Colorado City Witness List

8/20/2019 Colorado City Witness List

http://slidepdf.com/reader/full/colorado-city-witness-list 1/98

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R. BLAKE HAMILTON, Utah Bar No. 11395ASHLEY M. GREGSON, Utah Bar No. 13716DURHAM JONES & PINEGAR111 East Broadway, Suite 900Salt Lake City, Utah 84111Telephone: (801) 415-3000Facsimile: (801) 415-3500 [email protected]@djplaw.com

Attorneys for Defendants City of Hildale, Utah and

Twin City Water Authority, Inc.

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

United States of America,

Plaintiff,

v.

Town of Colorado City, Arizona; City of Hildale, Utah; Twin City Power; and TwinCity Water Authority, Inc.,

Defendants.

Case No. CV-12-8123-PCT-HRH

DEFENDANTS’ JOINT AMENDEDFINAL TRIAL WITNESS LIST

Pursuant to this Court’s prior Order [Doc. 626], the Defendants provide the

following amended final, revised trial witness list.1 The amendments were necessary to

correct typographical errors in certain deposition designations (corrections in bold).

1. Philip Barlow

Philip Barlow is a fact witness. Mr. Barlow is the current Mayor of Hildale City

He is expected to testify regarding allegations in the Complaint, including but not limited

to testimony that the Defendants have a secular purpose, that they do not have the

principal or primary effect of advancing or inhibiting religion, that they do not foster an

excessive government entanglement with religion or endorse one religion over another,

1 The Defendants intend to call these witnesses in the order listed. However, dependingupon the evidence the United States presents, the Defendants may adjust the order of thesewitnesses, or may not call each witness listed.

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 1 of 61

mailto:[email protected]








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and they do not coerce people to support or participate in religion, or exercise or otherwise

act in a way that establishes a state religion or tends to do so. He is also expected to

testify that Defendants do not treat people unequally compared to other similarly situated

individuals, they have not acted or failed to act with the intent or purpose to discriminate

based upon religion, and that religion is not a motivating factor for Defendants’ actions or

inaction. He is also expected to testify that Defendants have not engaged in a pattern or

practice of discrimination, they have not denied FHA rights to a group of persons

including non-FLDS members, they have not attempted to make housing unavailable or

deny housing opportunities to any person, discriminated in the terms, conditions, or

privileges in the sale or rental of a building or the provision of services or facilities in

connection therewith, and they have not coerced, intimidated, threatened, or interfered

with any person in the exercise or enjoyment of, or on account of that person exercising or

encouraging others to exercise FHA rights, and that religion is not a motivating factor for

Defendants. Specifically, his testimony is expected to conform to his deposition

testimony, and will include, but not be limited to: background of the Towns, development

of the Towns, Towns structure and organization, operations of the Towns, subdivision in

Hildale City, evictions in Hildale City, building permit applications, his duties as Mayor,

the duties of other Town employees, Hildale City Council operating procedures and

meeting minutes, executive sessions, Hildale and Colorado City employees, Hildale City

Ordinances and Resolutions, intergovernmental agreements, Twin City Improvemen

Association, Hildale City streets, Twin City Water Authority, utility policies, utilities

applications and procedure, the Utility Board, water availability in the community, City

recordkeeping, City finances and budget, the City’s interaction with outside agencies

communications with FLDS leaders regarding City business, applications for city council

the voting/election/nomination/appointment process in Hildale, his becoming mayor of

Hildale, employment decisions regarding the CCMO, municipal grants, his awareness of

FLDS directives, interaction between Town employees and the FLDS, FLDS Church

Security, FLDS video surveillance, City video surveillance, City fiberoptic lines and




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computer servers, school setup crews, service of legal papers, CCMO training civilians,

interactions with Jethro Barlow and Willie Jessop.

2. Carvel Neilson

Carvel Nielsen serves as a member of the Hildale City Council. He is expected to

testify regarding his knowledge of the allegations in the Complaint, the structure, history

and/or functioning of the City government, along with any other related issues. Mr

Nielsen was also present during Sabrina Broadbent Tetzner’s custody dispute. He is

expected to offer testimony consistent with his deposition and including, but not limited

to, his involvement in, and interactions with CCMO and Mohave County officers during

that incident, and his duties and involvement on the Hildale City Council. He is expected

to testify that the Defendants have a secular purpose, that they do not have the principal or

primary effect of advancing or inhibiting religion, that they do not foster an excessive

government entanglement with religion or endorse one religion over another, and they do

not coerce people to support or participate in religion, or exercise or otherwise act in a

way that establishes a state religion or tends to do so. He is also expected to testify that

Defendants do not treat people unequally compared to other similarly situated individuals

they have not acted or failed to act with the intent or purpose to discriminate based upon

religion, and that religion is not a motivating factor for Defendants’ actions or inaction.

He is also expected to testify that Defendants have not engaged in a pattern or practice of

discrimination, they have not denied FHA rights to a group of persons, including non-

FLDS members, they have not attempted to make housing unavailable or deny housing

opportunities to any person, discriminated in the terms, conditions, or privileges in the

sale or rental of a building or the provision of services or facilities in connection

therewith, and they have not coerced, intimidated, threatened, or interfered with any

person in the exercise or enjoyment of, or on account of that person exercising or


Defendants.




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3. Edwin Barlow

Edwin Barlow serves as a member of the Hildale City Council. He is expected to

testify regarding his knowledge of the allegations in the Complaint, the structure, history

and/or functioning of the City government. He is expected to testify that the Defendants

have a secular purpose, that they do not have the principal or primary effect of advancing

or inhibiting religion, that they do not foster an excessive government entanglement with

religion or endorse one religion over another, and they do not coerce people to support or

participate in religion, or exercise or otherwise act in a way that establishes a state religion

or tends to do so. He is also expected to testify that Defendants do not treat people

unequally compared to other similarly situated individuals, they have not acted or failed to

act with the intent or purpose to discriminate based upon religion, and that religion is not a

motivating factor for Defendants’ actions or inaction. He is also expected to testify tha

Defendants have not engaged in a pattern or practice of discrimination, they have not

denied FHA rights to a group of persons, including non-FLDS members, they have not

attempted to make housing unavailable or deny housing opportunities to any person

discriminated in the terms, conditions, or privileges in the sale or rental of a building or

the provision of services or facilities in connection therewith, and they have not coerced

intimidated, threatened, or interfered with any person in the exercise or enjoyment of, or

on account of that person exercising or encouraging others to exercise FHA rights, and

that religion is not a motivating factor for Defendants.

4. Jeremiah Barlow

Jeremiah Barlow was the Town Manager for the City of Hildale and the Utilities

Board Business Manager. Mr. Barlow is expected to testify concerning his knowledge of

the allegations in the Complaint regarding utilities services in the area. It is anticipated

that Mr. Barlow may also provide testimony regarding official policies, ordinances, and/or

resolutions of the City of Hildale. He is expected to testify that the Defendants have a




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secular purpose, that they do not have the principal or primary effect of advancing or

inhibiting religion, that they do not foster an excessive government entanglement with















5. Joseph Allred

Joseph Allred is the Mayor of Colorado City. He is expected to testify about his

education, training, and experience as the Mayor, the respective roles of the Mayor and

Town Council, the other positions he has held for Colorado City, his former employment

with Twin City Water Works, and his knowledge about the provision of utilities

(including water) to residents of Colorado City.

Mayor Allred is also expected to testify about the following topics: his general

knowledge of the FLDS Church, its leaders, teachings, and its practices; his appointment

as Mayor; his employment as office clerk for Twin City Water Works, including, but not

limited to, his appointment and duties; his knowledge of services provided by Twin City

Water Works; his knowledge of Twin City Improvement Association, including, but not




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limited to, its efforts to obtain water for housing units; his knowledge, as Water

Superintendent, of the process of giving water hookups, including, but not limited to, the

application process, challenges in giving water hookups, whether applications were

denied, efforts to expand the capacities of the cities to obtain additional water, discussions

with the Utility Board about expansion and obtaining additional water, and efforts to

develop more water sources; whether he has sought or received guidance and/or directives

from FLDS Church leaders on how to perform his official duties as Town Clerk, Water

Superintendent, or Mayor; his knowledge regarding a water shortage in the community;

his knowledge about and interactions with Willie Jessop; his knowledge about and

interactions with Bruce Wisan, Jethro Barlow, Isaac Wyler, and other representatives of

the UEP Trust; whether he has ever discriminated against anyone on the basis of religion

while working as Water Superintendent, Town Clerk, or Mayor, and whether he has

observed any other town employee discriminate based on religion; his conversations with

Helaman Barlow, including Helaman Barlow’s work as a police officer and the Town’s

decision to terminate his employment; and all related issues.

Mayor Allred is also expected to testify that the Defendants have a secular purpose,

that they do not have the principal or primary effect of advancing or inhibiting religion,

that they do not foster an excessive government entanglement with religion or endorse one

religion over another, and they do not coerce people to support or participate in religion,

or exercise or otherwise act in a way that establishes a state religion or tends to do so. He

is also expected to testify that Defendants do not treat people unequally compared to other

similarly situated individuals, they have not acted or failed to act with the intent or

purpose to discriminate based upon religion, and that religion is not a motivating factor

for Defendants’ actions or inaction. He is also expected to testify that Defendants have

not engaged in a pattern or practice of discrimination, they have not denied FHA rights to

a group of persons, including non-FLDS members, they have not attempted to make

housing unavailable or deny housing opportunities to any person, discriminated in the

terms, conditions, or privileges in the sale or rental of a building or the provision of




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services or facilities in connection therewith, and they have not coerced, intimidated

threatened, or interfered with any person in the exercise or enjoyment of, or on account of

that person exercising or encouraging others to exercise FHA rights, and that religion is

not a motivating factor for Defendants.

6. David Darger

David Darger is the Town Manager for Colorado City. He is expected to testify

about his education, training, and experience as the Town Manager, along with the other

positions he has held within Colorado City. He is also expected to testify about the

government structure of Colorado City, the decisions reserved to the Town Council and

the Town Manager, the process by which residents within Colorado City can obtain

utilities (including water, power, and sewer), the hiring and firing of police officers for the

Marshal’s Department, Colorado City’s investigation into allegations against former

Marshal Helaman Barlow, Colorado City’s hiring of a Prosecutor, interactions with the

United Effort Plan Trust regarding its subdivision proposals, his attendance at Council

meetings, and all related issues.

Mr. Darger is also expected to testify about the following topics: his genera

knowledge of the FLDS Church, its leaders, teachings, and its practices; his employment

with Colorado City, including, but not limited to, his positions as building inspector

deputy town clerk, and Town Manager, his appointment to these positions, his duties, and

the Town’s policies and procedures; whether FLDS Church leaders direct his officia

conduct; his knowledge of the duties and responsibilities of the records custodians of the

Town, and the Towns’ policies and procedures regarding records retention of public

records; his knowledge and observations of the Town’s surveillance system, and who has

authority to access, view, and monitor the camera feeds, who maintains it, and the

retention schedule for the feeds; his employment as secretary and treasurer for the

Colorado City Fire District and his plea agreement and criminal conviction for misuse of

public funds; whether he directed fire district funds to the FLDS Church; his knowledge




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of and interactions with outside law enforcement, such as the Mohave County Sheriff’s

Office and their discriminatory practices towards FLDS residents; his knowledge of and

communications and interactions with Bruce Wisan and employees or representatives of

the UEP Trust, including, but not limited to, whether they are prejudiced against the

FLDS; the UEP Trust’s various subdivision proposals and unwillingness to comply with

the Town’s land division ordinance; his knowledge and observations of, and

communications and interactions related to, the enactment of the land division ordinance

and how the Town applies it to the UEP Trust and other individuals; his knowledge of the

Utah State Probate proceedings and the scope of Judge Lindberg’s authority over

Colorado City; his knowledge and observations of, and communications and interactions

with, Helaman Barlow, including, but not limited to, claims that he altered Helaman

Barlow’s police reports; his knowledge and observations of, and communications and

interactions with, Joseph Allred; his knowledge and observations of, and communications

and interactions with, Twin City Water Works and its employees, including, but no

limited to, whether it improperly diverted funds and failed to develop water resources for

the Town; his knowledge and observations of, and communications and interactions with,

Willie Jessop, including, but not limited to, whether he and other town employees

attended town business-related meetings on R & W business premises; his knowledge and

observations of, and communications and interactions with, Lyle Jeffs, including, but not

limited to, whether Lyle Jeffs discussed Town business with him or other Town

employees or directed how to conduct Town business; his knowledge and observations of

and communications and interactions with, Virgil Steed; his knowledge and observations

of, and communications and interactions with, William K. Steed, including, but not

limited to, any incidents related to children working on pecan harvests; his knowledge and

observations of Town employees leaving the community at the direction of the FLDS

Church; the Town’s investigation of officers for misconduct and work with Arizona and

Utah POST regarding investigations into officers for misconduct; the Town’s response to

Arizona or Utah POST’s decision to decertify a police officer; his knowledge and




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observations of, and communications and interactions with, Jessie Barlow; his knowledge

and observations of any FLDS Church directives requiring FLDS members to donate

money to Warren Jeffs while he was a fugitive; his knowledge and observations of, and

communications and interactions with, Haven Barlow, including, but not limited to, an

incident where Sam Brower attempted to serve papers upon Haven Barlow; his knowledge

and observations of, and communications and interactions with, Sam Brower; his

knowledge and observations of FLDS Church directives regarding new building

construction; his knowledge and observations of, and communications and interactions

relating to, the Town’s attempts to develop more water resources, including, but no

limited to, the water shortage in Colorado City, the implementation of an impact fee, the

hiring of Sunrise Engineering and other engineers, the policies and practices of the Town

to resolve the water shortage issues, the incident of a well pump sucking air in Colorado

City in 2014, and the Town’s attempts to resolve and repair the issues; his knowledge and

observations of, and communications and interactions related to, financial audits of the

Town; his knowledge and observations of, and communications and interactions with, the

UEP Trust, including, but not limited to, paying property taxes and the UEP Trust’s mass

evictions of Colorado City residents; the Town’s efforts to aid those who the UEP Trust

has evicted; his observations regarding any religious discrimination by any Town

employee; the Town’s policies and procedures against religious discrimination; the

Town’s training on anti-discrimination, for both employees and police officers; and all

related issues.

Mr. Darger is also expected to testify that the Defendants have a secular purpose,










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7. Vance Barlow

Vance Barlow is the Town Clerk for Colorado City. He is expected to testify about

his training, education, and experience as the Town Clerk. He is also a former officer

with the Marshal’s Department and is expected to testify about his application, training

education, and experience as an officer. He is also expected to testify about his

conversations with representatives from Colorado City and the Marshal’s Department, hisinteractions with Bruce Wisan and others from the United Effort Plan Trust, the policies,

procedures, ordinances, and resolutions that Colorado City established regarding utilities

the structure of Colorado City and its relationship and agreements with Hildale City, Twin

City Water Authority, and Twin City Water Works, the structure of the Utility Board, his

experience with water shortages within Colorado City and Hildale City, and all related

issues.

Mr. Barlow is also expected to testify about the following topics: his genera

knowledge of the FLDS Church, its leaders, and its practices; his knowledge of the

Town’s policies, procedures, and practices regarding the retention of records and file

servers to preserve official records; his knowledge and observations of, and his

communications and interactions with, Isaac Wyler, Bruce Wisan, and Willie Jessop




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including, but not limited to, responding to their requests for records; his knowledge and

observations of the Marshal’s Department’s policies and practices regarding locating

Warren Jeffs, including, but not limited to, squad meetings discussing the apprehension of

Warren Jeffs and interviewing residents about their knowledge of Warren Jeffs

whereabouts; his knowledge and investigation of missing persons complaints and

underage marriages; his knowledge of Bruce Wisan’s authority over the UEP Trust and

whether Town officials are hostile to Bruce Wisan at Warren Jeff’s directive; his

knowledge regarding the decertification of police officers and whether the Town or the

Marshal’s Department conducted investigations, or assisted with the on-going

investigations; whether he has ever received direction from any FLDS Church leader on

how to perform his duties as the Town Clerk or as a police officer; whether he has ever

discriminated against a non-FLDS resident; his knowledge of, and any involvement in

Twin City Water Works; and all related issues.

Mr. Barlow is also expected to testify that the Defendants have a secular purpose,


















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8. Jacob Barlow

Jacob Barlow was Colorado City’s Planning and Zoning Director. He is expected

to testify about his knowledge of the events alleged in the Complaint, including, for

example, the building permit process and requests for utility services. Mr. Barlow may

also provide testimony about Colorado City’s policies, procedures, ordinances, and

resolutions. He is expected to testify that that the Defendants have a secular purpose, that

they do not have the principal or primary effect of advancing or inhibiting religion, that

they do not foster an excessive government entanglement with religion or endorse one






for Defendants’ actions or inaction. He is also expected to testify that Defendants havenot engaged in a pattern or practice of discrimination, they have not denied FHA rights to











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9. Andy Barlow

Andy Barlow is currently serving as a building official for the Town of Colorado

City and Hildale City. Mr. Barlow is expected to testify regarding his knowledge of the

allegations in the Complaint, the structure and functioning of the City government

employment practices at the Cities, and other related matters. He is expected to testify that

the Defendants have a secular purpose, that they do not have the principal or primary

effect of advancing or inhibiting religion, that they do not foster an excessive government

entanglement with religion or endorse one religion over another, and they do not coerce

people to support or participate in religion, or exercise or otherwise act in a way that

establishes a state religion or tends to do so. He is also expected to testify that Defendants

do not treat people unequally compared to other similarly situated individuals, they have

not acted or failed to act with the intent or purpose to discriminate based upon religion

and that religion is not a motivating factor for Defendants’ actions or inaction. He is also

expected to testify that Defendants have not engaged in a pattern or practice of








Defendants.

10. Lovisa White

Lovisa White works for Colorado City as the administrative assistant and secretary

She also works as a part-time secretary for the Marshal’s Department. She is expected to

testify about her job duties, education, training, and experience with Colorado City and

the Marshal’s Department, her discussions with officers from the Marshal’s Department,




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her attendance at Council meetings, her interactions with the public who visit the Town

Hall or call the Town offices, and her experiences as a female working for, and living in

Colorado City. Ms. White is also expected to testify about her work with the payroll for

Colorado City, her knowledge regarding whether the police officers are members of the

FLDS Church or United Order, her experience regarding keeping separate from her

official duties any religious principles or beliefs, and all related issues.

Ms. White is also expected to testify about the following topics: her general

knowledge of the FLDS Church and its practices; her knowledge about the Town’s and

the Marshal’s Department’s policies regarding records retention; policies and procedures

related to claiming impounded animals and euthanization of unclaimed animals; her

knowledge about obtaining a business license; her knowledge and experience with

assisting people who come into the Town office who want to file an incident report or

witness statement, or file a complaint against an officer; her knowledge and understanding

of how religious principles interact with governmental duties; her knowledge and

observations of the Town’s surveillance cameras; and all related issues.

In the event that Ms. White is not available to testify at trial, the following

deposition testimony will be offered:

September 20, 2013 Deposition

- p. 4, line 7 to p. 5, line 12

- p. 12, line 18 to p. 31, line 13

- p. 36, lines 8 – 20

- p. 51, line 4 to p. 52, line 10

- p. 53, lines 1 – 9

- p. 54, line 23 to p. 56, line 12

- p. 56, line 13 to pg. 59, line 5

- p. 62, line 2 to p. 65, line 25

- p. 66, line 12 to p. 68, line 23

- p. 69, line 6 to p. 73, line 6




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- p. 81, line 13 to p. 82, line 19

- p. 85, line 16 to p. 88, line 18

June 25, 2014 Deposition

- p. 9, line 12 to p. 10, line 11

- p. 15, lines 12 – 17

11. Heber White

Heber White works in the Hildale Utility Office. He is expected to testify about

the process used when he receives any utility application. He is expected to testify that

















Defendants.




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12. Richard Barlow

Richard Barlow is the Treasurer for Hildale City. Mr. Barlow is expected to testify

concerning his knowledge of the allegations in the Complaint, including but not limited to

testimony that the Defendants have a secular purpose, that they do not have the principal

or primary effect of advancing or inhibiting religion, that they do not foster an excessive















Defendants.

13. Mike Spilker

Mike Spilker is a CPA at Hinton Burdick CPAs & Advisors. Hinton Burdick has

provided financial and audit services for Hildale and Colorado City for several years. Mr

Spilker is expected to testify regarding the audits they have performed. His testimony is

expected to include, but not be limited to, his experiences that show that the Defendants






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or tends to do so.

14. Jonathan Fischer

Jonathan Fischer is the past President of the Water Board and past President of

Twin City Water Authority. He is expected to testify about the water shortage within

Colorado City and Hildale, the water policies recommended, conversations within the

City Councils of Colorado City and Hildale. He is expected to testify that the Defendants




















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15. Victor Jessop

Victor Jessop has served as the water/wastewater superintendent with Twin City

Water Authority. Mr. Jessop is expected to testify consistent with his deposition

testimony, including but not limited to, his knowledge of the allegations in the Complaint

pertaining to utility services and building permits. Mr. Jessop may also testify regarding

historical issues regarding water supply in Hildale and Colorado City, and the availability

of culinary water for new service locations, along with any other related issues. He is

expected to testify that the Defendants have a secular purpose, that they do not have the
















Defendants. Specifically, his testimony is expected to include, but not be limited to, the

water policies and procedures of the Towns, the day to day operations of TCWA, the

supply and demand for water in the communities, the conservation and development

efforts of the Towns, and the structure and organization of the water supply systems.




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16. Weston Barlow

Weston Barlow is currently employed doing field work for the Hildale and

Colorado City Utilities. He is expected to have knowledge regarding the allegations in the

Complaint, the structure and functioning of the City government and its utilities. He is

















Defendants.

17. Jacob Jessop

Jacob Jessop is the President of the Utility Board and was the President of Twin

City Water Authority. He is expected to testify about the water shortage within Colorado

City and Hildale, water policies recommended, conversations with the City Councils of

Colorado City and Hildale. He is expected to testify that that the Defendants have a





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18. Berklee Holm, Sr.

Berklee Holm, Sr. was a member of the Twin City Water Authority Utility Board

He is expected to testify regarding his knowledge of the allegations in the Complaint, the

structure, history and/or functioning of the City government and utilities, and his

involvement and knowledge regarding the Holm School incident. He is expected to

testify that the Defendants have a secular purpose, that they do not have the principal or

primary effect of advancing or inhibiting religion, that they do not foster an excessive









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Defendants.

19. Justin Barlow

Justin Barlow is a fact witness. He is the Utilities Business Manager for the City of

Hildale. Mr. Barlow is expected to testify regarding his knowledge of the allegations in

the Complaint, the structure and functioning of the City government and its utilities

including but not limited to testimony that the Defendants have a secular purpose, that
















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not a motivating factor for Defendants. His testimony is expected to include, but not be

limited to, the utility policies and ordinances, the business decisions of the utilities, water

development, contractual relationships including those to help develop water, customer

demands regarding utilities, applications and hiring at the Cities, water demand in the

community, and the day to day operations of the utilities.

20. Warren Barlow

Warren Barlow is expected to testify via designated deposition pages:

May 30, 2014

- p, 10, lines 11-12

- p. 10, line 16 to p. 16, line 25

- p. 18, lines 10-19

- p. 34, line 16 to p. 36, line 4

- p. 38, lines 8-16

- p. 39, lines 5-9

- p. 39, line 22 to p. 40, line 6

- p. 46, lines 10-21

- p. 47, lines 6-21

- p. 48, line 1 to p. 50, line 4

- p. 52, line 18 to p. 53, line 13

- p. 54, lines 15-21

- p. 60, line 22 to p. 65, line 25

- p. 66, line 22 to p. 70, line 14

- p. 73, line 12 to pg. 76, line 7

- p. 78, lines 16-19




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- p. 84, lines 18-23

- p. 85, lines 21-25

- p. 88, line 6 to p. 89, line 20

- p. 93, line 22 to p. 94, line 1

- p. 97, line 9-16

- p. 112, line 21 to p. 113, line 2

- p. 115, line 10 to p. 125, line 25

- p. 127, line 10 to p. 130, line 3

- p. 130, line 24 to p. 135, line 9

- p. 135, line 25 to p. 136, line 3

- p. 139, line 24 to p. 143, line 3

- p. 152, line 12 to p. 159, line 18

- p. 161, line 11 to p. 163, line 2

- p. 174, line 8 to p. 185, line 11

- p. 187, line 21 to p. 188, line 12

21. Leonard Black

Leonard Black is serving as the Hildale City IT Manager. Mr. Black has

knowledge of the allegations in the Complaint, the structure and functioning of the City

government and IT systems, and any other related matters. He is expected to testify that












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Defendants. Specifically, he is expected to testify consistent with his deposition

including but not limited to the following: his work history, his interactions with

Defendants, his industrial lot lease, his FLDS membership status, his interaction with

FLDS leaders while employed with the Cities, FLDS meetings and services, his

application and employment at the Cities, communications with FLDS leaders regarding

City business, City network infrastructure and servers and data storage, fiberoptic lines,

City WiFi, FLDS video surveillance, FLDS IT support, CCMO radio communications

and City dispatch recordkeeping.

22. Lorin Fischer

Lorin Fischer is expected to testify via designated deposition pages:

May 28, 2014

- p, 10, lines 16-18

- p. 12, lines 9-25

- p. 13, line 1 to p. 16, line 18

- p. 17, lines 9-14

- p. 18, lines 10-19

- p. 48, line 47 to p. 49, line 20

- p. 48, line 4 to p. 49, line 20

- p. 50 lines 14-17




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- p. 58, lines 20-22

- p. 63, line 14 to p. 67, line 8

- p. 70, line 25 to p. 78, line 21

- p. 88, line 20 to p. 95, line 8

- p. 96, lines 8-21

- p. 97, line 8 to p. 99, line 5

- p. 99, line 24 to p. 100, line 11

- p. 100, line 19 to p. 108, line 9

- p. 109, line 2 to p. 113, line 15

- p. 109, line 2 to p. 113, line 16

- p. 115, line 22 to p. 121, line 4

- p. 122 line 14 to p. 124, line 12

- p. 128, line 13 to p. 130, line 9

- p. 146, line 25 to p. 147, line 16

23. Brian Meldrum

Brian Meldrum is expected to testify via designated deposition pages:

May 24, 2013

- p. 5, lines 18-20

- p. 8, line 12 to p. 22, line 24

-p. 8, line 12 to p. 22, line 23

- p. 23, line 14 to p. 25, line 18

- p. 26, line 6 to p. 29, line 17

- p. 30, line 9 to p. 32, line 23

- p. 33, line 2 to p. 33, line 8

- p. 33, line 21 to p. 35, line 11

April 7, 2014

- p. 6, lines 1-4

- p. 6, lines 7-12




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- p. 12, line 13 to p. 16, line 1

- p. 17, lines 5-22

- p. 18, lines 4-8

- p. 26, lines 18-22

- p. 30, line 13 to p. 32, line 17

- p. 32, line 24 to p. 33, line 17

- p. 34, lines 3-6

- p. 34, line 22 to p. 36, line 11

- p. 37, line 22 to p. 38, line 6

- p. 41, line 25 to p. 43, line 11

- p. 43, line 17 to p. 47, line 8

- p. 47, line 15 to p. 49, line 2

- p. 47, line 15 to p. 48, line 2

- p. 50, line 19 to p. 52, line 4

- p. 52, lines 15-19

- p. 52, line 23 to p. 54, line 23

- p. 55, lines 4-24

- p. 56, line 2 to p. 57, line 10

- p. 58, lines 5-19

- p. 58, line 23 to p. 59, line 8

- p. 59, line 17 to p. 60, line 3

- p. 59, line 17 to p. 60, line 8

- p. 60, lines 6-8

- p. 60, line 24 to p. 62, line 16

- p. 33, line 21 to p. 35, line 11

- p. 96, line 8 to p. 101, line 15

- p. 104, line 20 to p. 105, line 11

- p. 110, line 17 to p. 111, line 6




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- p. 116, line 14 to p. 117, line 3

- p. 125, lines 10-17

- p. 137, lines 6-12

- p. 171, lines 2-13

- p. 199, line 20 to p. 200, line 10

- p. 211, line 10 to p. 212, line 3

- p. 213, line 14 to p. 214, line 21

- p. 215, line 15 to p. 216, line 21

- p. 217, line 5 to p. 218, line 6

- p. 219, lines 18-20

- p. 220, line 2 to p. 221, line 1

- p. 220, line 2 to p. 221, line 2

- p. 225, line 18 to p. 227, line 19

- p. 229, lines 13-21

24. Brian Zitting

Brian Zitting works for Canaan Peaks Engineering. He is expected to testify about

his education, training, and experience as an engineer. He is also expected to testify abou

his work for Colorado City regarding water resources, his work with Sunrise Engineering

on water resources, his work with Colorado City and Hildale to evaluate the United Effort

Plan Trust’s proposed subdivision plat, his work on the proposed plat and description

from the United Effort Plan Trust, his engineering work regarding Twin City

Improvement Association’s request for a new culinary water service connection, and all

related issues.

Mr. Zitting is also expected to testify about the following topics: his work for

municipalities in the areas of design, surveying, and planning; the bid process to work for

Colorado City and Hildale; his professional licenses and organization memberships; his

April 2007 letter to Colorado City regarding the UEP Trust’s proposed plats; his April




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2007 e-mail to Joel Heaton responding to a request for information on new development

in Colorado City; his work on the proposed plat note submitted to the UEP Trust for

review; his December 2007 communications with the towns and the Utility Department

regarding water supply and water sources; his March 2008 letter to Hildale re the UEP

Trust’s subdivision proposal and the use of “lots-not-served” and “not-a-part” on the plat

map; his December 2009 rate structure study for Colorado City, Hildale, and Twin City

Water Authority; his February 2010 letter to Victor Jessop regarding the housing project

by Twin City Improvement Association and his reliance upon the December 1986 Bryce

Montgomery Report; his knowledge about Colorado City’s and Hildale’s efforts to

develop new water; and all related issues.

25. Marvin Wilson

Marvin Wilson works for Sunrise Engineering. He is expected to testify about his

education, training, and experience as an engineer. He is also expected to testify about

Sunrise Engineering’s work for Colorado City regarding water planning, water resources,

and general planning, his examination, studies, and conclusions regarding the availability

of water within Colorado City and Hildale, the reports that Sunrise Engineering prepared

to Colorado City and Hildale, Sunrise Engineering’s work with Colorado City to conduct

an impact fee study and a master plan, and all related issues.

Mr. Wilson is also expected to testify about the following topics: his professional

licenses and organization memberships; whether he has ever been a member of the FLDS

Church or lived in Colorado City or Hildale; the 1998 Culinary Water Master Plan

completed for Colorado City and Hildale; the 2002 Water Resources Study completed for

Colorado City and Hildale; the 2002 Environmental Study of Water and Squirrel Canyon

completed for Colorado City and Hildale; the 2008 Letter Report to Colorado City

regarding wells; the differences between a water capacity test and a safe-yield test; his

work to bring the power plant into compliance for use as a culinary water source; his work

on water studies for other municipalities; his knowledge about other municipalities




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policies and ordinances regarding limiting new water connections, the imposition of

impact fees, and the enforcement water regulations; and other related issues.

26. Mark Stratton

Mark Stratton is an expert witness who will offer expert opinions regarding the

operations and management conduct of the Defendants with respect to the provision of

culinary water to the residents of Colorado City and Hildale. He is expected to testify

about his education, training, experience, and qualifications to offer expert opinions. See

Statement of Qualifications, attached as Exhibit 1. He is also expected to testify about

the documents he reviewed and other work he completed during his analysis in this case.

Mr. Stratton is further expected to testify consistent with his expert opinions

disclosed to the United States, including the following expert opinions:

(1) It was appropriate for the towns to take action to limit new connections to

the existing water system without those new connections bringing additional supplies.

(2) The towns are working on developing a capital program to identify the

future capital needs for the water system, determine the timing and funding needs for

those capital projects, and develop a financing plan that can be supported with the limited

financial resources available. This plan is a reasonable effort in that the towns are

focusing on how to best meet the future challenges of a growing community while

addressing how they can also meet the needs of additional water demand. The towns wil

also need to incorporate how new developments and developers can also contribute to

these financial needs.

(3) Until the completion of the capital program, the towns and the water utility

need to maintain a vigilant position of protecting the existing customers and residents with

the limited water supplies that currently exist.

(4) The UEP Trust has the ability to form its own water utility and

infrastructure separate from either the Colorado City or Hildale to provide water service to

its properties.




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27. Ken Brendel

Ken Brendel is the prosecutor for the Town of Colorado City. He is expected to

testify about his education, training, and experience as an Arizona lawyer and his service

and duties as Colorado City’s prosecutor. Mr. Brendel is also expected to testify about the

advice he has provided to the officers with the Marshal’s Department regarding arrests,

traffic stops, property disputes, and trespass calls that have occurred within Colorado City

and that sometimes also involve the United Effort Plan Trust. He is also expected to

testify about his discussions with the Mohave County Attorneys’ Office and other law

enforcement agencies regarding the Marshal’s Department and issues regarding the

United Effort Plan Trust. He is also expected to testify about the advice he has provided

to the officers regarding disputes (property and otherwise) involving Andrew Chatwin

Richard Holm, Christopher Jessop, Jesseca Jessop, Ron Rohbock, Jerold Williams

Ronald Cooke, Jinjer Cooke, Willie Jessop, Isaac Wyler, Ross Chatwin, Lori Chatwin

Bruce Wisan, Jethro Barlow, and others. Mr. Brendel is also expected to testify about his

advice to the officers on how to write police reports to document events. He is also

expected to testify about his advice to the officers and others regarding eviction actions,

notices of abandonment, unlawful detainer, and related issues under Arizona statutes.

28. Richard D. Carr

Richard D. Carr is the former Hildale Justice Court Judge. Mr. Carr is expected to

testify about his knowledge of allegations in the Complaint, including but not limited to

testimony that the Defendants have a secular purpose, that they do not have the principal









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Defendants. Specifically, his testimony is expected to include, but not be limited to, his

knowledge regarding the justice court system, how he adjudicated matters, his

observations regarding discrimination in charges brought before him, and the operation

and structure of the justice court.

29. Zachary J. Weiland

Zachary J. Weiland is the former Hildale City Prosecutor. Mr. Weiland is expected

to testify about his knowledge regarding allegations in the Complaint, including but not

limited to that the Defendants have a secular purpose, that they do not have the principal













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education, training, and experience as a Utah lawyer and his service and duties as

Hildale’s prosecutor. He is also expected to testify about the advice he has provided to

the officers with the Marshal’s Department regarding arrests, traffic stops, property

disputes, and trespass calls that have occurred within Hildale and that sometimes also

involve the United Effort Plan Trust. He is also expected to testify about his discussions

with the Washington County Attorneys’ Office and other law enforcement agencies

regarding the Marshal’s Department and issues regarding the United Effort Plan Trust

He is also expected to testify about the advice he has provided to the officers regarding

disputes (property and otherwise) involving Andrew Chatwin, Richard Holm, Christopher

Jessop, Jesseca Jessop, Ron Rohbock, Jerold Williams, Ronald Cooke, Jinjer Cooke

Willie Jessop, Isaac Wyler, Ross Chatwin, Lori Chatwin, Bruce Wisan, Jethro Barlow

and others. He is also expected to testify about his advice to the officers on how to write

police reports to document events. He is also expected to testify about his advice to the

officers and others regarding eviction actions, notices of abandonment, unlawful detainer,

and related issues under Utah statutes.

30. Nathan G. Caplin

Nathan G. Caplin served as the Hildale City Prosecutor. Mr. Caplin is expected to

testify about his knowledge regarding allegations in the Complaint, including but no

limited to testimony that the Defendants have a secular purpose, that they do not have the





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education, training, and experience as an Arizona lawyer and his service and duties as

Hildale’s prosecutor. He is also expected to testify about the advice he has provided to

the officers with the Marshal’s Department regarding arrests, traffic stops, property

disputes, and trespass calls that have occurred within Hildale and that sometimes also

involve the United Effort Plan Trust. He is also expected to testify about his discussions

with the Washington County Attorneys’ Office and other law enforcement agencies

regarding the Marshal’s Department and issues regarding the United Effort Plan Trust

He is also expected to testify about the advice he has provided to the officers regarding

disputes (property and otherwise) involving Andrew Chatwin, Richard Holm, Christopher

Jessop, Jesseca Jessop, Ron Rohbock, Jerold Williams, Ronald Cooke, Jinjer Cooke

Willie Jessop, Isaac Wyler, Ross Chatwin, Lori Chatwin, Bruce Wisan, Jethro Barlow

and others. He is also expected to testify about his advice to the officers on how to write

police reports to document events. He is also expected to testify about his advice to the




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officers and others regarding eviction actions, notices of abandonment, unlawful detainer,

and related issues under Utah statutes.

31. Richard K. Chamberlain

Richard K. Chamberlain is the former Hildale City Attorney. Mr. Chamberlain is

expected to testify regarding his knowledge of the allegations in the Complaint, the

structure, history and/or functioning of the City government. He is expected to testify that

















Defendants.

32. Samuel Johnson

Samuel Johnson serves as a Sergeant for the Hildale/Colorado City Marshal’s

Office. He is expected to testify regarding his knowledge of the allegations in the




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Complaint regarding unlawful policing, along with any other related issues. He is






testify that Defendants do not engage in unreasonable seizures, including traditional

arrests without probable cause of a crime, brief investigatory stops without suspicion of

criminal activity, or use of excessive force. He is also expected to testify that Defendants












Defendants. Specifically, his testimony is expected to conform to his deposition

testimony, and will include, but not be limited to, incidents he was involved in as a

CCMO officer that the Plaintiff has identified as relevant to its claims, how he became an

officer at the CCMO, his training and certification as an officer, that he is not directed by

the FLDS Church in his official duties, that he does not share law enforcement

information with the FLDS, his interactions with FLDS Church security, his

communication with FLDS leaders regarding City business, his FLDS membership status




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the organization and policies of the CCMO, the CCMO’s handling of property disputes,

and his interactions and cooperation with other agencies.

33. Daniel Musser

Daniel Musser is an officer for the Hildale/Colorado City Marshal’s Office. He is

expected to testify regarding his knowledge of the allegations in the Complaint regarding

unlawful policing, and FLDS control over the hiring of police officers, along with any

other related issues. He is also expected to offer testimony that will contest Charlene

Jeffs’ testimony. He is expected to testify that the Defendants have a secular purpose, that





is also expected to testify that Defendants do not engage in unreasonable seizures

including traditional arrests without probable cause of a crime, brief investigatory stops

without suspicion of criminal activity, or use of excessive force. He is also expected to












Defendants. Specifically, his testimony is expected to be consistent with his deposition




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and will include, but not be limited to, the process by which he applied for and became a

cadet for the CCMO, his training and certification through POST, and his experience as a

newly hired officer at the CCMO.

34. Daniel Roy Barlow

Daniel Roy Barlow is an officer with the Marshal’s Department. He is expected to

testify about his education, training, and experience as a police officer, the certifications

received from Arizona and Utah, the process by which he became an officer, his

application and interview process to become a police officer, the training he has received

as a police officer, the Marshal’s Department’s policies and procedures, his interactions

with the Town Council and Prosecutor, and all related issues.

Officer Barlow is also expected testify about the following topics: his genera

knowledge of the FLDS Church and its practices; his employment as an officer, including

but not limited to, his appointment, duties, and whether the FLDS Church or its leaders

influence his work or was involved in his appointment; his knowledge of the Bishop’s

Storehouse and its contents; his investigations, actions, and observations with respect to

an alleged trespass incident involving Jim Barlow on July 4, 2014; his knowledge and

training regarding how to handle child custody disputes, including, but not limited to,

policies and procedures, training materials, services of summons, and assisting in the

enforcement of custody orders; his knowledge of, and interactions and communications

with, Charlene Jeffs, including, but not limited to, conversations (or lack thereof

regarding his appointment as a police office, information regarding her child custody

dispute, and his involvement in the custody dispute between Charlene Jeffs and Sabrina

Holms; his communications, if any, with Lyle Jeffs concerning his duties as a police

officer and whether he reports to Lyle Jeffs or any leader of the FLDS Church; his

knowledge of his and other officers’ participation in the United Order; his knowledge of

whether Town officials and officers separate non-United Order members from United

Order members, and non-FLDS members from FLDS members; his knowledge regarding




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whether officers sent consecrated money to Warren Jeffs when he was a fugitive, whether

he or other officers give Lyle Jeffs weekly reports regarding law enforcement activity

whether Lyle Jeffs directed him or the other officers to be hostile to Bruce Wisan, whether

Warren Jeffs dictates the conduct of him or other officers from prison; and all other

related issues.

Officer Barlow is also expected to testify that the Defendants have a secular

purpose, that they do not have the principal or primary effect of advancing or inhibiting

religion, that they do not foster an excessive government entanglement with religion or

endorse one religion over another, and they do not coerce people to support or participate

in religion, or exercise or otherwise act in a way that establishes a state religion or tends to

do so. He is also expected to testify that the CCMO and its officers do not engage in

unreasonable seizures, including traditional arrests without probable cause of a crime

brief investigatory stops without suspicion of criminal activity, or use of excessive force

He is also expected to testify that the CCMO and its officers do not treat people unequally

compared to other similarly situated individuals, they have not acted or failed to act with

the intent or purpose to discriminate based upon religion, and that religion is not a


the CCMO and its officers have not engaged in a pattern or practice of discrimination,

they have not denied FHA rights to a group of persons, including non-FLDS members,

they have not attempted to make housing unavailable or deny housing opportunities to any

person, discriminated in the terms, conditions, or privileges in the sale or rental of a

building or the provision of services or facilities in connection therewith, and they have

not coerced, intimidated, threatened, or interfered with any person in the exercise or

enjoyment of, or on account of that person exercising or encouraging others to exercise

FHA rights, and that religion is not a motivating factor for the CCMO and its officers.




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35. Hyrum Roundy

Hyrum Roundy is an officer with the Marshal’s Department. He is expected to

testify about his education, training, and experience as a police officer, the certifications

received from Arizona and Utah, the process by which he became an officer, his

application and interview process to become a police officer, the training he has received

as a police officer, the Marshal’s Department’s policies and procedures, his interactions

with the Town Council and Prosecutor, and all related issues.

Officer Roundy is also expected to testify about the following topics: his general

knowledge of the FLDS Church and its practices and leaders; whether he receives any

direction from the FLDS Church on how to conduct his official duties or interact with

Bruce Wisan or the UEP Trust; his knowledge about Saturday work projects; his

employment as an officer, including, but not limited to, his appointment and if the FLDS

Church was involved, his training, duties, and whether or not he accepts direction from

Warren Jeffs’ or other FLDS leaders in the performance of his official duties, and whether

he has observed government employees attempting to help FLDS members avoid service

of legal papers or personally had conversations on the issue; whether he assisted in the

avoidance of the service of legal papers or “slow walked” someone trying to serve legal

papers; his understanding of Court orders; the Marshal’s Department’s practices

procedures, and training regarding the service of documents; his knowledge and

observations of, and communications with, Helaman Barlow, including, but not limited to

changes Helaman Barlow made to his police reports; his knowledge and interactions with

Willie Jessop, including whether to arrest him on various criminal offenses; the Town’s

investigation into his conduct regarding Willie Jessop, including disciplinary action

against him by the Town; his knowledge regarding whether he or other officers altered

any police reports; his knowledge about and involvement in the July 2012 incident

involving Jerold Nathan Williams; his knowledge about and involvement in the January

2013 incident involving Sam Brower; his knowledge about and involvement in Ruby

Jessop’s custody battle with her husband Haven Barlow; his knowledge about and




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involvement in Sam Brower’s attempts to serve him with custody papers involving Haven

Barlow and Ruby Jessop; his knowledge and understanding of enforcing UEP Trust

occupancy agreements, including, but not limited to, his related communications with,

training, and advice from the Prosecutor, training from Arizona and Utah POST, and

training from the Marshal’s Department; his knowledge about and involvement in the

Holm School incident in December 2012; his communications, interactions, and

investigation of Isaac Wyler, including, but limited to, a trespass complaint regarding the

Fanita family property, or other allegations of trespassing; a 2009 incident where Isaac

Wyler complained that people were taking rocks out of a quarry; his knowledge about and

involvement in the April 2011 incident where William E. Timpson Jessop was arrested for

trespass; his knowledge about and involvement in property disputes between Jessica

Jessop, Christopher Jessop, and Penny Barlow; his knowledge about and involvement in a

February 2013 incident involving ECO Alliance and Willie Jessop; whether he

consecrated his official equipment to the FLDS Church; his knowledge of whether FLDS

Church leaders gave instructions to remove Helaman Barlow from the Marshal’s

Department; his working relationship with Helaman Barlow and concerns about Helaman

Barlow’s ability to lead as the Marshal; his knowledge about and observations of

interactions with Charlene Jeffs, including, but not limited to, his communications with

Charlene Jeffs regarding a welfare check on her children; his knowledge regarding

whether he or other officers sent consecrated money to Warren Jeffs when he was a

fugitive; whether he or other officers give Lyle Jeffs weekly reports regarding law

enforcement activity; whether Lyle Jeffs directed that he or other officers be hostile to

Bruce Wisan or the UEP Trust; whether he or other officers receive any direction from

Lyle Jeffs, Warren Jeffs, or any other FLDS Church leader regarding how to conduct their

official duties; his knowledge about and involvement in the child custody dispute

involving Sabrina Tetzner; and all related issues.

Officer Roundy is also expected to testify that the Defendants have a secular





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36. Curtis Cooke

Curtis Cooke serves as an officer for the Colorado City/Hildale Marshal’s Office.

He is expected to testify regarding his knowledge of the allegations in the Complaint

regarding unlawful policing, along with any other related issues. He is also expected to

offer testimony that will contest Charlene Jeff’s testimony. He is expected to testify that

that the Defendants have a secular purpose, that they do not have the principal or primary







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do not engage in unreasonable seizures, including traditional arrests without probable

cause of a crime, brief investigatory stops without suspicion of criminal activity, or use of

excessive force. He is also expected to testify that Defendants do not treat people











that religion is not a motivating factor for Defendants. Specifically, his testimony is

expected to conform with his deposition testimony and will include, but not be limited to,

incidents he was involved in as a CCMO officer that the Plaintiff has identified as relevant

to its claims, how he became an officer at the CCMO, his training and certification as an

officer, that he is not directed by the FLDS Church in his official duties, that he does not

share law enforcement information with the FLDS, his interactions with FLDS Church

security, his communication with FLDS leaders regarding City business, his FLDS

membership status, the organization and policies of the CCMO, the CCMO’s handling of

property disputes, and his interactions and cooperation with other agencies.

37. Shem Jessop

Shem Jessop served as an officer for the Colorado City/Hildale Marshal’s Office.

He is expected to testify regarding his knowledge of the allegations in the Complaint

regarding unlawful policing, including but not limited to that the Defendants have a




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or tends to do so. He is also expected to testify that Defendants do not engage in



He is also expected to testify that Defendants do not treat people unequally compared to

other similarly situated individuals, they have not acted or failed to act with the intent or










not a motivating factor for Defendants. Specifically, his testimony is expected to conform

with his deposition testimony and will include, but not be limited to, incidents he was

involved in as a CCMO officer that the Plaintiff has identified as relevant to its claims

how he became an officer at the CCMO, his training and certification as an officer, that he

is not directed by the FLDS Church in his official duties, that he does not share law

enforcement information with the FLDS, his interactions with FLDS Church security, his

communication with FLDS leaders regarding City business, his FLDS membership status

the organization and policies of the CCMO, the CCMO’s handling of property disputes,

and his interactions and cooperation with other agencies.




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38. Jonathan Roundy

Jonathan Roundy is the former Marshal for the Marshal’s Department. He is

expected to testify about his education, training, and experience as a police officer, the

certifications received from Arizona and Utah, the process by which he became an officer,

his decision to retire, and all related issues.

Mr. Roundy is also expected to testify about the following topics: his employment

as an officer and the Marshal, including, but not limited to, his appointment, retirement,

duties, and whether he followed the directives of Warren Jeffs or other leaders of the

FLDS Church in the performance of his duties; whether officers overlooked plural and/or

underage marriages in the community; training and advice received from the Prosecutor;

his knowledge of how individuals were appointed or employed as officers; his general

knowledge of the FLDS Church and its practices; his personal knowledge of the FLDS

Church, its leaders, and its practices, including, but not limited to, the United Order and

church security; his knowledge of the Marshal’s Department’s involvement in the

attempts to locate Warren Jeffs while he was a fugitive; his knowledge of, and interactions

with, Willie Jessop, including, but not limited to, attending meetings at his R&W

business; his knowledge of UEP Trust occupancy agreements; his knowledge about and

involving in the Holm Sunday School disputes involving Richard Holm and his brothers;

his knowledge about and involvement in a November 2008 incident involving Fred Jessop

and David Stubbs regarding the planting of wheat in a field; his knowledge about and

involvement in a May 2010 incident involving Shane Stubbs’ field; his knowledge about

and involvement in the euthanization of Lydia Stubbs’ horse; his knowledge about and

involvement in a July 2005 incident involving Andrew Chatwin attempting to obtain

possession of a property previously occupied by Orson Black; his knowledge about and

involvement in the 2010 arrest of Genevieve Hainline and Matthew Hainline; and al

related issues.

Officer Roundy is also expected to testify that the Defendants have a secular





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39. Keith Sobraske

Keith Sobraske works for Investigative Research, Inc. He was hired to conduct an

independent investigation into alleged misconduct on the part of then-Marshal Helaman

Barlow. Mr. Sobraske is expected to testify about his education, training, and experience

as an investigator, the analysis and investigation that he completed into Helaman Barlow,

and the conclusions that he reached. Mr. Sobraske is also expected to testify that he

investigated the following five allegations against Helaman Barlow, as set forth in his July

29, 2014 investigative report: (1) Making false claims with intent to bring discredit to

other officers; (2) Failure to maintain satisfactory working relationships with other




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employees (including the Town Manager) and his effectiveness to lead the Department;

(3) Confidence, or lack thereof, between the Marshal and the other officers and their

ability to effectively work together in responding to incidents; (4) Whether the use of

alcohol affected Helaman Barlow’s ability to lead the department; and (5) Admission fact

by Helaman Barlow that he lies and how that credibility affected his ability to function as

head of the Marshal’s Department. Mr. Sobraske will also testify about his conclusions

reached on each of these allegations.

40. Greg Meyer

Greg Meyer is an expert witness who will offer expert opinions (both affirmative

and in rebuttal to the United States’ police practice expert) regarding the conduct of the

Marshal’s Department and its officers. He is expected to testify about his education

training, experience, and qualifications to offer expert opinions. See Statement of

Qualifications, attached as Exhibit 1. He is also expected to testify about the documents

he reviewed, his interview with Ken Brendel, and other work he completed during his

analysis in this case.

Mr. Meyer is further expected to testify consistent with his expert opinions

disclosed to the United States, including the following affirmative expert opinions:

(1) It is proper for the officers to follow the advice of Ken Brendel, the

Prosecutor. Mr. Brendel generally advised handling property disputes involving the UEP

Trust as civil matters, and it is proper for police officers to follow the advice of

prosecutors. Also, the testimony of Mohave County Sheriff’s Department Sergeant Mike

Hoggard indicates that Mohave County Sheriff’s Department handles UEP property

disputes in the same manner as Colorado City Prosecutor Kenneth Brendel has advised

the CCMO to handle such disputes; and Sergeant Hoggard would not fault CCMO for

handling property disputes in that manner, which he believes is an appropriate manner. In

addition, staff of the Office of the Attorney General (Utah) documented that UEP Trust

Occupancy Agreements do not have the force of eviction orders.




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(2) The CCMO’s Policies and Procedures Manual was adequate, and it was

updated several times from 1989 through at least 2011. The manual quotes from the "Law

Enforcement Code of Ethics" that has been used in many places in the United States for

many years. The 2007 CCMO policies repeatedly emphasized the need for professional

police conduct, to avoid conflicts of interest, and to maintain an impartial attitude. In

particular, Section 2.6 under "Rules of Conduct" directed, "Use of profane, demeaning, or

insulting language will not be tolerated, nor will disrespect for the political or religious

views of others be accepted." Section 3.4 directed that personnel must cooperate with

other agencies. Section 4.1 directed that employees will not interfere with the lawfu

business of any person. Section 4.2 directed that personnel may not use their official

positions to intimidate persons engaged in a civil controversy. And Section 3.01 directed

that the selection and placement of agency personnel are to be based upon Equal

Employment 0pportunity provisions.

(3) Police officers have a duty to report and investigate crimes that they become

aware of. It is part and parcel of any police officer’s duty to do this. Chief Helaman

Barlow acknowledged this duty. Colorado City Prosecutor Kenneth Brendel stated that he

told CCMO officers that if they witnessed criminal activity, they should take appropriate

enforcement action (which would result in submission of paperwork to Mr. Brendel's

office for consideration of whether charges should be brought). This conduct was proper.

(4) No documented evidence exists to show any discrimination by CCMO

officers. No language in any of the reports provided a "red flag" that indicated that

discrimination was or may have been occurring.

(5) CCMO police officers appear to have provided police services to witness

Jesseca Jessop without discrimination against her. Ms. Jessop testified that she had no

problem with the way the CCM0 police officers handled 10 of the 12 matters in which she

interacted with them. She disputed the CCMO handling of two of those matters. The firs

is a property occupancy dispute with Penny Barlow. She recalled that Deputy Hyrum

Roundy advised her to go to court to get an eviction order, and Deputy Roundy provided




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her with a witness statement form. However, she faults Deputy Roundy for not doing his

job because he did not arrest Penny Barlow for trespass on the basis of occupancy

agreement paperwork without an eviction order from the court. She testified that she was

unaware that Deputy Roundy submitted the case to the Prosecutor, who rejected it as a

civil matter. There appears to be a conflict between a court order that Judge Lindberg

made regarding how occupancy agreement paperwork is to be considered during property

occupancy disputes, and the advice of the Prosecutor to treat such disputes as civil

matters, along with CCMO training or direction to gather the information from parties in

the dispute and submit it to the city prosecutor for enforcement advice and decisions. It is

appropriate for police officers to handle matters in the manner advised by the Prosecutor.

Second, Jesseca Jessop testified about an incident where she and her husband had rented a

house from Genevieve Hainline, but there was a trespasser (Enrique LeBaron) on the

properly. She called the police. LeBaron was arrested. She testified that she had no

problem with the way CCMO Deputy Hyrum Roundy and Officer Curtis Cooke and

Sergeant Sam Johnson handled the matter. She also testified that she asked that the

investigation be turned over to the Mohave County Sheriff s Office (because she thought

Officer Cooke had somehow "mistreated" LeBaron), and that the CCMO personnel did

turn the investigation over to Mohave County. Overall, not all incidents were handled in

the way that Jesseca Jessop personally desired, but the vast majority of them were; and

even the incidents that were not handled in the way that she personally desired do not give

rise to a conclusion that there was discrimination against her, absent proof of

discrimination.

(6) No evidence exists to supports the allegation that the Marshal's Office

carried out Warren Jeffs' order to return an underage bride. This allegation apparently

involves Ruby Jessop, who testified that Sam Roundy came up to Canada with Willie

Jessop to bring her back. However, no evidence exists that any CCMO personnel acted in

an on-duty capacity or used CCMO resources in this matter.




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(7) CCMO police officers appear to have provided police services to witness

Stefanie Colgrove without discrimination against her. She testified that Officer Curtis

Cooke responded to her call about a group of people outside the fence in front of her

property. She wanted the people to leave. Officer Cooke talked to a member of the group

(John Nielson), and the group left. However, she thought Officer Cooke treated her like

she was making something out of nothing. She testified that in 2009 she reported to

Officer Helaman Barlow acts of vandalism to the library. Helaman Barlow investigated

including taking pictures of damage and footprints. She testified that on April 1 6, 2011

there was a "huge bonfire" outside the library. She testified that she wrote two versions of

her witness statement because part of her first witness statement was not true. She

testified that Officer Sam Johnson was unwilling to help with the library investigation.

She testified that Officer Sam Johnson assisted her and protected her property from a

neighbor boy who had pilfered some items. No evidence of any discrimination exists.

(8) The arrest of Genevive Hainline Stubbs appears to have been lawful. Police

officers are taught that probable cause is a strong, reasonable belief that a person has

committed, is committing, or is about to commit a crime. During a property occupancy

dispute (during which CCMO personnel advise that the matter is civil and handles it

according to the standing legal advice given by the Prosecutor), she ignored police

commands and the direction of her own friends not to go on the property. The police

verbally and clearly announced the arrest. She actively resisted arrest. She was taken to

the ground using soft-hand controls only, and she was handcuffed. She admitted that she

resisted arrest and stated, "l fought them for a while.” No evidence of any discrimination

exists.

(9) If Helaman Barlow were acting on the advice of the Prosecutor to handle

UEP Trust property disputes such as the Berry Knoll Farms dispute as civil matters, it was

reasonable police action. Helaman Barlow testified that he told Mayor Terrill Johnson

that the Berry Knoll Farms dispute was civil, per the direction of the Prosecutor. Sally

Stubbs was not satisfied with the police service on this occasion. She testified that she did




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not remember hearing from Helaman Barlow stating that it was a civil matter. Also, the

testimony of Mohave County Sheriff’s Department Sergeant Mike Hoggard indicates that

Mohave County Sheriff's Department handles UEP property disputes in the same manner

as Colorado City Prosecutor Kenneth Brendel has advised CCMO to handle such disputes

and Sergeant Hoggard would not fault CCMO for handling property disputes in that

manner, which he believes is an appropriate manner. In the case of the Berry Knoll Farms

dispute, Sergeant Hoggard testified that he assessed that both parties in the dispute had

been violating parts of the related court order, and that clarification of the court order was

needed. Sergeant Hoggard also testified that he has no idea if Helaman Barlow's decision

to handle the dispute was religiously motivated.

(10) Although Sally Stubbs disagreed with receiving a reckless driving citation

from CCMO Officer Jerry Darger, she did not believe that it was based on some type of

religious discrimination.

(11) Marshal Fred Barlow's letter in October 2005 to federal fugitive Warren

Jeffs was improper and unprofessional. The letter openly states that Marshal Fred Barlow

intends to do and is doing the bidding of Warren Jeffs (FLDS leader and federal fugitive)

It also states that all of the officers desire "to stand with you and the priesthood" (but all of

the officers have testified that they did not engage in discriminatory law enforcement

practices).

(12) If there were threats against the church and individuals, and disruptions at

the church, it was proper for the CCMO to respond to church security requests for law

enforcement intervention. It is part and parcel of a police officer's job to respond to

threats and disruption, regardless of the source or target.

(13) If, as claimed by Willie Jessop, there was "a very heavy interaction between

church security and law enforcement," this may well have been appropriate as long as law

enforcement was acting in its proper role (and not "being hijacked to do policing for the

church"). It is ludicrous for anyone to suggest that there should be no interaction between




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law enforcement agencies and private security interests in the community. Such

interaction is a basic tenet of community-based policing.

(14) There is not enough information in the record to determine the propriety or

impropriety of "a number of cases" where Willie Jessop testified that Chief Sam Roundy

would forward police investigation information or license plate information to church

security, because the reasons these things occurred (if they occurred) and the necessary

specifics are not in the record.

(15) If Sam Johnson left the FLDS Church but was still promoted to Sergeant

and was next in line to be Chief of Police [and as of March 18,2014 was the Acting Chief

of Police], this is evidence that the FLDS Church is not in control of CCMO, as alleged.

(16) If Helaman Barlow "ran" license plates or NCIC checks at the request of

Willie Jessop or anyone else without an official purpose, this would be inappropriate and

unprofessional. Helaman Barlow admitted that he ran license plates (i.e., used the police

computer to obtain information about vehicles/license plates/registrations/warrants) at the

request of Willie Jessop 10 or 20 times. However, the purpose of doing so was not made

clear in the documentation. He denied running NCIC checks for non-law-enforcemen

persons. He did not recall if Guy Timpson ever asked him to run a license plate. He did

not know (or recall) if anyone from the FLDS meeting house asked him or any deputies to

run license plates. Helaman Barlow's various testimonies (via depositions and cour

testimony) are also full of inconsistencies.

(17) No evidence exists to conclude that CCMO personnel were involved in

carrying out an FLDS Church edict by rounding up domestic dogs and shooting them.

Steven Bateman testified about this issue during his deposition. While he believes that it

happened, he testified that he has no proof that CCMO personnel were involved in the

destruction of dogs.

(18) Mohave County Sheriff's Sergeant Mike Hoggard and Washington County

Sheriff Deputy Darrell Cashin (who both had routine interaction with CCMO personnel)

testified that the CCMO was generally cooperative with their investigations. Mohave




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County Sheriff’s Sergeant Hoggard testified that he could not think of any instances

where the CCMO was not cooperative. Washington County Deputy Sheriff Cashin

testified that most of the time he agreed with the CCMO officers' assessments as to

whether a property-occupancy dispute was civil when non-FDLS people would call him.

He also testified that CCMO has been helpful to him.

(19) Hyrum Roundy testified that he participated in the building of a fence, bu

no evidence exists that he knew that the property was occupied illegally or that the

activity had a nexus to his job with CCMO.

(20) If Sergeant Sam Johnson contacted the Washington County Attorney's

office for advice in handling the Holm School property dispute, and the Washington

County Attorney's office advised Sergeant Johnson to handle it as a civil matter, then

Sergeant Johnson performed his duty properly. Hyrum Roundy testified that he left the

Holm School property dispute before the call was completed because he did not want any

part of what he believed was mishandling by the sheriffs. UEP Trust Fiduciary Bruce

Wisan wrote to Hildale City Mayor Zitting that, "Police Officers from the County and the

Marshal's Office agreed that Richard [Holm] would have to get a court ordered eviction

notice..." Richard Holm testified that Jonathan Roundy and Sam Johnson came to Holm's

property, asked FLDS men to leave, and they did. Later, the FLDS men returned and

began digging holes and installing fences, and Sam Johnson responded and told them to

stop.

(21) If Prosecutor Kenneth Brendel instructed CCMO Officer Curtis Cooke to

arrest Jerrold Williams if Williams did not leave the property he was allegedly trespassing

on, and if Williams did not leave the property despite lawful direction to do so, it was

reasonable for Officer Cooke to make that arrest, and any reasonable officer would have

done the same thing.

(22) No evidence supports the allegation that the Marshal's Office has seized the

property of non-FLDS individuals without due process of law.




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Mr. Meyer is further expected to testify consistent with his rebuttal expert opinions

disclosed to the United States, including the following expert opinions to rebut Joseph

DeLopez’s expert opinions:

(1) The United States’ expert makes repeated references to the wording of

CCMO policy and concludes that it provides officers "plausible deniability." However

the United States’ expert uses Helaman Barlow as his source, and because of Helaman’s

ever-changing testimony, it is not reasonable to rely upon him to support any opinions.

(2) Basic academy, POST-certified training does not appear to be at issue. The

United States’ expert is concerned about in-service training. But, as the exper

acknowledged: "Neither POST agency has found CCMO out of compliance with this

requirement." While everyone might wish that more hours of ln-service training on more

subjects were provided over and above POST requirements, the fact is that training is

expensive, and it costs patrol time out of the field. It is traditionally difficult (especially

with small departments) to have the luxury to have both the money and the time to do as

much extra training as an agency might like to do. The fact that the CCMO was in

compliance with in-service training requirements in the view of POST from both Utah and

Arizona negates the United States’ expert's criticism. The United States’ expert also

repeatedly refers to standards proffered by the Commission on Accreditation for Law

Enforcement Agencies (CALEA). However, less than 4 percent of the approximate

18,000 law enforcement agencies in the United States are accredited by CALEA. The two

agencies that employed the United States’ expert (Chicago and Winnetka, IL) are not

accredited by CALEA. And not a single one of the many dozens of law enforcement

agencies of the United States federal government is accredited by CALEA.

(3) Where there is an investigation about a matter, and the original reports were

not comprehensive enough to answer later questions, it is proper for an officer to write a

supplemental report. The arrest of Harvey Dockstader was appropriate. The CCMO also

appropriately handled the Eco Alliance / 340 Johnson Avenue incident. The counsel of

the Colorado City Prosecutor's Office is also wise, i.e., that arrests do not need to be made




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immediately, and that it is sometimes better to wait until all of the various reports are

finished so that the totality of the case can be evaluated prior to a decision to prosecute or

not.

(4) The 2007 CCMO Law Enforcement Policy and Procedures manual contains

specific anti-discrimination language. It is incumbent upon the department to ac

accordingly. And any police agency should have a valid, nondiscriminatory hiring

system.

(5) According to the U.S. Department of Justice, Bureau of Justice Statistics

"About half of local police departments employed fewer than 10 sworn personnel." The

CCMO employs fewer than 10. It is difficult to understand the United States’ expert's

opinions about supervision ratios. There are police departments in this country that have

only two or three officers. Not every agency has the luxury of deploying better

supervision ratios like Chicago or Winnetka, IL. It is quite the norm with small agencies

for supervisors and chiefs and even other officers to be contacted in the off-hours as needs

arise.

41. Jeremiah Darger

Jeremiah Darger serves as the Hildale/Colorado City Chief Marshal. He is

expected to testify regarding his knowledge of the allegations in the Complaint regarding

unlawful policing, along with any other related issues. He is also expected to offer

testimony that will contest Charlene Jeffs’ testimony. He is expected to testify that the

Defendants have a secular purpose, that they do not have the principal or primary effect of

advancing or inhibiting religion, that they do not foster an excessive governmen




do not engage in unreasonable seizures, including traditional arrests without probable

cause of a crime, brief investigatory stops without suspicion of criminal activity, or use of




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excessive force. He is also expected to testify that Defendants do not treat people











that religion is not a motivating factor for Defendants. Specifically, his testimony is

expected to conform with his deposition testimony and will include, but not be limited to,

incidents he was involved in as a CCMO officer that the Plaintiff has identified as relevant

to its claims, how he became an officer at the CCMO, his training and certification as an

officer, that he is not directed by the FLDS Church in his official duties, that he does not

share law enforcement information with the FLDS, his interactions with FLDS Church

security, his communication with FLDS leaders regarding City business, his FLDS

membership status, the organization and policies of the CCMO, the CCMO’s handling of

property disputes, and his interactions and cooperation with other agencies.

42. Bruce Wisan

Bruce Wisan is expected to testify via designated deposition pages:

May 15, 2014

- p, 9, line 15 to p. 11, line 3

- p. 12, lines 10-12

- p. 13, lines 1-9

- p. 15, lines 3-14




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- p. 16, lines 3-5

- p. 16, line 10 to p. 17, line 22

- p. 18 line 16 to p. 29, line 15

- p. 32, line 10 to p. 33, line 12

- p. 34, line 23 to p. 35, line 2

- p. 35, line 11 to p. 47, line 2

- p. 50, line 17 to p. 70, line 7

- p. 72, line 20 to p. 75, line 18

- p. 76, line 20 to p. 78, line 3

- p. 79, line 13 to p. 83, line 20

- p. 86, line 19 to p. 89, line 12

- p. 89, line 24 to p. 104, line 1

- p. 105, line 6 to p. 119, line 1

- p. 119 lines 20-25

- p. 121, line 10 to p. 122, line 6

- p. 122, line 23 to p. 128, line 25

- p. 129, line 22 to p. 151, line 23

- p. 153, line 1 to p. 180, line 13

- p. 182, line 9 to p. 123, line 24

- p. 182, line 9 to p. 223, line 24

43. Sgt. Rich Fordham

Sgt. Rich Fordham is expected to testify via designated deposition pages:

July 23, 2014

- p, 5, lines 1-4

- p. 8, lines 2-6

- p. 19, line 19 to p. 20, line 21

- p. 21, lines 10-15




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- p. 21, line 23 to p. 24, line 8

- p. 26, line 9 to p. 30, line 12

- p. 32 line 19 to p. 33, line 10

- p. 60, line 21 to p. 61, line 17

- p. 67, line 25 to p. 68, line 15

- p. 108, line 22 to p. 115, line 3

- p. 118, lines 1-15

- p. 124, line 3 to p. 125, line 10

- p. 126, lines 20-24

- p. 137, lines 18-25

- p. 139, lines 11-19

- p. 153, line 12 to p. 163, line 22

- p. 166, lines 7-21

- p. 168, lines 15-21

- p. 169 lines 1-5

- p. 171, lines 1-10

August 20, 2014

- p, 180, lines 4-12

- p. 180, line 23 to p. 184, line 18

- p. 185, line 2 to p. 188, line 16

- p. 191, line 10 to p. 193, line 11

- p. 194, lines 5-19

- p. 195, line 24 to p. 199, line 25

- p. 200, line 23 to p. 208, line 1

- p. 208, line 20 to p. 214, line 14

- p. 214, line 21 to p. 215, line 18

- p. 214, line 21 to p. 215, line 19




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44. Stefanie Colgrove

Stefanie Colgrove is expected to testify via designated deposition pages:

May 22, 2013

- p, 7, line 24 to p. 8, line 2

- p. 22, lines 18- 20

- p. 54, lines 6-12

- p. 88, line 1 to pg. 90, line 9

- p. 93, lines 6-15

- p. 94, line 25 to p. 97, line 9

- p. 94, line 25 to p. 97, line 8

- p. 141, line 21 to p. 142, line 4

45. Raymon Christensen

Raymon Christensen is expected to testify via designated deposition pages:

September 12, 2013

- p, 25, lines 15-20

- p. 29, line 11 to p. 31, line 8

- p. 31, lines 13-24

- p. 32, line 6 to p. 33, line 9

- p. 33, line 21 to p. 34, line 2

- p. 34, line 9 to p. 35, line 6

- p. 36 lines 3-5

- p. 36, lines 12-14

- p. 37, lines 7-11

- p. 37, line 16 to p. 38, line 1

- p. 62, line 20 to p. 64, line 12

- p. 64, line 21 to p. 65, line 13

- p. 66, lines 3-10




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20

21

22

23

24

25

26

27

28

59

- p. 87, line 25 to p. 88, line 17

46. Sgt. Taylor Nelson

Sgt. Taylor Nelson is expected to testify via designated deposition pages:

September 1, 2015

- p, 10, lines 5-7

- p. 15, line 21 to p. 16, line 12

- p. 15, line 24 to p. 21, line 12

- p. 22, line 24 to p. 25, line 4

- p. 25, line 22 to pg. 26, line 18

- p. 27, lines 4-14

- p. 27, line 18 to p. 28, line 3

- p. 28, line 17 to pg. 29, line 2

- p. 30, lines 2-18

- p. 31, lines 4-19

- p. 44, lines 10-20

- p. 45, line 20 to p. 46, line 9

- p. 47, line 25 to p. 50, line 9

- p. 50, line 18 to p. 51 line 11

- p. 56, line 22 to p. 57 line 16

- p. 56, line 22 to p. 57, line 15

- p. 58, lines 5-25

- p. 62, lines 17-23

- p. 63, lines 10 to p. 65 line 1

- p. 66, line 1 to p. 70 line 9

- p. 66, line 1 to p. 70 line 8

- p. 70, line 25 to p. 71 line 24

- p. 73, line 11 to p. 75 line 7




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- p. 76, lines 14-25

- p. 77, lines 23-25

- p. 83, line 5 to p. 84 line 4

- p. 85, line 2 to p. 87 line 7

- p. 87, line 13 to p. 89 line 4

- p. 90, line 17 to p. 92 line 20

- p. 94, line 22 to p. 95 line 10

- p. 110, line 14 to p. 111 line 25

- p. 114, line 5 to p. 116 line 3

- p. 119, line 14 to p. 121 line 4

- p. 130, line 21 to p. 131 line 12

- p. 131, line 25 to p. 132 line 9

- p. 131, line 25 to p. 132 line 8

- p. 137, lines 8-22

- p. 138, line 6 to p. 140 line 23

Dated on November 12, 2015.

DURHAM JONES & PINEGAR

By: /s/ R. Blake Hamilton

R. Blake Hamilton

Ashley M. Gregson

Attorneys for Hildale City and Twin CityWater Authority




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61

CERTIFICATE OF SERVICE

I hereby certify that on November 12, 2015, I electronically transmitted theforegoing document to the Clerk’s Office using the CM/ECF system for filing andtransmittal of Notice of Electronic filing to the following CM/ECF registrants:

R. Tamar Hagler

Eric W. Treene

Sean R. Keveney

Jessica C. Crockett

Matthew J. Donnelly

Emily M. Savner

Sharon I. Brett

United States Department of Justice

Civil Rights Division

950 Pennsylvania Avenue, NWWashington, D.C. 20530

Attorneys for Plaintiff United State of America

Jeffrey C. Matura

Asha Sebastian

Graif Barrett & Matura, P.C.

1850 North Central Avenue, Suite 500

Phoenix, Arizona 85004

Attorneys for Defendant Town of Colorado City, Arizona

/s/ ASHLEY M. GREGSON4821-2744-5289




EXHIBIT

Case 3:12-cv-08123-HRH Document 770-1 Filed 11/12/15 Page 1 of 37



NAME:

LOCATION:

CONTACTS:

BIRTH:

EDUCATION:

CERTIFICATES

&

LICENSES:

EMPLOYMENT:

GREG MEYER

CURRICULUM

VITAE

Greg Meyer

Los

Angeles,

CA

Offìce:

(818)956-1303

Cell:

(562)

715-7497

E-Mail :

greq

mever(ò.e

arthl i

n

k. net

1948 -

Culver City

(Los

Angeles),

CA

M.S.

-

Public

Administration,

Cal

State

Los Angeles

(1991)

Master's

Thesis:

"Nonlethal

Weapons

vs.

Conventional

police

Tactics:

The

Los

Angeles

Police

Department

Experience"

B.A.

-

Journalism,

Cal

State

Long

Beach

(1979)

A.A.

-

Journalism,

Los

Angeles

Pierce

College

(1974)

Gertified Force

Science

Analyst

Force

Science

lnstitute

(2009 - present)

Certified

Litigation

Specialist

Americans

for

Effective

Law Enforcement (2003

-

present)

Certified

instructor,

TASER

X-26

(2005,2009)

Certified

instructor,

TASER

M-26

lnstructor (2001,2003,2005,

2009)

Certified

instructor,

Tasertron

(various

TASER

devices,

1992

-

1999)

Teaching

Credential

(Police

Science)

State

of California

(1981

-

Lifetime)

California

Peace

Officer

Standards

and Training

(p.O.S.T.)

(Basic,

lntermediate,

Advanced,

Supervisory,

Management

Certificates)

Police

Tactics

and

Procedures

Consultant

(Author,

Lecturer,

Consultant,

Expert

Witness)

-

self-employed

(1989

-

present)

Los

Angeles

Police

Department (1976

- present)

Offìcer,

Detective,

Sergeant,

Lieutenant,

Captain,

including

assignments

in

patrol,

detectives,

vice,

traffic,

planning

and research,

tactical

planning,

administration,

and training.

Retired

from

active

service s-31-06.

Field

Reserve

Officer

(1976-77);

Reserve

Officer

(2006,2012);

Speciatist

Volunteer,

LAPD

Training

Group

(2013

-

present).

updared 08125114

Pagc I

MEYER

OOO2I




GREG MEYER

Long Beach

Police Department, PatrolOfficer

(1977-78)

Los Angeles Police Department,

Field Reserve

Offìcer

(1976-77)

McDonald's Corporation, Restaurant Manager,

Training

Coordinator

(1572-76)

ASSOCIATIONS:

Force

Science

Research

Center

(FSRC)

National Advisory Board member

(2006 -

present)

Certified

Force Science Analyst

(2009 -

present)

Police Executive

Research

Forum

(PERF)

Associate Member

(2005

-

present);

advisor, PERF's

Center

for Force

and Accountability

(2005

-

2007);

panel

member

for

development of Conducted Energy Device

guidelines

(2005

and

2010); attended annual meetings

2004,2005,2006,2012

Peace Officers

Association

of

Los

Angeles

Gounty

(POALAC)

Training Seminars Committee chair

(2003

-

2011); Board of Directors

(2004

-

present);

member

(1981

-

present)

Americans

for Effective Law Enforcement

(AELE)

Certified

Litigation Specialist

(2003

-

present);Academic

Committee

member for AELE's Certifìed Litigation Specialist

program

(2002

-

present); Chairman, Association of Certified Litigation Specialists

(2011-

2013); law

journal

review

panelist

(2009

-

present);

seminar instructor

for

"Critical

lncident Response: Management and Legal Liability" seminar

(2002-2005);

seminar instructor for

"Lethal

and Less-Lethal Force"

seminar

(2006-2013);

seminar

instructor for

"Management,

Oversight and

Monitoring of Use of Force"

(2013)

American

Society for Law

Enforcement Training

(ASLET)

Vice

Chair

(2003-2004);

Treasurer

(2001-2003);

Executive Board

(2001-

2004);

seminar

instructor

(1994 -

2004);

master of ceremonies

for

annual

seminar opening ceremonies in Anchorage, Ontario

(CA),

and St. Louis

(2002-2004)

lnternational Association of Chiefs of Police

(IACP)

Co-author of Electronic Control

Weapons

model

policy

revision

(2010);

Project Advisor,

"Electro-Muscular

Disruption Technology:

A

Nine Step

Strategy for Effective Deployment"

(published

April 2005); IACP member

(1993

-

present);

attended IACP AnnualConference

(2004,2005,2006)

PoliceOne.com

Featured columnist

(2006

-

present)

Los

Angeles

Police

Command

Officers

Association

Member

(1998

- 2006)

POLICE Magazine

Advisory Board Member

and article contributor

(1997

-

present)

Updated 08125114

Pagc2

MEYER OOO22




GREG

MEYER

California Association of Force

lnstructors

(CAFI)

Presenter

and

Associate

Member

(1994

-

2000)

Public

Administration

Advisory

Committee

California State University,

Los Angeles

(1993

-

1998)

Pi

Sigma

Alpha

public

administration

honor

society

(1990)

California

Homicide lnvestigators Association

Past Member

California Peace Officers

Association

(CPOA)

Member

(1980

-

life member)

Century

Club,

West

Valley

Family YMCA

Member

(1974 -

2006)

President's Club, Los Angeles Metropolitan YMCA

Member

(1976

-

present)

Chairman's

Round Table, West

Valley

Family YMCA

Member

(2007

-

present)

MILITARY:

United

States

Army Security Agency

(1968-72)

Top

SecreUCryptographic security clearance;

Radio Traffic Analyst,

Airborne

Radio Direction Finding

Specialist and German Linguist; duty

stations included Pleiku and

Nha

Trang, Vietnam

(1969-'1970);

and

Bad

Aibling,

West

Germany

(1970

-

1972)

COMMUNITY

SERVICE:

Tri-Valley

YMCA

(San

Fernando Valley,

CA)

Chairman,

Board

of

Managers

(2012

-

present);

(a

combination of

three

YMCA

branches

under one managemenUleadership

team)

Los

Angeles Police

Museum

Chairman of the

Board

of

Directors

(1992-1995;

2007-2010); Vice

Chairman

(2014);

Director

(1989-present);

on-camera interviçw for

"The

History Channel"

program

on

the

1997 North Hollywood Bank Robbery

Shootout

(2008);

Co-Chair, Capital

Development

Campaign

(2000-2001

);

Producer,

AnnualJack

Webb

Awards

Night (1996,

1999,

2012);

Co-

producer,

Jack Webb Awards Night

(1997,

1998, 2001

,2004,

2014)

Valley Traffic Advisory Council

(San

Fernando Valley,

CA)

Founder

(2001);

Advisor

(2001-2004);

Director

(2007-

2009); Honorary

Member

(2009 -

present)

Updated 08125114

Pagc

3

MEYER OOO23




GREG MEYER

West

Valley Family

YMCA

(Reseda,

CA)

Member,

Board of Managers

(2011 -

2012); Leadership reunion

organizer

(2010);

Keynote speaker,

annual campaign

kickoff dinner

(2008

&

2009); Chairman's

Round Table

(2007-present);

President's

Club

(1974-present);Century

Club

(1974

-

2006); Board of

Managers

(1973-76);

Camp Committee

Chairman

(1974)

HONORS &

AWARDS:

"Lifetime

Achievement

A'ùvard"

(2012):

"Member of

the

Year"

(2006)

Peace Officers Association

of Los

Angeles County

(POALAC)

LAPD Management

Achievement

Award

Nominee,

for leadership

accomplishments

as

a division commanding

officer

(2001)

"Volunteer

of

the

Year"

Los Angeles Police Historical Society

(2000)

LAPD Management

Achievement Award

Nominee,

for leadership of

Wilshire Area's

"Predators

to

Prison"

Program

(1996)

Defensive

Tactics Newsletter's Leadership

Award

to recognize

commitment

and contributions to

research

in

training

&

tactics

(1994)

Medallion

Recipient,

National Philanthropy

Day in Los

Angeles for activities

with the

Los Angeles Police

HistoricalSociety

(1992)

LAPD's Hollywood

Detective

of

the Year

(1983)

Soldier

of

the

Quarter,

U.S.

Army Field Station

Bad

Aibling,

Germany

(1971)

l\rmy

Commendation Medal, Vietnam

(1969-1970)

Updated 08125114

Pagc 4

MEYER

OOO24




LAPD

PROFESSIONAL

ACTIVITIES:

*

GREG MEYER

Member,

Tactics Training

Review

Committee,

a

work

group

that

creates and updates

LAPD

Use

of

Force

Tactics

Directives

for

the

Chief

of

Police; monthly meetings

(2013

-

present)

Leader, LAPD Use-of-Force

"Best

Practices" Strategic Planning

Work Group,

direction and coordination

of

internal

subcommittees

and

outside consultants examining policy, training, equipment,

tactics,

post-

incident review

processes;

directed LAPD's TASER

ModelX-26

field test;

LAPD media resource

on

these

issues

(2005-2006)

Member, LAPD Use-of-Force

"Best

Practices" Strategic Planning

Work

Group

(2006

-

2009)

(turned

over

the

leadership role

upon retiring

from

LAPD in May 2006,

continued as

work

group

member); recognized

by

the

Los

Angeles

Board

of

Police Commissioners

during

its

adoption

of

a

revised LAPD

use-of-force

policy

resulting

from a four-year

project

(200e)

Member,

Professional Advisory

Committee,

a

work

group

focusing on

police

improvement

training

issues, coordinated

by

the

LAPD

Director

of

Police Training

and

Education, LAPD Academy

(2009 -

present)

Demonstrated ïASER-Cam

device

for

the

Chief

of

Police

(2007)

Presenter,

LAPD

Chief of Police and United States Military

Delegation from

Baghdad,

lraq, on crime and

traffic

issues,

Los Angeles

(August

2006)

PaÉicipant, National

lnstitute

of Justice

Conference,

featuring

nonlethal weapons session and force-options

simulator technology

session,

Washington, DC

(July

2006)

Participant,

Police Executive

Research Forum

(PERF)

focus

group

on

officer safety

issues,

Washington,

DC

(May

2006)

Participant, Police Executive Research Forum

(PERF)

Annual

Meeting,

focused on law enforcement

"best

practices,"

San

Francisco

(April2006)

Presenter, TREXPO-West

on TASERs and Excited Delirium

(March

2006)

Presenter,

LAPD ln-Seruice

Training Section Training

Day

on

TASERS

and

Excited Delirium

(March

2006)

Presenter, LAPD Chief

of

Police

press

conference,

to

announce

LAPD's field

test

of

TASER

ModelX-26

(February

2006)

Updated 08125114

Pagc

5

MEYER OOO25




GREG

MEYER

*

Presenter,

lnstitute

for Law

Enforcement

Administration

(ILEA)

national

summit on

use

of

force,

Plano, TX

(January

2006)

*

Presenter,

TASER

Executive

Course

for

law enforcement

leaders,

risk

managers,

and

legal

staff,

Scottsdale

(December

2005)

*

Participant, Police Executive

Research Forum

(PERF) conference

on

handling

the

mentally ill

and use

of

force,

San

Diego

(December

2005)

*

Member, California

Peace

Officer

Standards

and

Training

Gommission

(POST)

committee

to

create

a statewide

standardized

lesson

plan

for TASER

instructor

certification,

Sacramento

(2005)

*

Presenter,

Performance

lnstitute's

2005 Use

of

Force Summit,

Arlington

VA

(November

2005)

"

Participant,

Police

Executive Research

Forum

(PERF)

conference

on

TASER

policy

development,

Houston

(October,

2005)

"

Participant,

lnternational

Association

of Chiefs of

Police

(IACP)

annual

conference,

numerous use

of

force

seminars,

Miami

(September

2005)

"

Participant,

Canadian

Officer

Safety Conference,

Victoria

BC

(September

2005)

"

Participant,

Force

Science Research

Center

(FSRC)

seminar on

biomecha

nics of

off

icer-involved shooting

incidents,

"Winning

Extreme

Encounters from

Street to

Court,"

Seattle

(June

2005)

*

Advisor,

Police Executive

Research

Forum

(PERF)

Center

for Force

and

Accountability

(June

2005

-

present)

*

Participant,

Police

Executive

Research Forum

(PERF)

Annual

Meeting,

focused

on

international

police

use of

force

issues and

"best

practices,"

New York City

(April

2005)

*

Greator,

multi-agency

custody-death

research work

group

to

inspire

the

US

Surgeon

General to

involve

the

medical research

community in

this

persistent

law

enforcement problem (April 2005)

*

Project

Advisor,

lnternational

Association of Chiefs

of Police

(IACP)

publication,

"Electro-Muscular

Disruption

Technology: A Nine Step

Strategy for

Effective

Deployment"

(published

April 2005)

Updated

08125114

Pagc

6

MEYER

00026




GREG MEYER

Participant,

US

Department

of Justice

Symposium

on

Less-Lethal

Weapons Technology,

includ ing workshop

interaction

with international

law enforcement

and military

chiefs

and trainers, Arlington,

VA

(April2005)

Coordinator,

Chief of Police-directed

review of LAPD

use-of,force

policies

and

procedures

by

eight nationally

renowned

use-of-force

experts

(March

2005)

Participant,

lnternational

Association

of Chiefs

of

Police

(IACP)

annual conference,

attended

numerous

use

of

force seminars,

Los Angeles

(November

2004)

Participant, LAPD

Chief

of Police

"72-hour

Briefings"

following

officer-involved

shootings

and other

major incidents

(2004-2006)

Advisor, William

H.

Parker

Foundation

(2004-2006)

Guest lecturer

on

police

traffic safety

and management

issues,

Pepperdine

University's

School of Public

Policy,

graduate

seminar

(2004)

Chairman,

ad

hoc

committee

to improve

traffic

collision reporting

efficiency

(2003-2004)

Member,

Los

Angeles

City Gouncilman

Jack

Weiss'Advisory

Commissio n

(2002

-

2004)

First-level

adjudicator

as

the commanding

officer

for

hundreds

of

disciplinary

cases involving

public

and internal

personnel

complaints;

directed

these

investigations (1998

-

2006)

Presenter

of

facts,

findings

and recommendations

to

the Use

of

Force

Review Board

for officer-involved

shootings

and

other significant

use

of

force incidents

(1999

-

2006)

Board

member,

Police

Sergeant

selection

process

(2001)

Participant,

Law Enforcement

Ethics

Symposium

presented

by the

FBr

(2001)

Reviewer,

Police

Lieutenant

civil service

examination

(2001)

Assistant

Chair,

Area

lntegrity

Plan

Development

Committee

(2000)

Member,

Board

of lnquiry

to

examine

the suitability

of

particular

officers

to

be

promoted

to

the

rank

of detective

and

sergeant

(1999

-

present)

Updated 08125114

Page

7

MEYER

OOO27




GREG MEYER

*

Guest

speaker,

International

Traffic

Conference,

Madrid, Spain

(2000)

n

Participant,

California Office

of

Traffic Safety's annual

conference,

San

Diego

(2000)

*

Chairman

of the LAPD Board

of

Rights,

a de novo disciplinary

hearing

for

a

Los

Angeles

Police

Department

captain accused of

"neglect

of duty"

in

the

Department's "Rampart corruption scandal"

(2000)

*

Master

of ceremonies,

Valley

Traffic

Safety

Summit

(2000-2004)

*

Member,

LAPD lnformant

Policy

and

Procedures Review

Committee

(2000)

*

Panelist,

West

San

Fernando

Valley

Traffic Summit,

a seminar

for

community

activists, elected

officials, and

various

government

agencies

pertaining

to improving

traffic safety

(2000)

*

Guest

speaker,

California

Assembly

Speaker

Robert

Hertzberg's

Public

Safety

Advisory

Committee,

and his Families and Community

Advisory

Committee,

on

the

subjects of traffic

safety

and

the

Rampart

corruption

probe

(1

999-2000)

*

Civil

selice

interview and

personnel-package-review

panelist

for

the

sergeant's

exam process (1999)

*

Member,

Board of

lnquiry

committee to

examine

command

accountability for

reviews of

nondeadly force,

vehicle

pursuits,

and fleet

safety

issues

pertaining

to

policy,

training and

practices

of the

Los Angeles

Police

Department

(1999)

*

Commissioner,

San Fernando

Valley Public Safety

Advisory

Commission

convened

by

California State

Assembly Speaker

Bob Hertzberg

(1999

-

2003)

*

Member,

Traffic Strategic Committee

of the Los

Angeles

Police

Department,

to

develop

and recommend

improvements to the

Department's

efforts to

reduce

traffic

collisions

through education,

engineering

and enforcement

(1999

-2001)

*

Member, Detective

Strategy Committee of the

Los

Angeles

Police

Department,

to

develop

and recommend

improvements to the

Department's

efforts

to

produce

hig

h-quality criminal

investigations

(1

ee8-1

eee)

Updated

08125114

Pagc

8

MEYER OOO28




GREG MEYER

*

Member,

Short-Term

Strategy

Committee

on

Juvenile lssues

of

the

Los Angeles Police

Department,

to

develop and recommend

improvements to

the

Depañment's

efforts to

produce

high

quality

processes

involving

juveniles

(1

998-1 999)

*

Chairman or Member, numerous Boards

of Rights tribunals

to

adjudicate disciplinary matters within

the

Los

Angeles

Police Department

(1ee8

-

2006)

*

Chairman or

Member,

numerous Advanced

Paygrade Selection

lnterview

Panels for

Lieutenant

ll

and Detective

lll

(1998

-

2005)

*

LAPD-West Point Leadership Course instructional cadre member

(1997

-

2005)

*

Leadership Course instructor

for watch commanders,

sergeants,

and

field

training officers,

Los Angeles Police Academy

(1995

-

1997)

*

Use-of-Force

Review Coordinator, LAPD

Wilshire

Area

(1993

-

1994)

*

Advisor,

Use-of-Force

Management lnformation

System Task Force

(1

ee4)

*

Chairman

or

Member,

numerous

Advanced Paygrade Selection

lnterview

Panels for Sergeant

ll,

Detective

lll,

Detective

ll,

and

Police

Officer

lll

(Field

Training

Officers and Detective Trainees

(1993

-1998)

*

Member,

LAPD

Tactics Training

Review Committee

(1990

-

1993,

and

2004

-

2006)

*

Rodney

King

case:

Provided

expert consultation

on

use-of-force issues

to the

criminal and internal investigators

(1991),

state case

prosecutors

(

1 99 1

-92),

City Attorney

and administrative

defense

representatives

(1991-1994),

U.S. Attorney and Federal Bureau

of

lnvestigation

(1992);

memo to federal

judge

re

use

of force

policy/training

history

(1993).

*

Reviewed and analyzed use-of-force

and

officer-involved

shooting

repofts

for

the

Commanding

Officer, Operations-Headquarters Bureau

(1ee1-e3)

*

Conducted

a

special

investigation

of

a

command officer

at the

direction

of the Chief of

Police

(1987)

*

Authored

"The

Watch Commander's

Guide

for Control

of Disasters

and

Other

Emergencies"

(1982)

*

Developed

nonlethal weapons

policy

and training

material

(1980-81)

Updated 08125114

Pagc

9

MEYER OOO29




GREG

MEYER

Trained

67 instructor/divisional

coordinators

and

three

tactics

supervisors

on

the

TASER device,

LAPD

Academy

(1981)

Researched

and/or

tested

thirteen

nonlethal

weapons at Planning

and

Research

Division

(f

979-80)

Staffed

the

LAPD

Ad

Hoc

Committee

on

NonlethalWeapons

and

created

the

Nonlethal Control

Device

lncident

Report,

later adapted

as

LAPD's Use

of

Force Report

(1980)

Conducted

demonstrations

of nonlethal

weapons

for

the

Mayor

of

Los

Angeles,

the

Los Angeles

Board of

Police Commissioners,

and the

media

(1980)

Member/staffer, LAPD's

Human Resources

Development Committee

(1e80-81

)

SPECIALIZED

TRAINING

RECEIVED:

Managing,

Oversight

and

Monitoring of

Use

of

Force,

Americans for

Effective Law

Enforcement's

(AELE) (3

days, Las

Vegas)

(2013)

lnstitute for

Prevention of ln-Custody

Death (lPlCD)

annual seminar

(3

days,

Las

Vegas)

(annually

2006-2013)

Officer-lnvolved

Shooting

lnvestigation

Course,

Los

Angeles

Police

Department

(3

days, Los

Angeles, 2009)

Force Science

Analyst

Certification

Gourse,

Force Science

lnstitute

(5

days,

San Jose,

2009)

Lethal

and

Less-Lethal

Use

of Force Seminar,

Americans

for

Effective Law

Enforcement

(AELE)

(3

days,

annually or twice

per year

from

2002-2013)

Public

Safety

Discipline

and lnternal

Affairs

Course,

Americans for

Effective

Law

Enforcement

(AELE)

(3

days, 2005,

2009,

pending

in

2014)

Training on

California

Highway Patrol

(CHP)

Mobile

Video Audio

Recording System

(MVARS)

presented

by CHP staff at the

California

Department of Justice

(Los

Angeles office)

(February

2013)

Training

on

TASER X-2 and

X26,

presented

by Advanced Officer

Safety

Training staff

of

the

California

Highway

Patrol

(CHP)

at the

California

Department of Justice

(Los

Angeles office)

(August

2012)

Updated 08125114

Pagc I 0

MEYER

OOO3O




GREG MEYER

"

Jail

and Prison

Legal lssues,

Americans

for Effective

Law

Enforcement's

(AELE)

(3

days,

Las

Vegas)

(2005,

2011)

*

SWAT Debrief:

The Death

of

LAPD SWAT Officer

Randy Simmons

(3

hours,

Pleasanton,

CA, by

instructor Mike Odle, 2011)

*

Earthquake

Management Course,

California

Specialized

Training

lnstitute

(5

days,

San Luis

Obispo,

1981)

*

Civil

Disorders

Management

Gourse,

California Specialized

Training

lnstitute

(5

days,

San

Luis

Obispo,

1982)

*

Basic Detective

School,

LAPD

(15

days,

1982)

*

Supervisory

Development Course,

LAPD

(20

days,

1983)

*

Juvenile

Procedures

School,

LAPD

(3

days,

1983)

*

Vice School,

LAPD

(5

days,

1986)

*

Supervisory

Press Relations

Training,

LAPD

(1

day, 19BB)

*

Homicide

School,

LAPD

(5

days,

1991)

"

Watch Commander School,

LAPD (5

days,

1993)

*

Effective

Leadership

Course,

LAPD Wilshire Area

(1994)

*

P.O.S.T. Management Gourse

(10

days,

1993)

*

LAPD--West

Point Leadership

and Command Program

(24

days,

1 ee6)

*

LAPD Command

Development

Course

(24

days,

1998-1999)

*

Street

Survival

Seminar,

Calibre

Press

(3

days,

Honolulu

(1999)

*

"Leadership

in the

21"t Century,"

presented

by the

University

of

California at

Los Angeles,

the

University

of Southern California,

Pepperdine University,

and Claremont

Universily

(12

days,

1999

-

2003)

*

"Suicide

By Cop

-

Revisited," sponsored by

the

Peace Officers

Association of

Los

Angeles County

(1

day, 2000)

"

Live-fire weapons,

dynamic

building

entry, and

drug-lab

investigations,

by the

Drug

Enforcement Administration

(DEA),

4

hours

(shooting

M4,

M441,

HK53,

AR15),

Los Angeles

(1

day,

2007)

Updated

08125114

Pagc

I

I

MEYER

OOO31




GREG

MEYER

NON.LAPD

EXPERT

ACTIVITIES:

Presented

multi-media

lectures on

use-of-force

policy,

training,

equipment,

tactics,

ethics,

and

risk-management

processes

to:

*

Peace

Officers

Association

of

Los

Angeles County

(POALAC),

"Video

Evidence

lssues"

seminar

(Pending

in October 2014)

Peace Officers

Association

of

Los

Angeles

County

(POALAC),

use of

force

seminar,

focusing on

Force Science

issues,

video and

body-cam

issues, and

TASERs

(50

participants) (April

2014)

Americans

for

Effective Law

Enforcement's

(AELE)

Annual

Lethal

and

Less-Lethal Weapons

seminar,

Las

Vegas, focused on

Force

Science

issues

(95

participants) (October

2013)

::;i::;:iì'iiJïJf:i1"."Ë:fl

å"fi

ï;*iiiË:fi

;TT"1îi"",sedon

TASER issues

and

Force Science

issues, Santa

Ana

(CA)

(10

participants)

(June

2013)

Lorman

seminar

for

plaintiff

and

defense attorneys

and

law

enforcement

managementn

"Police

Liability

in California,"

focused

on

TASER

issues and

Force

Science

issues, Pasadena

(CA) (25

participants) (June 2013)

Americans

for

Effective Law

Enforcement's

(AELE)

Managing,

Oversight

and

Monitoring

of

Use

of

Force,

Las Vegas,

focused

on

TASER

issues

(135

participants)(April 2013)

Peace

Officers

Association

of

Los

Angeles

Gounty

(POALAC), use

of

force

seminar,

focusing on

Force Science

issues and

TASERS

(65

participants)

(January

2O13)

Americans

for

Effective

Law

Enforcement's

(AELE)

Annual

Lethal

and

Less-LethalWeapons

seminar

Las Vegas,

focused

on

Force

Science

issues

(110 participants)

(October

2012)

Peace

Officers

Association

of

Los

Angeles

County

(POALAC),

"Critical

lncidents:

Lessons

Learned" seminar,

focusing

on the

BART

shooting/weapons confusion case (55 participants)

(July

2012)

Lorman seminar for

plaintiff

and

defense

attorneys

and

law

enforcement

management,

"Police

Liability

in California,"

focused

on

TASER issues

and Force

Science issues,

Santa Ana

(48

participants)

(June

2012)

Updated

08125114

Page 12

MEYER

OOO32




GREG MEYER

*

Peace Officers

Association of

Los

Angeles County

(POALAC),

"Video

Evidence

lssues" seminar

(80

participants) (May

2012)

*

Travis County Grand

Jury

(Austin,

TX)

to

educate

Grand Jury

members on

officer-involved shooting

policy,

training, tactics,

and force-

science

issues

(February

2012)

*

Peace

Officers Association

of

Los

Angeles County

(POALAC),

use

of

force

seminar, focusing on

Force Science

issues and

TASERS

(55

participants)

(

Februa

ry 20 1 2)

*

Labor

Relations lnformation

System

(LRIS)

annual

lnternal Affairs

and Critical

lncidents seminar,

focus

on arrest-related deaths, use-of-

force

policy, police

trainers,

involuntary

firearms discharges, Las

Vegas

(1

10

participants) (November

2011)

*

Scottsdale

(AZ)

Police Department supervisors,

focus on

TASER

issues for supervisors,

trainers, and

SWAT

personnel (25 pafticipants)

(June

2011)

*

Public

Safety Training

lnstitute

(PSTI),

for various

"East

Bay"

(Northern

California)

law

enforcement

agencies,

240

participants (two,

4-hour

seminars)

(July

201 1)

*

Peace

Officers Association of

Los

Angeles

Gounty (POALAC),

use

of

force

seminar,

focusing on TASER

issues, Glendale, CA, 50

participants,

POST-certified

(June

201

1)

*

lndependent Cities

Risk Management Association

(ICRMA),

representing

22

cities

in the

greater

Los Angeles

Area,

50

participants

(May

20r

1)

n

Peace Officers

Association of

Los

Angeles County

(POALAC),

use

of

force seminar, focusing

on

TASER issues, Long Beach, CA, 45

participants,

POST-certified

(November

201

0)

*

lnstitute

for Law

Enforcement

Administration

(¡LEA)

Use

of

Force

and

Sudden ln-Custody

Death Seminar,

Plano

(TX),

75

participants

(September

2010)

*

Arroyo

Grande (CA)

Police

Department

(with guests from various

Central California

Agencies),

40

participants

(September

2010)

"

Americans

for

Effective Law Enforcement's

(AELE)

Annual

Lethal

and Less-Lethal Weapons

seminar

(formerly:

Gritical

lncident

Response Management Seminar),

Las

Vegas

(60-275 participants),

usually

twice

per year

(2002

-

2010)

Updated

08125114

Pagc

13

MEYER OOO33




GREG MEYER

*

Peace

Officers

Association

of

Los

Angeles County

(POALAC),

use

of

force

seminar, focusing

on TASER and nonlethalweapons

issues,

70

participants,

POST-certified,

Torrance, CA

(October

2009)

*

Lorman seminar

for

plaintiff

and defense

attorneys

and

law

enforcement

management,

"Police

Liability

in California,"

Santa Ana

(February

2009)

"

Penn

State

University's Center

for

Gommunity

and Public

Safety's

annual

seminar for

Pennsylvania constables,

presenting

on the

subject of

sudden

in-custody

death,

150

participants

including

police

training

personnel,

attorneys,

and

judges

(November

2008)

*

lnstitute

for Law Enforcement

Administration

(ILEA)

Use

of Force

and Sudden

ln-Custody Death Seminar,

150

participants,

Plano

(TX)

(2008)

*

Annual

TASER

lnstructor

Conference,

280

participants,

Chicago

(2oo7)

*

Beverly Hills

Rotary

Club,

lunch speaker,

police

use

of

force,

1 20

participants (2007)

*

Presenter,

Pepperdine University

public-policy graduate

seminar,

20 graduate students, requested

by

former

Los Angeles

Police

Commissioner

Racquelle

de

la Rocha

(2006)

*

Presenter and

panelist

on Tasers and

excited delirium, 30

law

enforcement

executives and ACLU

members,

presented

by

the

New York

Civil

Liberties Union

(Albany) (2006)

*

Performance

lnstitute's

2005

Use

of

Force Seminar,

30

participants,

Arlington VA

(2006)

*

TASER

lnternational's

Executive

Course,

150

participants,

Scottsdale

(2005)

*

TASER

lnternational's

Annual lnstructor Seminar,

Las Vegas

(150

participants)

(2002)

*

Defensive

Tactics Newsletter's Annual Training

Seminar,

Tallahassee,

Florida

(25

participants) (2002)

*

American Society

for

Law Enforcement Training

(ASLET),

lnternational

Training Seminar, Anchorage,

AK

(100

participants)

(2002)

*

Los

Angeles County

Sheriff's Department training

day

for

1,2O0

deputies, West Covina,

California

(2002)

Updated 08125114

Pagc

14

MEYER

OOO34




GREG MEYER

"

The Urban

Alliance on

Race

Relations

conference,

"Alternatives

to the

Use

of

Lethal

Force by Police," Ontario, Canada

(2000)

*

Galifornia Association of

Police

Training Officers

(CAPTO),

Norwalk,

California;

team-teach

use-of-force issues

with

police

defense

attorney

Michael P. Stone; and

panelist

with

Assistant

U.S.

Attorney

Michael

Gennaco and

plaintiff's

attorney Stephen Yagman

(160

participants)

(2000) (B-hour

POST cedified)

*

American

Society

for Law

Enforcement Training

(ASLET),

lnternational Training

Seminar, Richmond, VA

(200 participants)

(2000)

*

American

Society for Law Enforcement

Training

(ASLET),

Regional

Use

of

Force

Seminar, Ontario, California

(50

participants)

(1999)

"

American Society for Law Enforcement Training

(ASLET),

Regional

Use

of

Force Seminar, Los Angeles, California

(50

participants)

(1997)

"

Sudden ln-Gustody

Death

Seminar

(presenter

and

panelist),

Washington

State Criminal Justice Training Commission

(200

participants)

(1997)

*

California

Association of Police

Training Officers

(CAPTO),

Regional

Seminar,

Fresno,

CA

(50

participants)

(1

996)

(8-hour

POST-certified)

"

American

Society for


(ASLET),

lnternational

Training

Seminar, Grapevine, TX

(100

participants)

(1996)

"

California Association

of

Police

Training

Officers

(CAPTO),

Annual

Seminar

Bakersfield,

California

(80

participants)

(1995)

*

American

Society

for


(ASLET),

Regional

Use

of

Force Seminar, Albuquerque,

New Mexico

(50

participants)

(1995)

*

South

East

(Los

Angeles County)

Training Association,

at the University

of Southern California

(80

participants)

(1995)

"

American Society

for

Law Enforcement

Training

(ASLET),

lnternational

Training

Seminar, Anchorage,

Alaska

(100

participants)

(1995)

*

Los

Angeles Sheriffls

Academy,

for

the California Association of

Force

lnstructors

(CAFI) (35 participants)

(1

994)

*

Gentral

Florida Criminal Justice lnstitute at

Orlando

(20

participants)

(1

ee4)

*

Orange

County Traffic Officers' Association

(75

participants)

(1994)

*

Wisconsin Chiefs' Training Seminar

(200 participants),

Milwaukee

('1993)

Updated 08125114

Pagc 15

MEYER OOO35




GRËG MEYER

*

Wisconsin

Department

of Justice

Round Table

(35

chiefs and sheriffs),

Osh

Kosh

(1992)

*

Americans

for

Effective

Law

Enforcement

(AELE)

workshop

on Critical

Liability

lssues

(100+

participants),

Las Vegas

(1991

,

1996, 2000)

*

Trained

and

certified

more

than

375

TASER

instructors

for

dozens of law

enforcement

and corrections agencies, for Tasertron

(1991

-

1999)

"

State-licensed

chemical spray trainer, trained hundreds of civilians

(1981)

*

Trained

more

than

20

TASER

users,

lnglewood Police Department

(1981)

Updated 08/25114

Pagc

16

MEYER

00036






GREG MEYER

*

Reviewer, two draft National

Institute of Justice reports,

"Evaluation

of

Less Lethal Beanbag

Munitions

and Launchers" and

"Evaluation

of

Taser X2,"

(June

2012)

*

Contributing editor,

"Weapons

Gonfusion

and Civil Liability"

article,

for

Monthly Law

Journal of American's

for

Effective Law Enforcement

(AELE) (\/,ay

2012)

*

Participant,

Critical

lssues in Policing

Series:

An lntegrated

Approach to De-Escalation

and Minimizing

Use

of Force, Police

Executive Research

Forum

(PERF)

conference

(Washington

DC,

February

2012)

"

lnterviewed

by

Fox

News

11

(Los

Angeles) re the value

of

videotape

evidence;

and

whether

to

show

it

to

involved

officers before

or

after

interview;

live television,

"Studio

11

LA"

(January

2012)

*

Participant,

Use

of Force,

Electronic

Control Devices,

and

ln-

Custody Death-Formulating

a Plan, South

Bay

Training

Committee

(Redondo

Beach,

CA,

January 2012)

*

Participant, Use

of

Force

Investigation

and

Risk

Management

lecture

by attorney Randy Means,

Labor Relations lnformation

System

(LRIS)seminar

(2011)

*

lnterviewed

by Tammi Downey,

producer

for Discovery

Channel

Canada,

re

forthcoming documentary

on electronic

controlweapons

(2o11)

"

Reviewer,

Oakland

(CA)

use-of-force incident

Conducted

independent

external review

for the

chief

of

police

re

a use-of-

force

incident

involving TASER,

pepper

spray, and baton

(2010)

*

Participant, Police

Executive

Research

Forum

(PERF)

meeting

to

revise Conducted

Energy

Device Guidelines

and contributor

to the

final editing

process

(Philadelphia)

(August

2010)

*

Edited

Force Science

News

article

re

the

Oakland BART

Murder

trial

(2010)

*

Conducted internal affairs investigation

for

a local police agency to

determine

propriety

of a

TASER

use in a street

confrontation

between

an

officer and a subject

(2010)

*

Participant,

"The

Deadly Mix: 20

Years

of Officer Survival

Research,"

B-hour

class

by

former

FBI

staff who authored

"ln

the

Line

of

Duty,"

"ln

the

Line

of

Fire,"

and

"Violent

Encounters"

Updated

08125114

Pagc

I 8

MEYER OOO38




GREG

MEYER

*

lnterviewed

by

Karyn MacEwan,

producer

for

Discovery

Channel, re

forthcoming

documentary

on TASER inventor Jack Cover

(2010)

*

Participant,

lnternalAffairs

and Discipline

Seminar,

presented

by

Americans for

Effective Law

Enforcement

(AELE),

Las Vegas

(2009)

*

Participant,

New

Product Advisory

Meeting, TASER

lnternational

Headquarters, Scottsdale (2009)

*

lnterviewed by Hannah

Simon,

PoliceOne.com,

for an article relating

to

TASER

lnternational's

new

guidelines

for

probe

target areas

(2009)

*

lnterviewed by

Nick Berardini,

for

a

feature-length

documentary

film

on

TASERS

(2009)

*

lnterviewed

by Bill

Kidd,

"Law

Enforcement

Management

Bulletin,"

re TASER

policy

and training

issues

for

law enforcement executives and

superuisors

(2009)

*

lnterviewed by Chuck

Remsberg,

"Force

Sciences

News," re

TASER

recommendations

from

the

Braidwood

report in British

Columbia

(2009)

*

Advisor,

"Research

roundup: Latest on Tasers, arrest-related

deaths, excited delirium,"

Force

Science

News

Bullelin#127

(2009)

*

Co-author,

"Electronic

Control

Weapons

Model

Policy,"

lnternational Association of Chiefs

of

Police

(IACP),

revision

published

in

2010

*

Participant,

TASER

Annual lnstructor

Conference,

including rollout

of

the

TASER

X3

model, Ft.

McDowell

(AZ) (2009)

n

External

reviewer,

TASER

lnternational's revision of

"Product

Warnings: Law Enforcement" document

(July,

2009)

"

Participant,

TASER

lnternational's new

product

line

demonstration

including

X-REP

shotgun

(fired

it), Shockwave,

and

AXON,

Los Angeles

Sheriff's

Academy

(2009)

*

Certified instructor,

TASER

X-26

(2005,

2009)

*

Gertified

instructor,

TASER M-26

(2001,

2003, 2005, 2009)

*

Participant,

TASER

Executive

Conference,

Los

Angeles

Sheriff's

Academy

(March

2009)

Updated

08125114 Pagc

19

MEYER OOO39




GREG

MEYER

Co-producer

and

presenter,

lnstitute for Law

Enforcement

Administration

(ILEA)

use of

force

and

sudden in-custody death

seminar,

Texas

(2008)

External

reviewer,

TASER lnternational's

revision of

"Product

Warnings: Law Enforcement"

document

(January

&

April 2008)

Participant, Jail

and

Prison

Legal

lssues

Seminar,

presented

by

Americans for

Effective Law Enforcement, Las

Vegas

(2008)

Guest"

TASER

Scientific

and Medical

Advisory Board

Meeting

(Las

Vegas);

participated

in discussions

of current issues

(2007)

Monitored

TASER

user training

for

60

LAPD

officers

at the

Los Angeles

Police Academy,

including viewing all officers receive

TASER exposures for training

purposes

(September

18, 2007)

Edited three

articles on

Electronic ControlWeapons

issues

for

Americans for


(see

www.aele.orq

monthly

law

journals

for

March, April and

May

(2007)

Peer Reviewer,

US Department of

Homeland Security's

FY 2005

Commercial

Equipment

Direct

Assistance

Program

(2006)

lnterviewed

by Court-TV

for

a

half-hour program on

TASERS (2006)

Participant,

lnternational Association of Chiefs

of Police

(IACP)

annual conference,

attended use of force seminars,

Boston

(2006)

Reviewer,

Police Executive

Research

Forum national

survey on

Officer

Safety/Body

Armor,

sponsored by

United States Department

of

Justice,

Bureau of Justice

Assistance

(2006)

Radio

talk show

guest,

debating

Amnesty lnternational

on

stun-gun

issues,

Station WWRL

(New

York)

(2006)

Participant,

TASER

Annual lnstructor

Conference,

Las

Vegas

(2006)

Participant,

lnternalAffairs and Discipline Seminar,

presented

by

Americans

for


(AELE),

Las

Vegas

(2005)

Consultant, TASER issues

for Vista

Research

(2005

-

2008)

Presenter and

panelist

on the

state

and

future of law enforcement

training,

Academy

of

Criminal Justice

Sciences

(ACJS),

Las Vegas

(2o04)

Updated 08125114

Page20

MEYER

OOO4O




GREG

MEYER

*

Academic Committee member,

Americans

for

Effective

Law

Enforcement's

"Certified

Litigation Specialist"

program (20O2

-

present)

*

Presented

informal

session,

"Rafael

Perez

and

the LAPD

Rampart

Corruption

Game,"

American Society for

Law Enforcement Training,

Orlando

(2001).

"

Editor,

POST

instructor-course

proposal

"Weaponless

Defense

Against

Gontact

Weapons" for

Steve Tarani, Edge Defense

(2000)

n

Panelist,

"Mass

Violence

in

America:

The Law

Enforcement

Response,"

pertaining

to

Rapid-Response/Active

Shooter

tactics for

situations

like

the

Columbine school shooting and other in-progress major

incidents, for the American Society

for


(ASLET), Richmond, Virginia

(2000).

*

Expert

witness

and

consultant on use-of-force

issues

(1989

-

present)

"

Reviewer and editor

for

police

attorney

Michael P.

Stone's article,

"Lethal

Force and Law Enforcement Activity-Related

Deaths-A

Suggested

Protocol

for

Investigation"

(1

999)

*

Peer

review

panel member,

National lnstitute of Justice,

forfederal

grant

proposals

relating

to

the

lmpact

of

Technology

on

Policing,

Washington,

D.C.

(1998)

"

Presenter,

custody-death

issues

re Price v.

San

Diego

to

the

California

Association

of

Force

lnstructors

(CAFI),

Los Angeles

(1998)

*

Co-presenter,

"The

Value of Videotaped Evidence,"

American

Society

for


(ASLET),

Los

Angeles

(1997)

"

Presenter, causes and

prevention

of sudden in-custody death,

to the

California

Association

of

Force lnstructors

(CAFI),

Beverly

Hills, California

(1

ee7)

"

Met

with

the Director,

Science and

Technology Division,

National

Institute of Justice,

on concepts and issues surrounding development

of

improved

nonlethalweapons

policy

and

technology (1994)

"

Participant in

the

RAND

Corporation's

meeting

on transfer of less-

than-lethal military

technology

to

civilian law

enforcement arena;

and attended

the

House Armed Services Committee, Research

and

Technology

Subcommittee hearing on that subject

(1994)

Updated

08125114

Pagc

21

MEYER OOO41




GREG MEYER

*

Consultant

to California

Peace

Officer

Association, Standards

and

Ethics Committee

on

nonlethalweapons

policy,

tactics

and training

issues

(1993)

*

Consultant

to Galifornia

Peace

Officer

Standards

and

Training

Commission's

round table on

pepper

spray

policy

and

training

standards

(1993)

*

Conducted

nonlethalweapons demonstrations

and

presentations

to

the

following

during

1980-81 :

.

California

Peace Offìcers Association, Admin

lnstitutes

*

California

Highway Patrol Academy, including numerous

law

enforcement agency

and media representatives from the

Sacramento

area

:

::ï::::

ï::#:iiliiiJiïi;":i:ü""T:,,,,"

*

Rio Hondo Police

Academy, Whittier

-

:rrïi:Hi*Ïi:li"::"'""'

Chief

of

Police,

Los

Angeles

Updaied 08125114

Page

22

MEYER OOO42




lnterviewed

by

local

a

a

a

c

a

)

'a

a

a

a

a

)

a

t

a

t

a

a

GREG

MEYER

and

national

media

(1980

-

present):

Time

US News &

World

Report

Police

Chief

(magazine

of lnternational Association of Chiefs of

Police)

Los Angeles Times

(multiple

occasions)

Los

Angeles

Herald Examiner

(multiple

occasions)

Los Angeles Daily

News

Money Magazine

Good

Housekeeping

Grand Junction

(CO)

Sentinel

Aspen Daily

News

Miami Daily Business Review

The Mountain Enterprise

Court-TV

FOX

News

(Tampa,

FL)

POLICE

Magazine

(multiple

occasions)

San Francisco Chronicle

National Public

Radio

(NPR)

Austin

American-Statesman

(multiple

occasions)

o

Police &

Security

News

.

Force Science

News

(multiple

occasions)

r

Law Enforcement Management Bulletin

.

Nick Berardini

(documentary

fìlm

on TASERS)

r

PoliceOne.com

.

Discovery Channel

.

KNBC-TV, KABC-TV, KCBS-TV, KTLA-TV, KTTV-TV (Los Angeles)

.

St. Petersburg Times

.

Las Vegas

Sun

Times

.

The Capital

(Anne

Arundel, MD)

.

WNYC

Radio

(New

York)

.

San

Francisco Examiner

.

Slate

.

Las Vegas Review Journal

.

Discovery

Channel Canada

.

KLAS-TV

Channel

B

(Las

Vegas)

.

The Daily

(New

York)

.

Fox

News

11,

'Studio

11 LA"

(Los

Angeles)

.

Tampa

Bay Times

(multiple

occasions)

.

Columbus

(GA)

Ledger-Enquirer

.

Salt Lake Tribune

o

Associated

Press

(AP) (multiple

occasions)

.

Baltimore

Sun

.

Longview News-Journal (TX)

.

The Daily Breeze

(CA)

.

Charlotte

(NC)

Observer

o

Tallahassee Democrat

.

Long Beach

(CA)

Register

.

The Today Show

(NBC)

.

RT.com

.

The News Hour

(PBS)

Updated 08125114

Pagc

23

MEYER OOO43










GREG

MEYER

Authored

the

Office

of

Operations

Management Paper,

"1987-The

Year

of

Traffic Enforcement" and several articles for the Chief of Police.

985

-

1986

Officer-in-Gharge,

Prostitution Enforcement

Detail,

Hollywood

Vice

(Sergeant)

Line

supervision

and

performance

evaluation

for

personnel

assigned to

suppress

street

prostitution

in

Hollywood Area.

1984

-

1985

Officer-in-Charge, Hollenbeck Footbeats;

and

Patrol

Supervisor

(Sergeant)

Line

supervision

and

performance

evaluation

for

uniformed

personnel

assigned to

footbeat

patrols

in several

housing

projects

and business

districts;

and

perform general patrol

supervision.

Officer-in-chargeof

field

transportation

detail in the ColiseumiUSC/Exposition Park venue

during the

1984 Olympic Games.

1982

-

1984 Detective Trainee,

Hollywood

Area

(Police

Officer

Ill)

Gonduct

follow-up investigations

on reports of crime

(robberies,

sexual

assaults, auto-related crimes, burglaries and thefts). Honored as

the

1983

Hollywood Detective of the Year.

1981

-

1982

Researcher,

Tactical Planning

Section

(Police

Officer lll)

Author of

LAPD's Watch

Commander's Guide

for

Control

of

Disasters

and

Other

Emergencies,

as

well

as

numerous

other

staff

research

projects.

Field

command post equipment driver.

1980

-

1981

Field Training Officer, Venice Area

(Police

Officer lll)

Train, evaluate and document the

performance

of

probationary police

officers, respond

to

calls for

service and conduct

general patrol

functions.

1979

- 1980

Staff

Researcher/Adjutant, Planning

and

Research

Division

(Police

Officer ll and

lll)

Primary

researcher and

field-test coordinator,

LAPD's

nonlethal

weapons

program

including TASER,

teargas sprays, other devices.

Demonstrate

these devices to

police

managers,

political

officials, and

the

media.

Write LAPD

policy

and training material on nonlethal weapons.

Train front-line

supervisors as users of

these devices.

Author

of

numerous

other staff

projects.

Perform

administrative functions for

the commanding

officer.

1978

-

1g7g

Patrol Officer, Southwest Area

(Police

Officer I and ll)

Respond

to calls

for

service and conduct

general patrol

functions.

1978

Recruit Officer

(

Police

Officer

l)

1977

-

1978

Patrol Officer, Long

Beach

Police Department

(Police

Officer)

Respond

to

calls for service

and conduct

general patrol

functions.

Updated

08125114

Pagc27

MEYER OOO47




GREG MEYER

1976

-

1977

Reserve

Police

Officer,

Wilshire

Area

(Line

Reserve

Officer)

Respond

to

calls

for

service and conduct

general patrol

functions.

PARTIAL

BIBLIOGRAPHY:

[redacted

to

most recent

10

years]

"Tactics

and

science of

TASER

deployment,"

article,

PoliceOne.com

(January

2014)

"Lessons

from the Onion Field,"

article, POLICE Magazine

online

(March

2013)

"Latest

Medical

Research

on

TASERs,"

article,

PoliceOne.com

(October

2012)

"Video

Evidence

lssues: Conflict

and

ControVêt'S¡¡," article,

PoliceOne.com

(June

2012)

"The

L.A. Riot

-

20

Years

Later,"

article,

POLICE

website

(April

2012)

"Training

Crisis,"

editorial,

ghost-written

for

the

publisher,

POLICE

magazine

(April2012)

"TASER

Drive-Stun Heading

to

US

Supreme Court?" article,

PoliceOne.com

(Februa

ry

2012)

"The

'Occupy'

Movement and

Your Agency Response,"

article,

POLICE website

(December

2011) and magazine

(January

2012)

"TASER

ECW Basics,"

article, PoliceOne.com

(November

2011)

"Tactical

Ghallenge:

Suicidal Person with a Knife," article,

PoliceOne.com,

(June

201

1)

"PERF

Updates

lts Electronic

ControlWeapons Guidelines,"

article,

PoliceOne.com

(April

201

1)

"Rodney King:

20

Years Later,"

article, PoliceOne.com (March

2011)

"Two

Major

TASER

Cases on Appeal

at

the 9th Circuit,"

article,

PoliceOne.com

(January

201 1)

"Analysis

of the

BART

Cop's

2-Year

Prison

Sentence," article,

PoliceOne.com

(November

201

0)

Updated 08125114

Pagc

28

MEYER OOO48




GREG

MEYER

"The

BART Shooting

Tragedy:

Lessons

to

be

Learned,"

article,

PoliceOne.com

(July

201

0)

"Getting

lt

Off

My

Chest:

TASER's

New

Aiming Guidelines," article,

PoliceOne.com

(Oct.

2009)

"Why

History

Makes

the Case

for

Less Lethal," article, PoliceOne.com

(Sep. 2009)

"The

AMA Takes on

TASER Tactics,"

article,

PoliceOne.com

(Aug.

200e)

"The

UCLA

Library

lncident-Revisited," article,

PoliceOne.com

(Jun.

200e)

"Emergency

Room Doctor

Survey

re Police

'Excessive

Force' .

. .

Ouch "


(Apr.

2009)

"Conducted

Energy

Weapons:

A User's

Perspective,"

chapter for

TASER@

Electronic

Control

Devices: Physiology, Pathology, and

Law,

in

collaboration with

numerous

doctors and

medical

examiners,

a

32-chapter book

(published

by

Springer, Mar. 2009)

******

"TASER

lnventor Jack

Cover,

Rest

in

Peace," article,

PoliceOne.com

(Mar.2009)

"The

Latest

Amnesty lnternational

Report

on Electronic

Weapons,

article,

PoliceOne.com

(Dec.

2008)

"Another

Federal

Court Supports Officers

in

TASER

Lawsuit,"

article,

PoliceOne.com

(Oct.

2008)

"TASER

lncidents in

the News,"


(Sept.

2008)

"Telling

Your

Story,"


(August

2008)

"A

Ghecklist to

Enhance

Your

Nonlethal

Weapons Program,"

journal

article,

California

Peace

Officer,

(Fall

2008)

"Nonlethal

Weapons: The Promise

and the Challenge,"

journal

article,

Law Enforcement Executive Forum (July 2008)

"Little

Words, Big

Consequences,"


(June

2008)

"Court

Backs TASER

Use,"


(April

2008)

"Taking

on

the Media,"


(February

2008)

Updated 08125114

Pagc29

MEYER OOO49




GREG MEYER

"Tons

of

TASER

News,"


(October

2007)

"TASER

Tactics, Training

lnjuries,

and

the Kitchen

Sink," article,

PoliceOne.com

(August

2007)

"Do

Away

with the Anyways," article,

PoliceOne.com

(June

2007)

"They're

Still Out

There,"


(April

2007)

"One-on-One,

in

the Backyard," article, PoliceOne.com

(Feb.

2007)

"The

Gap:

How Loss of

the

Neck

Restraints

Led

to the

Rodney King

lncident,"

article,

PoliceOne.com

(January

2007)

"Rodney

King Revisited,"


(December

2006)

"Police

Force,

in

Golor," article,

published

on the LAPD website

blog

(mentioned

by the

Los

Angeles Times 11-14-06),

also

published

under

various titles

by

PoliceOne.com,

American

Police

Beat, and

The

Beat

(LAPD) (November-December

2006)

"TASER

Tactics

Update,"

article,

PoliceOne.com

(October

2006)

"Caught

on

Tape

. . .

Nice

Save "


(September

2006)

"Resources

for Sudden ln-Custody

Deaths," article, PoliceOne.com

(August

2006)

"Tactical

Hindsight: Tactics and

equipment have

improved in

the

last

30

years,

but the

job

of

law

enforcement remains

the same," article,

POLICE

magazine's

30th

anniversary issue

(October

2006)

"Horsing

Around and

Weapons

Retention," article, PoliceOne.com

(July

2006)

"Hands-on

versus Nonlethal

Weapons,"

article, PoliceOne.com (June

2006)

"Nonlethal

Weapons:

Early

use means

fewer

deaths

and

injuries,"

article,

PoliceOne.com

(May

2006)

"Nonlethal or Less-Lethal:

Does

it matter?"


(April

2006)

"NonlethalWeapons:

What's

Up?"

article, PoliceOne.com (March

2006)

"Train

to Win

Quickly,"

article,

"Police"

magazine

(November

2004)

Updated 08125114

Pagc

30

MEYER

OOO5O




GREG

MEYER

LITIGATION

ACTIVITIES: CASES:223 DEPOSED:43

ïESTIFIED:40

*

Numerous cases involved multiple

lssues

*"

ARD

=

arrest-related death, non-shooting

[redacted

to

list

testimony of

past

4

years]

Fowler

v.

State

of Galifornia

(CA) (2013) (Federal)

Expert witness for

the defense, civil suit alleging excessive force during

a

DUI

arrest

(Testifìed.)

Atencio

v.

Arpaio,

et al.

(AZ) (2013) (Federal)

Expert witness for the defense

(City

of Phoenix

defendants), civil suit excessive

force,

arrest-related death,

TASER

issues

(Deposed)

Tatro

v

City of

Paso Robles

(CA) (2013)

Expert witness for the defense,

civil suit alleging employee harassment,

retaliation, imposition

traffic

citation

quotas

by a

police

agency

(Deposed)

Bieg

v.

Gity

of Springfield

(MO) (2013) (Federal)

Expert witness for the defense, civil suit

alleging excessive force, TASER

involved

(Deposed)

Gonzales-Guerrero v. Gity of

San

Jose


Expert witness for

the

defense,

civil suit alleging excessive force, nonfatal

officer-

involved

shooting

(Deposed)

Coto and Molina v. County of Los Angeles

(CA)

(2012) (Federal)

Expert

witness

for the defense, civil suit

alleging excessive

force

resulting

in

arrest-related death,

TASER

involved

(Deposed)

Sparks

and

Murr

Administrative

Appeal

(CO) (2012)

Expert witness for

the City

of

Denver, administrative

appeal of discipline imposed

on

two offìcers

in

a use-of-force incident

(Testifìed)

Shooting

ARD**

Excessive

Force

TASER

False

Arrest

Pursuit Jail/Prison Other

CIVIL

For Pltf

b

11

5 2

1

7

For Deft

34 23 134 79

t6

I

11

17

CRIMINAL

For

Pros

2

1

b

4

For

Deft

t

J

7

5 1

ADMIN

For Deot

2 1

For Ofcr

3

4

2

Grand Jurv 1

TOTAL

46 24 163 98 28

I

12 27

Updated

08125114

Pagc

3 I

MEYER

OOO5i






GREG

MEYER

Deputy

Dobbins admin appeal(WA)

(2010)

Expert witness for

the officer

in

an administrative

hearing related

to

discipline

resulting

from

a

TASER weapons-confusion

incident.

(Testified)

Shreve

v. Franklin County

(OH) (2010) (Federal)

Expert witness for the defense, civil suit arising out of TASER uses

in

the

jail,

multiple

plaintiffs (Deposed

in

2010;deposed

in2012)

Remato

v.

City

of

Phoenix


Expert witness for

the defense, civil

suit

arising out

of

a

fatal officer-

involved

shooting

(Testifìed)

Arambula

v.

City

of

Phoenix


Expert witness for the defense, civil suit arising out of a nonfatal offìcer-

involved shooting

(Deposed.)

Oakes

v.

DeKalb

County

(GA)

(2010)(Federal)

Expert

witness for

the defense, civil suit arising out of a

fatal

officer-

involved shooting

(Deposed)

Salinas

v.

Gity

of

San

Jose


Expert witness for

the defense, civil suit arising out of an arrest-related death,

TASER

issues

(Testified)

Wozniak

v.

State

of

Arizona,

City of

Glendale, et al

(AZ) (2010)

Expert witness for

the defense, civil suit arising out of an excessive

force

claim,

TASER

issues (Deposed)

People

v.

Hanafi

and Liggins

(CA) (2010)

Expert witness for the defense on the issue of an alleged assault

by use of a

stun-gun

(Testified)

Williams

v.

Gity

of Mesa

(AZ)

(2010)(Federal)

Expert witness for the defense, civil suit alleging excessive force

(Deposed,

settled.)

Vasquez

v.

City

of

Santa

Paula


Expert witness for the defense, civil suit alleging

excessive

force, TASER

issues

(Testified)

Ahmad

v.

State of

Arizona

(AZ)

(2010)

Expert witness for the defense, civil suit arising out of

a

fatal

pursuit

(Deposed,

testified)

Former Orange Gounty

Sheriffls

Deputy Hibbs

arbitration

(GA) (2010)

Expert

witness for

the appellant who

was

terminated

from

employment

following

a use-of-force

incident, TASER issues.

(Testified)

Gomez v. City of Torrance


Expert witness for

the defense, fatal offìcer-involved shooting.

(Deposed)

Updated 08125114

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33

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GREG MEYER

Hirschfield

v.

San

Diego

Unified Port District

(CA)

(2009) (Federal)

Expert witness for

the defense, fatal offìcer-involved

shooting, TASER

issues.

(Deposed)

Dill

v. City

of Shreveport

(LA) (2009)

(Federal)

Expert witness for

the defense,

fatal

offìcer-involved

shooting.

(Deposed)

State

of

Louisiana v.

Christopher

Marlowe

(LA)2009

Expert witness for

the defense, security

offìcer accused of attempt

murder

(shooting).

(Testified)

People v. Orange

Gounty

(GA)

SherifPs Deputy Hibbs

(2009)

Expert witness

for the criminal

defense, deputy

accused of excessive force,

TASER

issues.

(Testified)

People

v.

Former

BART Officer Mehserle (CA) (2009)

Expert

witness for the

criminal defense, fatal

offìcer involved shooting,

offìcer

accused

of murder, TASER

issues.

(Testified)

La Voie

v.

City of

Mesa


Expert

witness for the

defense, use of force involving

fleeing

burglary suspect

(Deposed;

testifìed)

Verna

v.

Gounty

of

Orange,

CA

(2008)

Expert

witness for

the defense in a civil

suit arising

out of use of a TASER in

the

jail.

(Deposed,

testifìed)

Updated

08125114

Pagc

34

MEYER

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Documents

Colorado City Witness List