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1 Steven H. Rosenbaum (NY Bar #1901958) 2 Judy Preston (MD Bar) 3 4 5 6 7 8 9 10 11 12 13 14
R. Tamar Hagler (CA Bar #189441) Christy E. Lopez (DC Bar #473612) Eric W. Treene (NY Bar #2568343) Sean R. Keveney (TX Bar #24033862) Jessica Clarke (NY Bar #4694972) Matthew J. Donnelly (IL Bar #6281308) Emily M. Savner (NY Bar #5214358) Sharon I. Brett (NY Bar #5090279) United States Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530 Phone: (202) 305-4013 Facsimile: (202) 514-1116 E-mail:
[email protected] Attorneys for the United States IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA
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United States of America,
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Plaintiff;
No. 3:12cv8123-HRH
v. UNITED STATES’ TRIAL WITNESS LIST AND DESIGNATION OF DEPOSITION TESTIMONY
Town of Colorado City, Arizona, et al.,
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Defendants.
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Pursuant to the Court’s order of July 24, 2015, ECF No. 626, the United States submits the following list of witnesses it intends to call at trial. 1. Isaac Wyler
Mr. Wyler is a fact witness. witness. He is a former member member of the FLDS Church, a long-
26 time resident of the Colorado City/Hildale community, and works for the United Effort 27 Plan Trust (“UEP (“UEP Trust”). He is expected to testify regarding claims and facts facts alleged in 28 the United States’ Complaint in this case, as well as the matters discussed in his
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1 deposition and trial testimony in Cooke v. Town of Colorado City, 3:10-cv-08105 (D.
testimony will include: his excommunication excommunication from the FLDS FLDS 2 Ariz.). In particular, his testimony 3 Church; tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS 4 Church; instructions and directives from FLDS leaders; consequences of losing 5 membership in the FLDS Church; the treatment of non-FLDS members living in the 6 7 8 9 10 11 12 13 14 15 16 17 18
community by Defendants’ city officials, FLDS Church Security, the CCMO, and other community members; the FLDS’ opposition to Bruce Wisan and his administration of the UEP Trust; the CCMO’s failure to enforce UEP Trust Occupancy Agreements; FLDS leaders’ control over the Cities; the CCMO’s failure to respond to vandalism of UEP Trust property; Defendants’ interference with the administration of the UEP Trust; the CCMO’s refusal to investigate or arrest FLDS individuals for trespass; his prosecution by the Cities Cities for allegedly trespassing on UEP UEP Trust property while while working for the UEP Trust at that time; his knowledge of Ron and Jinjer Cooke’s inability to secure a water connection from the Cities; his knowledge of other homes and buildings on UEP Trust property that received water connections; his knowledge of building permits received for homes and businesses on UEP Trust property; property; and his knowledge of homes, buildings, utilities, businesses, and individuals on UEP Trust property. 2. Richard Holm
Mr. Holm is a fact witness. witness. He is a former member of the FLDS Church and a
19 long-time resident of the Colorado City/Hildale City/Hildale community. He is expected to testify testify 20 regarding claims and facts alleged in the Complaint, as well as the matters discussed in 21 his deposition and trial testimony in Cooke. In particular, his testimony will include: his 22 excommunication excommunication from the FLDS Church; tenets of the FLDS religion; how Warren 23 Jeffs became the leader of the FLDS Church; instructions and directives f rom FLDS 24 leaders; consequences of losing membership in the FLDS Church; the treatment of non25 FLDS members living in the community by Defendants’ city officials, FLDS Church 26 Security, the CCMO, and other community members; his experiences as a Hildale City 27 councilmember and the control the FLDS Church had over the City; the CCMO’s 28 handling of a trespass complaint at a property for which Mr. Holm had a UEP Trust
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1 Occupancy Agreement; and his arrest by the CCMO for criminal trespass at a 2 commercial property to which he had title and the County Attorney’s subsequent 3 decision to decline to prosecute that charge. 4 5 6 7 8 9 10 11 12 13 14 15 16 17
3. Robert Foster
Mr. Foster is a fact witness. witness. He is a FBI agent who helped search for and apprehend Warren Warren Jeffs. Agent Foster Foster is expected expected to testify testify regarding claims and facts alleged in the Complaint, as well as the matters discussed in his testimony in Cooke. In particular, his testimony testimony will include the law enforcement search search for fugitive Warren Jeffs; the CCMO and other Defendant employees’ resistance to capturing Warren Jeffs; and foundational testimony to admit letters and other documents from that search, including documents seized from Seth Jeffs’s vehicle and documents and items seized s eized at the time of Warren Jeffs’s arrest. 4. Charlene Jeffs
Ms. Jeffs is a fact witness. She is a former member member of the FLDS Church and and the ex-wife of FLDS Bishop Lyle Jeffs. Ms. Jeffs is expected to testify testify regarding claims and facts alleged in the Complaint, as well as the matters discussed in her deposition. deposition. In particular, her testimony testimony will include: tenets of the FLDS religion; religion; instructions and directives from FLDS leaders; consequences of losing membership in the FLDS Church
18 and the United Order; the CCMO’s involvement in her child custody dispute and legal 19 proceedings involving Lyle Lyle Jeffs; FLDS Church directives directives regarding the selection selection of 20 CCMO officers; CCMO officers consecrating money for fugitive Warren Jeffs; CCMO 21 reporting law enforcement information to Lyle Jeffs; Lyle Jeffs’s phone calls requesting 22 license plate checks of vehicles; membership of CCMO officers and Defendants’ city 23 officials in the FLDS Church, United Order, and FLDS Church Security; former Town 24 Council member Vergel Steed’s role in facilitating the separation of non-United Order
f amily members; ECO Alliance’s relationship to the 25 members from their United Order family 26 FLDS Church; then Town Council Member Kimball Barlow’s role in administering the 27 Bishop’s Storehouse; Isaac and Nephi Jeffs’s role as messengers between imprisoned 28
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1 Warren Jeffs and Bishop Lyle Jeffs; and Warren Jeffs’s role in directing the Church 2 from prison. 3
5. Dowayne Barlow
Mr. Barlow is a fact witness. He is a former member of the the FLDS Church and a
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FLDS Bishop Lyle Jeffs. Mr. Barlow is expected expected to testify regarding 5 former aide to FLDS 6 7 8 9 10 11 12 13 14 15 16 17
claims and facts alleged in the Complaint, as well as the matters discussed in his deposition. In particular, his testimony will will include: his departure departure from the FLDS Church; tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS Church; instructions and directives from FLDS leaders; consequences of losing membership in the FLDS Church and United Order; the treatment of non-FLDS members living in the community by Defendants’ city officials, FLDS Church Security, the CCMO, and other community members; his knowledge and experience with FLDS Church Security; the surveillance conducted by FLDS Church Security of non-FLDS; the coordination between the CCMO and FLDS Church Security, including by sharing surveillance equipment and information in law enforcement databases; harassment of non-FLDS members by FLDS Church Security; participation by Defendants’ city officials in FLDS Church Security; FLDS directives to separate family members, including the families of Defendants’ city officials and CCMO officers; membership of
18 CCMO officers and Defendants’ city officials in the FLDS Church; the operation of the 19 Bishop’s Storehouse and illegal activity conducted out of the Storehouse; and 20 Defendants’ city officials and CCMO officers consecrating money for fugitive Warren 21 Jeffs. 22 23
6. John Nicholas Hanna
Mr. Hanna is a fact witness. He is a Texas Ranger with with the Texas Department Department of
24 Public safety who was involved in the criminal investigations and conviction of Warren
expected to testify regarding claims claims and facts alleged alleged in the 25 Jeffs. Ranger Hanna is expected well as the matters discussed in his testimony testimony in Cooke. In particular, his 26 Complaint, as well 27 testimony will include the criminal investigation regarding Warren Jeffs, the conviction, 28 and Warren Jeffs’s communications and activities during his incarceration in Texas; the
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1 CCMO and other Defendant employees’ resistance to helping with the criminal 2 investigations of Warren Jeffs; and foundational and explanatory testimony to admit 3 FLDS priesthood records and other documents uncovered during the criminal 4 investigation of Warren Jeffs, including documents seized from the YFZ Ranch. 5 6 7 8 9 10 11 12 13 14 15 16 17 18
7. Jennifer Smith
Ms. Smith is a fact witness. witness. She is a mail room employee employee in prisons run by the Texas Department Department of Criminal Justice. In particular, Ms. Smith Smith will be asked to authenticate documents documents sent to or from Warren Jeffs during during his incarceration. Ms. Smith will also testify about the amount of mail Warren Jeffs receives and how he selects the mail he reads. 8. Rosemarie Urbanski
Ms. Urbanski is an expert witness witness for the United States. States. She is a forensic scientist and owner owner of The Drake Group. She has expertise in handwriting handwriting identification identification and analysis. analysis. Her additional additional qualifications qualifications are attached. attached. Ms. Urbanski is expected to testify consistent with the expert opinions provided in her reports and deposition in this case. In particular, her testimony testimony will cover the authentication authentication of documents documents signed by Joseph Allred, George Barlow, and Vance Barlow. 9. Willie R. Jessop
Mr. Jessop is a fact witness. He is a former member member of the FLDS Church, the the
19 former Legal Coordinator for Church affairs, and the former f ormer head of Church Security. 20 Mr. Jessop is expected to testify regarding claims and facts alleged in the Complaint, as 21 well as the matters matters discussed in his deposition. In particular, his testimony testimony will include: 22 his decision to leave the FLDS Church; tenets of the FLDS religion; how Warren Jeffs
leader of the FLDS Church; Church; instructions and directives directives from FLDS leaders; 23 became the leader 24 consequences of losing membership in the FLDS Church; the treatment of non-FLDS 25 members living in the community by Defendants’ city officials, FLDS Church security, 26 the CCMO, and other community members; his knowledge and experience with FLDS 27 Church Security; the surveillance conducted by FLDS Church Security of non-FLDS; 28 the coordination between the CCMO and FLDS Church Security, including training
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1 FLDS Security and the sharing of surveillance equipment and information in law
b y FLDS Church Security; 2 enforcement databases; harassment of non-FLDS members by Defendants’ city officials in FLDS FLDS Church Security; Security; FLDS directives directives to 3 participation by Defendants’ 4 separate family members, including the families of Defendants’ city officials and
off icials and FLDS leaders at R&W; 5 CCMO officers; interactions with Defendants’ city officials 6 7 8 9 10 11 12 13 14 15 16 17
the identification of signatures of Defendants’ city officials; the arrest of Harvey Dockstader; Defendants’ city officials and FLDS leaders conspiring or agreeing to use a water shortage as a pretext for discrimination; FLDS and CCMO involvement in the burglary of R&W Construction, Construction, Inc. in 2011; FLDS and and CCMO involvement in in an alleged burglary at ECO Alliance and an alleged home invasion at a home on Johnson Ave.; and FLDS and CCMO involvement in the theft of two vehicles and their contents from Mr. Jessop’s home. 10. Gary Wilbanks
Mr. Wilbanks is a fact witness. witness. He is an agent with with the Texas Office of Inspector Inspector General. His testimony will include: include: the authenticity authenticity of audio recordings of Warren Jeffs taken at the Powledge Unit of the Texas Department of Criminal Justice; the timing and frequency of various individuals’ visits with Warren Jeffs Jeff s while Warren Jeffs has been imprisoned at the the Powledge Unit, including Isaac and Nephi Nephi Jeffs; Texas
18 Department of Criminal Justice policy concerning visitation with prisoners, including 19 dress code and jewelry; information concerning visitors of Warren Jeffs recording 20 conversations with him via wrist watch recorders; and Warren Jeffs’ violation of prison 21 rules regarding communications. 22 23
11. Isaac Jeffs
The United States will offer Mr. Jeffs’ deposition testimony in lieu of live
trial. The United States States designates the follow deposition deposition testimony by page 24 testimony at trial. 25 and line numbers: 26 27
16:23-16:25
21:17-22:14
32:2-33:1
19:14-20:13
27:18-28:1
33:13-36:8
28
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38:2-38:7
58:10-58:14
87:23-88:12
38:19-47:5
61:5-69:9
88:14-91:11
47:12-48:13
70:7-71:9
93:5-93:21
48:20-48:25
74:10-76:5
94:11-99:15
49:4-49:21
79:12-83:17
99:25-102:9
51:22-52:1
83:19-85:6
53:15-54:2
85:24-86:4
12. Guy Timpson
Mr. Timpson is a fact witness. witness. He is former member member of the FLDS Church, a former member of the Utility Board, a former member of FLDS Church Security, and the former president of Pure Pure Ph8, a water bottling bottling company in Hildale. Hildale. He is expected to testify regarding his knowledge of claims and facts alleged in the Complaint, and matters discussed in his depositions in this case and in Cooke and his trial testimony in Cooke. In particular, his testimony will include: FLDS leaders’ control of the Cities,
14 TCWA, TCWW, Inc., and the CCMO; FLDS’s treatment of non-FLDS; his knowledge 15 and experience with FLDS Church Security; the surveillance conducted by FLDS 16 Church Security of non-FLDS; the coordination between the CCMO and FLDS Church 17 Security, including by sharing surveillance equipment and information in law 18 enforcement databases; harassment of non-FLDS members by b y FLDS Church Security;
Defendants’ city officials in FLDS FLDS Church Security; Security; his knowledge of 19 participation by Defendants’ 20 Pure Ph8 and its water connection; his knowledge of the Cities’ discriminatory water
Cities’ enforcement of that policy; policy; the Cities providing a new water 21 policy and the Cities’ 22 connection to Twin City Improvement Association; his experiences on the Utility Board; 23 consequences of losing membership in the FLDS Church and United Order; his 24 termination from the Utility Board after he was no longer a member of the FLDS 25 26 27 28
Church; and the Cities’ opposition to the administration of the UEP Trust. 13. Thomas Jeffs
Mr. Jeffs is a fact witness. He is a former member member of the FLDS Church and and the son of FLDS Bishop Lyle Lyle Jeffs. Mr. Jeffs is expected to testify regarding claims and and
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the Complaint, as well as as the matters discussed in his deposition. deposition. In 1 facts alleged in the testimony will include: his his excommunication from the FLDS FLDS Church; 2 particular, his testimony 3 tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS Church; 4 instructions and directives from FLDS leaders; consequences of losing membership in 5 the FLDS Church; the treatment of non-FLDS members living in the community by 6 7 8 9 10 11 12 13 14 15 16 17
Defendants’ city officials, FLDS Church Security, the CCMO, and other community members; his knowledge and experience with FLDS Church Security; the surveillance conducted by FLDS Church Security of non-FLDS; the coordination between the CCMO and FLDS Church Security, including by sharing surveillance equipment and information in law enforcement databases; harassment of non-FLDS members by FLDS Church Security; participation by Defendants’ city officials off icials in FLDS Church Security; FLDS directives to separate family members, including the t he families of Defendants’ city officials and CCMO officers; membership of CCMO officers and Defendants’ city officials in the FLDS Church and United Order; the operation of the Bishop’s Storehouse and illegal activity conducted out of the Storehouse; and Defendants’ city officials and CCMO support for fugitive Warren Jeffs. 14. Lyle Mann
Mr. Mann is a fact witness. witness. Mr. Mann is the Director Director of Arizona Peace Officer
18 Standards and Training Training Board. Mr. Mann is expected to testify regarding which which CCMO 19 officers have been decertified since 2003, and the factual f actual findings and reasons for each 20 decertification. 21 22
15. Vincen Barlow
Mr. Barlow is a fact witness. His is a former member of the FLDS Church and
Manager for Hildale. Mr. Barlow is expected expected to testify regarding claims claims 23 the former City Manager 24 and facts alleged in the Complaint, as well as the matters discussed in his depositions
particular, his testimony will include: include: tenets of the FLDS 25 and Cooke testimony. In particular, 26 religion; how Warren Jeffs became the leader of the FLDS Church; instructions and 27 directives from FLDS leaders regarding city business and picking officials of the Cities; 28 Defendants’ city officials sharing information with FLDS leaders; intermingling of
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1 Church and Hildale records; consequences of losing membership in the FLDS Church
e mployees; 2 and United Order; treatment of non-FLDS members by Defendants’ city employees; 3 authentication of documents produced or created by Hildale and TCWA; knowledge of 4 and experience with Church Security, including coordination and training with the
participation by Defendants’ city officials, video surveillance surveillance and harassment 5 CCMO, participation 6 7 8 9 10 11 12 13 14 15 16 17
of non-FLDS members; the Bishop’s Storehouse and illegal activity conducted out of the Storehouse; FLDS directives to cities to oppose efforts of UEP Trust Special Fiduciary Wisan; the Cities’ water policy and water rights. 16. Jethro Barlow
Mr. Barlow is a fact witness. He is a former member of of the FLDS Church and an employee of the UEP UEP Trust. He is expected to testify testify regarding his knowledge of of claims and facts alleged in the Complaint, and matters discussed in his depositions and trial testimony in Cooke. In particular, his testimony testimony will include: his excommunication excommunication from the FLDS Church; consequences of losing membership in the FLDS Church; the treatment of non-FLDS non-FLDS members living in in the community by Defendants’ Defendants’ city officials, FLDS Church Security, the CCMO, and other community members; the Cities’ interference with non-FLDS members’ members’ use and enjoyment of UEP Trust property; the CCMO’s refusal to enforce UEP Trust Occupancy Agreements; his prosecution by the
18 Cities for allegedly trespassing on UEP Trust property even though he was serving as a 19 representative for the UEP Trust; Ron and Jinjer Cooke’s attempts to obtain housing 20 from the UEP Trust; Ron and Jinjer Cooke’s Coo ke’s attempts to obtain utility service from the 21 Cities; UEP Trust’s attempts to work with the Cities regarding water rights and the 22 subdivision; the Cities’ changed building permit requirements; Twin City Water Works’ 23 transfer of public money to the FLDS Church; his attempts to serve on Hildale’s City 24 Council; his knowledge of homes and buildings on UEP Trust property that received 25 water connections; his knowledge of building permits received for homes and businesses 26 on UEP Trust property; and his knowledge of homes, buildings, utilities, businesses, and 27 individuals on UEP Trust property. 28
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17. Jerold N. Williams
Mr. Williams is a fact fact witness. He is a former member member of the FLDS Church and and a
elder. Mr. Williams is expected expected to testify regarding claims claims and facts 3 former FLDS elder. Complaint, as well as the matters matters discussed in his deposition. In 4 alleged in the Complaint, testimony will include: his his excommunication from the FLDS FLDS Church; 5 particular, his testimony 6 7 8 9 10 11 12 13 14 15 16 17
tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS Church; instructions and directives from FLDS leaders; consequences of losing membership in the FLDS Church and United Order; the treatment of non-FLDS members living in the community by Defendants’ Defendants’ city officials; the authentication authentication of Church records; the marriage of his underage daughter to the Mayor of Colorado City; the CCMO’s decision to arrest him for criminal trespass at a property that he built and for f or which he had a UEP Trust Occupancy Agreement; the emotional distress, embarrassment, and humiliation he suffered as a result of the CCMO’s conduct; the role of the Cities, their employees, and the FLDS Church in constructing a compound for Warren Jeffs and the Bishop’s Storehouse, including the Cities’ decision to permit a water connection at that compound. 18. Timothy Rohbock
Mr. Rohbock is a fact witness. witness. Mr. Rohbock is a former member member of the FLDS
18 and former member member of FLDS Church Security. Security. He is expected to testify testify regarding his 19 knowledge of claims claims and facts alleged in the Complaint. Complaint. In particular, his testimony testimony will 20 include: tenets of the FLDS Church; Church; directives from Warren Jeffs; Jeffs; the consequences of 21 losing membership in the FLDS Church and United Order; his knowledge kno wledge and 22 experience with FLDS Church Security; the surveillance conducted by FLDS Church 23 Security of non-FLDS members; the coordination between the CCMO and FLDS 24 Church Security, including by sharing surveillance equipment and information in law
b y FLDS Church Security; 25 enforcement databases; harassment of non-FLDS members by Defendants’ city officials in FLDS FLDS Church Security; Security; the CCMO’s 26 participation by Defendants’ 27 actions and the FLDS Church’s involvement in the arrest of Jerold N. Williams for 28 trespassing.
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19. Elizabeth Wayman
Ms. Wayman is a fact witness. witness. Ms. Wayman is a resident resident of the Twin Cities and
member. She is expected to testify testify regarding her knowledge of claims 3 a former FLDS member. testimony will include: the the tenets 4 and facts alleged in the Complaint. In particular, her testimony 5 of the FLDS religion and structure of FLDS leadership; FLDS leaders’ control of the 6 7 8 9 10 11
Cities and the CCMO; her departure from the Church; the consequences of losing membership in the FLDS Church and United Order; knowledge of the Bishop’s Storehouse and illegal activity conducted out of the Storehouse; CCMO’s treatment of her once she left the Church; the arrest of her husband, JJerold erold N. Williams, for trespassing; and the emotional distress, embarrassment, and humiliation she experienced as a result of that incident. 20. Helaman Barlow
12 13 14 15 16 17
Mr. Barlow is a fact witness. He is a former member of of the FLDS Church and a former Chief of the CCMO. CCMO. Mr. Barlow is expected to testify regarding claims claims and facts alleged in the Complaint and the matters discussed in his depositions in this case, as well as the matters discussed in his depositions and trial testimony in Cooke. In particular, his testimony will include: his excommunication from the FLDS Church; tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS Church; instructions
18 and directives from FLDS leaders; consequences of losing membership in the FLDS 19 Church; authentication authentication of documents produced or created created by Defendants’ city officials 20 and the CCMO; the treatment of non-FLDS members living in the community by 21 Defendants’ city officials and the CCMO; the the coordination between between the CCMO and 22 FLDS Church Security, including training FLDS Security and the sharing of 23 surveillance equipment and information in law enforcement databases; membership of
Defendants’ city officials in the FLDS FLDS Church and United Order; Order; 24 CCMO officers and Defendants’ 25 CCMO efforts to interfere with outside law enforcement; the operation of the Bishop’s 26 Storehouse and illegal activity conducted out of the Storehouse; the CCMO handling of 27 alleged trespassing at various properties; the CCMO’s knowledge of underage 28 marriages; FLDS Church’s influence over the operations of the CCMO.
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1 2
21. Joseph DeLopez
Mr. DeLopez is an an expert witness for the United United States. He is a consultant
3 regarding police practices and services and a former Chief of the Village of Winnetka, 4 Illinois, Police Department and former high-ranking Chicago Police Department officer.
in police policies, procedures, procedures, practices, and administration. administration. His 5 He has expertise in 6 7 8 9 10 11 12 13 14 15 16 17
additional qualifications qualifications are attached. attached. Chief DeLopez is expected expected to testify consistent with the expert opinions provided in his report and in his deposition. In particular, his testimony will include include expert opinions on the CCMO’s: CCMO’s: administration; policies policies and procedures; practices; practices; training; accountability accountability systems/practices; investigations; police reports; coordination with the FLDS Church; and religiously biased policing. 22. Steven Bateman
Mr. Bateman is a fact witness. witness. Mr. Bateman is a former FLDS FLDS member. He is expected to testify regarding his knowledge of claims and facts alleged in the Complaint, and matters discussed in his deposition in this case and in Cooke. Mr. Bateman testified in the Cooke trial by deposition. In particular, his testimony will include: his departure departure from the Church; the treatment of non-FLDS members living in the community by by Defendants’ city officials, FLDS Church Church Security, the CCMO, CCMO, and other community members; the consequences of losing membership in the FLDS Church; the CCMO’s CC MO’s
18 search of his vehicle without probable cause; his interactions with CCMO during a 19 subsequent traffic stop. 20 21
23. Randy Servis
Mr. Servis is a fact witness. witness. He is employed by the Arizona Arizona Department of of
22 Agriculture and investigated the CCMO’s euthanization of non-FLDS member Lydia
matters discussed in his 23 Cooke’s horse in 2011. He is expected to testify regarding matters testimony will include: his investigation investigation of the horse 24 deposition. In particular, his testimony 25 euthanization and his findings; and his review of CCMO records produced to him during 26 the course of his investigation. 27 28
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1 2
24. Samuel Brower
Mr. Brower is a fact fact witness. He is a private investigator. Mr. Brower is
3 expected to testify regarding claims and facts alleged in the Complaint, as well as the
deposition. In particular, his testimony will will include: the 4 matters discussed in his deposition. 5 CCMO’s discriminatory treatment of non-FLDS members; the CCMO’s efforts to 6 7 8 9 10 11 12 13 14 15 16 17
obstruct the service of process on FLDS members; the Cities’ assistance to the FLDS Church in its surveillance of non-FLDS members; and the coordination of FLDS Church Security personnel and the CCMO. 25. Jesseca Jessop
Ms. Jessop is a fact witness. She is a resident of the Colorado Colorado City/Hildale community and has never been a member of the FLDS FLDS Church. She is expected to testify regarding claims and facts alleged in the Complaint, as well as the matters discussed in her deposition. In particular, her testimony testimony will include: the CCMO’s CCMO’s failure to take action to enforce a valid UEP Trust Occupancy Agreement; harassment (including acts of vandalism and property damage) by members of the community and the CCMO’s response to and/or investigation of these incidents; employees or officials Defendants’ threats, intimidation and interference with the Jessops’ use and enjoyment of the property for which they received a UEP Trust Occupancy Occupancy Agreement; treatment treatment
18 as a non-FLDS person residing on UEP Trust land; various interactions with FLDS 19 Church Security, including incidents of monitoring and video surveillance and a hit-and20 run involving her son, Randy West, as well as the CCMO’s involvement in and response re sponse 21 to these incidents; and the emotional distress, embarrassment, and humiliation she 22 suffered as a result of the CCMO’s actions regarding her home. 23 24
26. Christopher Jessop
Mr. Jessop is a fact f act witness. He is a former member of the FLDS Church and a
City/Hildale community. community. He is expected to testify testify regarding 25 resident of the Colorado City/Hildale alleged in the United States’ States’ Complaint in this this case. In particular, his 26 claims and facts alleged 27 testimony will include: his departure from the FLDS Church; the treatment of non-FLDS
Security, 28 members living in the community by Defendants’ city officials, FLDS Church Security, 13
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1 the CCMO, and other community members; consequences of losing membership in the 2 FLDS Church; his experiences growing up in the Colorado City/Hildale area; the 3 CCMO’s failure to take action to enforce a valid UEP Trust Occupancy Agreement; 4 harassment (including acts of vandalism and property damage) by members of the 5 community and the CCMO’s response to and/or investigation of these incidents; 6 7 8 9 10 11 12 13 14 15 16 17
employees or officials Defendants’ threats, intimidation and interference with the Jessops’ use and enjoyment of the property for which they received a UEP Trust Occupancy Agreement; treatment treatment as a non-FLDS person residing on UEP Trust land; various interactions with Church Security, including incidents of monitoring and video surveillance and a hit-and-run involving his son, Randy West, as well as the CCMO’s involvement in and response to these incidents; and the emotional e motional distress, embarrassment, and humiliation he suffered as a result of the CCMO’s actions regarding his home. 27. Darrell Cashin
Mr. Cashin is a fact witness. witness. He is a Deputy with the the Washington County Sheriff’s Office (“WCSO”). (“WCSO”). He is expected to testify regarding claims and facts alleged alleged in the United States’ Complaint and will testify consistent with his deposition testimony. In particular, Deputy Cashin’s testimony will include the CCMO’s lack of cooperation
18 with and lack of support of the WCSO; the CCMO’s coordination with FLDS Church 19 Security; the CCMO’s actions during UEP Trust Occupancy Agreement disputes; the 20 Holm School incident; and the Willie R. Jessop stolen generator incident. 21 22
28. Lyle Jeffs
Mr. Jeffs is a fact witness. Mr. Jeffs is the Bishop of the FLDS FLDS Church and
to testify regarding the matters matters discussed in his 23 brother of Warren Jeffs. He is expected to testimony will cover: his communications communications with 24 deposition in this case. In particular, his testimony 25 Warren Jeffs; his role in the FLDS Church; Warren Jeffs’ control over FLDS Church
Defendants’ city officials, from 2004 through the present; present; 26 members, including Defendants’ communication with Warren Jeffs while he was a federal 27 Defendants’ city officials’ communication 28 fugitive; FLDS Church instructions regarding non-members and membership in the
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1 United Order; Warren Jeffs’ dictations and edicts; the Cities’ opposition to the UEP 2 Trust and its subdivision efforts; the Bishop’s Storehouse and illegal conduct conducted 3 out of the Storehouse; directions he has given to the CCMO and Defendants’ city 4 officials regarding government business; the incident at Eco Alliance involving Willie 5 Jessop and theft of Mr. Jessop’s property; the role of FLDS Church Security and its 6 7 8 9 10 11
coordination with with the CCMO and Defendants’ Defendants’ city officials; the CCMO enforcing enforcing FLDS Church edicts or directives; the CCMO’s protection of FLDS Church leaders; the FLDS membership status of Defendants’ employees; and interactions with Defendants’ city officials, and their their counsel, at R&W. In lieu of live testimony, the United United States States may present Mr. Jeffs’ deposition deposition testimony at trial. As such, the United States States designates the follow deposition testimony by page and line numbers: 19:22-19:24
31:4-31:7
61:5-73:19
20:8-20:10
31:13-31:20
73:25-74:15
21:5-21:6
32:10-33:16
74:21-91:6
21:10-21:20
35:3-45:1
92:6-94:24
22:5-22:16
45:21-47:15
95:3-101:6
23:3-23:10
48:14-52:22
101:19-101:23
17
23:13-23:15
53:7-58:7
18
29:1-29:5
58:11-60:23
12 13 14 15 16
19 20
29. Zachary Renstrom
Mr. Renstrom is an expert witness witness for the United States. States. He is a Washington
21 County Commissioner and a licensed professional engineer. engineer. He has expertise in 22 municipal water water systems. Prior to serving as a County Commissioner, Commissioner, he was the 23 President of Bush & Gudgell, Inc. Inc. His additional additional qualifications qualifications are attached. attached. Mr. 24 Renstrom evaluated the Colorado City/Hildale water system for the UEP Trust and as an
the expert 25 expert witness in Cooke. Mr. Renstrom is expected to testify consistent with the 26 opinions provided in his reports for the UEP Trust, Cooke, and the United States, his 27 depositions in this case and in Cooke, and his trial testimony in Cooke. In particular, his 28 testimony will include his expert opinions on: the water supply and distribution system
15
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Cit y/Hildale area; the availability of water for new culinary water 1 in the Colorado City/Hildale 2 connections; the incident that occurred with the water system in July 2007; the Cities’
investigate or develop additional sources sources of water; the additional sources of 3 failure to investigate 4 water reasonably available to the Cities; the effect on the water system of additional
Joh n Cook; Twin City 5 water connections to Ron and Jinjer Cooke, Patrick Barlow, and John 6 7 8 9 10 11 12 13 14 15 16 17
Improvement Association and other entity’s receipt of water; whether there were additional ways for the the Cities to conserve water water other than instituting a moratorium; moratorium; the Cities’ impact fee study; and the opinions of Defendants’ expert witnesses. 30. Ronald Cooke
Mr. Cooke is a fact witness. witness. He is a former member of the the FLDS Church and a resident of the Colorado City/Hildale City/Hildale community. community. He is expected to testify testify regarding claims and facts alleged in the United States’ Complaint in this case, as well as the matters discussed in his deposition and trial testimony in Cooke. His testimony will include: his experiences experiences growing up in the Colorado City/Hildale area; his departure from the FLDS Church; the treatment of non-FLDS members living in the community by Defendants’ city officials, FLDS Church Security, the CCMO, CCMO, and other community members; consequences of losing membership in the FLDS Church; his accident, disability and disability-related housing needs; his family’s application for and selection
18 of a property on UEP Trust land; his family’s efforts to obtain utilities for the that 19 property through Defendants; Defendants; denial of water and obstruction and delays regarding regarding other 20 utilities and municipal services, including a building permit, for that property by 21 Defendants; Defendants’ threats, intimidation and interference with the Cookes’ use and 22 enjoyment of the property for which they obtained a UEP Trust Occupancy Agreement; 23 treatment as a non-FLDS member residing on UEP Trust land; and the fair housing 24 complaint the Cookes filed with the Arizona Attorney General and the subsequent 25 lawsuit. 26 27
31. Jinjer Cooke
Ms. Cooke is a fact witness. witness. She is a resident of the Colorado Colorado City/Hildale
FLDS Church. She is expected to 28 community and has never been a member of the FLDS 16
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1 testify regarding claims and facts alleged in the United States’ Complaint in this case, as 2 well as the matters discussed in her deposition and trial testimony in Cooke. In
testimony will include: Ronald Cooke’s accident, disability, disability, and 3 particular, her testimony disability-related housing needs; her family’s f amily’s application for and selection of a property 4 disability-related 5 on UEP Trust land; her family’s efforts to obtain utilities for the that property through 6 7 8 9 10 11 12 13 14 15 16 17
Defendants; denial of water and obstruction and delays regarding other utilities and municipal services, including a building permit, for that property by Defendants; Defendants’ threats, intimidation and interference with the Cookes’ use and enjoyment of the property for which they obtained a UEP Trust Occupancy Agreement; treatment as a non-FLDS person residing on UEP Trust land; interactions with the CCMO involving the Stubbs’ farm; and the fair housing complaint the Cookes filed with the Arizona Attorney General and the subsequent lawsuit. 32. John Cook
Mr. Cook is a fact witness. witness. He is a former member of the Colorado City/Hildale City/Hildale community and has never been a member of the FLDS FLDS Church. He is expected to testify testify regarding claims and facts alleged in the United States’ Complaint in this case and the matters discussed in his deposition, as well as the matters discussed in his deposition and trial testimony in Cooke. In particular, his testimony testimony will include: his his efforts to procure
18 water services in Colorado City; the Defendants’ actions to prevent him fro m living in 19 the Twin Cities; and the emotional distress, embarrassment, and humiliation he suffered 20 as a result of the above-described conduct by Defendants. 21 22
33. Joseph Allred
Mr. Allred is a fact witness. witness. He is the Mayor of Colorado City. He is expected expected to
23 testify regarding his knowledge of claims and facts alleged in the Complaint, and 24 matters discussed in his depositions in this case and in Cooke and his trial testimony in
cities, 25 Cooke. In particular, his testimony will include: FLDS leaders’ control of the cities, 26 TCWW, Inc., TCWA, and the CCMO; treatment of non-FLDS members; his knowledge
eff orts to discriminate against 27 and experience with FLDS Church Security; Defendants’ efforts 28 Ron and Jinjer Cooke; membership in the United Order; Defendants’ use of an alleged
17
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1 water shortage as a pretext for discrimination; his marriage to an underage girl; and his
off icial, to embezzle money from TCWW, Inc. for the 2 efforts, while serving as a city official, FLDS Church. 3 benefit of the FLDS 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
34. Patrick Barlow
Mr. Barlow is a fact witness. Mr. Barlow is a former member member of the FLDS Church and a former member member of FLDS Church Security. Security. He is expected to testify testify regarding his knowledge of claims and facts alleged in the Complaint, and matters discussed in his deposition and trial testimony in Cooke. In particular, his testimony will include: tenets of the FLDS Church; directives from FLDS leaders; the consequences of losing membership in the FLDS Church and the United Order; his knowledge and experience with FLDS Church Security; the surveillance conducted by FLDS Church Security of non-FLDS members; coordination between the CCMO and FLDS Church Security, including by sharing surveillance equipment and information in law enforcement databases; harassment of non-FLDS members by b y FLDS Church Security; participation by Defendants’ Defendants’ city officials in FLDS Church Security; the water water connection provided to Espresso Creek; his failure to obtain a water connection from the Cities at his home on Arizona Avenue; and the emotional distress, embarrassment, and humiliation he suffered as a result of not receiving water to his home. 35. Claude Seth Cooke
Mr. Cooke is a fact witness. witness. He is Ronald Cooke’s brother, a general contractor,
20 a former member of the UEP Trust Housing Board, a former FLDS member, and a 21 successful party in Jeffs v. Stubbs. He is expected expected to testify regarding claims and facts 22 alleged in the United States’ Complaint in this case, as well as the matters discussed in 23 his deposition and trial testimony in Cooke. In particular, his testimony will include: his 24 departure from the FLDS Church; the treatment of non-FLDS members living in the
Defendants’ city officials, FLDS Church Security, Security, the CCMO, and other 25 community by Defendants’ 26 community members; consequences of losing membership in the FLDS Church; FLDS
fro m UEP Trust land and related litigation; the UEP 27 efforts to remove him and others from 28 Trust under Wisan’s administration; Defendants’ changed policies regarding building
18
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connections, and subdivision after Wisan’s Wisan’s appointment as UEP Trust Trust 1 permits, water connections, 2 Special Fiduciary, and the UEP Trust’s inability to complete unfinished homes on UEP 3 Trust land; Ronald Cooke’s disability and disability-related housing needs; the Cookes’ 4 application for and selection of a property on UEP Trust land; the Cookes’ applications 5 and efforts to obtain utilities and a building permit for the subject property through 6 7 8 9 10 11 12 13 14 15 16 17
Defendants, their agents, employees or officials; the CCMO’s enforcement of church law against him and others, including intimidation and interference with the Cookes’ use and enjoyment of the property for which they had obtained a UEP Trust Occupancy Agreement and his arrest by the CCMO; and his interactions with the CCMO and arrests at the Cottonwood Zoo in October 2015. 36. Taylor Nelson
Mr. Nelson is a fact witness. witness. He is a Sergeant with with the Mohave County Sheriff’s Sheriff’s Office (“MCSO”). (“MCSO”). He is expected to testify testify regarding claims and facts alleged in the United States’ States’ Complaint in this case and the matters discussed in his deposition. deposition. In particular, his testimony testimony will include: the the CCMO’s arrest of Patrick Patrick Pipkin and Andrew Chatwin, on two occasions in October 2015, for allegedly trespassing on commercial property that Mr. Pipkin Pipkin and Mr. Chatwin had had permission to access; the CCMO’s CCMO’s refusal to cooperate with outside law enforcement; CCMO Chief Jerry Darger’s assault on Mr.
18 Pipkin; the CCMO’s handling of an incident involving Sabrina Tetzner, including that 19 CCMO officers stood by and provided insufficient insuff icient police services regarding the 20 enforcement of Ms. Tetzner’s child custody orders. 21 22
37. Patrick Pipkin
Mr. Pipkin is a fact witness. witness. He is expected to testify testify regarding claims and facts facts
United States’ Complaint Complaint in this case. He is a non-FLDS member member whose 23 alleged in the United 24 testimony will include: the CCMO’s arrest of him and Andrew Chatwin, on two 25 occasions, for allegedly trespassing on commercial property that he and Mr. Chatwin 26 had permission to access; the CCMO’s refusal to cooperate with outside law 27 enforcement; and CCMO Chief Jerry Darger’s assault on him. 28
19
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1 2
38. Andrew Chatwin
Mr. Chatwin is a fact fact witness. He is a former FLDS member and has worked for
testify regarding claims and facts facts alleged in the United United 3 the UEP Trust. He is expected to testify 4 States’ Complaint in this case, as well as the matters discussed in his deposition
testimony will include: his knowledge knowledge of homes 5 testimony in Cooke. In particular, his testimony 6 7 8 9 10 11 12 13 14 15 16 17 18
and buildings on UEP Trust property that received water connections; treatment as a non-FLDS person residing on UEP Trust land; Defendants’ interference with non-FLDS individuals’ use and enjoyment of UEP Trust housing; and his interactions with the CCMO and the arrests of him and Patrick Pipkin at the Cottonwood Zoo. 39. Lorin Holm
Mr. Holm is is a fact witness. witness. He is a former former FLDS member. member. He is expected expected to testify regarding claims and facts alleged in the United States’ Complaint, as well as the matters discussed in his deposition. deposition. In particular, his testimony will will include: consequences of losing FLDS membership; CCMO’s reports to FLDS leaders; membership of CCMO officers and Defendants’ city officials in FLDS Church Security; CCMO officers becoming FLDS Church Security members after being decertified; and the CCMO’s traffic stop of him after FLDS Church Security was following him. 40. Ron Rohbock
Mr. Rohbock is a fact witness. witness. He is a former member member of the FLDS Church and a
19 former FLDS elder. elder. Mr. Rohbock is expected to testify testify regarding claims claims and facts 20 alleged in the Complaint, Complaint, as well as the matters matters discussed in his deposition. In 21 particular, his testimony testimony will include: tenets tenets of the FLDS religion; religion; how Warren Jeffs 22 became the leader leader of the FLDS Church; Church; instructions and directives directives from Warren Jeffs; 23 consequences of losing membership in the FLDS Church; the treatment of non-FLDS 24 members living in the community by Defendants’ city officials; the CCMO’s failure to 25 investigate underage marriages; the CCMO’s actions regarding enforcement of his UEP 26 Trust Occupancy Agreement and harassment at his home; and the emotional distress, 27 embarrassment, and humiliation he suffered as a result of the CCMO’s actions regarding 28 his home.
20
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1
41. Mark LoManto
Mr. LoManto is an expert expert witness. He is a CPA with with expertise in auditing,
2
tax issues. His expertise is in the area area of accounting services related related to 3 accounting, and tax and government contracts. His additional qualifications are attached. His 4 government and 5 testimony is relevant to the existence and, more particularly, the scope of a conspiracy 6 7 8 9 10 11 12
among City officials, FLDS leaders, and employees of TCWW to cede control over their operations to the FLDS FLDS Church and to divert funds improperly improperly to the FLDS Church. He is expected to testify regarding Colorado City Mayor Joseph Allred’s efforts to advance FLDS Church interests by improperly diverting TCWW funds to a series of activities unrelated to the business business operations of TCWW. He is also expected to testify testify that the value of the TCWW funds diverted to other than TCWW business operations totaled $1,729,987.29.
42. R. Brian Jessop
13 14 15
1
Mr. Jessop is a Hildale City City Council member. The United States States may present Mr. Jessop’s deposition testimony at at trial. As such, the United States States designates the follow deposition testimony by page and line numbers:
16
6:14-7:18
9:8-9:10
25:20-27:16
17 18 19 20 21 22 23 24 25 26 27
1
The United States recognizes that this Court previously issued an order regarding Mr. LoManto’s testimony. See Order, Hildale Defendants’ Motion in Limine; Proposed Testimony of LoManto LoManto at 2 (Mar. 17, 2015), ECF No. No. 606. However, “[i]t is well well settled law that rulings on on motions in limine are provisional. provisional. Such ‘rulings are not binding on on the trial judge [who] may always change his mind during the course of a trial.” BNS Ry. Co. v. Quad City Testing Laboratory, 7-CV-170, 2010 WL 4337827, at *1 (D. Mont. Oct. 26, 2010) (quoting Ohler v.United States, 529 U.S. 753, 758 n.3 (2000)). This Court’s earlier earlier order was based in part on the Court’s finding that the United States “has not demonstrated . . . any cconnection onnection between [the] alleged diversion of [TCWW] funds and” an alleged water shortage. Id . at 2. The United States States intends to prove that connection connection at trial. The United States further further intends to prove that Mayor Mayor Joseph Allred’s diverting funds was in furtherance of a conspiracy conspiracy with the FLDs FLDs Church. Proof of these facts will make Mr. LoManto’s testimony relevant.
28
21
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1
29:8-29:24
33:20-34:16
38:6-40:2
2
41:14-44:17
47:5-49:2
49:12-50:18
3
54:19-57:3
60:1-62:8
64:3-65:12
4
70:14-70:19
76:19-88:23
88:24-89:20
5
90:6-92:4
92:5-94:9
94:10-94:23
96:5-97:22
99:15-101:2
103:20-104:22
6 7 8 9 10 11 12 13 14 15 16 17
111:5-112:22 43. Jack Harris
Mr. Harris is a rebuttal rebuttal expert witness for the United United States. He is the former Chief of the Phoenix Police Department, the former Public Safety Manager for the City of Phoenix, and is an expert in police policies, practices, procedures, and administration. His additional qualifications qualifications are attached. attached. He is expected to testify testify consistent with the expert opinions provided in his report and in his deposition in this this case. He reviewed the expert report and opinions offered by the Defendants’ police-procedures expert, Greg Meyer, and is prepared prepared to rebut those opinions. He is prepared to testify, testify, among other things, that Greg Meyer: did not address appropriately all the police misconduct issues involved in this case; did not address the extent to which CCMO policies and training failed to address recurring policing issues associated with UEP Trust property; did not
18 consider adequately that the CCMO waited until 2007 to include non-discrimination 19 language in its policy manual; did not consider adequately the extent to which CCMO 20 officers omitted data from their reports; did not consider the extent to which CCMO 21 officers engaged in, ignored, ignored, or failed adequately to investigate illegal acts; did not 22 adequately consider evidence that the CCMO was taking direction from FLDS leaders or 23 sharing law enforcement resources with the FLDS Church; did not consider evidence 24 that the CCMO fails to cooperate with outside law enforcement; and did not adequately 25 consider the CCMO’s seizure of property without due process. 26 27
44. Kenneth Spiers
Mr. Spiers is a rebuttal rebuttal expert witness for the United United States. He is the Vice
28 President of Bowen Collins & Associates, Inc., and he is a licensed professional
22
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municipal water water systems. His additional additional qualifications qualifications are 1 engineer. He has expertise in municipal Southwest, LLC on 2 attached. Mr. Spiers evaluated the report produced by Agua Southwest, behalf. He is expected to testify testify consistent with the expert expert opinions 3 Defendants’ behalf. his deposition in this case. His testimony will include include that: 4 provided in his report and his 5 the Cities failed to act reasonably when they limited new water connections; the Cities 6 7 8
failed to timely improve and update their water system; and it is not sensible or economically feasible for the UEP Trust to construct, operate, and maintain a separate parallel water water system.
9 10 11 12
The United States will also call records custodians, as necessary, to admit documents produced during discovery, including custodians from the Mohave County Sheriff’s Office, the Washington County Sheriff’s Office, South Central Communications, American West Bank, and the State Bank of Southern Utah.
13 14
Respectfully submitted this 2nd day 2nd day of November, 2015,
15
R. TAMAR HAGLER CHRISTY E. LOPEZ Deputy Chiefs
16 17 18
ERIC W. TREENE Special Counsel
19
/s/ Jessica Clarke SEAN R. KEVENEY JESSICA CLARKE MATTHEW J. DONNELLY EMILY M. SAVNER SHARON I. BRETT United States Department of Justice Civil Rights Division 950 Pennsylvania Avenue, NW Washington, DC 20530 Phone: (202) 305-4013 Facsimile: (202) 514-1116 E-mail:
[email protected]
20 21 22 23 24 25 26 27 28
23
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1 2 3 4 5 6
CERTIFICATE OF SERVICE
I certify that on November 2, 2015, I caused a copy of the foregoing to be sent by the Court’s ECF system to the following: f ollowing: Jeffrey C. Matura Asha Sebastian Melissa Jane England Graif Barrett & Matura, P.C. 1850 North Central Avenue, Suite 500 Phoenix, Arizona 85004 Attorneys for Defendant Town of Colorado Colorado City
7 8 9 10
R. Blake Hamilton Ashley M. Gregson 111 East Broadway, Suite 900 Salt Lake City, Utah 84111 Attorneys for Defendants City of Hildale Hildale and Twin City Water Water Authority
11
/s/ Jessica Clarke Clarke JESSICA CLARKE Attorney for the United States
12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
24
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RESUME AND AMPLIFICATION
OF
JOSEPH A. DeLOPEZ
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ASSIGNMENT BACKGROUND
MARCH 2013
Vice Chancellor, Safety and Security, City Colleges of Chicago
25 MARCH 2002-
Chief of Police, Village of Winnetka
31 JANUARY 2011-
JANUARY 2011 1 FEBRUARY 2000-
Deputy Superintendent, Chicago Police Department
16 FEBRUARY 2002 30 JULY 1998-
Deputy Chief, Patrol Administration
31 JANUARY 2000 26 MAY 1995-
rd
Commander, 23 District
29 JULY 1998 13 JULY 1992-
Commander, Training Division
25 MAY 1995 20 MAY 1989-
th
Commander, 10 District
12 JULY 1992 26 JANUARY 1988-
Deputy Chief, Patrol Division, Area 4
19 MAY 1989 12 JULY 1985-
th
Commander, 14 District
25 JANUARY 1988 16 AUGUST 1984-
Youth Division, Commanding Officer, Area 5 Youth
11 JULY 1985 12 JULY 1984-
th
20 District, Acting Watch Commander
15 AUGUST 1984 16 MAY 1984-
th
13 District, Acting Watch Commander & Field Lieutenant
11 JULY 1984
3 MAY 198415 MAY 1984
Promoted to the rank of Lieutenant, attended Pre-service Lieutenant’s Training School
Case 3:12-cv-08123-HRH Document 758-2 Filed 11/02/15 Page 3 of 19
2 MAY 1984
Youth Division, Watch Commander and Field Supervisor, Area 4 Youth Section
2 APRIL 1981-
18 District, Patrol Supervisor
28 MAY 1981-
th
27 MAY 1981 26 JUNE 198019801 APRIL 1981
Traffic Division, Watch Commander, Public Vehicle and Major Accident Investigations Section
16 JUNE 1980-
Training Division Awaiting permanent assignment
26 JUNE 1980 13 SEPT 1979-
Northwestern University Traffic Institute, Institute, 9 month Police
Traffic 14 JUNE 1980
Administration Training Program
OCTOBER 1978-
Detailed to Training Division. Assisted in the coordination of Cardiovascular Health Program for Police Department
13 SEPT 1979
th
13 District, District Supervisor
JUNE 1977OCTOBER 1978
Promoted to rank of Sergeant, attended Pre-service Sergeant’s School
MAY 1977 JUNE 1977 OCTOBER 1973-
Special Operations Group, Tactical Section North
MAY 1977 NOVEMBER 1971-
th
14 District, Patrol Officer
OCTOBER 1973
Basic Recruit Training
14 JUNE 1971 NOVEMBER 1971 14 JUNE 1971
Appointment Date to Chicago Police Department
(For Additional Information See Amplified Resume)
Case 3:12-cv-08123-HRH Document 758-2 Filed 11/02/15 Page 4 of 19
EDUCATION
1988 - 1992
Lew Lewi s Un Uni ver si t y, Cr i mi nal / Soc i al Mast er ’ s Deg Degrr ee Pr ogr ogr am Degr ee: M. S. Cr i mi nal J ust i ce
June 1991 -
Pol i ce Execu xecutt i ve Resea sear ch For For um Seni or Management I nst i t ut e f or Pol Pol i ce
July 1991
J us t i c e
Degr ee: Cer t i f i cat cat e, Execut cut i ve St r at egi egi es Manag anagem ement ent
1979 - 1980
1965 - 1969
1961 - 1965
Other Training and Certification:
Nor t hwest er n Uni ver si t y Tr af f i c I nst i t ut e Degr ee: Cer t i f i c at e, Tr af f i c Pol i c e Admi ni st r at i on Tr ai ni ng Pr ogr am Act i vi t i es: Cl ass Soci al Co- Chai r man Uni ver s i t y of of I l l i noi s at at Ch Chi c ago Ci r c l e Degr egr ee: ee: B. S. i n Manag anagem ement ent Honor s: Dean' s Li st Act i vi t i es: Uni ver ver si t y swi mmi ng and and wat er Pol o t eams, i nt r amur al wr est l i ng DePaul Academy Gr aduat ed f r om Pr e- Engi neer i ng Col l ege Pr ep Pr ogr am i n upper 5% of cl ass
Numer ous Chi Chi cago Pol Pol i ce Depar epar t ment Pr of es s i onal Cer t i f i c at at e Ex Ext ens i on Cour our ses Bl ood Pr essur e Techn chni ci an Tr ai ni ng and Cer t i f i cat cat e, Chi cag cago Hear t Assoc. ssoc. Car di opul monar y Resu susci sci t at i on I ns t r uc t or o r Tr ai ni ng an and Cer t i f i c at at e Pol i ce I nst r uct or Tr ai ni ng Co Cour se Cer t i f i c at e I l l i noi s St St at e Po Pol i ce Acad cademy, Di mens ens i onal onal Manag anagem ement ent Tr ai ni ng
and and
Case 3:12-cv-08123-HRH Document 758-2 Filed 11/02/15 Page 5 of 19
Law Law Enf or cem cement Of f i cer cer s Tr ai ni ng Schoo chooll - Medi a Rel at i ons ons Cou Courr se One Mi nut e Manager s Semi nar Pr omot i onal Assessor Tr ai ni ng Chi cago cago Pol Pol i ce Dep Depar ar t ment ent Cook Coun Countt y Depa Deparr t ment of Per s onne onnell I l l i noi s St St at a t e Pol i c e Met r o Dad Dade e Pol i ce Dep Depar ar t ment ent I nt er nat i onal As s oc oc i at i on of of Chi ef s of of Pol i c e
Case 3:12-cv-08123-HRH Document 758-2 Filed 11/02/15 Page 6 of 19
PERSONAL
Born:
19 May 1947,
Physical:
Hei ght :
Health:
Excel cel l ent
Marital
Status:
Residence: Hobbies: Additional Work Experience:
Chi cag cago,
5/ 10" , Wei ght
Mar r i ed, ed,
I l l i noi s 165
14 J une 1969 ( 5 Chi l dr en)
Own Hom Home Racqu cquet bal l ,
swi mmi ng,
r unni ng
Adj unct Pr of essor ssor of Cr i mi nal J ust i c e, Uni ver s i t y of I l l i noi s at Chi cago, cago, - 1994 I l l i noi s Po Pol i c e As s oc oc i at i on
Affiliations: Present and Past
I l l i noi s As so soc i at i on of of Chi ef s of of Pol i c e I nt er nat i onal Associ ssoci at i on of of Chi ef s of of Pol i c e Uni ver s i t y of of I l l i noi s Al umni As s oc oc i at i on Seni or Management I nst i t ut e f or Pol i ce Al umni Associ at i on Lat Lat i n Amer i can can Po Pol i ce Associ ssoci at i on St .
J ude Pol i ce Lea League
Nor t hwest er n Uni ver si t y Tr af f i c I nst i t ut e Al umni Associ ssoci at i on Hi spa spani c I nst i t ut e of of Law Law Enf or cem cement Hi span spani c Am Amer i can Pol Pol i ce Command and Of f i cer ' s Associ ssoci at i on For mer Adv Advii sor y Boar oar d Member , Gener al Woods Boys Cl Cl ub Civic:
Past Past Pr ogr ogr amC amChai hai r man I mmacul acul at e Con Concep ceptt i on Par ent ' s Cl Cl ub
Case 3:12-cv-08123-HRH Document 758-2 Filed 11/02/15 Page 7 of 19
Awards:
Chi cago cago Cr Cr i me Commi ssi on Pu Publ i c Ser Ser vi ce Awar e Chi cag cago Pa Par k Di st r i ct
Recog cogni t i on Aw Awar d
Cer t i f i cat cat e of of Ap Appr eci at i on, Li ons Boa oarr d of
Log Logan Squar e
Educat i on Awar d of Ap Appr eci at i on
Amer i can G. I . For umA um Award
Li t t l e Vi l l age age Ch Chamber of Commer ce Out st andi andi ng Per f or mance ance Awar d Pi l sen Nei ghbor s Communi t y Co Counci l Ser vi ce Lead Leader er shi p Aw Awar d
Publ i c
12t h War d Publ Publ i c Ser Ser vi ce Awar d U. S. Post al Ser vi ce Awar d of of Appr eci at i on Concer cer ned Awar d
Ci Ci t i zens zens Of L i t t l e Vi l l age Ser vi vi ce
La Mexi exi cana cana Rad Radii o Ci Ci t i zen of t he Wee eek k zen of La Tribuna de Chicago Newspaper Ci t i zen t he Week Chi cago cago Pol Pol i ce Depar t ment Yo You ut h Di vi si on Rol e Model odel Recogni ecogni t i on Awar d 2 Chi cago cago Pol Pol i ce Depar t ment Uni t Mer i t or i ous Awar ds 2 Chi cago Pol i ce Depar epar t ment ent Commendat endat i ons ons Chi cago cago Pol Pol i ce Depar epar t ment ent Fi t ness Aw Awar d Chi cago Pol i ce Dep Depar ar t ment ent Appea ppearr ance ance Aw Awar d Numer ous ous Chi Chi cago Pol i ce Depar epar t ment ent Honor onor abl abl e Ment ent i on Aw Awar ds
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AMPLIFIED RESUME
Case 3:12-cv-08123-HRH Document 758-2 Filed 11/02/15 Page 9 of 19
AMPLIFIED
RESUME
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
31 January 2011-March 2013 Vice Chancellor, Safety and Security City Colleges of Chicago
Hi r ed by Ci Ci t y Co Col l eges of Chi cag cago t o coo coor di nat e t he cen cent r al i zat zat i on and r e- or gani zat zat i on of t he Of f i ce of Saf et y an and Secur cur i t y. The Ci t y Col l eges of of Chi cag cago sy syst st em i s com compr i sed sed of ei ght pr i mar y l ocat cat i ons an and si x sat sat el l i t e l ocat cat i ons ser ser vi ng a st udent ent popu opul at i on of app appr oxi oxi mat el y 120, 000 and and a f acul acul t y an and st af f popul at i on of appr oxi mat el y 6000. The Of f i ce of Saf et y and Secur cur i t y pr pr ovi des al al l of t he publ i c saf saf et y ne needs of of t he Ci t y Col Col l ege syst em t hr oug ough t he empl oym oyment ent of a combi nat i on of 500 of f - dut y an and r et i r ed member s of t he Ch Chi cag cago Pol Pol i ce Depar t ment , t he I l l i noi s St at e Pol Pol i ce Depar t ment and t he Cook ook Coun ount y Sher i f f ’ s Depar t ment . The The annual ope oper at i ng budget f or t he Of f i ce of Saf et y and Secur cur i t y i s $1 $11. 5 Mi l l i on.
25 March 2002 – January 2011 Chief of Police, Village of Winnetka
AS Chi ef of Pol i ce f or t he Vi l l age of Wi nnet ka, ka, ser ser ved a communi t y of 12, 500 r esi dent s. The The Vi l l age of Wi nnet ka i s l ocat ocat ed 14 mi l es f r om downt own Ch Chi cago cago al al ong ong t he shor shor es of Lake Lake Mi chi gan. gan. The The Wi nnet nnet ka Pol i ce Depar epar t ment ent had had a compl ement ent of 36 per sonn sonnel and a t ot al budget of $6. 3 Mi l l i on. The Depar epar t ment ent was nat nat i onal onal l y accr accr edi edi t ed by t he Commi ss i on on Accr edi edi t at i on f or Law Enf or cement ent Agenci enci es ( CALEA LEA) . Dur i ng my t enur e as Ch Chi ef i n Wi nnet ka, ka, I r e- or gani zed zed t he Pol i ce Depar epar t ment ent , enh enhanced t r ai ni ng of per sonn sonnel t hr oug ough a col l abor at i ve ef f or t wi t h Oakt on Communi t y Col Col l ege an and t he Nor t heast er n I l l i noi s Pu Publ i c Sa Saf et y Tr Tr ai ni ng Acad cademy ( NI PSTA) , wher e I ser ser ved i n t he r ol es of Pr esi dent , Vi cece- Pr esi dent and as an Of f i cer cer of t he NI PSTA Fou Foundat i on.
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AMPLIFIED
RESUME
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
1 February 2000 - 16 February 2002 Bureau of Technical Services Assigned as Deputy Superintendent, Superintendent, Bureau of Technical Services. This position coordinates one of the five Bureaus that comprise the Police Department. The Bureau consists of the Communications Division, the Electronics and Motor Maintenance Division, Evidence and Recovered Property Section, and the General Support Division. Duties included coordinating police communications issues and needs with w ith the Chicago Office of Emergency Communications, Communications , which includes the Alternate Response Res ponse Program. Respondent was also responsible for overseeing the maintenance and replacement of the Department's vehicle v ehicle and Marine Unit fleets, and establishing and implementing policy for management of the Central Detention Section, Evidence and Recovered Property Section, Equipment and Supply Section and the Reproduction and Graphic Arts Section. Respondent also als o coordinated the Chicago Police Department's Capital Development and Improvement Programs, overseeing construction of and repairs to Department facilities. Responsibilities also required overseeing a personnel and non-personnel budget of over 60 Million dollars.
30 July 1998 - 31 January 2000 Patrol Division Administration
Assi gned as as Deput y Chi ef of Pat Pat r ol Admi ni st r at i on. Respo sponsi bi l i t i es i ncl uded t he coo coor di nat i on of al l admi ni st r at i ve f unct i ons f or t hi s 10, 000 member Di vi si on. Thi s posi t i on ent ai l ed ser vi ng as a member of t he Depar t ment ' s l abor con cont r act negot i at i on t eam, member of Chi cago' s Communi uni t y Pol i ci ng Managem anagement Team, member ber of t he I nf or mat i on Syst ems Devel opment Gr oup oup, and and num numer ous ous ot her depar depar t ment ent al and and i nt er gover over nment ent al pl ann anni ng an and over over si ght gr oup oups.
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AMPLIFIED RESUME
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
26 May 1995 - 29 July 1998 23rd District:
Assi gned t o t he 23r d Di st r i ct , Town Hal l , as t he Di st r i ct Commander . Resp spo onsi bi l i t i es i ncl uded ove over seei seei ng t he i mpl ement at i on of an i nnovat i ve comu comun ni t y pol i ci ng i ni t i at i ve, known as Ch Chi cag cago' s Al t er nat i ve Pol i c i ng St r at egy ( C. A. P. S. ) . I n addi t i on, di r ect i on and l eader shi shi p of appr oxi oxi mat el y 300 300 swor n and and ci vi l i an per sonn sonnel , adh adher ence ence t o and and i mpl ement ent at i on of l abor abor cont cont r act pr ovi si ons, and al l ocat cat i on of of r esou sour ces ces t o ensur sur e t hat cri me con condi t i ons an and qual i t y of of l i f e i ssue ssues wer e addr essed wer e pr i mar y r espo sponsi bi l i t i es. Thr ough ough use of j oi nt communi uni t y- pol i ce pr obl obl em sol vi ng meet i ngs, pr obl ems wer e i dent i f i ed an and pr i or i t i zed zed and st r at egi es pl anned. Addr essi ng and sol sol vi ng pr obl ems i ncl uded l i ai son son wi t h ot her ci t y agen agenci ci es, cham chamber ber s of commer ce, chur chur ches ches and communi t y gr oup oups as wel l as i ndi vi dual communi t y member ber s .
13 July 1992 - 25 May 1995 Training Division:
Ass i gned as as Com Command ander of Tr ai ni ng Di Di vi si on. on. Respo sponsi bi l i t i es i ncl uded managi ng an and di r ect i ng t he i mpl ement ent at i on and and per per f or mance ance of t he pr ogr ogr ams of t he Chi cag cago Po Pol i ce Depar t ment ' s Tr ai ni ng Di vi si on. The Commander ander al s o r epr esent s t he Super Super i nt endent endent of Pol i ce when si t t i ng on on t he I l l i noi s Law Law Enf or cem cement Tr ai ni ng and St andar andar ds Boar d l ocat ed i n Spr Spr i ngf ngf i el d, I l l i noi s . Dut i es al s o ent ai l ed s er er vi ng as Sec r et et ar y of t he Chi cago cago Pol Pol i ce Depar t ment ' s Acad Academ emi c Sel ect i on Boar d.
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AMPLIFIED RESUME
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
The under under s i gned gned conf er r ed wi t h managem anagement and sup su per vi sor y per sonn sonnel t o det er mi ne t r ai ni ng ne needs; i mpl ement ent ed and and moni oni t or ed new new t r ai ni ng pr ogr ogr ams ; manag anaged ed and and di r ect ed r esear esear ch i nt o new t r ai ni ng met hods hods and and t echni echni ques; ques; super super vi sed t he devel devel opm opment ent of t r ai ni ng po pol i ci es and pr oced cedur es and and moni t or ed t hei hei r i mpl ement ent at i on; on; over over saw and and i mpl ement ent ed ass as s ess es s ment of any t r ai ni ng or or educat cat i onal needs and and subsequent pr ogr ogr ams. As Co Commander of t he Tr ai ni ng Di Di vi si on, t he sel sel ect i on, t r ai ni ng an and su sup per vi si on of of a st af f of appr oxi mat el y 120 per sons, sons, and t he pr epar at i on and con cont r ol of t he Tr ai ni ng Di vi s i on budget budget was a pr i mar y r esponsi bi l i t y.
20 May 1989 - 12 July 1992 10th District:
Assi gned t o t he l Ot h Di st r i ct , Mar quet t e, as t he Di st r i ct Commander . Resp spo onsi bi l i t i es i ncl uded ensu surr i ng t he pr ovi si on of of qual i t y pol i ce ser ser vi ces ces t o t he communi t y i n conf conf or mance ance wi t h t he pol i ci es and and pr oced ocedur es of of t he Chi cago cago Pol Pol i ce Depar epar t ment ent . The The r epor t i ng sub subj ect was r esp spo onsi bl e f or t he gui dance ance and di r ect i on of over 300 swor n and ci vi l i an per son sonnel i n an ef f or t t o maxi mi ze t he ef f i ci ency an and ef f ect i veness of del i ver y of po pol i ce ser ser vi ces ces t o a mul t i - r aci al and mul t i - et hni c po popul at i on of appr oxi mat el y 14 140, 000 per sons. sons. The under under s i gned gned ut i l i z ed Mi s s i on- Or i ent ed Di r ect ed Pat r ol , Sel ect i ve Enf or cem cement Techn chni ques, and St r at egi c Foo Foot Pat r ol i n or der t o deal wi t h cr cr i me con condi t i ons and and i mpr ove t he qual i t y of of l i f e f or communi t y r esi dent ent s. Gui dance ance and and t r ai ni ng of subor subor di nat es by Wat ch Command ander s, Fi el d Li eut eut enan enantt s, and and Sect Sect or Ser Ser gean eant s was assu assurr ed, as wel l as ef f ect i ve t r ai ni ng an and eval uat i on of Pr obat i onar y P Po ol i ce Of f i cer cer s by by P Pa at r ol Spec i al i s t s .
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AMPLIFIED RESUME
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
The The r epor epor t i ng s ubj ubj ect est abl abl i shed a l i ai s on wi t h ot her her ci t y age agen nci es, Chamber ber s of Commer ce, Chur hur ches, ches, and and Communi t y Gr Gr oups i n an ef f or t t o mi ni mi ze or el i mi nat e t he adver ver se i mpact of t he mul t i t ude of of soci soci al , econ economi c, and and cr i me pr obl obl ems af af f ect i ng t he Lawndal e, Li t t l e Vi l l age, and t he Pi l se sen n Communi t i es w wh hi ch com compr i se t he Mar quet t e Di Di st r i ct .
Dur i ng t he t i me ass ass i gned as Di st r i ct Command ander , t he under si gned ned r ecei ecei ved ved ove overr 50 l et t er s of Commenda endatt i on, on, 8 Awar ds of Ap Appr eci at i on, on, and and The The Pi Pi l sen Nei ghbor s Communi t y Cou Coun nci l Pu Pub bl i c Ser Ser vi ce Lead Leader shi p Awar d.
26 January 1988 – 19 May 1989 Patrol Division:
Assi gned as Deput y Chi ef of Pat r ol , Ar ea 4. 4. Ar ea 4 was com compr i sed of t he l Ot h, 11t h, 12t h, and and 13 13t h Di st r i ct s and and cov cover ed ap appr oxi mat el y one one- si xt h of of t he geogr aphi c ar ea of t he Ci t y of Chi cag cago. Resp spo onsi bi l i t i es i ncl uded over see seei ng t he act i vi t i es of of f our Di st r i ct Commander s t o ensu surr e t he ef f ect i ve an and ef f i c i ent del i ver y of of pol i c e s er er vi c es es t o t he communi t y. The wr i t er was r espon sponsi bl e f or t he gui dance ance and and di r ect i on of app appr oxi oxi mat el y 1, 400 per sonn sonnel , and and i mpl ement ent ed i nnovat ovat i ve app appr oache oaches s to deal wi t h cr cr i me and qual i t y of of l i f e i ssu ssue es.
12 July 1985 - 26 January 1988 14th District:
Assi gned t o t he 14 14t h Di st r i ct , Shakesp kespe ear e, as t he Di st r i ct Commander . Resp spo onsi bi l i t i es i ncl uded ensu surr i ng t he pr ovi si on of of qual i t y po pol i ce ser ser vi ces ces t o t he communi t y i n conf conf or mance ance wi t h t he pol i ci es and pr oced ocedur es of t he Chi cago cago Pol Pol i ce Depar t ment . The The r epor t i ng sub subj ect was r esp spo onsi bl e f or t he gui dance and di r ect i on of of 266 swor n pol i ce pe per sonn sonnel and t wo ci vi l i an em empl oyees i n an ef f or t t o maxi mi ze t he ef f i ci ency and ef f ect i veness of del i ver y of pol i ce ser ser vi ces ces t o a mul t i - r aci al and mul t i - et hni c popul at i on
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AMPLIFIED RESUME
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
of app appr oxi oxi mat el y 15 155, 000 per sons. sons. The The under si gned assur ed t he i mpl ement at i on of of mi ssi on- or i ent ed di r ect ed pat r ol , Super vi sor sor y gu gui dance and r espon sponsi bi l i t y f or subor subor di nat es by Wat ch Com Command ander s, and Se Sect or Ser geant ant s, and and a Fi el d Li eut enant s , and con cont i nuous an anal ysi s of t he ef f ect i veness of t he enf or cem cement ef f or t s The r epor epor t i ng s ubj ubj ect al s o wor ked cl ose os e wi t h ot her Ci t y Agency he heads ads as wel l as l eade ader s of communi t y- based ased or gani ani zat i ons ons and and ser ser vi ce age agenci es t o see seek sol sol ut i ons t o, or pr pr event , t he many s oci al , econ economi c, and and cr i me pr obl obl ems af f ect i ng t he Shakespe akespear ar e Communi t y. Dur i ng t he t enu enur e as Di st r i ct Command ander of t he 14 14t h Di st r i ct , t he under si gned r ecei cei ved over 60 l et t er s of of commendat i on, on, f i ve awar ds of app appr eci at i on, on, and and t he Chi cago cago Cr Cr i me Com Commi ss i on Pub Publ i c Ser Ser vi ce Awar d.
16 August 1984 - 12 July 1985 Youth Division:
Assi gned t o t he Yout h Di vi si on, Ar ea 5 Yout h Se Sect i on, as t he Command andi ng Of f i cer cer . Dut i es con consi st ed of deci si on maki aki ng, gui dance ance,, and and i mpl ement at i on at t he Ar ea l evel vel of pol i ci es and pr oced cedur es adopt ed by t he Chi cago Pol Pol i ce Dep Depar ar t ment ent and and t he Commande anderr of t he Yout h Di vi s i on. The r epor epor t i ng s ubj ubj ect was r espon es pons s i bl e f or t he coo coor di nat i on of of t he ef f or t s of of sev seven Ser geant s, 40 Yout h Of f i cer cer s, and 11 11 Scho chool Pat r ol Of f i c er er s s o t hat t he gr eat es t pos s i bl e ut i l i z at at i on of of per sonn sonnel and and equ equi pment ent was di di r ect ed t owar d t he basi c pol i ce f unct i ons of of aggr essi ve and pr event i ve pa pat r ol and pr ompt and ef f i ci ent r esp spo onse t o cal cal l s f r om ot her uni t s f or yo yout h ser ser vi ces. ces. The r epor t i ng s ubj ubj ect al s o par t i ci pat ed act i vel y and posi t i vel vel y wi t h com communi t y gr gr oup oups and and agen agenci ci es i n pr ogr ogr ams desi gned f or t he pr even vent i on of of j uven veni l e del i nquency an and r el at ed yout h pr obl ems. To t hi s en end, t he r epor t i ng sub subj ect has has been been a member ber of t he Mayor ' s Task For ce on Yout Yout h Cr Cr i me
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AMPLIFIED RESUME
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
t hr ough ough t he Ar ea 9 Yo You ut h Advi sor y Coun ounci l , a member ber of t he Bo Boar d of of Educat i on Di st r i ct 4 Gang Co Commi t t ee ee,, a member of t he Mayor ayor ' s Po Poll i ce Com Communi uni t y Rel at i ons ons Commi t t ee f or t he Fou Four t eent h Di Di st r i ct , and r egul ar l y met wi t h t he Boa oarr d of Ed Educat i on Sup Super i nt end endent ent s and and Pr i nci pal s a an nd wi t h r epr ese esen nt at i ves ves of com communi t y base ased d you yout h ag agenci enci es.
Dur i ng t he t i me as as Com Commandi andi ng Of Of f i cer of Ar ea 5 Yout Yout h, t he under si gned r ecei cei ved ved n nu umer ous ous l et t er s of of commenda endatt i on, on, a Recogni ecogni t i on Awar d f r omt he Chi cago cago Par k Di st r i ct , a Ser vi ce Awar d f r omSch mScho ool Di st r i ct 4, and a Cer t i f i cat cat e of of Appr eci at i on f r omt he Nor t h Cent r al Manag anagem ement Ass oci at i on f or s er vi ng as an an Eval Eval uat uat i on TeamM TeamMember ber . 12 July 1984 - 16 August 20th District:
1984
Dut i es con consi st ed of deci si on maki ng an and coo coor di nat i on of ef f or t s of of a com compl ement of of f i cer cer s assi assi gned t o pat r ol and c l er i c al al f unc t i ons . 16 May 1984 - 12 July 1984 13th District:
Dut i es co consi st ed of f i el d su sup per vi si on and deci si on maki ng wi t h r egar d t o t he pat r ol f unct i ons of of si x Ser geant s and 30 Pol i ce Of f i cer cer s. Dur i ng t he t i me assi gned, r epor t i ng subj subj ect al so command anded on one- hal f of t he Spani ani sh Com Company any ass ass i gned t o secur secur i t y at at t he Humbol dt Par Par k Pu Puer t o Ri can Week eek Fest i val val .
3 May 1984 - 16 May 1984:
Pr e- ser ser vi ce Li eut enant ' s Tr Tr ai ni ng.
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AMPLIFIED RESUME
28
May 1981 - 3 Youth Division:
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
May
1984
Assi gned t o t he Yout h Di vi si on, Ar ea 4 Yout h Se Sect i on, i n t he capaci capaci t y of Wat ch Com Command ander and and Fi el d Super vi sor . Dut i es con consi st ed of de deci si on maki ng, sup super vi si on a an nd gui dance of Yout h Of f i cer cer s i nvol ved i n a br oad spe spect r um of j uveni l e r el at ed si t uat i ons. Ar ea of r espo sponsi bi l i t y was appr oxi mat el y on one- si xt h of t he Ci t y of Chi cag cago, encom compassi ng f our pol i ce di st r i ct s. The The r epor epor t i ng member ber was r esponsi esponsi bl e f or t he pr oper oper i nvest i gat i on, cl assi f i cat cat i on and coo coor di nat i on of mi ssi ng pe per so son ns, chi chi l d abuse se,, f ami l y r el at ed an and j uveni uveni l e r el at ed case cas e i nvest nvest i gat gat i ons. ons. Member ber wor ked di r ect l y wi t h t he Yo You ut h Ar ea Com Command ander t o assur e t hat uni t goal goal s wer e met and and t hat manp anpower was al l ocat ed ef f i c i ent l y an and ef f ec t i vel y. Addi t i onal onal l y, t he r epo epor t i ng subj subj ect was a member of t he Ci t y of of Chi cago cago Depa epar t ment of Pe Perr sonn sonnel Po Poll i ce Of f i cer Scr ee eeni ni ng and and Ass essment ent Te Team am.
Dut i es consi consi st ed of cond conduct i ng a on one- day Ass essment ent Cent er t o obser ve and eval val uat e ap appl i can cant s f or t he pos i t i on of Pol i c e Of f i c er er . Thi s r epor t i ng s ub ubj ec t has s er ved bot h as an As s ess ment TeamMember , and as Ass ess ment TeamLea TeamLead der . The The opp oppor t uni t y al al so ar ose t o ser ve on t he Ass essment ent cent cent er panel anel f or t he Coo Cook k Coun ount y Ci Ci vi l Ser vi ce Commi ss i on dur i ng May, ay, 1983.
2 April 1981 18th
1981 - 28 May District:
Tempor por ar y assi ass i gnm gnment ent . Dut i es consi s t ed of f i el d sup super vi si on of of uni f or med pa pat r ol of f i cer cer s and and deci si on maki ng as a f i r st - l i ne sup super vi sor . Repor t i ng member was rout rout i nel y ut i l i ze zed d i n t he cap capaci t y of of Act Act i ng Li eut enant .
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AMPLIFIED RESUME
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
26 June 1980 - 2 April 1981 Traffic Division:
Assi gned t o t he Traf f i c Di vi si on upon com compl et i on of ni ne mont h co cour se of st udy i n P o l i c e Admi ni st r at i on at at t he Nor t hwest er n Uni ver si t y Traf f i c I nst i t ut e. Dut i es i n t he Traf f i c Di vi si on i ncl uded assi gnment s as Wat ch Commander , f i r st i n t he Publ i c Vehi cl e Se Sect i on, and and t hen i n t he Maj or Acci Acci dent I nvest vest i gat i on Se Sect i on. Thi s member was exposed exposed t o var i ous aspect s of i nvest vest i gat i on, and coo coor di nat ed manpower ef f or t s i n or der t o achi chi eve desi r ed r esu sull t s i n a cost cost - ef f ect i ve manner anner . Member ber ass umed pr ogr ess i vel y mor e r es po pons i bi l i t y f or admi ni s t r at i ve ac ac t i vi t i es .
13 September 1979 - June 1980 Northwestern University Traffic Institute:
Assi gned t o Tr af f i c Po Pol i ce Admi ni st r at i on Tr Tr ai ni ng Pr ogr am at No Nor t hwest er n Un Uni ver si t y Tr Tr af f i c I nst i t ut e. Whi l e at t he I nst i t ut e, t he ni ne- mont h co cour se of st udy expo exposed sed subj subj ect t o adva advance nced d manag anager er i al t echni echni ques ques and and pr act i ces ces whi ch i ncl uded gr aduat e l evel vel cou cour se mat er i al .
October 1978 - September 1979 Training Division:
Whi l e det ai l ed t o t he Tr ai ni ng Di vi si on, t hi s member was assi assi gned t o pr ogr essi vel vel y i nt ense and r espo sponsi bl e f unct i ons i n t he ar ea of i n- ser ser vi ce t r ai ni ng. I ni t i al l y, r epor t i ng member was assi assi gned t he dut y of assi st i ng i n coo coor di nat i on of Car di ovascul scul ar Heal t h Pr ogr am. Subsequ sequent l y, t hi s sup super vi sor sor t ook on t he added r espo sponsi bi l i t y of of Car di opul monar y Re Resusci susci t at i on TeamSu Team Super per vi s or , Us e of For ce I nst r uct or , and ass i s t ed i n t he r evi si on of Ci vi l Di sor sor der Tr ai ni ng f or Sp Speci al Oper at i ons Gr Gr oup and Di st r i ct Tact i cal cal Uni t s.
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AMPLIFIED RESUME
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
Whi l e i nvol vol ved ved i n t r ai ni ng, member r ecei cei ved ved com commendat i ons ons f r om t he Chi cag cago Hear t Associ at i on f or con cont r i but i ons and ef f or t s at at r educt i on of hear t di se sea ase and r el at ed di sa sab bi l i t i es, and a Chi cag cago Pol i ce Depar t ment Commendat i on f or c ar di opul monar y r esusc suscii t at i on t r ai ai ni ng ef f or t s .
June 1977 - October 1978 13th District:
Upon com compl et i on of pr e- ser ser vi ce Se Ser geant ' s t r ai ni ng, member was assi gned t o t he 13t h Di st r i ct . Dut i es con consi st ed of of f i el d su sup per vi si on and deci si on maki ng. Upon demonst onst r at i on of abi l i t i es, member was r out out i nel y ut i l i zed zed i n t he cap capaci t y of of Acti Acti ng Fi Fi el d Li eut enant .
May 1977 - June 1977:
Pr e- ser ser vi ce Ser geant ' s Tr Tr ai ni ng.
October 1973 - May 1977 Special O peration pera tions s Gro up, Tactical Section North: Nort h:
Dut i es i nvol ved se sel ect i ve enf or cem cement of sp spe eci f i cal cal l y i dent i f i ed cr i me pr obl ems, som somet i mes r equi r i ng cove coverr t t echni echni ques. ques. Member ber was was r equi equi r ed t o dem demonst onst r at e abi l i t y t o assu ssum me r esp spo onsi bi l i t y and wor k wi t h mi ni mal amount ount of super super vi si on. on. Accumul at ed num numer ous ous Hon Honor or abl abl e Ment ent i on Awar ds and and ci t i zens zens l et t er s of commend endat i on, on, and ear ned t he Uni t Mer i t or i ous Ci t at i on.
November 1971 - October 1973 14th District:
Wor ked ked as pat r ol of f i cer cer , enf or ci ng l aws and or di nances, ces, pr ovi di ng nee needed publ i c saf saf et y and communi t y ser vi ces. Recei ecei ved ved sever sever al Hon Honor or abl abl e ment i on Awar ds f or ef ef f or t i n cr i me r educt i on, on, and was even vent ual l y assi gned t o at t end Chi cag cago Pol i ce Depar epar t ment ent Span Spanii sh Langua Language ge School School .
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AMPLIFIED RESUME
JOSE JOSEPH PH A. DeLO DeLOPE PEZ Z
June 1971 - November 1971 Basic Recruit Training:
Whi l e assi gned t o Recr ui t Tr ai ni ng, ear ned di di st i nct i on of of mai nt ai ni ng t he di st i nct i on of Cl ass Com Command ander t hr oug oughout out t he t r ai ni ng per i od.
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Case 3:12-cv-08123-HRH Document 758-4 Filed 11/02/15 Page 1 of 6 Appendix II Page 1 M A R K L O M A N T O - C U RR RR I C U L U M V I T A E
Mark F. LoManto
Telephone: Office (215) 579-8555
EMPLOYMENT HISTORY ML Weekes & Company, PC Principal
Jan. 2000 - Present
Ernst & Young LLP Government Contract Services/Sr. Mgr.
Sep.1994 - Jan. 2000
GE Aerospace Group (acquired by Martin Marietta in 1994) Astrospace Div./ Mgr, Program Finance
Sept. 1992 - Aug. 1994
Astrospace Div./ Mgr, Contract Practices
Jun. 1990 - Aug. 1992
Govt Electronics Systems Div./ Mgr, Govt Accounting
Jun. 1988 - May 1990
Harris/RF Communications Senior Analyst
Mar.1986 - May 1987
Defense Contract Audit Agency
Senior Auditor
Dec. 1981 – 1981 – Mar. Mar. 86
US Dept of Labor/Office of Inspector General
Auditor
Jul. 1979 – 1979 – Dec. Dec. 81
EDUCATION B.B.A., Accounting Niagara University
May 1979
Case 3:12-cv-08123-HRH Document 758-4 Filed 11/02/15 Page 2 of 6 Appendix II Page 2
PROFESSIONAL PROFESSIONAL CERTIFICATES & ASSOCIATIONS Professional Certifications & Licenses Certified Public Accountant licensed in the Commonwealth of Pennsylvania Professional Association Memberships American Institute of Certified Public Accountants (AICPA) Pennsylvania Institute of Certified Public Accountants (PICPA) American Bar Association (ABA) National Contract Management Association (NCMA)
Case 3:12-cv-08123-HRH Document 758-4 Filed 11/02/15 Page 3 of 6 Appendix II Page 3 MARK F. LOMANTO
Addendum EMPLOYMENT HISTORY ML Weekes & Company, PC I am presently a Principal (and co-founder) of the accounting firm of ML Weekes & Company, which is headquartered in Stamford, Stamford, Connecticut. The firm provides auditing, accounting, tax and advisory services to various clients who have contracts or grants with federal, state, state, and local government agencies. The firm’s client base spans various industries including Aerospace & Defense, Healthcare, and the Public Sector. My services include auditing, accounting and tax services predominately related to the government industry. My advisory services services include the development and review of indirect rates, analysis of billing, estimating, and project accounting systems, proposal preparation, interpretation of public laws and procurement regulations, and assistance in the resolution of disputes, including those requiring litigation.
Ernst & Young LLP My most recent position was a Senior Manager in Ernst & Young LLP's Government Contract Services practice. In this capacity I provided a variety of services to contractors doing business with the Government. While at Ernst & Young, I assisted clients on numerous federal contract matters, including the preparation, review and settlement of contract claims and equitable adjustments; cost or pricing data analysis; litigation support; and determining compliance with Government procurement regulations and Cost Accounting Standards (CAS). I have also supported clients in the development of indirect expense rates, as well as indirect cost submissions. I have served numerous clients, including those specializing in large vehicle and aircraft manufacturing, complex electronic systems, as well as pharmaceutical companies, healthcare insurers and not-for-profit organizations.
Case 3:12-cv-08123-HRH Document 758-4 Filed 11/02/15 Page 4 of 6 Appendix II Page 4 MARK F. LOMANTO
Addendum EMPLOYMENT HISTORY - continued
GE Aerospace Group (acquired by Martin Marietta in 1994) As Manager, Program Finance (government program finance lead) for GE Aerospace’s Astrospace Division in East Windsor, NJ (a large manufacturing facility producing satellites for the government), I maintained financial reporting responsibility for a number of major government projects which included customer reports such as Contract Funds Status Reports (CFSR), Cost Performance Reports (CPR), Cost/Schedule Control Systems Criteria (C/SCSC); as well as all internal financial reporting applicable to the projects. As the Manager, Contract Practices (government compliance lead) for GE Aerospace’s Astrospace Division in East Windsor, NJ (a large manufacturing facility producing satellites for the government), I was responsible for all divisional government compliance matters including: primary interface with DCAA an d DACO, final indirect rate preparation and certification, problem analysis and resolution, interpretation of public laws and procurement regulations, and ethics training. I also chaired the Division’s Government Compliance Committee, which was formed to ensure that all know and potential compliance issues were being addressed. As the Manager, Government Accounting for GE Aerospace’s Government Electronics System Division in Syracuse, NY (a large manufacturing facility producing radar and sonar systems for the government), I reported directly to the Manager, Contract Practices (government compliance lead) and assisted in many government compliance matters including: primary interface with DCAA and DACO, final indirect rate preparation and certification, problem analysis ana lysis and resolution, interpretation of public laws and procurement regulations, and ethics training. Harris/RF Communications As a senior financial analyst for Harris Corporation/RF Communications in Rochester, NY (a midsize manufacturing facility producing radio and communication equipment for the government), I was responsible for all Government compliance related issues, include the preparation and response to any audit issues related to the Company’s pricing proposals, proposals, indirect rate submissions submissions and other DCAA DCAA cost and systems systems reviews.
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MARK F. LOMANTO
Addendum EMPLOYMENT HISTORY - continued
Defense Contract Audit Agency
As a DCAA senior auditor at IBM’s Federal Systems Division Systems Division in Owego, NY (a large manufacturing facility producing electronics for the government), my oversight responsibilities included audits related to contract proposals, indirect rate submissions, cost estimating systems and various systems and control reviews.
US Dept of Labor/Office of Inspector General
As an IG auditor in the USDOL’s Chicago Regional Office, my oversight responsibilities primary focused on financial and compliance audits related to state and local government agencies and non-for-profit organization receiving funds under the Comprehensive Employment and Training Administration (CETA) program.
Case 3:12-cv-08123-HRH Document 758-4 Filed 11/02/15 Page 6 of 6 Appendix II Page 6 MARK F. LOMANTO
PRIOR EXPERT WITNESS TESTIMONY AND LITIGATION SUPPORT ENGAGEMENTS United States of America ex rel, Robinson, et al. v. Northrop Corporation, US District Court, Northern District of Illinois* Martin Dresser v. DRC and Albert Rand, US District Court, District of Massachusetts United States of America ex rel. Educational Educa tional Career Development Inc. v. Central Florida Regional Workforce Development Board, Inc. and Workforce Central Florida Inc., US District Court, Middle District of Florida US ex rel, Yannacopoulos v. General Dynamics and Lockheed Martin Corporation, US District Court, Northern District of Illinois Metro Machine Corp., GAO File No. B-297879 CACI Inc. v. Robert Donovan and Multimax Corporation, Arlington County (VA) Circuit Court* United States of America v. Robert P. Knowles, US District Court, District of Connecticut United States of America ex rel. Becker v. Tools & Metals, Inc., US District Court, Northern District of Texas United States of America v. Nicholas Baroni and Keith Baroni, US District Court, District of Maryland Richard J. Ford and FedSys, Inc. v. Jerry W. Torres and Torres Advanced Enterprise Solutions, LLC, US District Court, Eastern District of Virginia* United States of America v. Michael Walker, US District Court, District of Eastern Pennsylvania* United States of America ex rel . Melan Davis and Brad Davis v. Erik Prince, Blackwater Security Consulting, LLC, et al. US District Court for the Eastern District of Virginia
* Includes testimony.
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JACK HARRIS CURRICULUM VITAE
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Case 3:12-cv-08123-HRH Document 758-6 Filed 11/02/15 Page 1 of 2
K ENNETH L . SPIERS, P.E. VICE PRESIDENT B OWEN COLLINS & A SSOCIATES, INC. EDUCATION B.S., Civil Engineering, Brigham Young University, 1976
PROJECT EXPERIENCE Municipal Water Supply •
Arsenic Removal Study Study – Washington County Water Conservancy Conservancy District (St. (St. George, Utah) Utah)
•
General Services – Virgin Valley Water District (Mesquite, Nevada)
•
General Services – Moapa Valley Water District (Overton, Nevada)
•
Jordan Aqueduct Terminal Reservoir 33 MG Expansion – Central Utah Water Conservancy District (Utah)
•
Huntington Water Treatment Plant Upgrade – Energy West, Inc. (Utah)
•
7800 South Water Transmission Pipeline – City of West Jordan (Utah)
•
Butte and Deer Mountain Booster Pumping Stations – Jordanelle Special Service District (Utah)
•
Water Treatment Plant No. 3 Upgrade – Weber Basin W ater Conservancy District (Utah)
•
Water System Master Plan – City of Ogden (Utah)
•
10 MG Reservoir – Metropolitan Water District of Salt Lake City (Utah)
•
Water System Master Plan – Bona Vista Water Improvement District (Utah)
•
Water System Feasibility Studies – Jordanelle Special Service District (Utah)
•
Water System Master Plan – City of North Logan (Utah)
•
City Water Supply Pipeline – City of Preston (Idaho)
•
Water Rate Study – City of Logan (Utah)
•
Water System Improvement Project – City of Mendon (Utah)
•
Water System Improvements Project – City of Pleasant Grove (Utah)
Municipal Wastewater Collection and Treatment •
Jordan Basin Wastewater Reclamation Reclamation Facility – South Valley Sewer District
•
Timpanogos Water Reclamation Facility Facility 2009 Expansion – Timpanogos Special Service District District
•
South Jordan Pump Station and Force Main – South Valle y Sewer District
•
West Regional Interceptor Sewer and Pump Station – City of Logan
•
Pleasant Grove/Cedar Hills Interceptor Sewer – Timpanogos Special Service District
•
Midas Pond Road Interceptor Sewer – South Valley Sewer District
•
12300 South Interceptor Interceptor Sewer – South Valley Sewer District District
•
City-Wide Sewer System, Trunkline and Pump Station – City of Providence
Case 3:12-cv-08123-HRH Document 758-6 Filed 11/02/15 Page 2 of 2
•
City-Wide Sewer System and Trunkline – City of North Logan
•
City-Wide Sewer System and Treatment Facility – City of Franklin
•
2001 Sewer Project – City of Monticello
•
400 South Sewer Lift Station – City of Preston
•
Sewer Rate Study – South Valley Sewer District
Storm Drainage and and Flood Contr ol •
Storm Drain Master Plan, City of Hurricane
•
Great Salt Lake Diking Feasibility Study, Utah Division of Water Resources
•
Fiddlers Canyon Detention Basin, Cedar City Corporation
•
Dry Canyon Flood Control Project, Cedar City Corporation
•
Stephens Canyon Flood Control Project, Cedar City Corporation
•
1100 West Storm Drain Improvements, City of Woods Cross
•
Holmes Creek Detention Basin and Channel Improvements, City of Kaysville
Hydropower •
Betasso Hydroelectric Project, City of Boulder
•
Preston Hydroelectric Project, City of Preston
•
Ralston Hydroelectric Feasibility Study, City of Arvada
•
First Dam Hydroelectric Feasibility Study, City of Logan
Roads and and Bri dges •
400 East Street Improvements, City of North Loga n
•
Center Street Improvements, City of Providence
•
Rudd Creek Flood Restoration, City of Farmington
•
800 North/UPRR Bridge, City of Clearfield
Other Projects Projects •
Little Cottonwood Water Treatment Plant HVAC Rehabilitation, MWDSLS
•
Maintenance Building, MWDSLS
PROFESSIONAL REGISTRATION Professional Engineer - Utah
PROFESSIONAL ORGANIZATIONS American Water Works Association Water Environment Federation American Council of Engineering Engineering Companies