1

It Began In January 2001 With It Began In January 2001 With Todd Crafting A Back Room DealTodd Crafting A Back Room Deal

The MOU resulted in only white males being The MOU resulted in only white males being eligible for Police Chiefeligible for Police Chief

This was in exchange for votes for Councilman This was in exchange for votes for Councilman MorielMoriel

South Gate filed a lawsuit in which it claimed the South Gate filed a lawsuit in which it claimed the MOU was illegal, because it had a discriminatory MOU was illegal, because it had a discriminatory impact.impact.

When the City realized the discriminatory impact, When the City realized the discriminatory impact, of Todd’s back room deal, they sought to select the of Todd’s back room deal, they sought to select the best possible candidate.best possible candidate.

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The Discriminatory MOUThe Discriminatory MOU

3

July 2001, The PMA Learns that a July 2001, The PMA Learns that a Deputy Chief Will be Deputy Chief Will be

Selected - and Calls a MeetingSelected - and Calls a Meeting

4

October 2001 Harassment of The October 2001 Harassment of The First Ever Latino ChiefFirst Ever Latino Chief

Lopez was selected as the best qualified candidate out of Lopez was selected as the best qualified candidate out of 150 applicants150 applicants

OCTOBER 23, 2001 CITY COUNCIL MEETINGOCTOBER 23, 2001 CITY COUNCIL MEETING

"Get the fuck out of my city.""Get the fuck out of my city."

"Where’s that fucking Lopez""Where’s that fucking Lopez"

Mad doggingMad dogging

Over 150 Officers and their supporters packed the Council Over 150 Officers and their supporters packed the Council Meeting to intimidate Chief Lopez.Meeting to intimidate Chief Lopez.

5

October 24 - 26, 2001October 24 - 26, 2001 Caucasin Management - Todd, Richert, Key and Caucasin Management - Todd, Richert, Key and

Galbreath all filed complaints of discrimination.Galbreath all filed complaints of discrimination.

The PMA filed suit to stop the selection of Rick The PMA filed suit to stop the selection of Rick Lopez as the first ever Latino Chief.Lopez as the first ever Latino Chief.

The PMA started a recall of the three city council The PMA started a recall of the three city council members and city treasurer who selected Chief members and city treasurer who selected Chief Lopez.Lopez.

South Gate’s witnesses admitted that recalling South Gate’s witnesses admitted that recalling council members would result in the elimination council members would result in the elimination of Lopez.of Lopez.

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The November 1, 2001 The November 1, 2001 Harassment of Lopez’ FamilyHarassment of Lopez’ Family

Todd obtained the CONFIDENTIAL home address of Chief Todd obtained the CONFIDENTIAL home address of Chief Lopez.Lopez.

He did not have permission to do this.He did not have permission to do this.

He provided it to Captain Key.He provided it to Captain Key.

4 South Gate cops served Lopez terrifying him and his 4 South Gate cops served Lopez terrifying him and his small children.small children.

Service on an officer at home was unprecedented.Service on an officer at home was unprecedented.

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Chief Lopez WithdrewChief Lopez Withdrew

8

Plaintiffs were associated with and Plaintiffs were associated with and perceived to be associated with perceived to be associated with

Chief Lopez Chief Lopez Lopez hired Officer Hernandez.Lopez hired Officer Hernandez.

Lopez promoted Officer Corbet.Lopez promoted Officer Corbet.

Lopez promoted Officer Matsukiyo.Lopez promoted Officer Matsukiyo.

Lopez sent Officer Matsukiyo to FTO school.Lopez sent Officer Matsukiyo to FTO school.

Lopez sent Officer Carrillo to FTO school.Lopez sent Officer Carrillo to FTO school.

Captain Richert, Captain Key and Sgt. Saldivar Captain Richert, Captain Key and Sgt. Saldivar admitted they associated Officer Carrillo with admitted they associated Officer Carrillo with Lopez. Lopez.

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The Plaintiffs were further The Plaintiffs were further associated with Lopez because of associated with Lopez because of lack of participation in the recall lack of participation in the recall

Officer Carrillo refused to contribute Officer Carrillo refused to contribute money or time to the recall.money or time to the recall.

Officer Matsukiyo was called at home and Officer Matsukiyo was called at home and pressured to participate in the recall.pressured to participate in the recall.

Officer Corbet was told “what the fuck are Officer Corbet was told “what the fuck are you thinking, this is your job and your you thinking, this is your job and your livelihood.”livelihood.”

Officer Hernandez was pressured to Officer Hernandez was pressured to participate because he was a “new guy.” participate because he was a “new guy.”

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The Plaintiffs were perceived as associated The Plaintiffs were perceived as associated with Chief Lopezwith Chief Lopez

After Matsukiyo was promoted, Sgt Perez asked him After Matsukiyo was promoted, Sgt Perez asked him about his association with Chief Lopez.about his association with Chief Lopez.

Lt. Arocha told Carrillo not to go to FTO school.Lt. Arocha told Carrillo not to go to FTO school.

Mendez played I’m your puppet over the loud Mendez played I’m your puppet over the loud speaker when Officer Carrillo entered the station. speaker when Officer Carrillo entered the station.

Lieutenant Galbreath testified Todd had a black list Lieutenant Galbreath testified Todd had a black list and that something bad would happen to those and that something bad would happen to those officers.officers.

11

Officer Valentine’s Statement Officer Valentine’s Statement References a ListReferences a List

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Officers with little involvement in Officers with little involvement in the recall were associated with the recall were associated with

Chief LopezChief Lopez The names of Officers that did not pay the $200 The names of Officers that did not pay the $200

were posted on the POA board which Lt. Sullivan were posted on the POA board which Lt. Sullivan and Officer Flanagan testified anyone could and Officer Flanagan testified anyone could access.access.

Officer Mena was called a traitor just for speaking Officer Mena was called a traitor just for speaking with Chief Lopez.with Chief Lopez.

Mena’s dog was pepper sprayed.Mena’s dog was pepper sprayed.

Sgts Rivera and Campos incited Explorer Scouts Sgts Rivera and Campos incited Explorer Scouts to quit because Mena was associated with Lopez. to quit because Mena was associated with Lopez.

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Campos and Rivera Harassed Campos and Rivera Harassed Officers Associated with LopezOfficers Associated with Lopez

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Further Evidence Of Harassment based on Further Evidence Of Harassment based on AssociationAssociation

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Officer Fernandez described the Officer Fernandez described the associational harassment because of associational harassment because of his limited involvement in the recallhis limited involvement in the recall

16

Officer Chacon described harassment Officer Chacon described harassment because of his association with Lopezbecause of his association with Lopez

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All of the Plaintiffs received the All of the Plaintiffs received the “Resister”“Resister”

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Officer Corbet was subjected to Officer Corbet was subjected to Race based Harassment, Race based Harassment,

Discrimination and Retaliation. Discrimination and Retaliation. Officer Corbet was referred to as:Officer Corbet was referred to as:

““Gook”Gook” ““Nip”Nip” ““Tight eyed bastard”Tight eyed bastard” ““Looks like someone I used to shoot at in Vietnam Looks like someone I used to shoot at in Vietnam

only taller”only taller”

Richert told Corbet he would run him out of the department.Richert told Corbet he would run him out of the department.

Corbet’s supervisory duties were taken from him.Corbet’s supervisory duties were taken from him.

Corbet was denied overtime.Corbet was denied overtime.

Corbet was taken off the range staff without justification. Corbet was taken off the range staff without justification.

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Race Based Harassment and Race Based Harassment and Discrimination of Officer CorbetDiscrimination of Officer Corbet

Officer Corbet was denied a promotion to Sergeant.Officer Corbet was denied a promotion to Sergeant.

He was subjected to a POA recall after assisting Troy He was subjected to a POA recall after assisting Troy Hernandez.Hernandez.

His bullet proof vest and other SWAT equipment was stolen His bullet proof vest and other SWAT equipment was stolen from the secure police facility and defendants did not from the secure police facility and defendants did not investigate. investigate.

Homsher (the enforcer) intimidated Officers Corbet and Matsukiyo Homsher (the enforcer) intimidated Officers Corbet and Matsukiyo just before trial.just before trial.

Corbet was taken off the range staff without justification. Corbet was taken off the range staff without justification.

20

Disability Harassment to Disability Harassment to Officer CorbetOfficer Corbet

Harassing comments made by Harassing comments made by management to Officer Corbet after his management to Officer Corbet after his prostate surgery:prostate surgery:

ADWADW “ “ how does your dick work?”how does your dick work?” “ “ how do you make it work?”how do you make it work?” “ “have you tried Viagra?”have you tried Viagra?”

His buttock was grabbed to see if he wore His buttock was grabbed to see if he wore diapers.diapers.

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Officer Matsukiyo was subjected to Officer Matsukiyo was subjected to Harassment, Discrimination and Harassment, Discrimination and

RetaliationRetaliation

Officer Matsukiyo was called racial slurs for years; a few examples: Officer Matsukiyo was called racial slurs for years; a few examples: ““Gook”Gook” ““Godzilla”Godzilla” ““Godzuki”Godzuki” ““Tight eyed bastard”Tight eyed bastard” ““Jap”Jap” ““Japanese Jew”Japanese Jew” ““You Koreans are all the same”You Koreans are all the same” ““Co-chino”Co-chino” ““Cap-a-chino”Cap-a-chino” ““Lance Ito”Lance Ito” Comments were made about Pearl Harbor Comments were made about Pearl Harbor The Atomic Bomb, etc.The Atomic Bomb, etc.

Many of these comments were made in front of supervisorsMany of these comments were made in front of supervisors

22

Officer Matsukiyo was subjected to Officer Matsukiyo was subjected to DiscriminationDiscrimination

In July 2004 Richert ordered In July 2004 Richert ordered Matsukiyo to work weekends for a Matsukiyo to work weekends for a full year contrary to policy.full year contrary to policy.

When Matsukiyo complained Richert When Matsukiyo complained Richert said, “ if you don’t like it, you can said, “ if you don’t like it, you can give up your stripes.”give up your stripes.”

23

Officer Matsukiyo was Retaliated AgainstOfficer Matsukiyo was Retaliated Against

Sgt Edwards was instructed to scrutinize him.Sgt Edwards was instructed to scrutinize him.

In September 2004, following the grievance, Officer In September 2004, following the grievance, Officer Matsukiyo received an unjustified Personnel Report, for Matsukiyo received an unjustified Personnel Report, for a “disgruntled outburst.”a “disgruntled outburst.”

However, employees signed a statement that there However, employees signed a statement that there were no disgruntled outbursts.were no disgruntled outbursts.

The personnel director failed to investigate his The personnel director failed to investigate his complaints.complaints.

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Exhibit 139-2Exhibit 139-2

25

Officer Matsukiyo was subjected to Officer Matsukiyo was subjected to Additional RetaliationAdditional Retaliation

Supervisory duties taken away. Supervisory duties taken away.

Denied vacation. Denied vacation.

Assigned menial tasks.Assigned menial tasks.

Denied entry school training. Denied entry school training.

Denied MP-5 machine gun training.Denied MP-5 machine gun training.

Promotional opportunities eliminated.Promotional opportunities eliminated.

26

Officer Matsukiyo was terrorizedOfficer Matsukiyo was terrorized

Officer Garcia warned that “they’re coming Officer Garcia warned that “they’re coming after you.”after you.”

Officer Matsukiyo moved because he Officer Matsukiyo moved because he feared for his family’s safety after feared for his family’s safety after reporting Edwards.reporting Edwards.

Officer Homsher drove his motorcycle at Officer Homsher drove his motorcycle at 30MPH towards Officers Matsukiyo and 30MPH towards Officers Matsukiyo and Corbet when they were on the sidewalk.Corbet when they were on the sidewalk.

27

Officer Hernandez was subjected to Officer Hernandez was subjected to Discrimination, Harassment and Retaliation Discrimination, Harassment and Retaliation

because of his National Originbecause of his National Origin Called:Called:

Slow, Stupid, RetardedSlow, Stupid, Retarded FNGFNG ““dick”dick” ““fucking idiot”fucking idiot”

Under POST Guidelines, the use of Under POST Guidelines, the use of profane speech or humiliating tactics profane speech or humiliating tactics is not acceptable conduct, Lt. Arocha.is not acceptable conduct, Lt. Arocha.

28

Officer Hernandez was HarassedOfficer Hernandez was Harassed

His gun was removed from his locker and was His gun was removed from his locker and was taken apart and returned to him in pieces.taken apart and returned to him in pieces.

Captain Key testified the POBR required a warrant Captain Key testified the POBR required a warrant to open an officer’s locker. to open an officer’s locker.

He was denied meal breaks.He was denied meal breaks.

Management was aware that Hernandez was left Management was aware that Hernandez was left in the police parking lot for hours without in the police parking lot for hours without justification on several occasions.justification on several occasions.

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Avila was not aware of any reasons for Avila was not aware of any reasons for denying the attorney of his choicedenying the attorney of his choice

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Hernandez was Wrongfully FiredHernandez was Wrongfully Fired

Falsely accused of lying.Falsely accused of lying.

Todd fired him.Todd fired him.

The Civil Service Commission unanimously concluded The Civil Service Commission unanimously concluded all charges were unfounded.all charges were unfounded.

To further harass Hernandez, Todd appealed to the To further harass Hernandez, Todd appealed to the City Council.City Council.

After Hernandez was reinstated, he was harassed After Hernandez was reinstated, he was harassed

further.further.

Any reasonable person would find the environment Any reasonable person would find the environment intolerable.intolerable.

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Harassment and RetaliationHarassment and Retaliation

Hernandez complained of harassment Hernandez complained of harassment to Mayor Martinez and Ms. Fletcher.to Mayor Martinez and Ms. Fletcher.

The City failed to investigate.The City failed to investigate.

Hernandez was constructively Hernandez was constructively discharged.discharged.

After escaping South Gate, Sgt. After escaping South Gate, Sgt. Arakawa defamed Hernandez.Arakawa defamed Hernandez.

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Officer Carrillo was Subjected to Discrimination, Officer Carrillo was Subjected to Discrimination, Harassment and RetaliationHarassment and Retaliation

Officer Carrillo’s radio transmissions were interfered Officer Carrillo’s radio transmissions were interfered with from 2000 – 2004.with from 2000 – 2004.

In 2001, Officer Carrillo was discriminated against. In 2001, Officer Carrillo was discriminated against. He was forced to stay at the El Paseo substation. He was forced to stay at the El Paseo substation.

In February, 2002, Officer Carrillo was not allowed to In February, 2002, Officer Carrillo was not allowed to pick his area of patrol in violation of seniority pick his area of patrol in violation of seniority practices. practices.

He was given the assignment furthest from the He was given the assignment furthest from the station, which took the longest time for back up.station, which took the longest time for back up.

He was ostracized.He was ostracized.

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Carrillo was harassed because Carrillo was harassed because of his association with Roblesof his association with Robles

From 2002-2006, police management allowed From 2002-2006, police management allowed offensive materials to remain in the police offensive materials to remain in the police department.department.

Officer Homsher shouted “This is bullshit, it’s Officer Homsher shouted “This is bullshit, it’s lovely to work 5 days a week, 8 hours a day. I lovely to work 5 days a week, 8 hours a day. I wish that fuckin’ Robles would die.”wish that fuckin’ Robles would die.”

Although officer Carillo complained to the Although officer Carillo complained to the Personnel Department about this, Homsher was Personnel Department about this, Homsher was not ever interviewed about his comments.not ever interviewed about his comments.

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Continuing HarassmentContinuing Harassment Officer Carrillo complained to Chief Officer Carrillo complained to Chief

Lopez who acknowledged the Lopez who acknowledged the department was out of control.department was out of control.

After being harassed, Officer Carrillo After being harassed, Officer Carrillo applied to Alhambra P.D. to escape applied to Alhambra P.D. to escape the hostile atmosphere. The the hostile atmosphere. The statement, “Alhambra is hiring statement, “Alhambra is hiring laterals” was written on the board in laterals” was written on the board in briefing. briefing.

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Exhibit 615-4Exhibit 615-4

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Racial Slurs are RampantRacial Slurs are Rampant

Title 8 (undocumented Hispanic)Title 8 (undocumented Hispanic) 927 (“suspicious male black”) 927 (“suspicious male black”) ““N” WordN” Word Buckwheat (Dictate) Buckwheat (Dictate) P.O.N.T.I.A.CP.O.N.T.I.A.C Cap-a-chinoCap-a-chino PorschePorsche

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Management Knew or Should have Management Knew or Should have Known of the HarassmentKnown of the Harassment

The harassment was so pervasive that The harassment was so pervasive that Management had to know about it. Management had to know about it.

A good example of management’s A good example of management’s indifference is the persistence of the rat indifference is the persistence of the rat poster from 2002 -2006. It remained on poster from 2002 -2006. It remained on the board until Officer Matsukiyo testified the board until Officer Matsukiyo testified as a witness in another proceeding against as a witness in another proceeding against South Gate. South Gate.

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HypocrisyHypocrisy

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ExhibitExhibit 18-3 18-3

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Failure to take corrective Failure to take corrective actionaction

Chief TunsonChief Tunson

Personnel Director failed to investigate the Personnel Director failed to investigate the complaints from Officers Matsukiyo, complaints from Officers Matsukiyo, Carrillo, Hernandez and Lowinger.Carrillo, Hernandez and Lowinger.

Inspector General was terminated in Inspector General was terminated in February of 2003 before completing the February of 2003 before completing the Resistor investigation.Resistor investigation.

Todd instructed Sullivan not to investigate.Todd instructed Sullivan not to investigate.

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Chief Todd prevented a Chief Todd prevented a complete investigation into the complete investigation into the

resisterresister

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Investigations without conclusionInvestigations without conclusion

Ex 169 is 181 pages long and has no Ex 169 is 181 pages long and has no conclusion.conclusion.

Ex 1104 is over 80 pages long and Ex 1104 is over 80 pages long and has no conclusion.has no conclusion.

The investigation into Sgt Edwards’ The investigation into Sgt Edwards’ sexual indiscretions is missing.sexual indiscretions is missing.

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Officer Carillo was denied promotions Officer Carillo was denied promotions due to discriminationdue to discrimination

Denied the Detective Bureau position.Denied the Detective Bureau position.

Denied CIT position.Denied CIT position.

Denied MP-5 training.Denied MP-5 training.

Delayed promotion to FTO. Delayed promotion to FTO.

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Economic Damages of Officer Economic Damages of Officer Carrillo, $1,099,301Carrillo, $1,099,301

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Economic Damages of Officer Economic Damages of Officer Matsukiyo, $546,266.00Matsukiyo, $546,266.00

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Economic Damages of Officer Economic Damages of Officer Hernandez, $759,480Hernandez, $759,480

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Economic Damages Pension of Economic Damages Pension of Officer Corbet, $54,100.00Officer Corbet, $54,100.00

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Special Verdict Form Q9 Damages Special Verdict Form Q9 Damages For Harassment For Harassment

9a Troy Hernandez past and future 9a Troy Hernandez past and future economic damages $759,480.economic damages $759,480.

9b Dave Matsukiyo past and future 9b Dave Matsukiyo past and future economic damages $546,266.economic damages $546,266.

9c Ron Corbet past and future economic 9c Ron Corbet past and future economic damages $54,100.damages $54,100.

9d Albert Carrillo past and future economic 9d Albert Carrillo past and future economic damages $1,099,301.damages $1,099,301.

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Special Verdict Form Q9Special Verdict Form Q9

Past and future non-economic Past and future non-economic damages.damages.

Lifetime of mental and emotional Lifetime of mental and emotional distress.distress.

$4,000,000 - $8,000,000 per plaintiff. $4,000,000 - $8,000,000 per plaintiff.

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Special Verdict Form Q13 Special Verdict Form Q13 Constructive DischargeConstructive Discharge

Past and future economic damages $220,249.Past and future economic damages $220,249.

The economist used an extremely conservative The economist used an extremely conservative figure for the difference in earning between South figure for the difference in earning between South Gate and Arcadia.Gate and Arcadia.

In the past three years South Gate has had 29% In the past three years South Gate has had 29% raises from the council.raises from the council.

29% of $759,480 = $220,24929% of $759,480 = $220,249

Past and future non-economic damages Past and future non-economic damages $100,000.$100,000.

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Special Verdict Form Q18 Special Verdict Form Q18 FEHA Retaliation Damages Under FEHA Retaliation Damages Under

a Termination Scenarioa Termination Scenario If the plaintiffs are terminated in retaliation after this If the plaintiffs are terminated in retaliation after this

trial, their lost total wages (earnings capacity) trial, their lost total wages (earnings capacity)

9b Dave Matsukiyo past and future economic 9b Dave Matsukiyo past and future economic damages $1,456,380 (45 years old) ($97,092 x 15 damages $1,456,380 (45 years old) ($97,092 x 15 years)years)

9c Ron Corbet past and future economic damages 9c Ron Corbet past and future economic damages $679,644 (48 years old) ($97,092 x 7 years)$679,644 (48 years old) ($97,092 x 7 years)

9d Albert Carrillo past and future economic damages 9d Albert Carrillo past and future economic damages $2,038,932 (37 years old) ($97,092 x 21 years)$2,038,932 (37 years old) ($97,092 x 21 years)

Less offset you find to be reasonable. Less offset you find to be reasonable.

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Special Verdict Form Q21 Special Verdict Form Q21 1102.5 Retaliation Damages1102.5 Retaliation Damages

9a Troy Hernandez past and future non- 9a Troy Hernandez past and future non- economic damages $50,000.economic damages $50,000.

9b Dave Matsukiyo past and future non-9b Dave Matsukiyo past and future non-economic damages $100,000.economic damages $100,000.

9c Ron Corbet past and future non-9c Ron Corbet past and future non-economic damages $50,000.economic damages $50,000.

9d Albert Carrillo past and future non-9d Albert Carrillo past and future non-economic damages $50,000.economic damages $50,000.

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Troy Hernandez Non-Economic Troy Hernandez Non-Economic DamagesDamages

Stomach Pains and GI problemsStomach Pains and GI problems

HeadachesHeadaches

InsomniaInsomnia

StressStress

FearFear

AnxietyAnxiety

Damaged ReputationDamaged Reputation

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David Matsukiyo’s Non-Economic David Matsukiyo’s Non-Economic DamagesDamages

Chest PainsChest Pains

DepressionDepression

Adjustment Adjustment DisorderDisorder

AnxietyAnxiety

HypertensionHypertension

IrritabilityIrritability

Increased Housing Increased Housing ExpensesExpenses

Fear for SafetyFear for Safety

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Ron Corbet’s Non-Economic Ron Corbet’s Non-Economic DamagesDamages

EmbarrassmentEmbarrassment

HumiliationHumiliation

DepressionDepression

Worsening Worsening DiabetesDiabetes

StressStress

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Albert Carrillo’s Non-Economic Albert Carrillo’s Non-Economic DamagesDamages

OstracismOstracism

Fear for SafetyFear for Safety

Fear of Unjustified TerminationFear of Unjustified Termination

HeadachesHeadaches

InsomniaInsomnia

Unfairly Singled OutUnfairly Singled Out

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Some Of The People Who Did Not Receive Some Of The People Who Did Not Receive The “Resister" Letter In Their Mailbox Are The “Resister" Letter In Their Mailbox Are

Also The People Who Were PromotedAlso The People Who Were Promoted

AvilaAvila

KeyKey

ToddTodd

RichertRichert

WellsWells

MendezMendez

CamposCampos

GutierrezGutierrez

PixlerPixler

Many Many others…others…

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Officers Who Received The Officers Who Received The “Resister” Were those perceived “Resister” Were those perceived

Associated With Chief LopezAssociated With Chief Lopez Matsukiyo Matsukiyo

Carrillo Carrillo

Hernandez Hernandez

Corbet Corbet

Mena Mena

ValentinValentin

FernandezFernandez

ChaconChacon

Pellerin Pellerin

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Party Having Power to Produce Party Having Power to Produce Better Evidence Better Evidence

Failure to produce the Sergeants exam.Failure to produce the Sergeants exam.

Failure to produce evidence that anyone Failure to produce evidence that anyone was better qualified than Carrillo for was better qualified than Carrillo for detective.detective.

Failure to produce documents that Failure to produce documents that Matsukiyo was certified on the MP-5.Matsukiyo was certified on the MP-5.

Failure to present witnesses to Homsher’s Failure to present witnesses to Homsher’s intimidation.intimidation.

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Failure to Explain or Deny Failure to Explain or Deny EvidenceEvidence

Failure to produce Lt. Sullivan.Failure to produce Lt. Sullivan.

Failure to produce a single officer who is not Failure to produce a single officer who is not currently employed.currently employed.

Failure to produce the exit interview with Officer Failure to produce the exit interview with Officer Hernandez.Hernandez.

Failure to produce notes on conversation with Failure to produce notes on conversation with Carrillo.Carrillo.

Failure of economist to bring all of his materials. Failure of economist to bring all of his materials.

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Credibility of WitnessesCredibility of Witnesses Defendants witnesses appeared to look to Defendants witnesses appeared to look to

defense counsel for answers.defense counsel for answers.

Defendants witnesses were asked the same Defendants witnesses were asked the same questions and gave identical answers - questions and gave identical answers - obviously coached.obviously coached.

South Gate's witnesses appeared confused South Gate's witnesses appeared confused when they could not give their "canned" when they could not give their "canned" script.script.

Witnesses supporting the police officer Witnesses supporting the police officer plaintiffs are independent. Many have left plaintiffs are independent. Many have left South Gate because of the harassment, South Gate because of the harassment, discrimination and retaliation they suffered.discrimination and retaliation they suffered.