

graduating [1] - 32:24

graduation [1] - 10:3

Gray [1] - 158:14

great [2] - 5:24, 67:1

grievance [8] - 112:7,

112:15, 121:14,

122:23, 122:24,

123:8, 123:10,

158:16

grieve [1] - 113:10

group [1] - 34:1

Group [1] - 2:2

groups [1] - 156:17

guess [6] - 30:11,

88:17, 88:19, 113:7,

130:3, 130:10

guns [2] - 88:20

guy [1] - 59:8

H

half [4] - 10:7, 19:10,

31:17, 128:6

hand [5] - 121:22,

124:6, 125:19,

141:15, 142:21

handed [1] - 119:17

happy [1] - 7:9

hard [2] - 91:4, 94:15

harm [4] - 46:22,

49:12, 94:22, 95:8

Harris [4] - 141:11,

141:12, 141:21,

142:11

Hawkins [2] - 22:1,

22:6

head [3] - 6:2, 19:1,

44:1

healed [1] - 123:3

hear[4] - 7:7, 65:5,

96:9, 140:3

heard [13] - 8:1, 40:18,

40:20, 41:5, 54:15,

55:1, 55:2, 55:4,

71:11, 96:20, 118:3,

126:22, 150:4

heat [1] - 73:22

Heidi [5] - 72:19,

72:23, 74:10, 97:6,

143:1

held [4] - 11:22, 43:8,

128:10, 134:13

help [4] - 27:10, 41:12,

60:5, 60:17

hereby [2] - 162:5,

162:13

herein [2] - 1:13, 4:7

hereinafter[1] - 5:2

hereto [1] - 162:8

hidden [4] - 53:21,

54:2, 59:9, 59:12

high [6] - 9:3, 9:17,

9:20, 32:3, 81:13,

101:6

High [5] - 9:4, 10:19,

11:1, 50:2

higher [1] - 98:24

higher-ups [1] - 98:24

himself [2] - 62:5,

117:11

historically [1] - 60:23

history [4] - 57:1,

135:3, 151:12,

151:18

hit [1] - 105:10

hold [1] - 128:13

holds [1] - 155:7

holler [1] - 64:4

home [4] - 10:1, 10:2,

91:3, 91:11

honest [1] - 50:18

honestly [1] - 8:16

honorable [1] - 32:1

hotel [9] - 14:7, 63:20,

64:11, 64:20, 64:21,

64:23, 65:17, 65:18,

66:1

hotels [10] - 13:20,

14:3, 14:5, 14:9,

14:11, 14:18, 17:10,

17:14, 44:7, 104:17

hours [3] - 10:18,

120:24, 122:17

house [2] - 30:18,

30:19

houses [1] - 30:21

housing [3] - 30:2,

30:5, 30:16

human [16] - 14:23,

19:16, 19:21, 37:7,

43:5, 77:15, 77:17,

77:22, 79:4, 79:14,

80:22, 82:1, 82:5,

104:16, 105:7, 138:7

hung [1] - 134:3

I

IA [1] - 134:11

ICE [3] - 20:11, 20:12,

43:6

idea [1] - 17:6

identifies [1] - 17:16

identify [8] - 119:19,

122:4, 124:8, 124:9,

125:20, 141:18,

142:22, 153:24

illegal [5] - 23:1,

150:10, 150:11,

150:12, 150:16

illicit [1] - 89:8

implement [1] - 30:9

important [2] - 5:24,

118:18

impression [1] - 53:12

INC [3] - 110:21,

111:4, 159:17

incidences [1] - 62:22

including [1] - 147:19

independently [2] -

51:22, 52:6

indicated [1] - 145:17

individual [4] - 20:5,

32:6, 40:11, 98:13

individuals [1] - 55:1

individuals' [2] -

16:10, 66:4

6

INE [2] - 110:20, 111:4

inform [2] - 43:17,

69:6

information [4] - 51:9,

62:7, 98:22, 131:21

informed [9] - 14:4,

44:2, 54:1, 69:2,

82:14, 96:12, 97:4,

117:8, 137:2

initial [3] - 79:15,

157:7, 158:4

inputs [1] - 107:10

inside [1] - 12:22

instances [1] - 100:13

Instead [1] - 123:9

instructions [1] -

109:8

intention [1] - 6:19

interact [2] - 34:18,

34:21

interaction [4] - 18:1,

18:18, 41:4, 41:7

interested [4] - 82:14,

97:18, 149:19, 150:2

internal [12] - 92:14,

98:21, 98:23,

112:13, 112:14,

125:12, 131:9,

134:9, 136:7,

139:10, 140:6

interrupt [5] - 6:12,

6:18, 6:19, 6:21,

54:7

interrupted [1] - 6:21

interview [32] - 70:24,

71:2, 72:12, 72:16,

72:17, 72:18, 74:4,

79:7, 79:19, 81:8,

81:16, 81:21, 81:23,

82:19, 84:24, 85:16,

86:6, 86:8, 86:19,

87:6, 87:15, 87:20,

89:16, 97:5, 97:6,

102:17, 110:16,

110:17, 125:11,

125:16, 150:1, 150:5

interviewed [6] - 71:8,

71:12, 71:15, 71:22,

83:18, 85:19

interviewing [2] -

85:24, 89:22

introduce [2] - 5:10,

153:14

investigate [2] -

24:22, 130:10

investigated [4] -

56:5, 56:6, 56:12,

98:21

investigating [1] -

136:13

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 169 of 177 PAGEID #: 2328
investigation [7] -

14:7, 14:11, 14:15,

33:11, 131:8, 134:9,

134:11

investigations [6] -

15:7, 16:13, 17:13,

30:12, 35:23, 66:4

investigative [2] -

127:14, 151:19

Investigative [12] -

67:8, 144:9, 144:11,

144:14, 144:19,

145:7, 145:10,

145:11, 145:12,

150:21

investigator's [1] -

79:8

involved [4] - 20:13,

29:23, 58:6, 103:24

issue [8] - 29:14,

30:18, 37:8, 37:18,

39:7, 87:15, 101:21,

101:22

issues [32] - 18:8,

18:21, 21:13, 21:14,

21:16, 22:5, 23:8,

25:2, 28:1, 32:21,

35:22, 36:1, 36:5,

36:8, 36:11, 36:18,

38:4, 42:16, 42:20,

43:18, 44:9, 45:3,

53:17, 56:17, 62:23,

63:11, 64:7, 105:5,

105:6, 125:2,

126:23, 127:1

J

Jack [1] - 141:11

jack [1] - 141:12

Jackson [1] - 26:7

Jacobs [3] - 11:16,

11:18, 126:6

Jamaican [1] - 15:20

James [1] - 13:3

Jane [2] - 1:15, 6:14

JANE[1] - 1:21

Jeremy [4] - 58:5,

158:10, 158:15

Jeremy's [1] - 158:12

Jerry [3] - 129:12,

136:15, 137:1

Job [6] - 3:11, 3:12,

122:11, 152:15,

153:8, 154:20

job [159] - 9:16, 11:10,

11:13, 11:14, 11:20,

24:8, 24:9, 25:17,

26:13, 26:16, 26:18,

28:5, 28:6, 28:11,

28:23, 31:14, 33:3,

35:2, 35:14, 63:15,

63:17, 64:9, 64:10,

64:15, 66:24, 67:1,

67:3, 67:12, 67:21,

69:18, 70:2, 70:24,

71:3, 71:22, 72:22,

73:12, 73:14, 74:16,

74:18, 75:22, 76:1,

82:15, 83:6, 83:23,

86:1, 90:12, 90:21,

91:7, 93:9, 93:10,

93:21, 94:24, 96:4,

96:18, 97:9, 97:10,

97:18, 98:7, 98:11,

106:21, 107:2,

107:6, 107:18,

107:21, 107:24,

108:6, 109:21,

110:21, 112:21,

113:13, 113:16,

113:21, 114:1,

114:10, 114:13,

114:16, 114:22,

115:9, 115:15,

115:21, 115:23,

116:1, 116:21,

117:9, 117:19,

118:20, 120:22,

120:24, 121:5,

121:8, 121:10,

121:13, 121:16,

121:20, 121:21,

122:16, 122:19,

122:21, 123:1,

123:4, 123:18,

124:3, 124:16,

124:17, 135:16,

142:4, 142:6, 142:8,

145:10, 145:14,

145:18, 145:23,

146:6, 146:9,

146:10, 146:16,

146:24, 147:21,

148:1, 148:8,

148:11, 148:12,

148:13, 148:24,

149:5, 149:13,

149:14, 149:17,

149:20, 150:2,

152:11, 152:18,

152:21, 152:24,

155:8, 155:24,

156:10, 156:22,

157:7, 158:8,

158:11, 158:12,

158:15, 158:16,

158:18, 158:21,

159:12, 159:13,

159:14, 159:24,

160:7, 160:17,

160:18, 161:7

jobs [26] - 10:5, 10:14,

12:16, 24:11, 64:19,

66:21, 116:6, 116:8,

116:9, 116:23,

120:22, 142:16,

147:23, 148:21,

152:8, 154:13,

155:10, 155:17,

155:20, 156:1,

156:6, 158:4,

159:13, 159:17,

160:13, 160:16

jogs [1] - 8:7

John [13] - 21:3,

67:13, 67:24, 90:17,

92:4, 92:5, 92:8,

92:12, 96:15, 134:4,

141:21, 159:10

Johnson [1] - 20:21

joined [1] - 150:24

joint [2] - 10:15, 116:3

joints [1] - 22:24

Joyce [1] - 20:22

Jr[1] - 2:4

July [6] - 1:19, 4:2,

12:3, 106:2, 159:16,

162:7

Justice [1] - 88:23

K

KARL [1] - 5:1

Karl [9] - 1:6, 1:12,

4:6, 8:20, 47:17,

123:15, 162:5,

162:11, 162:14

keep [2] - 74:18,

119:16

keeping [1] - 18:24

kept [2] - 117:10,

133:23

kid [1] - 101:10

kids [5] - 9:12, 101:22,

116:3, 116:4, 118:17

Kimmerling [6] -

17:24, 18:2, 18:9,

18:15, 59:19, 104:24

kind [14] - 13:12,

19:13, 26:8, 36:16,

42:4, 45:10, 67:1,

68:14, 97:3, 100:4,

100:16, 106:8,

116:23, 126:21

Klein [1] - 1:17

knee [6] - 11:11, 28:1,

121:11, 121:12,

123:3, 142:10

kneecap [1] - 27:18

knowledge [27] -

15:10, 20:18, 39:1,

39:5, 39:19, 40:1,

40:2, 41:4, 41:6,

42:6, 42:9, 42:22,

45:19, 51:13, 51:15,

55:8, 55:9, 63:8,

65:21, 65:24, 68:18,

113:5, 129:4, 129:8,

134:13, 146:2

known [4] - 34:5,

38:19, 133:23,

134:10

L

Lancaster[7] - 13:3,

48:1, 48:4, 48:9,

50:10, 50:23, 72:6

Lang [17] - 77:6, 77:7,

77:12, 77:16, 77:18,

78:5, 78:9, 78:16,

78:17, 78:20, 78:24,

79:9, 80:4, 80:6,

80:12, 80:16

large [1] - 121:7

Larry [2] - 13:2, 134:4

last [3] - 52:17, 78:3,

149:23

late [5] - 46:12, 68:9,

119:2, 120:13,

130:15

Law [1] - 2:2

law [4] - 102:10,

135:18, 135:19,

136:1

lawyer[1] - 102:23

lawyers [1] - 8:1

lazy [4] - 46:20, 49:11,

81:12, 85:1

lead [1] - 20:9

learn [9] - 61:17, 65:8,

72:7, 84:12, 88:15,

95:6, 96:13, 101:12,

129:10

learned [4] - 97:8,

97:11, 97:13, 149:10

least [6] - 5:16, 7:18,

55:5, 64:6, 68:17,

130:14

leave [2] - 28:1,

138:14

leaves [2] - 63:9,

157:5

led [2] - 15:13, 82:1

left [24] - 20:14, 20:19,

23:6, 36:13, 37:13,

38:1, 45:12, 45:17,

45:22, 63:12, 64:8,

81:19, 108:12,

108:24, 110:20,

140:24, 144:10,

144:15, 145:5,

7

145:11, 148:17,

149:24, 158:11,

160:5

legal [1] - 150:10

less [10] - 92:24, 93:1,

93:2, 93:3, 94:7,

94:11, 149:2, 149:4,

149:8

letter[8] - 38:11,

38:13, 51:18, 122:6,

122:7, 123:18,

126:4, 126:5

Letter[2] - 3:9, 121:24

liaison [3] - 28:23,

29:1, 29:16

lie [1] - 138:9

lies [1] - 138:20

lieutenant [12] - 17:23,

21:20, 77:16,

108:13, 108:15,

108:16, 108:22,

109:2, 109:8,

109:13, 109:14,

141:12

Lieutenant [63] -

17:24, 18:2, 18:8,

18:15, 21:24, 22:4,

22:6, 22:8, 59:19,

65:2, 70:24, 72:12,

74:5, 75:11, 77:6,

77:7, 77:12, 77:15,

77:18, 78:5, 80:4,

80:6, 80:12, 84:24,

87:5, 97:14, 97:16,

97:22, 101:24,

102:6, 102:12,

103:16, 103:20,

106:10, 106:13,

106:16, 107:1,

107:15, 108:13,

109:3, 109:4,

109:23, 115:10,

115:12, 117:6,

117:8, 118:2, 118:7,

118:19, 119:22,

124:12, 124:14,

124:15, 141:21,

142:11, 145:17,

146:14, 146:21,

146:23, 147:15,

149:16, 149:24,

152:23

lieutenants [2] -

21:22, 109:10

light [1] - 149:21

lightning [15] -

127:19, 128:3,

129:3, 129:11,

130:9, 132:8,

132:14, 132:20,

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 170 of 177 PAGEID #: 2329
135:13, 135:22,

135:24, 136:4,

137:8, 150:8, 150:10

line [3] - 6:3, 7:13,

113:18

lines [1] - 47:16

link [15] - 127:19,

128:3, 129:3,

129:11, 130:9,

132:8, 132:14,

132:20, 135:14,

135:22, 135:24,

136:4, 137:8, 150:8,

150:10

liquor [1] - 23:1

list [20] - 66:13, 68:18,

75:21, 75:24, 76:4,

76:7, 76:10, 77:13,

77:20, 78:4, 78:11,

80:1, 80:21, 81:1,

81:4, 81:24, 130:4,

130:8, 130:11,

135:21

listed [1] - 12:1

listen [1] - 51:4

listened [1] - 51:3

listening [1] - 34:24

lists [1] - 116:9

litigation [2] - 72:9,

72:10

LLP [1] - 2:5

located [1] - 59:1

locations [1] - 17:16

look [12] - 58:3, 64:13,

77:5, 115:20,

125:23, 134:7,

139:20, 141:18,

153:22, 155:24,

156:12, 157:23

looking [13] - 15:4,

37:24, 39:8, 44:16,

53:24, 58:9, 58:12,

59:2, 120:17,

128:24, 153:23,

153:24, 155:21

looks [3] - 22:13,

23:15, 126:15

Los [1] - 88:24

lost [1] - 115:21

Lunch [1] - 105:15

lunch [3] - 47:10,

47:17, 106:7

M

Mail [6] - 3:8, 3:9,

3:10, 119:10, 124:5,

141:14

mail [55] - 39:9, 39:14,

39:22, 40:19, 40:20,

40:22, 41:8, 41:9,

41:10, 41:20, 44:23,

45:15, 45:17, 53:15,

53:18, 53:19, 53:23,

54:13, 54:19, 54:20,

55:12, 55:15, 55:23,

56:5, 56:11, 57:4,

57:8, 57:9, 57:10,

57:14, 57:16, 59:14,

59:16, 59:22, 60:1,

60:7, 60:10, 60:11,

60:12, 61:15, 69:7,

70:23, 72:14, 91:14,

97:17, 119:20,

119:21, 119:24,

124:11, 124:14,

141:20, 147:4

mailed [1] - 146:17

mails [1] - 138:5

main [3] - 13:18, 44:8,

46:8

maintaining [1] -

151:22

Malone [7] - 72:19,

72:23, 73:4, 74:10,

74:12, 97:7, 143:1

map [2] - 58:23, 59:2

marathon [1] - 10:7

March [8] - 126:16,

126:18, 126:19,

130:18, 133:10,

133:19, 147:13,

157:1

Marine [1] - 31:23

Mark [1] - 20:20

mark [2] - 123:2, 125:8

marked [17] - 119:9,

119:11, 121:23,

121:24, 124:5,

124:7, 125:18,

125:20, 141:14,

141:16, 141:17,

142:19, 142:22,

153:8, 153:12,

153:14, 154:20

mass [2] - 135:5,

135:11

math [2] - 22:12,

23:15

Mathis [1] - 13:4

matters [2] - 8:14,

52:14

max [1] - 24:18

MCL [1] - 27:17

mean [20] - 11:13,

12:15, 13:2, 14:13,

29:24, 34:12, 36:23,

39:20, 51:20, 54:7,

75:5, 82:1, 86:3,

89:22, 91:4, 91:14,

133:4, 140:2,

145:11, 154:16

meaning [1] - 90:13

means [1] - 11:14

meant [2] - 53:7,

148:21

mechanism [1] -

131:10

medical [1] - 27:24

meet [4] - 47:10,

97:19, 97:21, 104:15

meeting [11] - 13:23,

14:1, 14:3, 17:9,

53:13, 97:24,

102:18, 104:22,

105:3, 145:17,

145:20

meetings [1] - 29:3

member[3] - 52:14,

99:24, 129:19

members [2] - 20:1,

20:7

memory [2] - 8:3, 8:8

menacing [1] - 101:19

mentioned [2] - 53:15,

88:5

MERIT [1] - 1:22

message [25] - 72:19,

73:3, 73:5, 74:15,

90:9, 90:10, 90:15,

90:19, 90:23, 91:12,

91:15, 92:6, 92:13,

92:17, 92:20, 93:6,

93:15, 94:4, 94:9,

96:16, 99:10, 99:16,

141:5, 142:24, 143:2

messages [1] - 127:13

Messages [2] - 3:11,

142:19

messed [1] - 60:3

met [4] - 5:8, 34:4,

145:16, 146:20

method [2] - 43:3,

43:4

mid [1] - 128:24

middle [1] - 61:21

might [7] - 21:22,

21:23, 44:5, 53:13,

84:12, 91:2, 101:14

Mike [3] - 20:21,

110:24, 111:16

military [3] - 31:15,

128:10, 128:23

Miller[1] - 20:20

mind [9] - 7:2, 15:19,

64:17, 66:16, 73:21,

95:5, 107:13,

128:18, 141:9

minute [2] - 51:8,

105:13

mirror[1] - 81:9

misunderstood [2] -

78:12, 79:12

moment [7] - 12:20,

45:8, 115:7, 141:10,

141:23, 143:8,

147:10

Monday [5] - 1:18, 4:1,

10:21, 106:1, 162:7

monkeys [3] - 46:21,

49:11, 61:10

month [2] - 24:18,

96:21

months [7] - 24:6,

27:5, 27:12, 27:20,

83:6, 118:4

Moore [125] - 13:4,

33:11, 33:16, 33:17,

33:20, 34:22, 35:13,

36:3, 36:6, 36:9,

36:12, 37:12, 37:16,

37:23, 38:5, 38:16,

39:1, 39:11, 39:23,

40:3, 42:6, 42:10,

43:19, 44:10, 44:20,

44:22, 44:24, 45:6,

45:11, 45:16, 45:21,

49:10, 50:17, 53:16,

54:9, 54:15, 55:2,

56:7, 56:15, 56:19,

57:13, 58:16, 59:21,

60:1, 60:6, 60:21,

62:24, 63:12, 63:22,

64:8, 65:2, 65:5,

65:9, 65:10, 65:11,

65:16, 65:24, 66:7,

66:12, 67:6, 67:7,

69:5, 69:6, 69:15,

70:23, 71:14, 71:21,

72:11, 72:20, 81:9,

82:13, 86:4, 89:21,

90:8, 90:13, 91:21,

92:20, 92:22, 93:5,

93:8, 93:14, 93:17,

93:18, 93:20, 94:20,

94:23, 95:6, 96:3,

96:10, 97:9, 98:6,

98:17, 99:3, 99:8,

103:10, 104:11,

107:23, 114:7,

114:12, 114:19,

115:2, 115:4, 117:1,

117:2, 117:9,

126:22, 127:12,

129:24, 130:5,

131:7, 132:5,

132:12, 132:21,

133:11, 134:23,

135:13, 136:4,

144:13, 144:22,

8

144:24, 145:4,

145:13, 155:6, 160:3

Moore's [7] - 35:7,

35:14, 45:15, 46:3,

57:13, 133:19,

133:22

morning [3] - 5:6, 5:7,

5:14

Morning [1] - 4:1

Morse [1] - 13:20

most [5] - 9:10, 9:11,

10:14, 101:6, 135:5

motivated [5] - 56:21,

57:3, 59:22, 60:2,

139:11

motivating [2] -

120:15, 120:19

motivation [1] - 114:5

mouth [1] - 85:13

mouthing [1] - 65:12

move [3] - 49:5, 67:16,

113:15

moving [2] - 107:18,

107:20

MR [83] - 16:5, 16:8,

16:12, 21:6, 21:8,

21:10, 40:13, 40:15,

41:11, 41:13, 41:14,

41:16, 41:18, 41:23,

42:1, 42:12, 42:13,

60:15, 60:16, 60:17,

60:18, 60:19, 61:3,

61:6, 61:8, 66:8,

73:21, 73:23, 74:1,

82:22, 82:24, 84:3,

84:5, 85:2, 85:6,

85:9, 90:3, 90:6,

99:14, 99:19, 103:1,

103:2, 103:4,

105:12, 106:6,

111:10, 111:11,

119:5, 119:12,

119:13, 119:15,

125:23, 126:1,

126:3, 139:23,

143:13, 143:16,

143:19, 143:20,

146:10, 146:12,

147:22, 148:10,

149:18, 150:15,

150:17, 153:2,

153:7, 153:11,

153:13, 153:17,

153:18, 154:15,

155:13, 155:16,

159:1, 159:3, 159:6,

159:20, 161:10,

161:13, 161:15,

161:19

mud [1] - 161:11

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 171 of 177 PAGEID #: 2330
multiple [1] - 153:9

N

name [17] - 5:10, 8:19,

15:18, 16:3, 22:1,

22:4, 23:12, 67:11,

67:13, 77:13, 77:20,

78:3, 78:11, 108:18,

114:1, 158:24,

160:13

names [8] - 15:15,

20:5, 30:23, 33:15,

87:22, 88:18, 134:17

narcotics [50] - 19:7,

19:8, 19:11, 19:13,

19:23, 20:17, 22:14,

22:18, 23:24, 37:7,

63:15, 63:17, 64:9,

64:10, 64:15, 64:19,

66:22, 67:15, 69:10,

70:2, 71:7, 72:16,

72:22, 75:6, 75:10,

75:12, 75:16, 75:17,

76:24, 79:23, 86:10,

86:24, 87:13, 90:12,

104:23, 110:14,

111:20, 112:2,

117:9, 126:24,

127:14, 130:21,

130:22, 138:22,

140:15, 141:1,

144:14, 154:6,

154:7, 160:6

Navy [3] - 31:19,

128:6, 128:10

need [6] - 7:19, 20:4,

20:5, 34:18, 34:21,

143:10

needed [20] - 31:14,

35:12, 43:4, 43:12,

50:18, 50:19, 71:15,

71:21, 72:12, 91:16,

97:19, 102:19,

106:14, 106:17,

109:9, 109:12,

116:2, 118:17,

131:1, 131:5

needing [2] - 36:1

Neil [1] - 20:20

never[47] - 11:8,

15:11, 21:14, 21:16,

22:7, 22:9, 23:11,

23:14, 24:8, 25:13,

27:8, 28:4, 29:13,

33:4, 33:19, 56:12,

57:8, 57:9, 57:14,

60:6, 65:4, 80:24,

81:4, 85:13, 86:12,

92:12, 99:10,

101:21, 112:1,

113:21, 114:11,

117:10, 121:20,

121:21, 122:21,

123:22, 131:11,

131:22, 135:7,

136:20, 136:24,

137:3, 138:17,

138:18, 149:14,

150:6

new [4] - 19:23,

108:15, 119:12,

126:16

next [7] - 113:18,

125:13, 158:3,

160:8, 160:17,

160:18, 161:1

nine [3] - 27:5, 27:12,

27:20

none [3] - 25:4, 32:22,

39:12

normal [2] - 6:11,

10:18

North [2] - 1:18, 2:9

Nos [2] - 153:8,

154:20

Notary [5] - 1:15, 4:10,

4:13, 162:17, 162:20

notes [3] - 4:10, 49:6,

82:21

nothing [12] - 53:11,

55:21, 63:4, 63:24,

75:2, 75:18, 80:18,

87:10, 95:5, 135:5,

141:9, 161:13

notice [2] - 1:16,

26:13

notification [3] -

84:16, 84:21, 126:11

notifying [1] - 76:19

noting [1] - 162:9

November[1] - 31:11

nuisance [1] - 14:17

number[8] - 25:22,

28:12, 110:6,

110:10, 148:14,

156:13, 157:9,

157:13

numbered [1] - 88:17

numbers [6] - 92:23,

119:14, 156:1,

157:18, 157:21,

160:14

O

Oak [1] - 2:3

Objection [3] -

147:22, 149:18,

150:15

objection [8] - 85:2,

99:14, 99:19, 103:1,

146:10, 148:10,

149:21, 159:20

obligated [3] - 100:2,

100:4, 100:17

obligation [3] - 99:23,

100:16, 100:21

obligations [1] - 100:6

observed [1] - 40:18

obtain [3] - 43:3,

150:13, 150:14

occasions [2] - 28:19,

128:8

occurred [4] - 46:11,

49:24, 100:1, 100:20

occurrence [1] - 49:13

occurring [1] - 140:5

OF [1] - 1:3

offered [3] - 68:21,

116:15, 152:22

offhand [3] - 23:7,

30:8, 110:8

office [16] - 5:11, 20:3,

34:19, 35:24, 38:20,

48:18, 48:20, 72:21,

73:7, 125:14,

129:12, 129:23,

132:18, 133:24,

134:3, 134:14

officer[19] - 9:3, 9:6,

9:9, 9:16, 9:18, 9:20,

55:4, 58:17, 67:10,

70:14, 90:17, 95:10,

98:12, 101:6,

101:13, 110:20,

110:22, 136:23,

161:15

Officer[94] - 16:9,

30:24, 31:1, 32:23,

33:9, 33:12, 38:15,

39:8, 42:3, 45:1,

47:2, 47:13, 47:21,

47:24, 48:4, 48:9,

49:9, 49:15, 50:10,

50:16, 50:23, 51:5,

51:10, 53:6, 53:19,

54:14, 54:20, 54:23,

55:6, 55:8, 55:13,

55:18, 55:19, 56:11,

56:20, 58:5, 58:10,

59:13, 59:16, 61:14,

62:8, 62:12, 62:17,

62:19, 65:2, 65:9,

65:10, 66:10, 68:4,

68:10, 69:10, 69:18,

70:11, 70:21, 72:6,

72:23, 73:4, 74:3,

74:12, 83:23, 85:12,

90:18, 91:20, 91:21,

92:11, 92:22, 93:5,

93:11, 93:14, 94:1,

94:3, 94:18, 95:3,

95:7, 95:13, 95:14,

96:12, 96:14, 96:17,

96:19, 106:8,

133:18, 133:21,

143:14, 144:3,

144:6, 145:4, 148:2,

150:13, 153:22,

159:10, 159:11

officers [21] - 10:6,

20:17, 25:20, 26:4,

26:11, 37:18, 38:6,

38:10, 38:17, 39:2,

40:4, 42:7, 42:10,

42:19, 46:20, 71:11,

75:21, 76:3, 88:19,

89:7

offices [1] - 1:17

official [2] - 4:12,

126:11

officially [2] - 84:16,

84:21

officials [1] - 52:8

OHIO [2] - 1:3, 1:23

Ohio [11] - 1:16, 1:18,

2:3, 2:6, 2:9, 32:4,

135:18, 136:1,

137:7, 162:2, 162:21

old [1] - 58:11

Oliverio [2] - 23:4,

23:9

Olympics [1] - 128:14

once [6] - 21:21, 28:5,

45:12, 97:11, 97:13

one [80] - 12:14,

15:16, 15:19, 15:22,

15:23, 16:2, 19:24,

20:11, 20:14, 20:20,

20:21, 20:22, 21:6,

21:7, 21:24, 22:3,

23:4, 30:23, 33:10,

33:15, 42:17, 43:24,

46:4, 47:5, 47:9,

47:24, 48:15, 48:17,

49:2, 55:1, 55:3,

64:15, 65:1, 70:8,

70:10, 70:20, 75:24,

82:3, 82:9, 83:1,

83:17, 89:12, 89:14,

96:15, 100:20,

104:9, 106:22,

107:4, 111:13,

111:22, 112:3,

116:12, 118:16,

119:12, 120:16,

120:22, 121:1,

123:11, 124:13,

127:18, 136:13,

146:13, 146:19,

147:2, 148:17,

9

148:18, 156:18,

158:3, 158:8, 158:9,

158:11, 159:15,

160:8, 160:10,

160:12

ones [4] - 15:12, 53:5,

66:15, 104:4

open [9] - 116:6,

145:24, 146:1,

146:9, 146:16,

148:18, 148:22,

158:8, 158:11

opened [1] - 148:8

opening [2] - 67:5,

144:19

openings [1] - 147:21

opens [1] - 161:7

opportunities [1] -

9:19

Opportunity [1] - 52:7

opportunity [1] - 64:3

option [3] - 121:2,

121:4

Orak [10] - 129:12,

129:15, 129:17,

130:23, 131:11,

132:20, 133:1,

133:10, 136:15,

137:1

order[10] - 16:11,

37:11, 58:14, 58:22,

72:5, 109:1, 121:15,

136:19, 137:3,

158:23

Order[1] - 122:8

ordered [2] - 130:9,

135:22

ordering [6] - 127:19,

132:13, 135:10,

135:13, 136:15,

137:8

orders [1] - 109:9

original [1] - 20:1

originally [1] - 145:6

ouch [1] - 27:19

outside [4] - 10:5,

71:8, 114:18, 137:18

overtime [1] - 9:20

own [5] - 13:13, 30:16,

37:11, 43:15

owned [1] - 133:8

P

p.m [2] - 10:20, 161:21

Page [2] - 3:2, 3:7

page [7] - 5:20, 39:17,

79:21, 123:14,

156:15, 162:8

paper[1] - 87:21

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 172 of 177 PAGEID #: 2331
paperwork [2] - 121:9,

136:16

part [2] - 9:14, 96:14

participating [1] -

89:8

particular[3] - 10:13,

13:15, 16:9

particulars [1] - 39:9

parties [2] - 4:6, 16:8

parts [2] - 59:10,

59:12

party [1] - 40:7

pass [3] - 69:17,

98:11, 159:11

passed [8] - 67:12,

67:18, 83:22, 147:9,

157:7, 157:8,

158:23, 159:24

passing [1] - 69:3

past [1] - 127:23

patrol [6] - 11:2, 11:7,

115:19, 122:16,

123:18, 124:3

PCL [1] - 27:17

pending [1] - 7:22

Pendleton [1] - 31:24

people [35] - 14:15,

15:1, 16:18, 16:22,

20:19, 21:21, 29:22,

30:16, 35:16, 40:22,

47:23, 53:7, 53:24,

58:20, 59:1, 59:6,

65:1, 75:24, 80:21,

88:19, 91:19,

104:15, 108:12,

112:13, 127:12,

130:8, 130:11,

134:3, 134:12,

135:6, 135:11,

135:21, 137:14

perfect [1] - 6:9

performing [1] - 75:22

period [24] - 26:18,

30:17, 38:3, 38:21,

38:22, 40:2, 40:14,

40:16, 42:5, 42:11,

43:13, 43:17, 44:1,

45:11, 53:1, 71:24,

72:1, 75:15, 76:23,

88:9, 89:19, 89:21,

99:6, 118:5

person [13] - 7:3,

32:10, 47:24, 50:2,

58:9, 58:11, 58:13,

79:24, 92:13, 109:2,

109:16, 136:11,

148:23

personal [3] - 41:4,

41:7, 133:23

personally [4] - 40:17,

40:18, 149:15

personnel [1] - 35:22

phone [5] - 58:15,

58:19, 58:21, 58:24,

67:10

physical [2] - 94:22,

95:8

Piccinnini [2] - 21:5,

21:15

pick [2] - 13:12, 13:15

picturing [1] - 35:20

piece [1] - 87:21

ping [3] - 58:15,

58:23, 59:2

pinging [1] - 58:19

place [13] - 39:12,

45:2, 48:14, 53:17,

56:8, 56:16, 56:21,

57:2, 57:5, 57:6,

60:22, 60:23, 134:20

places [1] - 34:8

Plaintiff [4] - 1:7, 1:12,

2:7, 4:7

plan [2] - 14:22, 17:6

planting [1] - 88:19

plea [1] - 15:24

plus [1] - 50:7

point [23] - 13:5,

20:14, 26:6, 35:21,

46:23, 49:13, 51:12,

63:3, 79:1, 79:3,

79:13, 84:2, 84:3,

107:3, 108:3,

123:24, 132:22,

133:15, 143:14,

145:8, 145:16,

146:8, 154:18

pointing [1] - 157:19

Police [13] - 8:23,

52:15, 52:23, 88:24,

99:24, 102:24,

103:23, 122:8,

124:22, 127:7,

128:14, 137:17,

150:13

police [15] - 11:15,

27:14, 30:12, 31:12,

32:9, 58:12, 68:8,

82:8, 98:12, 98:23,

101:2, 101:3,

101:21, 128:22,

136:23

political [2] - 29:23,

29:24

pool [1] - 128:16

portion [1] - 127:11

position [42] - 11:19,

11:22, 26:15, 27:2,

28:17, 29:16, 68:15,

68:21, 70:15, 71:8,

79:8, 82:20, 82:21,

83:13, 83:16, 83:19,

84:6, 90:1, 106:11,

110:2, 110:11,

110:13, 110:19,

113:9, 115:13,

119:3, 120:4,

120:12, 122:14,

126:23, 144:17,

148:5, 148:6, 149:6,

149:12, 152:21,

154:6, 158:23,

160:4, 160:20,

160:23, 161:1

positions [12] - 25:21,

26:9, 26:11, 27:23,

66:24, 71:7, 83:11,

127:13, 130:20,

151:13, 152:7, 154:7

possess [1] - 137:13

possession [2] -

136:20, 136:21

post [1] - 113:9

posted [22] - 24:12,

27:2, 68:15, 70:3,

70:6, 70:9, 70:22,

83:5, 83:9, 83:12,

121:6, 148:15,

156:1, 156:6, 156:8,

158:5, 158:17,

158:19, 158:21,

159:14, 159:17,

160:16

posting [4] - 69:22,

70:20, 71:6, 159:22

postings [2] - 71:12,

130:20

Precinct [7] - 11:3,

11:6, 12:2, 25:10,

25:15, 27:3, 27:7

precinct [2] - 29:4,

88:18

precincts [1] - 88:17

preliminary [1] - 8:14

PremierOne [2] -

101:1, 101:9

presence [2] - 4:11,

162:19

present [2] - 80:9,

112:23

presentation [1] -

37:4

president [1] - 130:2

pretty [8] - 9:13,

13:23, 16:17, 51:3,

51:12, 73:10, 74:14,

94:16

previous [3] - 71:6,

87:13, 134:8

previously [16] - 8:10,

53:15, 72:24, 75:10,

75:15, 83:11, 87:11,

115:8, 121:22,

124:6, 141:15,

141:17, 142:21,

153:11, 153:14,

159:9

primarily [1] - 16:20

primary [1] - 22:22

printout [1] - 160:12

problem [3] - 41:15,

56:9, 157:14

Procedure [2] - 1:14,

4:9

process [1] - 148:1

proficient [1] - 128:16

programs [2] - 30:2,

30:5

project [1] - 15:11

promise [1] - 154:19

proof [4] - 4:12,

102:19, 102:20,

137:11

proper[3] - 82:8,

86:14, 138:7

properly [1] - 77:5

properties [2] - 30:10

prosecutions [1] -

16:10

prostitutes [1] - 14:24

prostitution [4] -

13:19, 14:2, 15:5,

22:24

protect [7] - 16:11,

98:8, 98:9, 102:3,

106:23, 118:9,

118:11

protected [2] - 115:11,

115:13

protection [2] -

106:14, 106:17

prove [2] - 87:23,

138:18

providing [1] - 30:12

Public [4] - 1:15,

122:9, 162:17,

162:20

punish [1] - 115:24

purchase [1] - 30:18

purchased [1] - 43:14

purposes [4] - 5:9,

11:12, 85:11, 130:13

pursuant [1] - 1:16

pursue [2] - 136:18,

137:12

put [39] - 15:12, 26:19,

30:3, 35:17, 39:12,

45:1, 53:16, 56:8,

56:16, 57:8, 59:14,

59:16, 60:6, 60:23,

10

61:15, 61:21, 73:11,

74:14, 75:21, 76:7,

76:10, 78:3, 80:19,

82:8, 85:13, 91:3,

91:11, 97:17, 101:1,

101:8, 115:18,

120:21, 128:7,

135:2, 135:8,

138:10, 138:16,

142:16, 145:10

putting [8] - 30:16,

56:20, 57:2, 57:5,

57:6, 60:21, 86:13,

105:6

Q

qualification [1] - 4:13

qualifications [1] -

128:9

questioned [3] - 82:7,

127:19, 146:22

questions [9] - 6:14,

7:2, 8:15, 43:24,

48:4, 49:21, 53:7,

67:22, 143:18

R

race [5] - 68:11, 110:4,

111:1, 127:4, 127:7

races [1] - 10:7

racial [3] - 125:2,

131:8, 140:18

racially [8] - 56:21,

57:3, 59:22, 60:1,

127:15, 137:19,

139:11, 151:24

racist [5] - 60:22,

65:20, 66:7, 66:12,

81:6

raised [2] - 56:24,

87:15

Rampart [7] - 81:17,

86:22, 88:6, 88:10,

88:13, 88:16, 89:4

ran [1] - 155:1

rape [2] - 12:18, 24:22

rationale [1] - 26:1

rattled [1] - 134:17

re [8] - 70:9, 148:8,

156:6, 158:5,

158:16, 158:17,

158:19, 158:21

re-opened [1] - 148:8

re-posted [6] - 70:9,

156:6, 158:5,

158:17, 158:19,

158:21

reach [1] - 131:6

reached [2] - 114:24,

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 173 of 177 PAGEID #: 2332
121:14

reaction [2] - 87:18,

90:22

read [2] - 162:6,

162:17

reading [2] - 134:11,

162:15

ready [1] - 154:1

real [1] - 94:17

really [8] - 6:4, 7:7,

33:10, 44:7, 67:12,

108:4, 153:1

reason [23] - 8:14,

10:13, 10:16, 17:17,

28:22, 34:19, 55:16,

56:7, 56:14, 71:16,

109:18, 109:20,

112:19, 115:9,

117:22, 122:22,

131:14, 135:20,

138:11, 140:16,

140:24, 156:21,

156:22

reasoning [1] - 112:18

reasons [12] - 59:20,

59:23, 60:13, 60:20,

61:12, 66:6, 66:11,

99:2, 114:19,

114:24, 134:22,

151:24

recalling [1] - 51:17

receipt [1] - 50:7

receive [4] - 41:10,

41:20, 109:9, 126:9

received [10] - 15:21,

39:22, 40:22, 67:10,

70:22, 72:18, 109:1,

126:5, 126:12, 130:8

recent [1] - 15:20

recess [1] - 105:15

Recess [3] - 41:24,

73:24, 143:22

recognize [2] -

119:16, 122:2

recollection [12] -

12:8, 46:10, 46:18,

49:17, 57:4, 57:7,

66:22, 70:12, 98:1,

120:8, 133:14,

133:17

recollections [1] -

44:18

recommended [4] -

148:2, 149:6,

149:11, 150:5

Recon [2] - 31:23,

32:7

record [40] - 5:9, 6:6,

8:19, 11:12, 16:5,

16:7, 21:8, 21:9,

37:21, 42:2, 74:2,

78:15, 85:6, 85:8,

85:10, 85:11,

102:11, 104:21,

105:2, 105:12,

105:14, 106:7,

119:19, 122:4,

124:9, 124:10,

125:21, 141:19,

142:23, 145:16,

147:5, 147:19,

147:24, 153:20,

153:24, 155:13,

159:1, 159:7, 159:8,

161:18

recorded [3] - 101:23,

103:17, 104:24

recording [6] - 102:7,

102:17, 102:19,

104:8, 105:9

records [1] - 128:14

recovery[1] - 27:21

reduced [1] - 4:9

refer[1] - 57:1

referred [1] - 148:24

referring [2] - 49:10,

61:10

reflected [1] - 147:6

refresh [1] - 120:8

REGISTERED [1] -

1:22

regular[1] - 123:23

reiterated [1] - 73:11

related [1] - 150:8

relating [1] - 54:23

relationship [5] - 18:4,

18:7, 33:8, 34:11,

34:13

relative [2] - 44:22,

45:15

religious [2] - 46:24,

49:16

remember[36] - 8:6,

12:4, 13:11, 20:21,

23:13, 38:19, 48:6,

48:7, 48:8, 48:10,

48:24, 51:1, 62:1,

63:24, 64:12, 65:15,

67:20, 67:23, 69:7,

69:8, 73:15, 73:17,

74:7, 79:2, 79:5,

84:14, 86:18, 87:2,

87:5, 88:2, 103:10,

125:15, 136:14,

148:12, 148:13,

158:12

removed [4] - 15:11,

79:4, 79:13, 107:5

rent [1] - 30:16

rented [1] - 30:19

renting [1] - 30:21

repeat [1] - 7:10

rephrase [1] - 7:10

replacement[3] -

11:11, 121:11,

121:12

report [18] - 21:19,

51:22, 52:6, 52:11,

62:7, 62:13, 77:4,

100:3, 100:6,

100:16, 100:21,

101:4, 101:21,

108:9, 109:12,

109:19, 137:14,

140:22

reported [6] - 18:15,

80:12, 109:14,

109:16, 112:1, 136:7

REPORTER [1] - 1:22

reports [11] - 58:12,

77:1, 82:8, 100:4,

100:8, 100:11,

100:12, 100:17,

100:23, 101:2, 101:7

representative[1] -

129:24

representing [1] -

5:12

request [1] - 149:12

requirement [1] -

120:18

research [1] - 15:2

reservations [1] - 86:9

residing [1] - 58:13

resource [8] - 9:3, 9:5,

9:9, 9:16, 9:17, 9:20,

101:6, 101:13

respective [1] - 4:6

response [1] - 61:23

responsibilities [2] -

13:8, 13:11

responsibility [3] -

22:22, 35:7, 35:8

rest [1] - 61:5

restate [1] - 7:10

result [7] - 15:6, 15:9,

25:21, 26:23, 55:22,

89:3, 123:18

retaliating [2] - 139:2,

139:4

retaliation [1] - 139:16

retaliatory [7] -

137:22, 138:13,

138:15, 140:10,

141:3, 141:6, 143:7

retired [2] - 21:4,

158:14

retiring [1] - 21:21

reviewing [1] - 91:12

Rice [4] - 110:3,

152:14, 152:15,

152:24

Rice's [1] - 110:4

rich [2] - 73:21, 153:2

Rich [1] - 5:10

Rich's [1] - 149:21

Richard [10] - 2:8,

13:4, 65:2, 65:9,

65:10, 90:13, 91:20,

92:19, 93:18, 93:20

RICO [4] - 15:3, 15:5,

15:6, 105:6

rifle [1] - 127:20

risk [1] - 116:24

road [1] - 40:10

Road [1] - 13:20

rob [1] - 32:18

robbery [2] - 101:10,

101:11

robs [1] - 101:10

role [4] - 9:9, 16:9,

19:11, 98:12

room [4] - 39:21,

54:11, 85:21, 143:21

roster[3] - 110:7,

110:11, 157:3

roughly [1] - 22:21

round [1] - 25:22

Roundtree [2] - 29:8,

29:11

roundtree [1] - 29:9

route [1] - 43:13

routed [3] - 101:2,

101:4, 101:11

rule [1] - 28:10

Rules [2] - 1:14, 4:8

run [2] - 66:20, 66:23

running [2] - 59:7,

72:21

S

safety [3] - 104:15,

116:20, 116:23

Safety [1] - 122:9

sarge [2] - 69:2, 142:6

sat [2] - 5:15, 129:13

save [1] - 91:16

saving [1] - 105:10

saw [6] - 20:3, 41:5,

90:22, 136:24, 137:3

scenario [1] - 129:3

schedule [1] - 10:15

scheduled [1] -

121:11

school [9] - 9:3, 9:16,

9:17, 9:20, 10:3,

32:3, 82:10, 101:6,

101:12

School [3] - 9:4,

11

10:19, 11:1

Scott [2] - 54:10,

108:18

sealed [1] - 16:10

Sean [1] - 2:4

search [6] - 76:18,

76:20, 77:22, 80:23,

82:2, 82:3

season/year[1] -

96:22

second [25] - 11:2,

16:6, 22:3, 29:7,

47:4, 47:7, 48:15,

49:5, 49:23, 50:10,

64:10, 70:1, 70:19,

115:19, 116:1,

116:7, 116:9,

123:14, 124:3,

125:23, 144:19,

153:21, 158:18,

159:2, 159:4

security [2] - 91:3,

91:11

see [7] - 15:11,

107:11, 137:13,

143:17, 146:19,

156:18, 157:9

seeing [1] - 154:13

sell [1] - 30:19

selling [1] - 88:20

send [3] - 17:20,

58:21, 61:15

sending [1] - 56:1

seniority [15] - 24:13,

68:18, 83:22, 86:1,

110:7, 110:9,

110:11, 113:13,

113:15, 115:24,

149:2, 149:8,

155:18, 156:17,

157:3

seniority-wise [1] -

83:22

sent [21] - 39:9, 45:17,

53:20, 53:22, 55:15,

55:23, 56:11, 58:23,

59:18, 59:19, 60:12,

62:17, 82:9, 97:9,

107:23, 124:14,

127:13, 138:5,

138:9, 146:23, 147:4

separate [2] - 78:9,

83:2

sergeant [20] - 16:24,

17:2, 20:23, 21:12,

21:13, 23:2, 23:9,

23:12, 24:23, 27:6,

29:6, 33:24, 34:15,

35:4, 69:4, 109:17,

144:14, 144:22,

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 174 of 177 PAGEID #: 2333
155:3, 160:3

Sergeant [129] - 17:3,

17:19, 17:22, 18:12,

21:5, 21:11, 23:4,

23:6, 23:9, 25:1,

25:2, 29:8, 29:11,

33:16, 33:17, 33:20,

34:22, 35:5, 35:7,

35:8, 35:11, 35:12,

35:14, 35:16, 35:24,

36:2, 36:6, 36:8,

36:12, 37:12, 37:16,

37:23, 38:4, 38:16,

39:1, 39:11, 39:23,

40:3, 41:20, 42:6,

42:10, 43:19, 44:2,

44:5, 44:10, 44:20,

44:22, 45:1, 45:6,

45:11, 45:14, 45:16,

45:21, 46:2, 49:10,

50:4, 50:5, 50:17,

51:11, 55:2, 56:7,

56:14, 56:16, 56:19,

56:20, 59:18, 60:6,

62:23, 63:12, 63:22,

64:8, 65:5, 65:11,

65:16, 65:24, 66:7,

66:12, 67:6, 67:7,

69:5, 69:6, 69:15,

70:23, 71:14, 71:21,

72:11, 89:21, 90:8,

91:19, 92:1, 92:7,

92:10, 92:14, 92:16,

95:6, 95:11, 96:9,

96:19, 98:6, 98:17,

99:3, 99:7, 99:10,

104:24, 107:23,

114:12, 114:19,

115:2, 115:4, 117:1,

117:2, 121:8,

125:11, 125:16,

126:22, 127:12,

132:5, 132:12,

132:21, 133:11,

133:19, 134:23,

135:13, 136:4,

136:8, 144:13,

144:24, 145:4

serious [2] - 107:5,

131:19

serve [1] - 31:16

service [2] - 132:5,

132:9

services [1] - 30:12

serving [1] - 108:21

Session [2] - 4:1,

106:1

set [4] - 8:13, 47:9,

58:22, 72:15

setting [1] - 46:8

settlement [1] -

121:15

seven [2] - 31:17,

128:6

seven-and-a-half [2] -

31:17, 128:6

several [3] - 5:8,

12:21, 15:8

sexual [4] - 24:3,

24:21, 25:6, 27:2

shake [1] - 6:2

shall [1] - 89:8

share [1] - 131:14

Shaw [17] - 1:6, 1:12,

4:7, 5:6, 8:20, 8:21,

42:3, 66:10, 74:3,

106:8, 123:15,

143:14, 144:3,

161:15, 162:5,

162:11, 162:15

SHAW [1] - 5:1

Shaw's [1] - 16:9

sheet [1] - 17:15

sheriffs [1] - 27:15

Sherman [1] - 15:22

shift [14] - 11:2, 25:10,

115:19, 115:22,

116:1, 116:6, 116:7,

116:9, 116:13,

120:23, 120:24,

122:17, 123:19,

124:3

shoot [1] - 135:11

shooting [1] - 88:19

shootings [1] - 135:6

short [3] - 24:7, 41:11,

73:22

shortage [1] - 26:3

show [4] - 61:14,

85:16, 97:4, 119:8

showed [4] - 40:19,

78:1, 90:15, 90:18

showing [1] - 34:5

shown [1] - 90:9

sided [1] - 153:21

sides [1] - 61:7

sign [3] - 10:11, 43:9,

161:19

Signature [1] - 161:20

signature [4] - 123:15,

136:16, 136:21,

136:24

signed [2] - 123:24,

162:18

signees [1] - 123:11

signing [1] - 162:16

similar[3] - 6:4,

111:8, 111:12

simple [1] - 101:19

simplicity [1] - 64:20

simply [2] - 9:16,

151:6

sit [2] - 37:3, 104:23

sitting [1] - 129:23

situation [3] - 62:6,

135:3, 135:9

situations [2] -

100:11, 143:5

six [4] - 8:5, 13:6,

24:6, 24:18

six-month [1] - 24:18

skin [2] - 91:6, 91:9

Smith [1] - 15:20

someone [7] - 40:6,

58:9, 91:5, 91:14,

121:17, 135:2

someplace [1] - 26:19

sometime [6] - 12:3,

37:14, 84:21,

103:11, 130:17,

140:5

sometimes [3] -

22:13, 91:4, 132:17

somewhere [1] -

23:16

Sorell [37] - 30:24,

31:1, 32:23, 33:9,

33:12, 38:8, 38:9,

38:16, 46:2, 46:16,

47:3, 47:14, 47:21,

48:3, 49:9, 49:15,

50:10, 50:16, 51:4,

51:5, 51:10, 51:20,

51:21, 53:6, 54:10,

54:15, 54:24, 57:17,

95:9, 95:10, 95:14,

96:24, 133:1,

133:18, 133:21,

134:2

Sorell's [2] - 45:5,

45:20

sorry [16] - 35:5, 54:4,

54:7, 54:8, 56:10,

83:4, 83:10, 84:3,

84:5, 90:3, 93:18,

96:1, 103:19,

142:15, 146:5,

146:12

sound [4] - 6:4, 12:5,

22:15, 23:17

sounded [1] - 43:24

sounds [4] - 19:1,

27:24, 96:7, 151:12

South [1] - 50:2

Southern [1] - 137:7

SOUTHERN [1] - 1:3

span [1] - 86:12

speaking [5] - 7:1,

9:8, 54:13, 106:10,

131:12

Speaks [2] - 104:19,

104:21

special [6] - 9:22,

9:24, 10:4, 10:6,

10:9, 10:17

specific [2] - 43:20,

73:17

specifically [1] - 57:13

speculating [2] -

131:16, 131:18

speculation [2] -

71:20, 131:23

spell [2] - 21:6, 21:7

spelling [1] - 15:17

spent [1] - 127:11

spoken [2] - 89:17,

139:9

spring [2] - 39:4,

46:12

Sprint [2] - 58:21,

58:22

Spurlazza [2] - 14:1,

17:9

squad [5] - 24:3,

24:21, 25:6, 27:2,

32:14

SRB [36] - 11:23, 12:7,

12:13, 12:22, 17:1,

19:1, 19:6, 19:7,

19:18, 28:24, 29:2,

29:15, 30:6, 33:21,

34:6, 34:8, 35:5,

36:13, 36:17, 36:18,

37:13, 38:1, 48:17,

63:12, 64:8, 65:1,

84:1, 84:7, 84:9,

84:12, 124:23,

126:12, 159:19,

160:1, 160:6

SS [1] - 162:3

stand [1] - 156:21

start [8] - 17:13, 56:2,

64:21, 79:20, 86:6,

103:9, 140:4, 154:5

started [10] - 14:8,

15:3, 20:2, 20:4,

31:10, 58:12, 121:7,

124:21, 145:6,

150:20

starting [2] - 57:22,

74:4

state [3] - 8:18, 54:17,

127:5

State [3] - 1:16, 162:2,

162:20

statement [3] - 60:21,

64:20, 94:23

statements [10] - 38:8,

45:5, 45:21, 56:19,

59:21, 60:9, 63:19,

12

64:10, 65:6, 138:19

States [1] - 88:22

STATES[1] - 1:2

stating [4] - 38:11,

70:23, 72:19, 77:13

stationed [2] - 31:20,

32:7

statistics [3] - 87:12,

87:19, 88:3

stay [1] - 70:15

stayed [2] - 78:4,

158:8

stealing [1] - 88:20

stenotype [1] - 4:10

still [31] - 14:21,

32:16, 43:7, 43:8,

45:16, 45:18, 45:21,

45:24, 78:4, 82:14,

97:18, 108:9,

108:21, 113:4,

113:5, 117:3,

118:10, 138:20,

140:11, 145:23,

146:1, 146:9,

146:16, 147:15,

147:17, 148:18,

148:22, 149:19,

150:2, 150:5

stipulated [1] - 4:5

stipulations [1] -

111:23

STIPULATIONS[1] -

4:4

stop [4] - 72:22,

73:12, 73:14, 158:16

stopped [1] - 148:21

stored [1] - 132:18

story [1] - 54:23

street [2] - 12:17,

22:24

Street [5] - 1:18, 2:3,

2:5, 2:9, 50:2

strictly [1] - 86:1

strike [4] - 74:8,

103:22, 116:5,

116:18

Student [3] - 101:13,

101:14, 101:15

stuff [3] - 127:16,

128:2, 138:21

subjects [1] - 13:13

submit [2] - 17:18,

17:19

submitted [3] - 154:6,

155:4, 162:15

substance [1] - 162:9

substantive [1] - 75:2

sudden [1] - 115:14

summer[6] - 37:14,

38:1, 46:13, 159:15,

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 175 of 177 PAGEID #: 2334
160:6

summons [2] -

101:21, 101:22

Sunday/Monday [2] -

120:24, 122:18

supervisor[3] - 17:4,

29:12, 43:18

supplies [1] - 36:1

support [1] - 41:7

supported [1] - 18:10

supposed [1] - 121:6

supposition [3] - 72:2,

76:9, 81:3

surgeries [1] - 27:21

surgery [2] - 123:3,

142:10

surveillance [1] -

34:23

suspects [2] - 12:18,

16:21

swam [1] - 128:14

swimmer[1] - 128:13

switch [3] - 69:11,

69:13, 112:4

switched [2] - 151:4,

151:10

switching [5] - 112:2,

112:8, 151:13,

151:15, 151:19

sworn [1] - 5:2

system [4] - 91:3,

91:11, 101:1, 101:8

T

talks [3] - 62:17,

62:20, 122:11

Tanner[1] - 15:23

tape [1] - 104:8

tape-recording [1] -

104:8

taped [3] - 103:21,

103:24, 104:7

targets [1] - 17:16

task [44] - 9:14, 14:23,

19:17, 19:20, 19:21,

20:1, 20:4, 20:6,

20:8, 37:8, 43:6,

43:8, 44:8, 77:15,

77:17, 79:4, 79:14,

82:2, 82:5, 104:16,

111:16, 111:23,

112:1, 112:20,

112:24, 113:1,

113:2, 113:4, 113:5,

113:10, 114:3,

129:18, 129:21,

144:6, 144:11,

145:8, 145:9, 151:1,

151:7, 151:9,

151:13, 151:20,

151:23

tasked [1] - 12:17

teach [1] - 37:4

Team [1] - 144:9

team [18] - 13:1,

13:10, 33:3, 33:5,

34:15, 55:14, 67:4,

67:6, 67:16, 110:20,

112:22, 112:23,

113:22, 114:3,

115:5, 128:7,

128:20, 158:20

teams [8] - 12:14,

12:16, 12:22, 69:11,

69:14, 112:2, 112:5,

112:8

telephone [1] - 69:7

temp [3] - 24:8, 24:11,

24:19

ten [5] - 25:23, 92:24,

93:1, 94:7, 104:5

terms [1] - 145:3

test [1] - 8:3

testified [4] - 61:1,

117:13, 132:16,

159:9

testify [1] - 85:14

testimony [2] -

139:17, 160:18

text [33] - 72:19, 73:2,

73:4, 73:11, 74:15,

90:9, 90:10, 90:15,

90:19, 90:23, 91:12,

91:15, 92:5, 92:13,

92:17, 93:5, 93:14,

94:4, 94:9, 94:10,

95:21, 96:15, 97:6,

97:8, 97:12, 97:13,

99:9, 99:16, 107:23,

127:13, 141:5,

142:24, 143:2

Text [2] - 3:11, 142:19

texted [1] - 73:6

texts [1] - 92:20

THE [4] - 21:7, 41:17,

140:1, 155:15

theirs [1] - 88:17

themselves [1] - 58:3

thereabouts [2] -

19:4, 133:11

thereafter[1] - 4:11

thinking [1] - 98:22

third [3] - 120:23,

122:16

threat [10] - 95:20,

95:21, 95:23, 96:7,

96:10, 96:18, 98:6,

101:13, 101:18

threatened [5] - 49:12,

94:20, 95:7, 96:4,

106:20

threatening [2] -

46:21

threats [13] - 94:15,

94:16, 94:18, 95:2,

98:14, 98:17, 99:4,

99:8, 101:20, 131:9,

131:10, 132:4,

134:24

three [8] - 19:10,

22:21, 48:20, 50:14,

64:19, 66:21, 128:7,

147:21

three-and-a-half [1] -

19:10

timeline [1] - 97:4

timing [3] - 97:2,

145:3, 145:15

timing-wise [1] - 97:2

title [1] - 101:3

today [19] - 7:18, 8:16,

15:10, 20:18, 85:14,

107:11, 113:5,

124:21, 127:2,

127:11, 128:3,

137:18, 137:22,

141:4, 143:10,

144:18, 145:21,

146:22, 161:17

together[13] - 15:13,

16:11, 31:5, 55:14,

59:14, 59:16, 61:15,

66:20, 78:3, 80:20,

105:6, 138:11, 162:8

took [22] - 15:24, 24:8,

42:15, 48:14, 83:6,

83:12, 83:17,

110:21, 112:18,

114:10, 114:12,

114:15, 116:22,

117:20, 134:20,

136:20, 148:23,

148:24, 152:24,

158:10, 158:15,

159:16

topics [2] - 44:20,

144:4

tore [1] - 27:17

totally [3] - 83:1,

147:11, 147:12

toward [3] - 95:22,

95:23, 140:16

tracking [1] - 16:19

traffic [2] - 77:22,

122:12

trafficking [15] -

14:23, 19:16, 19:21,

37:8, 43:5, 77:15,

77:17, 79:4, 79:14,

80:22, 82:2, 82:5,

104:16, 105:7, 138:8

trained [2] - 128:6,

128:10

trainer[1] - 82:10

trainer's [1] - 82:10

training [4] - 52:13,

52:18, 138:7, 138:9

transcribed [1] - 4:11

transcript [2] - 162:6,

162:14

transfer[1] - 111:13

transferred [2] -

111:4, 123:17

treat [1] - 22:10

treated [3] - 21:17,

29:13, 57:1

treating [1] - 140:14

trick [1] - 7:6

tried [2] - 91:13,

118:11

triggered [1] - 44:24

trouble [1] - 37:15

Troy [1] - 22:4

true [2] - 18:11,

162:10

trusted [1] - 81:14

truth [1] - 50:19

truthfully [1] - 8:15

try [13] - 6:12, 7:1, 7:6,

16:15, 29:17, 40:5,

57:12, 60:17, 92:4,

98:7, 106:23, 108:6,

118:8

trying [33] - 27:13,

30:9, 30:15, 36:10,

36:18, 36:24, 37:10,

41:2, 44:6, 59:7,

63:7, 63:15, 63:17,

64:9, 72:21, 73:12,

73:13, 74:15, 74:17,

78:11, 80:19, 93:22,

100:18, 114:4,

115:18, 115:23,

127:24, 130:14,

132:11, 142:20,

146:20, 153:3

Tuesday/Wednesday

[1] - 116:10

Tuesdays [1] - 115:19

Tuesdays/

Wednesdays [1] -

116:2

turn [2] - 107:10,

161:3

turned [9] - 97:10,

104:4, 109:21,

118:21, 120:5,

121:9, 149:14,

152:12, 152:22

13

turning [1] - 106:11

twice [2] - 125:10,

158:19

two [36] - 10:15, 12:9,

14:21, 21:1, 21:22,

27:21, 28:19, 46:7,

55:1, 62:22, 70:3,

70:6, 76:12, 78:3,

83:5, 83:6, 83:9,

83:11, 86:12, 90:3,

94:24, 96:5, 144:4,

147:21, 147:23,

148:21, 153:21,

154:14, 154:23,

156:2, 156:6,

157:17, 158:4,

158:19, 160:13

two-sided [1] - 153:21

two-year[1] - 86:12

type [4] - 13:7, 53:21,

59:8, 100:12

types [3] - 13:15,

42:17, 100:11

U

U.S [1] - 137:6

ultimate [2] - 14:10,

14:13

ultimately [14] - 43:11,

88:12, 88:22, 97:21,

110:1, 116:22,

117:20, 118:21,

119:3, 120:5,

121:14, 124:18,

148:24, 152:19

under [4] - 1:13, 4:8,

104:5, 131:8

undersigned [1] -

162:17

understood [2] - 7:14,

82:19

unfortunately [1] - 7:3

union [1] - 121:15

unit [4] - 124:23,

126:24, 127:14

UNITED [1] - 1:2

United [1] - 88:22

units [3] - 12:22,

144:23, 151:19

up [62] - 7:11, 10:11,

13:20, 13:21, 14:3,

14:6, 14:12, 14:14,

14:20, 14:22, 17:10,

17:20, 21:19, 30:23,

33:16, 34:5, 35:20,

36:16, 39:9, 46:8,

47:9, 55:15, 57:12,

58:22, 60:3, 64:3,

64:5, 72:15, 73:22,

74:8, 80:20, 81:17,

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 176 of 177 PAGEID #: 2335
81:21, 82:1, 85:16,

86:11, 86:20, 88:23,

94:23, 97:4, 101:20,

106:23, 108:5,

108:8, 111:21,

111:24, 115:16,

118:14, 120:11,

123:3, 124:22,

130:20, 133:6,

134:9, 139:5,

142:20, 143:18,

152:5, 159:2, 160:13

ups [1] - 98:24

upset [5] - 56:7,

56:15, 59:5, 61:20,

94:14

V

vacancies [1] - 158:20

Vacancy [1] - 122:11

vacant [1] - 30:10

various [5] - 12:16,

42:17, 42:21,

126:22, 127:11

Vass [1] - 32:18

VEIL [1] - 1:22

verbally [2] - 6:1, 6:6

versus [1] - 132:13

vice [11] - 22:19,

22:20, 23:3, 23:10,

23:16, 24:2, 24:8,

24:10, 72:24, 73:1,

77:16

view [1] - 100:19

violation [3] - 135:17,

135:19, 135:24

violations [1] - 9:12

violence [1] - 101:18

violent [1] - 135:4

VIOLET [1] - 1:22

voluntarily [1] - 69:17

vs [1] - 1:8

W

wait [1] - 125:23

waiting [1] - 125:11

waived [2] - 4:14,

161:20

Walt [1] - 20:20

Walton [2] - 2:4, 2:5

warrant [3] - 76:19,

76:20, 77:22

warrants [3] - 80:23,

82:3

Warren [2] - 21:4,

21:11

waste [1] - 65:4

Watkins [5] - 54:10,

54:15, 54:24, 57:17,

134:2

weapon [3] - 132:6,

132:9, 132:13

Wednesday/

Thursday [1] -

116:10

Wednesdays [1] -

115:20

week [3] - 121:10,

123:2, 138:10

weekend [1] - 121:1

weekends [1] - 123:19

weeks [3] - 94:24,

96:5, 120:17

Wes [9] - 30:24, 38:8,

38:9, 45:5, 45:20,

46:2, 46:11, 46:16,

54:10

whereas [1] - 35:15

Whitaker's [1] - 68:11

white [3] - 68:12,

110:5, 111:2

Whitney [3] - 13:2,

48:1, 72:6

Whittaker[21] - 67:13,

67:24, 68:4, 68:23,

68:24, 69:10, 69:18,

70:14, 82:22, 82:23,

83:1, 83:5, 83:12,

83:15, 83:23, 84:6,

111:10, 159:10,

159:12, 159:22,

159:24

Whittaker's [1] -

111:12

Williams [27] - 17:2,

17:3, 17:20, 18:12,

35:6, 35:11, 35:16,

35:24, 39:11, 41:21,

44:2, 44:5, 44:22,

45:1, 45:15, 51:11,

53:16, 56:16, 56:20,

59:19, 91:20, 92:2,

92:7, 92:10, 92:16,

95:11, 96:19

Williams' [2] - 17:22,

35:8

Wilson [2] - 13:2,

134:4

wise [2] - 83:22, 97:2

withdrawn [1] -

149:12

Witness [1] - 159:5

witness [3] - 4:12,

39:20, 162:15

WITNESS [4] - 21:7,

41:17, 140:1, 155:15

witnessed [3] - 40:11,

40:17, 41:5

witnesses [1] - 8:2

14

word [2] - 102:4

words [2] - 73:17,

85:13

works [2] - 24:16,

32:17

wound [1] - 80:20

write [1] - 38:13

writing [1] - 4:10

written [1] - 26:13

wrote [7] - 38:11,

51:18, 54:14, 54:20,

57:14, 57:16, 82:3

Y

year[8] - 12:4, 14:21,

31:9, 52:19, 86:12,

96:22, 128:23, 158:3

years [14] - 8:5, 9:1,

9:7, 12:9, 15:21,

19:10, 22:21, 31:17,

44:16, 76:12, 78:3,

115:24, 128:6,

151:15

Young [1] - 20:20

Z

Zach [1] - 1:17

zero [2] - 76:11, 86:12

zeroes [1] - 87:22

zone [5] - 11:3, 11:4,

11:5, 13:23, 17:9

Zone [4] - 11:6, 12:2,

13:24, 124:3

Case: 2:18-cv-00483-JLG-CMV Doc #: 15-45 Filed: 08/15/19 Page: 177 of 177 PAGEID #: 2336