Colorado City Witness List

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 1 of 61
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R. BLAKE HAMILTON, Utah Bar No. 11395

ASHLEY M. GREGSON, Utah Bar No. 13716
DURHAM JONES & PINEGAR
111 East Broadway, Suite 900
Salt Lake City, Utah 84111
Telephone: (801) 415-3000
Facsimile: (801) 415-3500
bhamilton@djplaw.com
agregson@djplaw.com
Attorneys for Defendants City of Hildale, Utah and
Twin City Water Authority, Inc.
UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
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United States of America,
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Plaintiff,
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v.
Case No. CV-12-8123-PCT-HRH

DEFENDANTS JOINT AMENDED
FINAL TRIAL WITNESS LIST
Town of Colorado City, Arizona; City of

Hildale, Utah; Twin City Power; and Twin
City Water Authority, Inc.,
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Defendants.
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Pursuant to this Courts prior Order [Doc. 626], the Defendants provide the
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following amended final, revised trial witness list.1 The amendments were necessary to
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correct typographical errors in certain deposition designations (corrections in bold).
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1.
Philip Barlow
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Philip Barlow is a fact witness. Mr. Barlow is the current Mayor of Hildale City.
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He is expected to testify regarding allegations in the Complaint, including but not limited
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to testimony that the Defendants have a secular purpose, that they do not have the
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principal or primary effect of advancing or inhibiting religion, that they do not foster an
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excessive government entanglement with religion or endorse one religion over another,
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The Defendants intend to call these witnesses in the order listed. However, depending
upon the evidence the United States presents, the Defendants may adjust the order of these
witnesses, or may not call each witness listed.
and they do not coerce people to support or participate in religion, or exercise or otherwise
act in a way that establishes a state religion or tends to do so. He is also expected to
testify that Defendants do not treat people unequally compared to other similarly situated
individuals, they have not acted or failed to act with the intent or purpose to discriminate
based upon religion, and that religion is not a motivating factor for Defendants actions or
inaction. He is also expected to testify that Defendants have not engaged in a pattern or
practice of discrimination, they have not denied FHA rights to a group of persons,
including non-FLDS members, they have not attempted to make housing unavailable or
deny housing opportunities to any person, discriminated in the terms, conditions, or
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privileges in the sale or rental of a building or the provision of services or facilities in
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connection therewith, and they have not coerced, intimidated, threatened, or interfered
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with any person in the exercise or enjoyment of, or on account of that person exercising or
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encouraging others to exercise FHA rights, and that religion is not a motivating factor for
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Defendants.
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testimony, and will include, but not be limited to: background of the Towns, development
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of the Towns, Towns structure and organization, operations of the Towns, subdivision in
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Hildale City, evictions in Hildale City, building permit applications, his duties as Mayor,
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the duties of other Town employees, Hildale City Council operating procedures and
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meeting minutes, executive sessions, Hildale and Colorado City employees, Hildale City
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Ordinances and Resolutions, intergovernmental agreements, Twin City Improvement
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Association, Hildale City streets, Twin City Water Authority, utility policies, utilities
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applications and procedure, the Utility Board, water availability in the community, City
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recordkeeping, City finances and budget, the Citys interaction with outside agencies,
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communications with FLDS leaders regarding City business, applications for city council,
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the voting/election/nomination/appointment process in Hildale, his becoming mayor of
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Hildale, employment decisions regarding the CCMO, municipal grants, his awareness of
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FLDS directives, interaction between Town employees and the FLDS, FLDS Church
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Security, FLDS video surveillance, City video surveillance, City fiberoptic lines and
Specifically, his testimony is expected to conform to his deposition
computer servers, school setup crews, service of legal papers, CCMO training civilians,
interactions with Jethro Barlow and Willie Jessop.
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2.
Carvel Neilson
Carvel Nielsen serves as a member of the Hildale City Council. He is expected to
testify regarding his knowledge of the allegations in the Complaint, the structure, history
and/or functioning of the City government, along with any other related issues. Mr.
Nielsen was also present during Sabrina Broadbent Tetzners custody dispute. He is
expected to offer testimony consistent with his deposition and including, but not limited
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to, his involvement in, and interactions with CCMO and Mohave County officers during
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that incident, and his duties and involvement on the Hildale City Council. He is expected
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to testify that the Defendants have a secular purpose, that they do not have the principal or
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primary effect of advancing or inhibiting religion, that they do not foster an excessive
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government entanglement with religion or endorse one religion over another, and they do
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not coerce people to support or participate in religion, or exercise or otherwise act in a
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way that establishes a state religion or tends to do so. He is also expected to testify that
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Defendants do not treat people unequally compared to other similarly situated individuals,
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they have not acted or failed to act with the intent or purpose to discriminate based upon
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religion, and that religion is not a motivating factor for Defendants actions or inaction.
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He is also expected to testify that Defendants have not engaged in a pattern or practice of
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discrimination, they have not denied FHA rights to a group of persons, including non-
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FLDS members, they have not attempted to make housing unavailable or deny housing
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opportunities to any person, discriminated in the terms, conditions, or privileges in the
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sale or rental of a building or the provision of services or facilities in connection
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therewith, and they have not coerced, intimidated, threatened, or interfered with any
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person in the exercise or enjoyment of, or on account of that person exercising or
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Defendants.
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3.
Edwin Barlow
Edwin Barlow serves as a member of the Hildale City Council. He is expected to
testify regarding his knowledge of the allegations in the Complaint, the structure, history
and/or functioning of the City government. He is expected to testify that the Defendants
have a secular purpose, that they do not have the principal or primary effect of advancing
or inhibiting religion, that they do not foster an excessive government entanglement with
religion or endorse one religion over another, and they do not coerce people to support or
participate in religion, or exercise or otherwise act in a way that establishes a state religion
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or tends to do so. He is also expected to testify that Defendants do not treat people
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unequally compared to other similarly situated individuals, they have not acted or failed to
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act with the intent or purpose to discriminate based upon religion, and that religion is not a
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motivating factor for Defendants actions or inaction. He is also expected to testify that
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Defendants have not engaged in a pattern or practice of discrimination, they have not
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denied FHA rights to a group of persons, including non-FLDS members, they have not
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attempted to make housing unavailable or deny housing opportunities to any person,
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discriminated in the terms, conditions, or privileges in the sale or rental of a building or
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the provision of services or facilities in connection therewith, and they have not coerced,
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intimidated, threatened, or interfered with any person in the exercise or enjoyment of, or
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on account of that person exercising or encouraging others to exercise FHA rights, and
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that religion is not a motivating factor for Defendants.
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4.
Jeremiah Barlow
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Jeremiah Barlow was the Town Manager for the City of Hildale and the Utilities
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Board Business Manager. Mr. Barlow is expected to testify concerning his knowledge of
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the allegations in the Complaint regarding utilities services in the area. It is anticipated
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that Mr. Barlow may also provide testimony regarding official policies, ordinances, and/or
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resolutions of the City of Hildale. He is expected to testify that the Defendants have a
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secular purpose, that they do not have the principal or primary effect of advancing or
inhibiting religion, that they do not foster an excessive government entanglement with
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5.
Joseph Allred
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Joseph Allred is the Mayor of Colorado City. He is expected to testify about his
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education, training, and experience as the Mayor, the respective roles of the Mayor and
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Town Council, the other positions he has held for Colorado City, his former employment
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with Twin City Water Works, and his knowledge about the provision of utilities
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(including water) to residents of Colorado City.
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Mayor Allred is also expected to testify about the following topics: his general
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knowledge of the FLDS Church, its leaders, teachings, and its practices; his appointment
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as Mayor; his employment as office clerk for Twin City Water Works, including, but not
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limited to, his appointment and duties; his knowledge of services provided by Twin City
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Water Works; his knowledge of Twin City Improvement Association, including, but not
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limited to, its efforts to obtain water for housing units; his knowledge, as Water
Superintendent, of the process of giving water hookups, including, but not limited to, the
application process, challenges in giving water hookups, whether applications were
denied, efforts to expand the capacities of the cities to obtain additional water, discussions
with the Utility Board about expansion and obtaining additional water, and efforts to
develop more water sources; whether he has sought or received guidance and/or directives
from FLDS Church leaders on how to perform his official duties as Town Clerk, Water
Superintendent, or Mayor; his knowledge regarding a water shortage in the community;
his knowledge about and interactions with Willie Jessop; his knowledge about and
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interactions with Bruce Wisan, Jethro Barlow, Isaac Wyler, and other representatives of
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the UEP Trust; whether he has ever discriminated against anyone on the basis of religion
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while working as Water Superintendent, Town Clerk, or Mayor, and whether he has
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observed any other town employee discriminate based on religion; his conversations with
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Helaman Barlow, including Helaman Barlows work as a police officer and the Towns
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decision to terminate his employment; and all related issues.
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Mayor Allred is also expected to testify that the Defendants have a secular purpose,
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that they do not have the principal or primary effect of advancing or inhibiting religion,
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that they do not foster an excessive government entanglement with religion or endorse one
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religion over another, and they do not coerce people to support or participate in religion,
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or exercise or otherwise act in a way that establishes a state religion or tends to do so. He
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is also expected to testify that Defendants do not treat people unequally compared to other
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similarly situated individuals, they have not acted or failed to act with the intent or
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purpose to discriminate based upon religion, and that religion is not a motivating factor
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for Defendants actions or inaction. He is also expected to testify that Defendants have
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not engaged in a pattern or practice of discrimination, they have not denied FHA rights to
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a group of persons, including non-FLDS members, they have not attempted to make
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housing unavailable or deny housing opportunities to any person, discriminated in the
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terms, conditions, or privileges in the sale or rental of a building or the provision of

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services or facilities in connection therewith, and they have not coerced, intimidated,
threatened, or interfered with any person in the exercise or enjoyment of, or on account of
that person exercising or encouraging others to exercise FHA rights, and that religion is
not a motivating factor for Defendants.
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David Darger
David Darger is the Town Manager for Colorado City. He is expected to testify
about his education, training, and experience as the Town Manager, along with the other
positions he has held within Colorado City. He is also expected to testify about the
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government structure of Colorado City, the decisions reserved to the Town Council and
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the Town Manager, the process by which residents within Colorado City can obtain
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utilities (including water, power, and sewer), the hiring and firing of police officers for the
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Marshals Department, Colorado Citys investigation into allegations against former
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Marshal Helaman Barlow, Colorado Citys hiring of a Prosecutor, interactions with the
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United Effort Plan Trust regarding its subdivision proposals, his attendance at Council
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meetings, and all related issues.
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Mr. Darger is also expected to testify about the following topics: his general
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knowledge of the FLDS Church, its leaders, teachings, and its practices; his employment
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with Colorado City, including, but not limited to, his positions as building inspector,
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deputy town clerk, and Town Manager, his appointment to these positions, his duties, and
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the Towns policies and procedures; whether FLDS Church leaders direct his official
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conduct; his knowledge of the duties and responsibilities of the records custodians of the
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Town, and the Towns policies and procedures regarding records retention of public
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records; his knowledge and observations of the Towns surveillance system, and who has
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authority to access, view, and monitor the camera feeds, who maintains it, and the
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retention schedule for the feeds; his employment as secretary and treasurer for the
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Colorado City Fire District and his plea agreement and criminal conviction for misuse of
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public funds; whether he directed fire district funds to the FLDS Church; his knowledge
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of and interactions with outside law enforcement, such as the Mohave County Sheriffs
Office and their discriminatory practices towards FLDS residents; his knowledge of and
communications and interactions with Bruce Wisan and employees or representatives of
the UEP Trust, including, but not limited to, whether they are prejudiced against the
FLDS; the UEP Trusts various subdivision proposals and unwillingness to comply with
the Towns land division ordinance; his knowledge and observations of, and
communications and interactions related to, the enactment of the land division ordinance
and how the Town applies it to the UEP Trust and other individuals; his knowledge of the
Utah State Probate proceedings and the scope of Judge Lindbergs authority over
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Colorado City; his knowledge and observations of, and communications and interactions
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with, Helaman Barlow, including, but not limited to, claims that he altered Helaman
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Barlows police reports; his knowledge and observations of, and communications and
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interactions with, Joseph Allred; his knowledge and observations of, and communications
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and interactions with, Twin City Water Works and its employees, including, but not
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limited to, whether it improperly diverted funds and failed to develop water resources for
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the Town; his knowledge and observations of, and communications and interactions with,
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Willie Jessop, including, but not limited to, whether he and other town employees
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attended town business-related meetings on R & W business premises; his knowledge and
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observations of, and communications and interactions with, Lyle Jeffs, including, but not
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limited to, whether Lyle Jeffs discussed Town business with him or other Town
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employees or directed how to conduct Town business; his knowledge and observations of,
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and communications and interactions with, Virgil Steed; his knowledge and observations
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of, and communications and interactions with, William K. Steed, including, but not
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limited to, any incidents related to children working on pecan harvests; his knowledge and
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observations of Town employees leaving the community at the direction of the FLDS
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Church; the Towns investigation of officers for misconduct and work with Arizona and
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Utah POST regarding investigations into officers for misconduct; the Towns response to
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Arizona or Utah POSTs decision to decertify a police officer; his knowledge and
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observations of, and communications and interactions with, Jessie Barlow; his knowledge
and observations of any FLDS Church directives requiring FLDS members to donate
money to Warren Jeffs while he was a fugitive; his knowledge and observations of, and
communications and interactions with, Haven Barlow, including, but not limited to, an
incident where Sam Brower attempted to serve papers upon Haven Barlow; his knowledge
and observations of, and communications and interactions with, Sam Brower; his
knowledge and observations of FLDS Church directives regarding new building
construction; his knowledge and observations of, and communications and interactions
relating to, the Towns attempts to develop more water resources, including, but not
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limited to, the water shortage in Colorado City, the implementation of an impact fee, the
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hiring of Sunrise Engineering and other engineers, the policies and practices of the Town
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to resolve the water shortage issues, the incident of a well pump sucking air in Colorado
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City in 2014, and the Towns attempts to resolve and repair the issues; his knowledge and
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observations of, and communications and interactions related to, financial audits of the
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Town; his knowledge and observations of, and communications and interactions with, the
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UEP Trust, including, but not limited to, paying property taxes and the UEP Trusts mass
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evictions of Colorado City residents; the Towns efforts to aid those who the UEP Trust
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has evicted; his observations regarding any religious discrimination by any Town
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employee; the Towns policies and procedures against religious discrimination; the
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Towns training on anti-discrimination, for both employees and police officers; and all
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related issues.
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Mr. Darger is also expected to testify that the Defendants have a secular purpose,
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7.
Vance Barlow
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Vance Barlow is the Town Clerk for Colorado City. He is expected to testify about
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his training, education, and experience as the Town Clerk. He is also a former officer
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with the Marshals Department and is expected to testify about his application, training,
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education, and experience as an officer.
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conversations with representatives from Colorado City and the Marshals Department, his
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interactions with Bruce Wisan and others from the United Effort Plan Trust, the policies,
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procedures, ordinances, and resolutions that Colorado City established regarding utilities,
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He is also expected to testify about his
the structure of Colorado City and its relationship and agreements with Hildale City, Twin
City Water Authority, and Twin City Water Works, the structure of the Utility Board, his
experience with water shortages within Colorado City and Hildale City, and all related
issues.
Mr. Barlow is also expected to testify about the following topics: his general
knowledge of the FLDS Church, its leaders, and its practices; his knowledge of the
Towns policies, procedures, and practices regarding the retention of records and file
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servers to preserve official records; his knowledge and observations of, and his
communications and interactions with, Isaac Wyler, Bruce Wisan, and Willie Jessop,
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including, but not limited to, responding to their requests for records; his knowledge and
observations of the Marshals Departments policies and practices regarding locating
Warren Jeffs, including, but not limited to, squad meetings discussing the apprehension of
Warren Jeffs and interviewing residents about their knowledge of Warren Jeffs
whereabouts; his knowledge and investigation of missing persons complaints and
underage marriages; his knowledge of Bruce Wisans authority over the UEP Trust and
whether Town officials are hostile to Bruce Wisan at Warren Jeffs directive; his
knowledge regarding the decertification of police officers and whether the Town or the
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Marshals Department conducted investigations, or assisted with the on-going

investigations; whether he has ever received direction from any FLDS Church leader on
how to perform his duties as the Town Clerk or as a police officer; whether he has ever
discriminated against a non-FLDS resident; his knowledge of, and any involvement in,
Twin City Water Works; and all related issues.
Mr. Barlow is also expected to testify that the Defendants have a secular purpose,
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Jacob Barlow
Jacob Barlow was Colorado Citys Planning and Zoning Director. He is expected
to testify about his knowledge of the events alleged in the Complaint, including, for
example, the building permit process and requests for utility services. Mr. Barlow may
also provide testimony about Colorado Citys policies, procedures, ordinances, and
resolutions. He is expected to testify that that the Defendants have a secular purpose, that
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they do not have the principal or primary effect of advancing or inhibiting religion, that
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they do not foster an excessive government entanglement with religion or endorse one
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Andy Barlow
Andy Barlow is currently serving as a building official for the Town of Colorado
City and Hildale City. Mr. Barlow is expected to testify regarding his knowledge of the
allegations in the Complaint, the structure and functioning of the City government,
employment practices at the Cities, and other related matters. He is expected to testify that
the Defendants have a secular purpose, that they do not have the principal or primary
effect of advancing or inhibiting religion, that they do not foster an excessive government
entanglement with religion or endorse one religion over another, and they do not coerce
people to support or participate in religion, or exercise or otherwise act in a way that
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establishes a state religion or tends to do so. He is also expected to testify that Defendants
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do not treat people unequally compared to other similarly situated individuals, they have
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not acted or failed to act with the intent or purpose to discriminate based upon religion,
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and that religion is not a motivating factor for Defendants actions or inaction. He is also
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expected to testify that Defendants have not engaged in a pattern or practice of
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Defendants.
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10.
Lovisa White
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Lovisa White works for Colorado City as the administrative assistant and secretary.
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She also works as a part-time secretary for the Marshals Department. She is expected to
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testify about her job duties, education, training, and experience with Colorado City and
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the Marshals Department, her discussions with officers from the Marshals Department,
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her attendance at Council meetings, her interactions with the public who visit the Town
Hall or call the Town offices, and her experiences as a female working for, and living in,
Colorado City. Ms. White is also expected to testify about her work with the payroll for
Colorado City, her knowledge regarding whether the police officers are members of the
FLDS Church or United Order, her experience regarding keeping separate from her
official duties any religious principles or beliefs, and all related issues.
Ms. White is also expected to testify about the following topics: her general
knowledge of the FLDS Church and its practices; her knowledge about the Towns and
the Marshals Departments policies regarding records retention; policies and procedures
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related to claiming impounded animals and euthanization of unclaimed animals; her
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knowledge about obtaining a business license; her knowledge and experience with
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assisting people who come into the Town office who want to file an incident report or
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witness statement, or file a complaint against an officer; her knowledge and understanding
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of how religious principles interact with governmental duties; her knowledge and
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observations of the Towns surveillance cameras; and all related issues.
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In the event that Ms. White is not available to testify at trial, the following
deposition testimony will be offered:
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September 20, 2013 Deposition
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- p. 4, line 7 to p. 5, line 12
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- p. 12, line 18 to p. 31, line 13
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- p. 36, lines 8 20
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- p. 51, line 4 to p. 52, line 10
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- p. 53, lines 1 9
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- p. 54, line 23 to p. 56, line 12
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- p. 56, line 13 to pg. 59, line 5
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- p. 62, line 2 to p. 65, line 25
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- p. 66, line 12 to p. 68, line 23
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- p. 69, line 6 to p. 73, line 6

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- p. 81, line 13 to p. 82, line 19
- p. 85, line 16 to p. 88, line 18
June 25, 2014 Deposition
- p. 9, line 12 to p. 10, line 11
- p. 15, lines 12 17
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Heber White
Heber White works in the Hildale Utility Office. He is expected to testify about
the process used when he receives any utility application. He is expected to testify that
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Defendants.
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Richard Barlow
Richard Barlow is the Treasurer for Hildale City. Mr. Barlow is expected to testify
concerning his knowledge of the allegations in the Complaint, including but not limited to
testimony that the Defendants have a secular purpose, that they do not have the principal
or primary effect of advancing or inhibiting religion, that they do not foster an excessive
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Defendants.
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Mike Spilker
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Mike Spilker is a CPA at Hinton Burdick CPAs & Advisors. Hinton Burdick has
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provided financial and audit services for Hildale and Colorado City for several years. Mr.
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Spilker is expected to testify regarding the audits they have performed. His testimony is
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expected to include, but not be limited to, his experiences that show that the Defendants
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or tends to do so.
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14.
Jonathan Fischer
Jonathan Fischer is the past President of the Water Board and past President of
Twin City Water Authority. He is expected to testify about the water shortage within
Colorado City and Hildale, the water policies recommended, conversations within the
City Councils of Colorado City and Hildale. He is expected to testify that the Defendants
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Victor Jessop
Victor Jessop has served as the water/wastewater superintendent with Twin City
Water Authority.
Mr. Jessop is expected to testify consistent with his deposition
testimony, including but not limited to, his knowledge of the allegations in the Complaint
pertaining to utility services and building permits. Mr. Jessop may also testify regarding
historical issues regarding water supply in Hildale and Colorado City, and the availability
of culinary water for new service locations, along with any other related issues. He is
expected to testify that the Defendants have a secular purpose, that they do not have the
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Defendants. Specifically, his testimony is expected to include, but not be limited to, the
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water policies and procedures of the Towns, the day to day operations of TCWA, the
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supply and demand for water in the communities, the conservation and development
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efforts of the Towns, and the structure and organization of the water supply systems.
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Weston Barlow
Weston Barlow is currently employed doing field work for the Hildale and
Colorado City Utilities. He is expected to have knowledge regarding the allegations in the
Complaint, the structure and functioning of the City government and its utilities. He is
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Defendants.
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Jacob Jessop
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Jacob Jessop is the President of the Utility Board and was the President of Twin
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City Water Authority. He is expected to testify about the water shortage within Colorado
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City and Hildale, water policies recommended, conversations with the City Councils of
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Colorado City and Hildale. He is expected to testify that that the Defendants have a
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Berklee Holm, Sr.
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Berklee Holm, Sr. was a member of the Twin City Water Authority Utility Board.
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He is expected to testify regarding his knowledge of the allegations in the Complaint, the
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structure, history and/or functioning of the City government and utilities, and his
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involvement and knowledge regarding the Holm School incident. He is expected to
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testify that the Defendants have a secular purpose, that they do not have the principal or
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primary effect of advancing or inhibiting religion, that they do not foster an excessive
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Defendants.
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Justin Barlow
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Justin Barlow is a fact witness. He is the Utilities Business Manager for the City of
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Hildale. Mr. Barlow is expected to testify regarding his knowledge of the allegations in
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the Complaint, the structure and functioning of the City government and its utilities,
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including but not limited to testimony that the Defendants have a secular purpose, that
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not a motivating factor for Defendants. His testimony is expected to include, but not be
limited to, the utility policies and ordinances, the business decisions of the utilities, water
development, contractual relationships including those to help develop water, customer
demands regarding utilities, applications and hiring at the Cities, water demand in the
community, and the day to day operations of the utilities.
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Warren Barlow
Warren Barlow is expected to testify via designated deposition pages:
May 30, 2014
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- p, 10, lines 11-12
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- p. 10, line 16 to p. 16, line 25
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- p. 18, lines 10-19
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- p. 34, line 16 to p. 36, line 4
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- p. 38, lines 8-16
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- p. 39, lines 5-9
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- p. 39, line 22 to p. 40, line 6
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- p. 46, lines 10-21
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- p. 47, lines 6-21
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- p. 48, line 1 to p. 50, line 4
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- p. 52, line 18 to p. 53, line 13
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- p. 54, lines 15-21
25
- p. 60, line 22 to p. 65, line 25
26
- p. 66, line 22 to p. 70, line 14
27
- p. 73, line 12 to pg. 76, line 7
28
- p. 78, lines 16-19

22
- p. 84, lines 18-23
- p. 85, lines 21-25
- p. 88, line 6 to p. 89, line 20
- p. 93, line 22 to p. 94, line 1
- p. 97, line 9-16
- p. 112, line 21 to p. 113, line 2
- p. 115, line 10 to p. 125, line 25
- p. 127, line 10 to p. 130, line 3
- p. 130, line 24 to p. 135, line 9
10
- p. 135, line 25 to p. 136, line 3
11
- p. 139, line 24 to p. 143, line 3
12
- p. 152, line 12 to p. 159, line 18
13
- p. 161, line 11 to p. 163, line 2
14
- p. 174, line 8 to p. 185, line 11
15
- p. 187, line 21 to p. 188, line 12
16
17
18
21.
Leonard Black
Leonard Black is serving as the Hildale City IT Manager.
Mr. Black has
19
knowledge of the allegations in the Complaint, the structure and functioning of the City
20
government and IT systems, and any other related matters. He is expected to testify that
21
22
23
24
25
26
27
28
23
Defendants.
Specifically, he is expected to testify consistent with his deposition,
10
including but not limited to the following: his work history, his interactions with
11
Defendants, his industrial lot lease, his FLDS membership status, his interaction with
12
FLDS leaders while employed with the Cities, FLDS meetings and services, his
13
application and employment at the Cities, communications with FLDS leaders regarding
14
City business, City network infrastructure and servers and data storage, fiberoptic lines,
15
City WiFi, FLDS video surveillance, FLDS IT support, CCMO radio communications,
16
and City dispatch recordkeeping.
17
18
19
20
22.
Lorin Fischer
Lorin Fischer is expected to testify via designated deposition pages:
May 28, 2014
21
- p, 10, lines 16-18
22
- p. 12, lines 9-25
23
- p. 13, line 1 to p. 16, line 18
24
- p. 17, lines 9-14
25
- p. 18, lines 10-19
26
- p. 48, line 47 to p. 49, line 20
27
- p. 48, line 4 to p. 49, line 20
28
- p. 50 lines 14-17
24
- p. 58, lines 20-22
- p. 63, line 14 to p. 67, line 8
- p. 70, line 25 to p. 78, line 21
- p. 88, line 20 to p. 95, line 8
- p. 96, lines 8-21
- p. 97, line 8 to p. 99, line 5
- p. 99, line 24 to p. 100, line 11
- p. 100, line 19 to p. 108, line 9
- p. 109, line 2 to p. 113, line 15
10
- p. 109, line 2 to p. 113, line 16
11
- p. 115, line 22 to p. 121, line 4
12
- p. 122 line 14 to p. 124, line 12
13
- p. 128, line 13 to p. 130, line 9
14
- p. 146, line 25 to p. 147, line 16
15
16
17
23.
Brian Meldrum
Brian Meldrum is expected to testify via designated deposition pages:
May 24, 2013
18
- p. 5, lines 18-20
19
- p. 8, line 12 to p. 22, line 24
20
-p. 8, line 12 to p. 22, line 23
21
- p. 23, line 14 to p. 25, line 18
22
- p. 26, line 6 to p. 29, line 17
23
- p. 30, line 9 to p. 32, line 23
24
- p. 33, line 2 to p. 33, line 8
25
- p. 33, line 21 to p. 35, line 11
26
April 7, 2014
27
- p. 6, lines 1-4
28
- p. 6, lines 7-12
25
- p. 12, line 13 to p. 16, line 1
- p. 17, lines 5-22
- p. 18, lines 4-8
- p. 26, lines 18-22
- p. 30, line 13 to p. 32, line 17
- p. 32, line 24 to p. 33, line 17
- p. 34, lines 3-6
- p. 34, line 22 to p. 36, line 11
- p. 37, line 22 to p. 38, line 6
10
- p. 41, line 25 to p. 43, line 11
11
- p. 43, line 17 to p. 47, line 8
12
- p. 47, line 15 to p. 49, line 2
13
- p. 47, line 15 to p. 48, line 2
14
- p. 50, line 19 to p. 52, line 4
15
- p. 52, lines 15-19
16
- p. 52, line 23 to p. 54, line 23
17
- p. 55, lines 4-24
18
- p. 56, line 2 to p. 57, line 10
19
- p. 58, lines 5-19
20
- p. 58, line 23 to p. 59, line 8
21
- p. 59, line 17 to p. 60, line 3
22
- p. 59, line 17 to p. 60, line 8
23
- p. 60, lines 6-8
24
- p. 60, line 24 to p. 62, line 16
25
- p. 33, line 21 to p. 35, line 11
26
- p. 96, line 8 to p. 101, line 15
27
- p. 104, line 20 to p. 105, line 11
28
- p. 110, line 17 to p. 111, line 6

26
- p. 116, line 14 to p. 117, line 3
- p. 125, lines 10-17
- p. 137, lines 6-12
- p. 171, lines 2-13
- p. 199, line 20 to p. 200, line 10
- p. 211, line 10 to p. 212, line 3
- p. 213, line 14 to p. 214, line 21
- p. 215, line 15 to p. 216, line 21
- p. 217, line 5 to p. 218, line 6
10
- p. 219, lines 18-20
11
- p. 220, line 2 to p. 221, line 1
12
- p. 220, line 2 to p. 221, line 2
13
- p. 225, line 18 to p. 227, line 19
14
- p. 229, lines 13-21
15
16
24.
Brian Zitting
17
Brian Zitting works for Canaan Peaks Engineering. He is expected to testify about
18
his education, training, and experience as an engineer. He is also expected to testify about
19
his work for Colorado City regarding water resources, his work with Sunrise Engineering
20
on water resources, his work with Colorado City and Hildale to evaluate the United Effort
21
Plan Trusts proposed subdivision plat, his work on the proposed plat and description
22
from the United Effort Plan Trust, his engineering work regarding Twin City
23
Improvement Associations request for a new culinary water service connection, and all
24
related issues.
25
Mr. Zitting is also expected to testify about the following topics: his work for
26
municipalities in the areas of design, surveying, and planning; the bid process to work for
27
Colorado City and Hildale; his professional licenses and organization memberships; his
28
April 2007 letter to Colorado City regarding the UEP Trusts proposed plats; his April
27
2007 e-mail to Joel Heaton responding to a request for information on new development
in Colorado City; his work on the proposed plat note submitted to the UEP Trust for
review; his December 2007 communications with the towns and the Utility Department
regarding water supply and water sources; his March 2008 letter to Hildale re the UEP
Trusts subdivision proposal and the use of lots-not-served and not-a-part on the plat
map; his December 2009 rate structure study for Colorado City, Hildale, and Twin City
Water Authority; his February 2010 letter to Victor Jessop regarding the housing project
by Twin City Improvement Association and his reliance upon the December 1986 Bryce
Montgomery Report; his knowledge about Colorado Citys and Hildales efforts to
10
develop new water; and all related issues.
11
12
25.
Marvin Wilson
13
Marvin Wilson works for Sunrise Engineering. He is expected to testify about his
14
education, training, and experience as an engineer. He is also expected to testify about
15
Sunrise Engineerings work for Colorado City regarding water planning, water resources,
16
and general planning, his examination, studies, and conclusions regarding the availability
17
of water within Colorado City and Hildale, the reports that Sunrise Engineering prepared
18
to Colorado City and Hildale, Sunrise Engineerings work with Colorado City to conduct
19
an impact fee study and a master plan, and all related issues.
20
Mr. Wilson is also expected to testify about the following topics: his professional
21
licenses and organization memberships; whether he has ever been a member of the FLDS
22
Church or lived in Colorado City or Hildale; the 1998 Culinary Water Master Plan
23
completed for Colorado City and Hildale; the 2002 Water Resources Study completed for
24
Colorado City and Hildale; the 2002 Environmental Study of Water and Squirrel Canyon
25
completed for Colorado City and Hildale; the 2008 Letter Report to Colorado City
26
regarding wells; the differences between a water capacity test and a safe-yield test; his
27
work to bring the power plant into compliance for use as a culinary water source; his work
28
on water studies for other municipalities; his knowledge about other municipalities
28
policies and ordinances regarding limiting new water connections, the imposition of
impact fees, and the enforcement water regulations; and other related issues.
3
4
26.
Mark Stratton
Mark Stratton is an expert witness who will offer expert opinions regarding the
operations and management conduct of the Defendants with respect to the provision of
culinary water to the residents of Colorado City and Hildale. He is expected to testify
about his education, training, experience, and qualifications to offer expert opinions. See
Statement of Qualifications, attached as Exhibit 1. He is also expected to testify about
10
11
12
13
14
15
the documents he reviewed and other work he completed during his analysis in this case.
Mr. Stratton is further expected to testify consistent with his expert opinions
disclosed to the United States, including the following expert opinions:
(1)
It was appropriate for the towns to take action to limit new connections to
the existing water system without those new connections bringing additional supplies.
(2)
The towns are working on developing a capital program to identify the
16
future capital needs for the water system, determine the timing and funding needs for
17
those capital projects, and develop a financing plan that can be supported with the limited
18
financial resources available.
19
focusing on how to best meet the future challenges of a growing community while
20
addressing how they can also meet the needs of additional water demand. The towns will
21
also need to incorporate how new developments and developers can also contribute to
22
these financial needs.
23
(3)
This plan is a reasonable effort in that the towns are
Until the completion of the capital program, the towns and the water utility
24
need to maintain a vigilant position of protecting the existing customers and residents with
25
the limited water supplies that currently exist.
26
(4)
The UEP Trust has the ability to form its own water utility and
27
infrastructure separate from either the Colorado City or Hildale to provide water service to
28
its properties.
29
1
2
27.
Ken Brendel
Ken Brendel is the prosecutor for the Town of Colorado City. He is expected to
testify about his education, training, and experience as an Arizona lawyer and his service
and duties as Colorado Citys prosecutor. Mr. Brendel is also expected to testify about the
advice he has provided to the officers with the Marshals Department regarding arrests,
traffic stops, property disputes, and trespass calls that have occurred within Colorado City
and that sometimes also involve the United Effort Plan Trust. He is also expected to
testify about his discussions with the Mohave County Attorneys Office and other law
10
enforcement agencies regarding the Marshals Department and issues regarding the
11
United Effort Plan Trust. He is also expected to testify about the advice he has provided
12
to the officers regarding disputes (property and otherwise) involving Andrew Chatwin,
13
Richard Holm, Christopher Jessop, Jesseca Jessop, Ron Rohbock, Jerold Williams,
14
Ronald Cooke, Jinjer Cooke, Willie Jessop, Isaac Wyler, Ross Chatwin, Lori Chatwin,
15
Bruce Wisan, Jethro Barlow, and others. Mr. Brendel is also expected to testify about his
16
advice to the officers on how to write police reports to document events. He is also
17
expected to testify about his advice to the officers and others regarding eviction actions,
18
notices of abandonment, unlawful detainer, and related issues under Arizona statutes.
19
20
28.
Richard D. Carr
21
Richard D. Carr is the former Hildale Justice Court Judge. Mr. Carr is expected to
22
testify about his knowledge of allegations in the Complaint, including but not limited to
23
testimony that the Defendants have a secular purpose, that they do not have the principal
24
25
26
27
28
30
10
11
Defendants. Specifically, his testimony is expected to include, but not be limited to, his
12
knowledge regarding the justice court system, how he adjudicated matters, his
13
observations regarding discrimination in charges brought before him, and the operation
14
and structure of the justice court.
15
16
29.
Zachary J. Weiland
17
Zachary J. Weiland is the former Hildale City Prosecutor. Mr. Weiland is expected
18
to testify about his knowledge regarding allegations in the Complaint, including but not
19
limited to that the Defendants have a secular purpose, that they do not have the principal
20
21
22
23
24
25
26
27
28
discrimination, they have not denied FHA rights to a group of persons, including non31
education, training, and experience as a Utah lawyer and his service and duties as
Hildales prosecutor. He is also expected to testify about the advice he has provided to
10
the officers with the Marshals Department regarding arrests, traffic stops, property
11
disputes, and trespass calls that have occurred within Hildale and that sometimes also
12
involve the United Effort Plan Trust. He is also expected to testify about his discussions
13
with the Washington County Attorneys Office and other law enforcement agencies
14
regarding the Marshals Department and issues regarding the United Effort Plan Trust.
15
He is also expected to testify about the advice he has provided to the officers regarding
16
disputes (property and otherwise) involving Andrew Chatwin, Richard Holm, Christopher
17
Jessop, Jesseca Jessop, Ron Rohbock, Jerold Williams, Ronald Cooke, Jinjer Cooke,
18
Willie Jessop, Isaac Wyler, Ross Chatwin, Lori Chatwin, Bruce Wisan, Jethro Barlow,
19
and others. He is also expected to testify about his advice to the officers on how to write
20
police reports to document events. He is also expected to testify about his advice to the
21
officers and others regarding eviction actions, notices of abandonment, unlawful detainer,
22
and related issues under Utah statutes.
23
24
30.
Nathan G. Caplin
25
Nathan G. Caplin served as the Hildale City Prosecutor. Mr. Caplin is expected to
26
testify about his knowledge regarding allegations in the Complaint, including but not
27
limited to testimony that the Defendants have a secular purpose, that they do not have the
28
32
10
11
12
13
14
15
16
education, training, and experience as an Arizona lawyer and his service and duties as
17
Hildales prosecutor. He is also expected to testify about the advice he has provided to
18
the officers with the Marshals Department regarding arrests, traffic stops, property
19
disputes, and trespass calls that have occurred within Hildale and that sometimes also
20
involve the United Effort Plan Trust. He is also expected to testify about his discussions
21
with the Washington County Attorneys Office and other law enforcement agencies
22
regarding the Marshals Department and issues regarding the United Effort Plan Trust.
23
He is also expected to testify about the advice he has provided to the officers regarding
24
disputes (property and otherwise) involving Andrew Chatwin, Richard Holm, Christopher
25
Jessop, Jesseca Jessop, Ron Rohbock, Jerold Williams, Ronald Cooke, Jinjer Cooke,
26
Willie Jessop, Isaac Wyler, Ross Chatwin, Lori Chatwin, Bruce Wisan, Jethro Barlow,
27
and others. He is also expected to testify about his advice to the officers on how to write
28
police reports to document events. He is also expected to testify about his advice to the
33
officers and others regarding eviction actions, notices of abandonment, unlawful detainer,
and related issues under Utah statutes.
3
4
31.
Richard K. Chamberlain
Richard K. Chamberlain is the former Hildale City Attorney. Mr. Chamberlain is
expected to testify regarding his knowledge of the allegations in the Complaint, the
structure, history and/or functioning of the City government. He is expected to testify that
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Defendants.
25
26
27
28
32.
Samuel Johnson
Samuel Johnson serves as a Sergeant for the Hildale/Colorado City Marshals
Office.
He is expected to testify regarding his knowledge of the allegations in the

34
Complaint regarding unlawful policing, along with any other related issues.
testify that Defendants do not engage in unreasonable seizures, including traditional
arrests without probable cause of a crime, brief investigatory stops without suspicion of
criminal activity, or use of excessive force. He is also expected to testify that Defendants
10
11
12
13
14
15
16
17
18
19
20
21
Defendants.
22
testimony, and will include, but not be limited to, incidents he was involved in as a
23
CCMO officer that the Plaintiff has identified as relevant to its claims, how he became an
24
officer at the CCMO, his training and certification as an officer, that he is not directed by
25
the FLDS Church in his official duties, that he does not share law enforcement
26
information with the FLDS, his interactions with FLDS Church security, his
27
communication with FLDS leaders regarding City business, his FLDS membership status,
He is
Specifically, his testimony is expected to conform to his deposition
28
35
the organization and policies of the CCMO, the CCMOs handling of property disputes,
and his interactions and cooperation with other agencies.
3
4
33.
Daniel Musser
Daniel Musser is an officer for the Hildale/Colorado City Marshals Office. He is
expected to testify regarding his knowledge of the allegations in the Complaint regarding
unlawful policing, and FLDS control over the hiring of police officers, along with any
other related issues. He is also expected to offer testimony that will contest Charlene
Jeffs testimony. He is expected to testify that the Defendants have a secular purpose, that
10
11
12
13
14
is also expected to testify that Defendants do not engage in unreasonable seizures,
15
including traditional arrests without probable cause of a crime, brief investigatory stops
16
without suspicion of criminal activity, or use of excessive force. He is also expected to
17
18
19
20
21
22
23
24
25
26
27
28
Defendants. Specifically, his testimony is expected to be consistent with his deposition,

36
and will include, but not be limited to, the process by which he applied for and became a
cadet for the CCMO, his training and certification through POST, and his experience as a
newly hired officer at the CCMO.
4
5
34.
Daniel Roy Barlow
Daniel Roy Barlow is an officer with the Marshals Department. He is expected to
testify about his education, training, and experience as a police officer, the certifications
received from Arizona and Utah, the process by which he became an officer, his
application and interview process to become a police officer, the training he has received
10
as a police officer, the Marshals Departments policies and procedures, his interactions
11
with the Town Council and Prosecutor, and all related issues.
12
Officer Barlow is also expected testify about the following topics: his general
13
knowledge of the FLDS Church and its practices; his employment as an officer, including,
14
but not limited to, his appointment, duties, and whether the FLDS Church or its leaders
15
influence his work or was involved in his appointment; his knowledge of the Bishops
16
Storehouse and its contents; his investigations, actions, and observations with respect to
17
an alleged trespass incident involving Jim Barlow on July 4, 2014; his knowledge and
18
training regarding how to handle child custody disputes, including, but not limited to,
19
policies and procedures, training materials, services of summons, and assisting in the
20
enforcement of custody orders; his knowledge of, and interactions and communications
21
with, Charlene Jeffs, including, but not limited to, conversations (or lack thereof)
22
regarding his appointment as a police office, information regarding her child custody
23
dispute, and his involvement in the custody dispute between Charlene Jeffs and Sabrina
24
Holms; his communications, if any, with Lyle Jeffs concerning his duties as a police
25
officer and whether he reports to Lyle Jeffs or any leader of the FLDS Church; his
26
knowledge of his and other officers participation in the United Order; his knowledge of
27
whether Town officials and officers separate non-United Order members from United
28
Order members, and non-FLDS members from FLDS members; his knowledge regarding
37
whether officers sent consecrated money to Warren Jeffs when he was a fugitive, whether
he or other officers give Lyle Jeffs weekly reports regarding law enforcement activity,
whether Lyle Jeffs directed him or the other officers to be hostile to Bruce Wisan, whether
Warren Jeffs dictates the conduct of him or other officers from prison; and all other
related issues.
Officer Barlow is also expected to testify that the Defendants have a secular
purpose, that they do not have the principal or primary effect of advancing or inhibiting
religion, that they do not foster an excessive government entanglement with religion or
endorse one religion over another, and they do not coerce people to support or participate
10
in religion, or exercise or otherwise act in a way that establishes a state religion or tends to
11
do so. He is also expected to testify that the CCMO and its officers do not engage in
12
unreasonable seizures, including traditional arrests without probable cause of a crime,
13
brief investigatory stops without suspicion of criminal activity, or use of excessive force.
14
He is also expected to testify that the CCMO and its officers do not treat people unequally
15
compared to other similarly situated individuals, they have not acted or failed to act with
16
the intent or purpose to discriminate based upon religion, and that religion is not a
17
18
the CCMO and its officers have not engaged in a pattern or practice of discrimination,
19
they have not denied FHA rights to a group of persons, including non-FLDS members,
20
they have not attempted to make housing unavailable or deny housing opportunities to any
21
person, discriminated in the terms, conditions, or privileges in the sale or rental of a
22
building or the provision of services or facilities in connection therewith, and they have
23
not coerced, intimidated, threatened, or interfered with any person in the exercise or
24
enjoyment of, or on account of that person exercising or encouraging others to exercise
25
FHA rights, and that religion is not a motivating factor for the CCMO and its officers.
26
27
28
38
35.
Hyrum Roundy
Hyrum Roundy is an officer with the Marshals Department. He is expected to
testify about his education, training, and experience as a police officer, the certifications
received from Arizona and Utah, the process by which he became an officer, his
application and interview process to become a police officer, the training he has received
as a police officer, the Marshals Departments policies and procedures, his interactions
with the Town Council and Prosecutor, and all related issues.
Officer Roundy is also expected to testify about the following topics: his general
knowledge of the FLDS Church and its practices and leaders; whether he receives any
10
direction from the FLDS Church on how to conduct his official duties or interact with
11
Bruce Wisan or the UEP Trust; his knowledge about Saturday work projects; his
12
employment as an officer, including, but not limited to, his appointment and if the FLDS
13
Church was involved, his training, duties, and whether or not he accepts direction from
14
Warren Jeffs or other FLDS leaders in the performance of his official duties, and whether
15
he has observed government employees attempting to help FLDS members avoid service
16
of legal papers or personally had conversations on the issue; whether he assisted in the
17
avoidance of the service of legal papers or slow walked someone trying to serve legal
18
papers; his understanding of Court orders; the Marshals Departments practices,
19
procedures, and training regarding the service of documents; his knowledge and
20
observations of, and communications with, Helaman Barlow, including, but not limited to,
21
changes Helaman Barlow made to his police reports; his knowledge and interactions with
22
Willie Jessop, including whether to arrest him on various criminal offenses; the Towns
23
investigation into his conduct regarding Willie Jessop, including disciplinary action
24
against him by the Town; his knowledge regarding whether he or other officers altered
25
any police reports; his knowledge about and involvement in the July 2012 incident
26
involving Jerold Nathan Williams; his knowledge about and involvement in the January
27
2013 incident involving Sam Brower; his knowledge about and involvement in Ruby
28
Jessops custody battle with her husband Haven Barlow; his knowledge about and
39
involvement in Sam Browers attempts to serve him with custody papers involving Haven
Barlow and Ruby Jessop; his knowledge and understanding of enforcing UEP Trust
occupancy agreements, including, but not limited to, his related communications with,
training, and advice from the Prosecutor, training from Arizona and Utah POST, and
training from the Marshals Department; his knowledge about and involvement in the
Holm School incident in December 2012; his communications, interactions, and
investigation of Isaac Wyler, including, but limited to, a trespass complaint regarding the
Fanita family property, or other allegations of trespassing; a 2009 incident where Isaac
Wyler complained that people were taking rocks out of a quarry; his knowledge about and
10
involvement in the April 2011 incident where William E. Timpson Jessop was arrested for
11
trespass; his knowledge about and involvement in property disputes between Jessica
12
Jessop, Christopher Jessop, and Penny Barlow; his knowledge about and involvement in a
13
February 2013 incident involving ECO Alliance and Willie Jessop; whether he
14
consecrated his official equipment to the FLDS Church; his knowledge of whether FLDS
15
Church leaders gave instructions to remove Helaman Barlow from the Marshals
16
Department; his working relationship with Helaman Barlow and concerns about Helaman
17
Barlows ability to lead as the Marshal; his knowledge about and observations of
18
interactions with Charlene Jeffs, including, but not limited to, his communications with
19
Charlene Jeffs regarding a welfare check on her children; his knowledge regarding
20
whether he or other officers sent consecrated money to Warren Jeffs when he was a
21
fugitive; whether he or other officers give Lyle Jeffs weekly reports regarding law
22
enforcement activity; whether Lyle Jeffs directed that he or other officers be hostile to
23
Bruce Wisan or the UEP Trust; whether he or other officers receive any direction from
24
Lyle Jeffs, Warren Jeffs, or any other FLDS Church leader regarding how to conduct their
25
official duties; his knowledge about and involvement in the child custody dispute
26
involving Sabrina Tetzner; and all related issues.
27
Officer Roundy is also expected to testify that the Defendants have a secular
28
40
10
11
12
13
14
15
16
17
18
19
20
36.
Curtis Cooke
21
Curtis Cooke serves as an officer for the Colorado City/Hildale Marshals Office.
22
He is expected to testify regarding his knowledge of the allegations in the Complaint
23
regarding unlawful policing, along with any other related issues. He is also expected to
24
offer testimony that will contest Charlene Jeffs testimony. He is expected to testify that
25
that the Defendants have a secular purpose, that they do not have the principal or primary
26
27
28

41
do not engage in unreasonable seizures, including traditional arrests without probable
cause of a crime, brief investigatory stops without suspicion of criminal activity, or use of
excessive force.
10
11
12
13
14
15
that religion is not a motivating factor for Defendants. Specifically, his testimony is
16
expected to conform with his deposition testimony and will include, but not be limited to,
17
incidents he was involved in as a CCMO officer that the Plaintiff has identified as relevant
18
to its claims, how he became an officer at the CCMO, his training and certification as an
19
officer, that he is not directed by the FLDS Church in his official duties, that he does not
20
share law enforcement information with the FLDS, his interactions with FLDS Church
21
security, his communication with FLDS leaders regarding City business, his FLDS
22
membership status, the organization and policies of the CCMO, the CCMOs handling of
23
property disputes, and his interactions and cooperation with other agencies.
He is also expected to testify that Defendants do not treat people
24
25
37.
Shem Jessop
26
Shem Jessop served as an officer for the Colorado City/Hildale Marshals Office.
27
He is expected to testify regarding his knowledge of the allegations in the Complaint
28
regarding unlawful policing, including but not limited to that the Defendants have a
42
or tends to do so. He is also expected to testify that Defendants do not engage in
He is also expected to testify that Defendants do not treat people unequally compared to
other similarly situated individuals, they have not acted or failed to act with the intent or
10
11
12
13
14
15
16
17
18
19
not a motivating factor for Defendants. Specifically, his testimony is expected to conform
20
with his deposition testimony and will include, but not be limited to, incidents he was
21
involved in as a CCMO officer that the Plaintiff has identified as relevant to its claims,
22
how he became an officer at the CCMO, his training and certification as an officer, that he
23
is not directed by the FLDS Church in his official duties, that he does not share law
24
enforcement information with the FLDS, his interactions with FLDS Church security, his
25
communication with FLDS leaders regarding City business, his FLDS membership status,
26
the organization and policies of the CCMO, the CCMOs handling of property disputes,
27
and his interactions and cooperation with other agencies.
28
43
38.
Jonathan Roundy
Jonathan Roundy is the former Marshal for the Marshals Department. He is
expected to testify about his education, training, and experience as a police officer, the
certifications received from Arizona and Utah, the process by which he became an officer,
his decision to retire, and all related issues.
Mr. Roundy is also expected to testify about the following topics: his employment
as an officer and the Marshal, including, but not limited to, his appointment, retirement,
duties, and whether he followed the directives of Warren Jeffs or other leaders of the
FLDS Church in the performance of his duties; whether officers overlooked plural and/or
10
underage marriages in the community; training and advice received from the Prosecutor;
11
his knowledge of how individuals were appointed or employed as officers; his general
12
knowledge of the FLDS Church and its practices; his personal knowledge of the FLDS
13
Church, its leaders, and its practices, including, but not limited to, the United Order and
14
church security; his knowledge of the Marshals Departments involvement in the
15
attempts to locate Warren Jeffs while he was a fugitive; his knowledge of, and interactions
16
with, Willie Jessop, including, but not limited to, attending meetings at his R&W
17
business; his knowledge of UEP Trust occupancy agreements; his knowledge about and
18
involving in the Holm Sunday School disputes involving Richard Holm and his brothers;
19
his knowledge about and involvement in a November 2008 incident involving Fred Jessop
20
and David Stubbs regarding the planting of wheat in a field; his knowledge about and
21
involvement in a May 2010 incident involving Shane Stubbs field; his knowledge about
22
and involvement in the euthanization of Lydia Stubbs horse; his knowledge about and
23
involvement in a July 2005 incident involving Andrew Chatwin attempting to obtain
24
possession of a property previously occupied by Orson Black; his knowledge about and
25
involvement in the 2010 arrest of Genevieve Hainline and Matthew Hainline; and all
26
related issues.
27
Officer Roundy is also expected to testify that the Defendants have a secular
28
44
10
11
12
13
14
15
16
17
18
19
20
39.
Keith Sobraske
21
Keith Sobraske works for Investigative Research, Inc. He was hired to conduct an
22
independent investigation into alleged misconduct on the part of then-Marshal Helaman
23
Barlow. Mr. Sobraske is expected to testify about his education, training, and experience
24
as an investigator, the analysis and investigation that he completed into Helaman Barlow,
25
and the conclusions that he reached. Mr. Sobraske is also expected to testify that he
26
investigated the following five allegations against Helaman Barlow, as set forth in his July
27
29, 2014 investigative report: (1) Making false claims with intent to bring discredit to
28
other officers; (2) Failure to maintain satisfactory working relationships with other
45
employees (including the Town Manager) and his effectiveness to lead the Department;
(3) Confidence, or lack thereof, between the Marshal and the other officers and their
ability to effectively work together in responding to incidents; (4) Whether the use of
alcohol affected Helaman Barlows ability to lead the department; and (5) Admission fact
by Helaman Barlow that he lies and how that credibility affected his ability to function as
head of the Marshals Department. Mr. Sobraske will also testify about his conclusions
reached on each of these allegations.
8
9
40.
Greg Meyer
10
Greg Meyer is an expert witness who will offer expert opinions (both affirmative
11
and in rebuttal to the United States police practice expert) regarding the conduct of the
12
Marshals Department and its officers. He is expected to testify about his education,
13
training, experience, and qualifications to offer expert opinions.
14
Qualifications, attached as Exhibit 1. He is also expected to testify about the documents
15
he reviewed, his interview with Ken Brendel, and other work he completed during his
16
analysis in this case.
17
18
19
See Statement of
Mr. Meyer is further expected to testify consistent with his expert opinions
disclosed to the United States, including the following affirmative expert opinions:
(1)
It is proper for the officers to follow the advice of Ken Brendel, the
20
Prosecutor. Mr. Brendel generally advised handling property disputes involving the UEP
21
Trust as civil matters, and it is proper for police officers to follow the advice of
22
prosecutors. Also, the testimony of Mohave County Sheriffs Department Sergeant Mike
23
Hoggard indicates that Mohave County Sheriffs Department handles UEP property
24
disputes in the same manner as Colorado City Prosecutor Kenneth Brendel has advised
25
the CCMO to handle such disputes; and Sergeant Hoggard would not fault CCMO for
26
handling property disputes in that manner, which he believes is an appropriate manner. In
27
addition, staff of the Office of the Attorney General (Utah) documented that UEP Trust
28
Occupancy Agreements do not have the force of eviction orders.

46
(2)
The CCMOs Policies and Procedures Manual was adequate, and it was
updated several times from 1989 through at least 2011. The manual quotes from the "Law
Enforcement Code of Ethics" that has been used in many places in the United States for
many years. The 2007 CCMO policies repeatedly emphasized the need for professional
police conduct, to avoid conflicts of interest, and to maintain an impartial attitude. In
particular, Section 2.6 under "Rules of Conduct" directed, "Use of profane, demeaning, or
insulting language will not be tolerated, nor will disrespect for the political or religious
views of others be accepted." Section 3.4 directed that personnel must cooperate with
other agencies. Section 4.1 directed that employees will not interfere with the lawful
10
business of any person. Section 4.2 directed that personnel may not use their official
11
positions to intimidate persons engaged in a civil controversy. And Section 3.01 directed
12
that the selection and placement of agency personnel are to be based upon Equal
13
Employment 0pportunity provisions.
14
(3)
Police officers have a duty to report and investigate crimes that they become
15
aware of. It is part and parcel of any police officers duty to do this. Chief Helaman
16
Barlow acknowledged this duty. Colorado City Prosecutor Kenneth Brendel stated that he
17
told CCMO officers that if they witnessed criminal activity, they should take appropriate
18
enforcement action (which would result in submission of paperwork to Mr. Brendel's
19
office for consideration of whether charges should be brought). This conduct was proper.
20
(4)
No documented evidence exists to show any discrimination by CCMO
21
officers. No language in any of the reports provided a "red flag" that indicated that
22
discrimination was or may have been occurring.
23
(5)
CCMO police officers appear to have provided police services to witness
24
Jesseca Jessop without discrimination against her. Ms. Jessop testified that she had no
25
problem with the way the CCM0 police officers handled 10 of the 12 matters in which she
26
interacted with them. She disputed the CCMO handling of two of those matters. The first
27
is a property occupancy dispute with Penny Barlow. She recalled that Deputy Hyrum
28
Roundy advised her to go to court to get an eviction order, and Deputy Roundy provided
47
her with a witness statement form. However, she faults Deputy Roundy for not doing his
job because he did not arrest Penny Barlow for trespass on the basis of occupancy
agreement paperwork without an eviction order from the court. She testified that she was
unaware that Deputy Roundy submitted the case to the Prosecutor, who rejected it as a
civil matter. There appears to be a conflict between a court order that Judge Lindberg
made regarding how occupancy agreement paperwork is to be considered during property
occupancy disputes, and the advice of the Prosecutor to treat such disputes as civil
matters, along with CCMO training or direction to gather the information from parties in
the dispute and submit it to the city prosecutor for enforcement advice and decisions. It is
10
appropriate for police officers to handle matters in the manner advised by the Prosecutor.
11
Second, Jesseca Jessop testified about an incident where she and her husband had rented a
12
house from Genevieve Hainline, but there was a trespasser (Enrique LeBaron) on the
13
properly. She called the police. LeBaron was arrested. She testified that she had no
14
problem with the way CCMO Deputy Hyrum Roundy and Officer Curtis Cooke and
15
Sergeant Sam Johnson handled the matter. She also testified that she asked that the
16
investigation be turned over to the Mohave County Sheriff s Office (because she thought
17
Officer Cooke had somehow "mistreated" LeBaron), and that the CCMO personnel did
18
turn the investigation over to Mohave County. Overall, not all incidents were handled in
19
the way that Jesseca Jessop personally desired, but the vast majority of them were; and
20
even the incidents that were not handled in the way that she personally desired do not give
21
rise to a conclusion that there was discrimination against her, absent proof of
22
discrimination.
23
(6)
No evidence exists to supports the allegation that the Marshal's Office
24
carried out Warren Jeffs' order to return an underage bride. This allegation apparently
25
involves Ruby Jessop, who testified that Sam Roundy came up to Canada with Willie
26
Jessop to bring her back. However, no evidence exists that any CCMO personnel acted in
27
an on-duty capacity or used CCMO resources in this matter.
28
48
(7)
CCMO police officers appear to have provided police services to witness
Stefanie Colgrove without discrimination against her. She testified that Officer Curtis
Cooke responded to her call about a group of people outside the fence in front of her
property. She wanted the people to leave. Officer Cooke talked to a member of the group
(John Nielson), and the group left. However, she thought Officer Cooke treated her like
she was making something out of nothing. She testified that in 2009 she reported to
Officer Helaman Barlow acts of vandalism to the library. Helaman Barlow investigated,
including taking pictures of damage and footprints. She testified that on April 1 6, 2011,
there was a "huge bonfire" outside the library. She testified that she wrote two versions of
10
her witness statement because part of her first witness statement was not true. She
11
testified that Officer Sam Johnson was unwilling to help with the library investigation.
12
She testified that Officer Sam Johnson assisted her and protected her property from a
13
neighbor boy who had pilfered some items. No evidence of any discrimination exists.
14
(8)
The arrest of Genevive Hainline Stubbs appears to have been lawful. Police
15
officers are taught that probable cause is a strong, reasonable belief that a person has
16
committed, is committing, or is about to commit a crime. During a property occupancy
17
dispute (during which CCMO personnel advise that the matter is civil and handles it
18
according to the standing legal advice given by the Prosecutor), she ignored police
19
commands and the direction of her own friends not to go on the property. The police
20
verbally and clearly announced the arrest. She actively resisted arrest. She was taken to
21
the ground using soft-hand controls only, and she was handcuffed. She admitted that she
22
resisted arrest and stated, "l fought them for a while. No evidence of any discrimination
23
exists.
24
(9)
If Helaman Barlow were acting on the advice of the Prosecutor to handle
25
UEP Trust property disputes such as the Berry Knoll Farms dispute as civil matters, it was
26
reasonable police action. Helaman Barlow testified that he told Mayor Terrill Johnson
27
that the Berry Knoll Farms dispute was civil, per the direction of the Prosecutor. Sally
28
Stubbs was not satisfied with the police service on this occasion. She testified that she did
49
not remember hearing from Helaman Barlow stating that it was a civil matter. Also, the
testimony of Mohave County Sheriffs Department Sergeant Mike Hoggard indicates that
Mohave County Sheriff's Department handles UEP property disputes in the same manner
as Colorado City Prosecutor Kenneth Brendel has advised CCMO to handle such disputes;
and Sergeant Hoggard would not fault CCMO for handling property disputes in that
manner, which he believes is an appropriate manner. In the case of the Berry Knoll Farms
dispute, Sergeant Hoggard testified that he assessed that both parties in the dispute had
been violating parts of the related court order, and that clarification of the court order was
needed. Sergeant Hoggard also testified that he has no idea if Helaman Barlow's decision
10
11
to handle the dispute was religiously motivated.

(10)
Although Sally Stubbs disagreed with receiving a reckless driving citation
12
from CCMO Officer Jerry Darger, she did not believe that it was based on some type of
13
religious discrimination.
14
(11)
Marshal Fred Barlow's letter in October 2005 to federal fugitive Warren
15
Jeffs was improper and unprofessional. The letter openly states that Marshal Fred Barlow
16
intends to do and is doing the bidding of Warren Jeffs (FLDS leader and federal fugitive).
17
It also states that all of the officers desire "to stand with you and the priesthood" (but all of
18
the officers have testified that they did not engage in discriminatory law enforcement
19
practices).
20
(12)
If there were threats against the church and individuals, and disruptions at
21
the church, it was proper for the CCMO to respond to church security requests for law
22
enforcement intervention. It is part and parcel of a police officer's job to respond to
23
threats and disruption, regardless of the source or target.
24
(13)
If, as claimed by Willie Jessop, there was "a very heavy interaction between
25
church security and law enforcement," this may well have been appropriate as long as law
26
enforcement was acting in its proper role (and not "being hijacked to do policing for the
27
church"). It is ludicrous for anyone to suggest that there should be no interaction between
28
50
law enforcement agencies and private security interests in the community. Such
interaction is a basic tenet of community-based policing.
(14)
There is not enough information in the record to determine the propriety or
impropriety of "a number of cases" where Willie Jessop testified that Chief Sam Roundy
would forward police investigation information or license plate information to church
security, because the reasons these things occurred (if they occurred) and the necessary
specifics are not in the record.
8
9
10
11
(15)
If Sam Johnson left the FLDS Church but was still promoted to Sergeant,
and was next in line to be Chief of Police [and as of March 18,2014 was the Acting Chief
of Police], this is evidence that the FLDS Church is not in control of CCMO, as alleged.
(16)
If Helaman Barlow "ran" license plates or NCIC checks at the request of
12
Willie Jessop or anyone else without an official purpose, this would be inappropriate and
13
unprofessional. Helaman Barlow admitted that he ran license plates (i.e., used the police
14
computer to obtain information about vehicles/license plates/registrations/warrants) at the
15
request of Willie Jessop 10 or 20 times. However, the purpose of doing so was not made
16
clear in the documentation. He denied running NCIC checks for non-law-enforcement
17
persons. He did not recall if Guy Timpson ever asked him to run a license plate. He did
18
not know (or recall) if anyone from the FLDS meeting house asked him or any deputies to
19
run license plates. Helaman Barlow's various testimonies (via depositions and court
20
testimony) are also full of inconsistencies.
21
(17)
No evidence exists to conclude that CCMO personnel were involved in
22
carrying out an FLDS Church edict by rounding up domestic dogs and shooting them.
23
Steven Bateman testified about this issue during his deposition. While he believes that it
24
happened, he testified that he has no proof that CCMO personnel were involved in the
25
destruction of dogs.
26
(18)
Mohave County Sheriff's Sergeant Mike Hoggard and Washington County
27
Sheriff Deputy Darrell Cashin (who both had routine interaction with CCMO personnel)
28
testified that the CCMO was generally cooperative with their investigations. Mohave
51
County Sheriffs Sergeant Hoggard testified that he could not think of any instances
where the CCMO was not cooperative.
testified that most of the time he agreed with the CCMO officers' assessments as to
whether a property-occupancy dispute was civil when non-FDLS people would call him.
He also testified that CCMO has been helpful to him.
(19)
Washington County Deputy Sheriff Cashin
Hyrum Roundy testified that he participated in the building of a fence, but
no evidence exists that he knew that the property was occupied illegally or that the
activity had a nexus to his job with CCMO.
(20)
If Sergeant Sam Johnson contacted the Washington County Attorney's
10
office for advice in handling the Holm School property dispute, and the Washington
11
County Attorney's office advised Sergeant Johnson to handle it as a civil matter, then
12
Sergeant Johnson performed his duty properly. Hyrum Roundy testified that he left the
13
Holm School property dispute before the call was completed because he did not want any
14
part of what he believed was mishandling by the sheriffs. UEP Trust Fiduciary Bruce
15
Wisan wrote to Hildale City Mayor Zitting that, "Police Officers from the County and the
16
Marshal's Office agreed that Richard [Holm] would have to get a court ordered eviction
17
notice..." Richard Holm testified that Jonathan Roundy and Sam Johnson came to Holm's
18
property, asked FLDS men to leave, and they did. Later, the FLDS men returned and
19
began digging holes and installing fences, and Sam Johnson responded and told them to
20
stop.
21
(21)
If Prosecutor Kenneth Brendel instructed CCMO Officer Curtis Cooke to
22
arrest Jerrold Williams if Williams did not leave the property he was allegedly trespassing
23
on, and if Williams did not leave the property despite lawful direction to do so, it was
24
reasonable for Officer Cooke to make that arrest, and any reasonable officer would have
25
done the same thing.
26
27
(22)
No evidence supports the allegation that the Marshal's Office has seized the
property of non-FLDS individuals without due process of law.
28
52
Mr. Meyer is further expected to testify consistent with his rebuttal expert opinions
disclosed to the United States, including the following expert opinions to rebut Joseph
DeLopezs expert opinions:
(1)
The United States expert makes repeated references to the wording of
CCMO policy and concludes that it provides officers "plausible deniability." However,
the United States expert uses Helaman Barlow as his source, and because of Helamans
ever-changing testimony, it is not reasonable to rely upon him to support any opinions.
8
9
(2)
Basic academy, POST-certified training does not appear to be at issue. The
United States expert is concerned about in-service training.
But, as the expert
10
acknowledged: "Neither POST agency has found CCMO out of compliance with this
11
requirement." While everyone might wish that more hours of ln-service training on more
12
subjects were provided over and above POST requirements, the fact is that training is
13
expensive, and it costs patrol time out of the field. It is traditionally difficult (especially
14
with small departments) to have the luxury to have both the money and the time to do as
15
much extra training as an agency might like to do. The fact that the CCMO was in
16
compliance with in-service training requirements in the view of POST from both Utah and
17
Arizona negates the United States expert's criticism. The United States expert also
18
repeatedly refers to standards proffered by the Commission on Accreditation for Law
19
Enforcement Agencies (CALEA).
20
18,000 law enforcement agencies in the United States are accredited by CALEA. The two
21
agencies that employed the United States expert (Chicago and Winnetka, IL) are not
22
accredited by CALEA. And not a single one of the many dozens of law enforcement
23
agencies of the United States federal government is accredited by CALEA.
24
(3)
However, less than 4 percent of the approximate
Where there is an investigation about a matter, and the original reports were
25
not comprehensive enough to answer later questions, it is proper for an officer to write a
26
supplemental report. The arrest of Harvey Dockstader was appropriate. The CCMO also
27
appropriately handled the Eco Alliance / 340 Johnson Avenue incident. The counsel of
28
the Colorado City Prosecutor's Office is also wise, i.e., that arrests do not need to be made
53
immediately, and that it is sometimes better to wait until all of the various reports are
finished so that the totality of the case can be evaluated prior to a decision to prosecute or
not.
(4)
The 2007 CCMO Law Enforcement Policy and Procedures manual contains
specific anti-discrimination language.
accordingly.
system.
(5)
It is incumbent upon the department to act
And any police agency should have a valid, nondiscriminatory hiring
According to the U.S. Department of Justice, Bureau of Justice Statistics,
"About half of local police departments employed fewer than 10 sworn personnel." The
10
CCMO employs fewer than 10. It is difficult to understand the United States expert's
11
opinions about supervision ratios. There are police departments in this country that have
12
only two or three officers.
13
supervision ratios like Chicago or Winnetka, IL. It is quite the norm with small agencies
14
for supervisors and chiefs and even other officers to be contacted in the off-hours as needs
15
arise.
Not every agency has the luxury of deploying better
16
17
18
41.
Jeremiah Darger
Jeremiah Darger serves as the Hildale/Colorado City Chief Marshal.
He is
19
expected to testify regarding his knowledge of the allegations in the Complaint regarding
20
unlawful policing, along with any other related issues. He is also expected to offer
21
testimony that will contest Charlene Jeffs testimony. He is expected to testify that the
22
Defendants have a secular purpose, that they do not have the principal or primary effect of
23
advancing or inhibiting religion, that they do not foster an excessive government
24
25
26
27
do not engage in unreasonable seizures, including traditional arrests without probable
28
cause of a crime, brief investigatory stops without suspicion of criminal activity, or use of
54
excessive force.
10
11
12
that religion is not a motivating factor for Defendants. Specifically, his testimony is
13
expected to conform with his deposition testimony and will include, but not be limited to,
14
incidents he was involved in as a CCMO officer that the Plaintiff has identified as relevant
15
to its claims, how he became an officer at the CCMO, his training and certification as an
16
officer, that he is not directed by the FLDS Church in his official duties, that he does not
17
share law enforcement information with the FLDS, his interactions with FLDS Church
18
security, his communication with FLDS leaders regarding City business, his FLDS
19
membership status, the organization and policies of the CCMO, the CCMOs handling of
20
property disputes, and his interactions and cooperation with other agencies.
He is also expected to testify that Defendants do not treat people
21
22
23
24
42.
Bruce Wisan
Bruce Wisan is expected to testify via designated deposition pages:
May 15, 2014
25
- p, 9, line 15 to p. 11, line 3
26
- p. 12, lines 10-12
27
- p. 13, lines 1-9
28
- p. 15, lines 3-14

55
- p. 16, lines 3-5
- p. 16, line 10 to p. 17, line 22
- p. 18 line 16 to p. 29, line 15
- p. 32, line 10 to p. 33, line 12
- p. 34, line 23 to p. 35, line 2
- p. 35, line 11 to p. 47, line 2
- p. 50, line 17 to p. 70, line 7
- p. 72, line 20 to p. 75, line 18
- p. 76, line 20 to p. 78, line 3
10
- p. 79, line 13 to p. 83, line 20
11
- p. 86, line 19 to p. 89, line 12
12
- p. 89, line 24 to p. 104, line 1
13
- p. 105, line 6 to p. 119, line 1
14
- p. 119 lines 20-25
15
- p. 121, line 10 to p. 122, line 6
16
- p. 122, line 23 to p. 128, line 25
17
- p. 129, line 22 to p. 151, line 23
18
- p. 153, line 1 to p. 180, line 13
19
- p. 182, line 9 to p. 123, line 24
20
- p. 182, line 9 to p. 223, line 24
21
22
23
24
43.
Sgt. Rich Fordham

Sgt. Rich Fordham is expected to testify via designated deposition pages:
July 23, 2014
25
- p, 5, lines 1-4
26
- p. 8, lines 2-6
27
- p. 19, line 19 to p. 20, line 21
28
- p. 21, lines 10-15

56
- p. 21, line 23 to p. 24, line 8
- p. 26, line 9 to p. 30, line 12
- p. 32 line 19 to p. 33, line 10
- p. 60, line 21 to p. 61, line 17
- p. 67, line 25 to p. 68, line 15
- p. 108, line 22 to p. 115, line 3
- p. 118, lines 1-15
- p. 124, line 3 to p. 125, line 10
- p. 126, lines 20-24
10
- p. 137, lines 18-25
11
- p. 139, lines 11-19
12
- p. 153, line 12 to p. 163, line 22
13
- p. 166, lines 7-21
14
- p. 168, lines 15-21
15
- p. 169 lines 1-5
16
- p. 171, lines 1-10
17
August 20, 2014
18
- p, 180, lines 4-12
19
- p. 180, line 23 to p. 184, line 18
20
- p. 185, line 2 to p. 188, line 16
21
- p. 191, line 10 to p. 193, line 11
22
- p. 194, lines 5-19
23
- p. 195, line 24 to p. 199, line 25
24
- p. 200, line 23 to p. 208, line 1
25
- p. 208, line 20 to p. 214, line 14
26
- p. 214, line 21 to p. 215, line 18
27
- p. 214, line 21 to p. 215, line 19
28
57
44.
2
3
Stefanie Colgrove
Stefanie Colgrove is expected to testify via designated deposition pages:
May 22, 2013
- p, 7, line 24 to p. 8, line 2
- p. 22, lines 18- 20
- p. 54, lines 6-12
- p. 88, line 1 to pg. 90, line 9
- p. 93, lines 6-15
- p. 94, line 25 to p. 97, line 9
10
- p. 94, line 25 to p. 97, line 8
11
- p. 141, line 21 to p. 142, line 4
12
13
14
15
45.
Raymon Christensen
Raymon Christensen is expected to testify via designated deposition pages:
September 12, 2013
16
- p, 25, lines 15-20
17
- p. 29, line 11 to p. 31, line 8
18
- p. 31, lines 13-24
19
- p. 32, line 6 to p. 33, line 9
20
- p. 33, line 21 to p. 34, line 2
21
- p. 34, line 9 to p. 35, line 6
22
- p. 36 lines 3-5
23
- p. 36, lines 12-14
24
- p. 37, lines 7-11
25
- p. 37, line 16 to p. 38, line 1
26
- p. 62, line 20 to p. 64, line 12
27
- p. 64, line 21 to p. 65, line 13
28
- p. 66, lines 3-10

58
- p. 87, line 25 to p. 88, line 17
2
3
4
5
46.
Sgt. Taylor Nelson

Sgt. Taylor Nelson is expected to testify via designated deposition pages:
September 1, 2015
- p, 10, lines 5-7
- p. 15, line 21 to p. 16, line 12
- p. 15, line 24 to p. 21, line 12
- p. 22, line 24 to p. 25, line 4
10
- p. 25, line 22 to pg. 26, line 18
11
- p. 27, lines 4-14
12
- p. 27, line 18 to p. 28, line 3
13
- p. 28, line 17 to pg. 29, line 2
14
- p. 30, lines 2-18
15
- p. 31, lines 4-19
16
- p. 44, lines 10-20
17
- p. 45, line 20 to p. 46, line 9
18
- p. 47, line 25 to p. 50, line 9
19
- p. 50, line 18 to p. 51 line 11
20
- p. 56, line 22 to p. 57 line 16
21
- p. 56, line 22 to p. 57, line 15
22
- p. 58, lines 5-25
23
- p. 62, lines 17-23
24
- p. 63, lines 10 to p. 65 line 1
25
- p. 66, line 1 to p. 70 line 9
26
- p. 66, line 1 to p. 70 line 8
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- p. 70, line 25 to p. 71 line 24
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Dated on November 12, 2015.

DURHAM JONES & PINEGAR
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By:
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/s/ R. Blake Hamilton

R. Blake Hamilton
Ashley M. Gregson
Attorneys for Hildale City and Twin City
Water Authority
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CERTIFICATE OF SERVICE
I hereby certify that on November 12, 2015, I electronically transmitted the

foregoing document to the Clerks Office using the CM/ECF system for filing and
transmittal of Notice of Electronic filing to the following CM/ECF registrants:
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R. Tamar Hagler
Eric W. Treene
Sean R. Keveney
Jessica C. Crockett
Matthew J. Donnelly
Emily M. Savner
Sharon I. Brett
United States Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, NW
Washington, D.C. 20530
Attorneys for Plaintiff United State of America
Jeffrey C. Matura
Asha Sebastian
Graif Barrett & Matura, P.C.
1850 North Central Avenue, Suite 500
Phoenix, Arizona 85004
Attorneys for Defendant Town of Colorado City, Arizona
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/s/ ASHLEY M. GREGSON

4821-2744-5289
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Case 3:12-cv-08123-HRH Document 770-1 Filed 11/12/15 Page 1 of 37
EXHIBIT 1

GREG MEYER
CURRICULUM VITAE
NAME:
Greg Meyer
LOCATION:
Los Angeles, CA
CONTACTS:
Offce: (818)956-1303
Cell:
E-Mail
(562) 715-7497
: greq mever(.e arthl i n k. net
BIRTH:
1948 - Culver City (Los Angeles), CA
EDUCATION:
M.S. - Public Administration, Cal State Los Angeles (1991)

Master's Thesis: "Nonlethal Weapons vs. Conventional police Tactics:
The Los Angeles Police Department Experience"
B.A. - Journalism, Cal State Long Beach (1979)

A.A. - Journalism, Los Angeles Pierce College (1974)
CERTIFICATES
& LICENSES:
Gertified Force Science Analyst

Force Science lnstitute (2009 - present)
Certified Litigation Specialist

Americans for Effective Law Enforcement (2003
present)
Certified instructor, TASER X-26 (2005,2009)

Certified instructor, TASER M-26 lnstructor (2001,2003,2005, 2009)
Certified instructor, Tasertron (various TASER devices,
1992
1999)
Teaching Credential (Police Science)

State of California (1981 - Lifetime)
California Peace Officer Standards and Training (p.O.S.T.)

(Basic, lntermediate, Advanced, Supervisory, Management Certificates)
EMPLOYMENT:
Police Tactics and Procedures Consultant

(Author, Lecturer, Consultant, Expert Witness) - self-employed
(1989 - present)
Los Angeles Police Department (1976 - present)

Offcer, Detective, Sergeant, Lieutenant, Captain, including assignments
in patrol, detectives, vice, traffic, planning and research, tactical planning,
administration, and training. Retired from active service s-31-06. Field
Reserve Officer (1976-77); Reserve Officer (2006,2012); Speciatist
Volunteer, LAPD Training Group (2013 - present).
updared
08125114
Pagc I
MEYER
OOO2I

GREG MEYER
Long Beach Police Department, PatrolOfficer (1977-78)

Los Angeles Police Department, Field Reserve Offcer (1976-77)
McDonald's Corporation, Restaurant Manager, Training Coordinator

(1572-76)
ASSOCIATIONS: Force Science Research Center
(FSRC)
National Advisory Board member (2006 - present)

Certified Force Science Analyst (2009 - present)
Police Executive Research Forum (PERF)

Associate Member (2005 - present); advisor, PERF's
Center for Force and Accountability (2005 - 2007);
panel member for development of Conducted Energy Device guidelines
(2005 and 2010); attended annual meetings 2004,2005,2006,2012
Peace Officers Association of Los Angeles Gounty (POALAC)

Training Seminars Committee chair (2003 - 2011); Board of Directors
(2004 - present); member (1981 - present)
Americans for Effective Law Enforcement (AELE)

Certified Litigation Specialist (2003 - present);Academic Committee
member for AELE's Certifed Litigation Specialist program (2002
present); Chairman, Association of Certified Litigation Specialists (20112013); law journal review panelist (2009 - present); seminar instructor for
"Critical lncident Response: Management and Legal Liability" seminar
(2002-2005); seminar instructor for "Lethal and Less-Lethal Force"
seminar (2006-2013); seminar instructor for "Management, Oversight and
Monitoring of Use of Force" (2013)
American Society for Law Enforcement Training (ASLET)

Vice Chair (2003-2004); Treasurer (2001-2003); Executive Board (20012004); seminar instructor (1994 - 2004); master of ceremonies for annual
seminar opening ceremonies in Anchorage, Ontario (CA), and St. Louis
(2002-2004)
lnternational Association of Chiefs of Police (IACP)

Co-author of Electronic Control Weapons model policy revision (2010);
Project Advisor, "Electro-Muscular Disruption Technology: A Nine Step
Strategy for Effective Deployment" (published April 2005); IACP member
(1993 - present); attended IACP AnnualConference (2004,2005,2006)
PoliceOne.com
Featured columnist (2006 - present)
Los Angeles Police Command Officers Association

Member (1998 - 2006)
POLICE Magazine
Advisory Board Member and article contributor (1997 - present)
Updated 08125114
Pagc2
MEYER
OOO22

GREG MEYER
California Association of Force lnstructors (CAFI)

Presenter and Associate Member (1994
2000)
Public Administration Advisory Committee

California State University, Los Angeles (1993 - 1998)
Pi Sigma Alpha public administration honor society (1990)
California Homicide lnvestigators Association

Past Member
California Peace Officers Association (CPOA)

Member (1980 - life member)
Century Club, West Valley Family YMCA

Member (1974 - 2006)
President's Club, Los Angeles Metropolitan YMCA

Member (1976
present)
Chairman's Round Table, West Valley Family YMCA

Member (2007
MILITARY:
present)
United States Army Security Agency (1968-72)

Top SecreUCryptographic security clearance; Radio Traffic Analyst,
Airborne Radio Direction Finding Specialist and German Linguist; duty
stations included Pleiku and Nha Trang, Vietnam (1969-'1970); and
Bad Aibling, West Germany (1970 1972)
COMMUNITY
SERVICE:
Tri-Valley YMCA (San Fernando Valley, CA)

Chairman, Board of Managers (2012 - present); (a combination of three
YMCA branches under one managemenUleadership team)
Los Angeles Police Museum

Chairman of the Board of Directors (1992-1995; 2007-2010); Vice
Chairman (2014); Director (1989-present); on-camera interviw for "The
History Channel" program on the 1997 North Hollywood Bank Robbery
Shootout (2008); Co-Chair, Capital Development Campaign (2000-2001 );
Producer, AnnualJack Webb Awards Night (1996, 1999, 2012); Coproducer, Jack Webb Awards Night (1997, 1998, 2001 ,2004, 2014)
Valley Traffic Advisory Council (San Fernando Valley, CA)

Founder (2001); Advisor (2001-2004); Director (2007- 2009); Honorary
Member (2009 - present)
Updated
08125114
Pagc 3
MEYER
OOO23

GREG MEYER
West Valley Family YMCA (Reseda, CA)

Member, Board of Managers (2011 - 2012); Leadership reunion
organizer (2010); Keynote speaker, annual campaign kickoff dinner
(2008 & 2009); Chairman's Round Table (2007-present); President's
Club (1974-present);Century Club (1974 - 2006); Board of Managers
(1973-76); Camp Committee Chairman (1974)
HONORS &
AWARDS:
"Lifetime Achievement A'vard" (2012): "Member of the Year" (2006)

Peace Officers Association of Los Angeles County (POALAC)
LAPD Management Achievement Award Nominee, for leadership

accomplishments as a division commanding officer (2001)
"Volunteer of the Year" Los Angeles Police Historical Society (2000)

LAPD Management Achievement Award Nominee, for leadership of
Wilshire Area's "Predators to Prison" Program (1996)
Defensive Tactics Newsletter's Leadership Award to recognize

commitment and contributions to research in training & tactics (1994)
Medallion Recipient, National Philanthropy Day in Los Angeles for activities

with the Los Angeles Police HistoricalSociety (1992)
LAPD's Hollywood Detective of the Year (1983)
Soldier of the Quarter,
U.S. Army Field Station Bad Aibling, Germany (1971)
l\rmy Commendation Medal, Vietnam
Updated
08125114
(1969-1970)
Pagc 4
MEYER
OOO24

GREG MEYER
LAPD
PROFESSIONAL
ACTIVITIES:
Member, Tactics Training Review Committee, a work group that

creates and updates LAPD Use of Force Tactics Directives for the Chief
of Police; monthly meetings (2013 - present)
Leader, LAPD Use-of-Force "Best Practices" Strategic Planning
Work Group, direction and coordination of internal subcommittees and
outside consultants examining policy, training, equipment, tactics, postincident review processes; directed LAPD's TASER ModelX-26 field test;
LAPD media resource on these issues (2005-2006)
Member, LAPD Use-of-Force "Best Practices" Strategic Planning
Work Group (2006 - 2009) (turned over the leadership role upon retiring
from LAPD in May 2006, continued as work group member); recognized
by the Los Angeles Board of Police Commissioners during its adoption of
a revised LAPD use-of-force policy resulting from a four-year project
(200e)
Member, Professional Advisory Committee, a work group focusing on

police improvement training issues, coordinated by the LAPD Director
of Police Training and Education, LAPD Academy (2009 - present)
Demonstrated ASER-Cam device for the Chief of Police (2007)

Presenter, LAPD Chief of Police and United States Military
Delegation from Baghdad, lraq, on crime and traffic issues,
Los Angeles (August 2006)
Paicipant, National lnstitute of Justice Conference, featuring

nonlethal weapons session and force-options simulator technology
session, Washington, DC (July 2006)
Participant, Police Executive Research Forum (PERF) focus group on
officer safety issues, Washington, DC (May 2006)
Participant, Police Executive Research Forum (PERF) Annual

Meeting, focused on law enforcement "best practices," San Francisco
(April2006)
Presenter, TREXPO-West on TASERs and Excited Delirium (March
2006)
Presenter, LAPD ln-Seruice Training Section Training Day on

TASERS and Excited Delirium (March 2006)
Presenter, LAPD Chief of Police press conference, to announce

LAPD's field test of TASER ModelX-26 (February 2006)
Updated
08125114
Pagc 5
MEYER
OOO25

GREG MEYER
*
*
*
*
*
Presenter, lnstitute for Law Enforcement Administration (ILEA)

national summit on use of force, Plano, TX (January 2006)
Presenter, TASER Executive Course for law enforcement leaders, risk
managers, and legal staff, Scottsdale (December 2005)
Participant, Police Executive Research Forum (PERF) conference on

handling the mentally ill and use of force, San Diego (December 2005)
Member, California Peace Officer Standards and Training
Gommission (POST) committee to create a statewide standardized
lesson plan for TASER instructor certification, Sacramento (2005)
Presenter, Performance lnstitute's 2005 Use of Force Summit,

Arlington
"
"
VA (November 2005)
Participant, Police Executive Research Forum (PERF) conference on

TASER policy development, Houston (October, 2005)
Participant, lnternational Association of Chiefs of Police (IACP)

annual conference, numerous use of force seminars, Miami (September
2005)
"
Participant, Canadian Officer Safety Conference, Victoria BC

(September 2005)
"
Participant, Force Science Research Center (FSRC) seminar on

biomecha nics of off icer-involved shooting incidents, "Winning Extreme
Encounters from Street to Court," Seattle (June 2005)
Advisor, Police Executive Research Forum (PERF) Center for Force

and Accountability (June 2005 - present)
*
*
*
Updated
08125114
Participant, Police Executive Research Forum (PERF) Annual

Meeting, focused on international police use of force issues and "best
practices," New York City (April 2005)
Greator, multi-agency custody-death research work group to inspire
the US Surgeon General to involve the medical research community in
this persistent law enforcement problem (April 2005)
Project Advisor, lnternational Association of Chiefs of Police (IACP)

publication, "Electro-Muscular Disruption Technology: A Nine Step
Strategy for Effective Deployment" (published April 2005)
Pagc 6
MEYER 00026

GREG MEYER
Participant, US Department of Justice Symposium on Less-Lethal

Weapons Technology, includ ing workshop interaction with international
law enforcement and military chiefs and trainers, Arlington, VA
(April2005)
Coordinator, Chief of Police-directed review of LAPD use-of,force
policies and procedures by eight nationally renowned use-of-force
experts (March 2005)

annual conference, attended numerous use of force seminars,
Los Angeles (November 2004)
Participant, LAPD Chief of Police "72-hour Briefings" following
officer-involved shootings and other major incidents (2004-2006)
Advisor, William H. Parker Foundation (2004-2006)
Guest lecturer on police traffic safety and management issues,
Pepperdine University's School of Public Policy, graduate seminar
(2004)
Chairman, ad hoc committee to improve traffic collision reporting
efficiency (2003-2004)
Member, Los Angeles City Gouncilman Jack Weiss'Advisory
Commissio n (2002 - 2004)
First-level adjudicator as the commanding officer for hundreds of

disciplinary cases involving public and internal personnel complaints;
directed these investigations (1998
- 2006)
Presenter of facts, findings and recommendations to the Use of

Force Review Board for officer-involved shootings and other significant
use of force incidents (1999 - 2006)
Board member, Police Sergeant selection process (2001)
Participant, Law Enforcement Ethics Symposium presented by the
FBr (2001)
Reviewer, Police Lieutenant civil service examination (2001)
Assistant Chair, Area lntegrity Plan Development Committee (2000)

Member, Board of lnquiry to examine the suitability of particular officers
to be promoted to the rank of detective and sergeant (1999 - present)
Updated 08125114
Page 7
MEYER
OOO27

GREG MEYER
*
n
*
*
*
*
*
*
*
Guest speaker, International Traffic Conference, Madrid, Spain (2000)
Participant, California Office of Traffic Safety's annual conference,

San Diego (2000)
Chairman of the LAPD Board of Rights, a de novo disciplinary hearing
for a Los Angeles Police Department captain accused of "neglect of duty"
in the Department's "Rampart corruption scandal" (2000)
Master of ceremonies, Valley Traffic Safety Summit (2000-2004)
Member, LAPD lnformant Policy and Procedures Review Committee
(2000)
Panelist, West San Fernando Valley Traffic Summit, a seminar for
community activists, elected officials, and various government agencies
pertaining to improving traffic safety (2000)
Guest speaker, California Assembly Speaker Robert Hertzberg's
Public Safety Advisory Committee, and his Families and Community
Advisory Committee, on the subjects of traffic safety and the Rampart
corruption probe (1 999-2000)
Civil selice interview and personnel-package-review panelist for the

sergeant's exam process (1999)
Member, Board of lnquiry committee to examine command
accountability for reviews of nondeadly force, vehicle pursuits, and fleet
safety issues pertaining to policy, training and practices of the
Los Angeles Police Department (1999)
Commissioner, San Fernando Valley Public Safety Advisory

Commission convened by California State Assembly Speaker
Bob Hertzberg (1999
Updated 08125114
2003)
Member, Traffic Strategic Committee of the Los Angeles Police

Department, to develop and recommend improvements to the
Department's efforts to reduce traffic collisions through education,
engineering and enforcement (1999 -2001)
Member, Detective Strategy Committee of the Los Angeles Police
Department, to develop and recommend improvements to the
Department's efforts to produce hig h-quality criminal investigations
(1 ee8-1 eee)
Pagc 8
MEYER
OOO28

GREG MEYER
Member, Short-Term Strategy Committee on Juvenile lssues of the

Los Angeles Police Department, to develop and recommend
improvements to the Depament's efforts to produce high quality
processes involving juveniles (1 998-1 999)
Chairman or Member, numerous Boards of Rights tribunals to

adjudicate disciplinary matters within the Los Angeles Police Department
(1ee8
*
*
- 2006)
Chairman or Member, numerous Advanced Paygrade Selection

lnterview Panels for Lieutenant ll and Detective lll (1998 - 2005)
LAPD-West Point Leadership Course instructional cadre member

(1997 - 2005)
Leadership Course instructor for watch commanders, sergeants, and

field training officers, Los Angeles Police Academy (1995 - 1997)
Use-of-Force Review Coordinator, LAPD Wilshire Area (1993 - 1994)
Advisor, Use-of-Force Management lnformation System Task Force

(1
*
*
*
*
*
*
*
Updated 08125114
ee4)
Chairman or Member, numerous Advanced Paygrade Selection

lnterview Panels for Sergeant ll, Detective lll, Detective ll, and Police
Officer lll (Field Training Officers and Detective Trainees (1993 -1998)
Member, LAPD Tactics Training Review Committee (1990
2004 - 2006)
1993, and
Rodney King case: Provided expert consultation on use-of-force issues

to the criminal and internal investigators (1991), state case prosecutors
( 1 99 1 -92), City Attorney and administrative defense representatives
(1991-1994), U.S. Attorney and Federal Bureau of lnvestigation (1992);
memo to federal judge re use of force policy/training history (1993).
Reviewed and analyzed use-of-force and officer-involved shooting
repofts for the Commanding Officer, Operations-Headquarters Bureau
(1ee1-e3)
Conducted a special investigation of a command officer at the

direction of the Chief of Police (1987)
Authored "The Watch Commander's Guide for Control of Disasters
and Other Emergencies" (1982)
Developed nonlethal weapons policy and training material (1980-81)
Pagc 9
MEYER
OOO29

GREG MEYER
Trained 67 instructor/divisional coordinators and three tactics

supervisors on the TASER device, LAPD Academy (1981)
Researched and/or tested thirteen nonlethal weapons at Planning
and Research Division (f 979-80)
Staffed the LAPD Ad Hoc Committee on NonlethalWeapons and

created the Nonlethal Control Device lncident Report, later adapted as
LAPD's Use of Force Report (1980)
Conducted demonstrations of nonlethal weapons for the Mayor of
Los Angeles, the Los Angeles Board of Police Commissioners, and the
media (1980)
Member/staffer, LAPD's Human Resources Development Committee

(1e80-81
SPECIALIZED
TRAINING
RECEIVED:
Managing, Oversight and Monitoring of Use of Force, Americans for

Effective Law Enforcement's (AELE) (3 days, Las Vegas) (2013)
lnstitute for Prevention of ln-Custody Death (lPlCD) annual seminar

(3 days, Las Vegas) (annually 2006-2013)
Officer-lnvolved Shooting lnvestigation Course, Los Angeles Police

Department (3 days, Los Angeles, 2009)
Force Science Analyst Certification Gourse, Force Science lnstitute
(5 days, San Jose, 2009)
Lethal and Less-Lethal Use of Force Seminar, Americans for

Effective Law Enforcement (AELE) (3 days, annually or twice per year
from 2002-2013)
Public Safety Discipline and lnternal Affairs Course, Americans for
Effective Law Enforcement (AELE) (3 days, 2005, 2009, pending in
2014)
Training on California Highway Patrol (CHP) Mobile Video Audio
Recording System (MVARS) presented by CHP staff at the California
Department of Justice (Los Angeles office) (February 2013)
Training on TASER X-2 and X26, presented by Advanced Officer Safety

Training staff of the California Highway Patrol (CHP) at the California
Department of Justice (Los Angeles office) (August 2012)
Updated 08125114
Pagc I 0
MEYER
OOO3O

GREG MEYER
"
*
*
*
Jail and Prison Legal lssues, Americans for Effective Law

Enforcement's (AELE) (3 days, Las Vegas) (2005, 2011)
SWAT Debrief: The Death of LAPD SWAT Officer Randy Simmons
(3 hours, Pleasanton, CA, by instructor Mike Odle, 2011)
Earthquake Management Course, California Specialized Training

lnstitute (5 days, San Luis Obispo, 1981)
Civil Disorders Management Gourse, California Specialized Training

lnstitute (5 days, San Luis Obispo, 1982)
Basic Detective School, LAPD (15 days, 1982)
Supervisory Development Course, LAPD (20 days, 1983)
Juvenile Procedures School, LAPD (3 days, 1983)
Vice School, LAPD (5 days, 1986)
Supervisory Press Relations Training, LAPD (1 day, 19BB)
Homicide School, LAPD (5 days, 1991)
"
*
*
*
Watch Commander School, LAPD (5 days, 1993)

Effective Leadership Course, LAPD Wilshire Area (1994)
P.O.S.T. Management Gourse (10 days, 1993)
LAPD--West Point Leadership and Command Program (24 days,

1 ee6)
LAPD Command Development Course (24 days, 1998-1999)
Street Survival Seminar, Calibre Press (3 days, Honolulu (1999)
"Leadership in the 21"t Century," presented by the University of

California at Los Angeles, the University of Southern California,
Pepperdine University, and Claremont Universily (12 days, 1999
- 2003)
"Suicide By Cop - Revisited," sponsored by the Peace Officers
Association of Los Angeles County (1 day, 2000)
"
Updated 08125114
Live-fire weapons, dynamic building entry, and drug-lab

investigations, by the Drug Enforcement Administration (DEA), 4 hours
(shooting M4, M441, HK53, AR15), Los Angeles (1 day, 2007)
Pagc I I
MEYER
OOO31

GREG MEYER
NON.LAPD
EXPERT
ACTIVITIES:
Presented multi-media lectures on use-of-force policy, training, equipment,

tactics, ethics, and risk-management processes to:
Peace Officers Association of Los Angeles County (POALAC), "Video

Evidence lssues" seminar (Pending in October 2014)
Peace Officers Association of Los Angeles County (POALAC), use of
force seminar, focusing on Force Science issues, video and body-cam
issues, and TASERs (50 participants) (April 2014)
Americans for Effective Law Enforcement's (AELE) Annual Lethal

and Less-Lethal Weapons seminar, Las Vegas, focused on Force
Science issues (95 participants) (October 2013)
::;i::;:i'iiJJf:i1".":fl
"fi ;*iii:fi ;TT"1i"",sedon
TASER issues and Force Science issues, Santa Ana (CA) (10
participants) (June 2013)
Lorman seminar for plaintiff and defense attorneys and law

enforcement managementn "Police Liability in California," focused on
TASER issues and Force Science issues, Pasadena (CA) (25
participants) (June 2013)
Americans for Effective Law Enforcement's (AELE) Managing,

Oversight and Monitoring of Use of Force, Las Vegas, focused on
TASER issues (135 participants)(April 2013)
Peace Officers Association of Los Angeles Gounty (POALAC), use of
force seminar, focusing on Force Science issues and TASERS
(65 participants) (January 2O13)

and Less-LethalWeapons seminar Las Vegas, focused on Force
Science issues (110 participants) (October 2012)
Peace Officers Association of Los Angeles County (POALAC),
"Critical lncidents: Lessons Learned" seminar, focusing on the BART
shooting/weapons confusion case (55 participants) (July 2012)

enforcement management, "Police Liability in California," focused on
TASER issues and Force Science issues, Santa Ana
(48 participants) (June 2012)
Updated
08125114
Page 12
MEYER
OOO32

GREG MEYER
*
*
Peace Officers Association of Los Angeles County (POALAC), "Video

Evidence lssues" seminar (80 participants) (May 2012)
Travis County Grand Jury (Austin, TX) to educate Grand Jury

members on officer-involved shooting policy, training, tactics, and forcescience issues (February 2012)
*
*
*
*

force seminar, focusing on Force Science issues and TASERS (55
participants) ( Februa ry 20 1 2)
Labor Relations lnformation System (LRIS) annual lnternal Affairs

and Critical lncidents seminar, focus on arrest-related deaths, use-offorce policy, police trainers, involuntary firearms discharges, Las Vegas
(1 10 participants) (November 2011)
Scottsdale (AZ) Police Department supervisors, focus on TASER
issues for supervisors, trainers, and SWAT personnel (25 pafticipants)
(June 2011)
Public Safety Training lnstitute (PSTI), for various "East Bay" (Northern
California) law enforcement agencies, 240 participants (two, 4-hour
seminars) (July 201 1)
*
*
Peace Officers Association of Los Angeles Gounty (POALAC), use of

force seminar, focusing on TASER issues, Glendale, CA, 50 participants,
POST-certified (June 201 1)
lndependent Cities Risk Management Association (ICRMA),

representing 22 cities in the greater Los Angeles Area, 50 participants
(May 20r 1)
n
*

force seminar, focusing on TASER issues, Long Beach, CA, 45
participants, POST-certified (November 201 0)
lnstitute for Law Enforcement Administration (LEA) Use of Force

and Sudden ln-Custody Death Seminar, Plano (TX), 75 participants
(September 2010)
*
"
Updated 08125114
Arroyo Grande (CA) Police Department (with guests from various

Central California Agencies), 40 participants (September 2010)
and Less-Lethal Weapons seminar (formerly: Gritical lncident
Response Management Seminar), Las Vegas (60-275 participants),
usually twice per year (2002 - 2010)
Pagc
13
MEYER
OOO33

GREG MEYER
*
*

force seminar, focusing on TASER and nonlethalweapons issues, 70
participants, POST-certified, Torrance, CA (October 2009)

enforcement management, "Police Liability in California," Santa Ana
(February 2009)
"
Penn State University's Center for Gommunity and Public Safety's

annual seminar for Pennsylvania constables, presenting on the
subject of sudden in-custody death, 150 participants including police
training personnel, attorneys, and judges (November 2008)
lnstitute for Law Enforcement Administration (ILEA) Use of Force

and Sudden ln-Custody Death Seminar, 150 participants, Plano (TX)
(2008)
Annual TASER lnstructor Conference, 280 participants, Chicago

(2oo7)
*
*
*
*
Beverly Hills Rotary Club, lunch speaker, police use of force,

1 20 participants (2007)
Presenter, Pepperdine University public-policy graduate seminar,
20 graduate students, requested by former Los Angeles Police
Commissioner Racquelle de la Rocha (2006)
Presenter and panelist on Tasers and excited delirium, 30 law
enforcement executives and ACLU members, presented by the New York
Civil Liberties Union (Albany) (2006)
Performance lnstitute's 2005 Use of Force Seminar, 30 participants,

Arlington VA (2006)
*
*
*
*
TASER lnternational's Executive Course, 150 participants, Scottsdale

(2005)
TASER lnternational's Annual lnstructor Seminar,
Las Vegas (150 participants) (2002)
Defensive Tactics Newsletter's Annual Training Seminar,

Tallahassee, Florida (25 participants) (2002)
American Society for Law Enforcement Training (ASLET),

lnternational Training Seminar, Anchorage, AK (100 participants) (2002)
Los Angeles County Sheriff's Department training day for 1,2O0

deputies, West Covina, California (2002)
Updated
08125114
Pagc 14
MEYER
OOO34

GREG MEYER
"
*
The Urban Alliance on Race Relations conference, "Alternatives to the

Use of Lethal Force by Police," Ontario, Canada (2000)
Galifornia Association of Police Training Officers (CAPTO), Norwalk,

California; team-teach use-of-force issues with police defense attorney
Michael P. Stone; and panelist with Assistant U.S. Attorney Michael
Gennaco and plaintiff's attorney Stephen Yagman (160 participants)
(2000) (B-hour POST cedified)
American Society for Law Enforcement Training (ASLET),

lnternational Training Seminar, Richmond, VA (200 participants) (2000)
American Society for Law Enforcement Training (ASLET), Regional

Use of Force Seminar, Ontario, California (50 participants) (1999)
"
American Society for Law Enforcement Training (ASLET), Regional

Use of Force Seminar, Los Angeles, California (50 participants) (1997)
"
Sudden ln-Gustody Death Seminar (presenter and panelist), Washington

State Criminal Justice Training Commission (200 participants) (1997)
California Association of Police Training Officers (CAPTO), Regional

Seminar, Fresno, CA (50 participants) (1 996) (8-hour POST-certified)
"
American Society for Law Enforcement Training (ASLET), lnternational

Training Seminar, Grapevine, TX (100 participants) (1996)
"
California Association of Police Training Officers (CAPTO), Annual

Seminar Bakersfield, California (80 participants) (1995)
*
*
American Society for Law Enforcement Training (ASLET), Regional Use

of Force Seminar, Albuquerque, New Mexico (50 participants) (1995)
South East (Los Angeles County) Training Association, at the University
of Southern California (80 participants) (1995)
"
*
*
American Society for Law Enforcement Training (ASLET), lnternational

Training Seminar, Anchorage, Alaska (100 participants) (1995)
Los Angeles Sheriffls Academy, for the California Association of Force
lnstructors (CAFI) (35 participants) (1 994)
Gentral Florida Criminal Justice lnstitute at Orlando (20 participants)
(1
Updated
08125114
ee4)
Orange County Traffic Officers' Association (75 participants) (1994)
Wisconsin Chiefs' Training Seminar (200 participants), Milwaukee ('1993)
Pagc
15
MEYER
OOO35

GRG MEYER
Wisconsin Department of Justice Round Table (35 chiefs and sheriffs),

Osh Kosh (1992)
*
*
Americans for Effective Law Enforcement (AELE) workshop on Critical

Liability lssues (100+ participants), Las Vegas (1991 , 1996, 2000)
Trained and certified more than 375 TASER instructors for dozens of law
enforcement and corrections agencies, for Tasertron (1991
"
*
Updated 08/25114
- 1999)
State-licensed chemical spray trainer, trained hundreds of civilians (1981)

Trained more than 20 TASER users, lnglewood Police Department (1981)
Pagc 16
MEYER 00036

GREG MEYER
OTHER EXPERT
ACTlvlrlES:
Guest on pBS "The News Hour" and NPR Radio in the wake of
controversial use of force incidents in New York and Missouri (August
2014)
Panelist, "Journalist Law School," Loyola Law School, seminar on

how to fairly and accurately investigate allegations of excessive force or
other misconduct, for prominent television and print media from around
the country (40 participants) (May 2014)
lndependent Expert Reviewer, Office of the lnspector General,
Oakland (CA) Police Department, to review and report on selected OPD
use of force cases during internal adjudication and testify at
administrative hearings (2014
present)
Contributing editor, Electronic Control Weapons samples policies,

LAAW lnternational, LLC (2014)
Outside lndependent Expert Advisor, Long Beach (CA) Police

Chief's Community Use of Force Advisory Gommittee
(2013
present)
Edited article on OC (Pepper Spray) issues for Americans for Effective

Law Enforcement's monthly law journal (April 2014)
Participant, Annual Sudden and ln-Custody Death
Conference, presented by the lnstitute for Prevention of ln-Custody
Death, Las Vegas (each November 2005-2013)
Participant, National Conference on Body Cameras, Police Executive
Research Forum (PERF) conference, Washington DC (September 2013)
Donor, "The Greg Meyer Taser Collection," Smithsonian National
Museum of American History, a collection of artifacts and files from
TASER inventor Jack Cover and my personal equipment and files (2013)
Reviewer, United States Environmental Protection Agency
(EPA)/Criminal Investigation Division (GlD) shooting incident (201 3)
Conducted independent external review for the EPA lnspector General re
a shooting involving EPA/CID personnel in Florida (2013)
Consultant, California Peace Officer Standards and Training (POST),

re development of their lesson plan for the officer-involved shooting
investigations course (July 2012)
Updated 08125114
Page
l7
MEYER
OOO37

GREG MEYER
*
*
*
"
*
*
*
"
*
*
*
*
Updated 08125114
Reviewer, two draft National Institute of Justice reports, "Evaluation

of Less Lethal Beanbag Munitions and Launchers" and "Evaluation of
Taser X2," (June 2012)
Contributing editor, "Weapons Gonfusion and Civil Liability" article,

for Monthly Law Journal of American's for Effective Law Enforcement
(AELE) (\/,ay 2012)
Participant, Critical lssues in Policing Series: An lntegrated
Approach to De-Escalation and Minimizing Use of Force, Police
Executive Research Forum (PERF) conference (Washington DC,
February 2012)
lnterviewed by Fox News 11 (Los Angeles) re the value of videotape
evidence; and whether to show it to involved officers before or after
interview; live television, "Studio 11 LA" (January 2012)
Participant, Use of Force, Electronic Control Devices, and lnCustody Death-Formulating a Plan, South Bay Training Committee
(Redondo Beach, CA, January 2012)
Participant, Use of Force Investigation and Risk Management
lecture by attorney Randy Means, Labor Relations lnformation System
(LRIS)seminar (2011)
lnterviewed by Tammi Downey, producer for Discovery Channel
Canada, re forthcoming documentary on electronic controlweapons
(2o11)
Reviewer, Oakland (CA) use-of-force incident
Conducted independent external review for the chief of police re a use-offorce incident involving TASER, pepper spray, and baton (2010)
Participant, Police Executive Research Forum (PERF) meeting to

revise Conducted Energy Device Guidelines and contributor to the
final editing process (Philadelphia) (August 2010)
Edited Force Science News article re the Oakland BART Murder
trial (2010)
Conducted internal affairs investigation for a local police agency to
determine propriety of a TASER use in a street confrontation between an
officer and a subject (2010)
Participant, "The Deadly Mix: 20 Years of Officer Survival
Research," B-hour class by former FBI staff who authored "ln the Line of
Duty," "ln the Line of Fire," and "Violent Encounters"
Pagc
I8
MEYER
OOO38

GREG MEYER
*
*
*
lnterviewed by Karyn MacEwan, producer for Discovery Channel, re

forthcoming documentary on TASER inventor Jack Cover (2010)
Participant, lnternalAffairs and Discipline Seminar, presented by
Americans for Effective Law Enforcement (AELE), Las Vegas (2009)
Participant, New Product Advisory Meeting, TASER lnternational
Headquarters, Scottsdale (2009)
*
*
*
lnterviewed by Hannah Simon, PoliceOne.com, for an article relating

to TASER lnternational's new guidelines for probe target areas (2009)
lnterviewed by Nick Berardini, for a feature-length documentary film
on TASERS (2009)
lnterviewed by Bill Kidd, "Law Enforcement Management Bulletin,"
re TASER policy and training issues for law enforcement executives and
superuisors (2009)
*
*
*
*
n
"
*
*
*
Updated
08125114
lnterviewed by Chuck Remsberg, "Force Sciences News," re TASER

recommendations from the Braidwood report in British Columbia (2009)
Advisor, "Research roundup: Latest on Tasers, arrest-related

deaths, excited delirium," Force Science News Bullelin#127 (2009)
Co-author, "Electronic Control Weapons Model Policy,"
lnternational Association of Chiefs of Police (IACP), revision published in
2010
Participant, TASER Annual lnstructor Conference, including rollout of
the TASER X3 model, Ft. McDowell (AZ) (2009)
External reviewer, TASER lnternational's revision of "Product
Warnings: Law Enforcement" document (July, 2009)
Participant, TASER lnternational's new product line
demonstration including X-REP shotgun (fired it), Shockwave, and
AXON, Los Angeles Sheriff's Academy (2009)
Certified instructor, TASER X-26 (2005, 2009)
Gertified instructor, TASER M-26 (2001, 2003, 2005, 2009)
Participant, TASER Executive Conference, Los Angeles Sheriff's
Academy (March 2009)
Pagc
19
MEYER
OOO39

GREG MEYER
Co-producer and presenter, lnstitute for Law Enforcement

Administration (ILEA) use of force and sudden in-custody death
seminar, Texas (2008)
External reviewer, TASER lnternational's revision of "Product
Warnings: Law Enforcement" document (January & April 2008)
Participant, Jail and Prison Legal lssues Seminar, presented by
Americans for Effective Law Enforcement, Las Vegas (2008)
Guest" TASER Scientific and Medical Advisory Board Meeting (Las
Vegas); participated in discussions of current issues (2007)
Monitored TASER user training for 60 LAPD officers at the

Los Angeles Police Academy, including viewing all officers receive
TASER exposures for training purposes (September 18, 2007)
Edited three articles on Electronic ControlWeapons issues for
Americans for Effective Law Enforcement (see www.aele.orq monthly
law journals for March, April and May (2007)
Peer Reviewer, US Department of Homeland Security's FY 2005

Commercial Equipment Direct Assistance Program (2006)
lnterviewed by Court-TV for a half-hour program on TASERS (2006)

annual conference, attended use of force seminars, Boston (2006)
Reviewer, Police Executive Research Forum national survey on
Officer Safety/Body Armor, sponsored by United States Department of
Justice, Bureau of Justice Assistance (2006)
Radio talk show guest, debating Amnesty lnternational on stun-gun
issues, Station WWRL (New York) (2006)
Participant, TASER Annual lnstructor Conference, Las Vegas (2006)

Participant, lnternalAffairs and Discipline Seminar, presented by
Americans for Effective Law Enforcement (AELE), Las Vegas (2005)
Consultant, TASER issues for Vista Research (2005 - 2008)
Presenter and panelist on the state and future of law enforcement
training, Academy of Criminal Justice Sciences (ACJS), Las Vegas
(2o04)
Updated 08125114
Page20
MEYER
OOO4O

GREG MEYER
Academic Committee member, Americans for Effective Law

Enforcement's "Certified Litigation Specialist" program (20O2
present)
Presented informal session, "Rafael Perez and the LAPD Rampart

Corruption Game," American Society for Law Enforcement Training,
Orlando (2001).
"
n
*
"
*
"
*
Editor, POST instructor-course proposal "Weaponless Defense

Against Gontact Weapons" for Steve Tarani, Edge Defense (2000)
Panelist, "Mass Violence in America: The Law Enforcement
Response," pertaining to Rapid-Response/Active Shooter tactics for
situations like the Columbine school shooting and other in-progress major
incidents, for the American Society for Law Enforcement Training
(ASLET), Richmond, Virginia (2000).
Expert witness and consultant on use-of-force issues (1989
present)
Reviewer and editor for police attorney Michael P. Stone's article,

"Lethal Force and Law Enforcement Activity-Related Deaths-A
Suggested Protocol for Investigation" (1 999)
Peer review panel member, National lnstitute of Justice, forfederal
grant proposals relating to the lmpact of Technology on Policing,
Washington, D.C. (1998)
Presenter, custody-death issues re Price v. San Diego to the California
Association of Force lnstructors (CAFI), Los Angeles (1998)
Co-presenter, "The Value of Videotaped Evidence," American Society

for Law Enforcement Training (ASLET), Los Angeles (1997)
"
Presenter, causes and prevention of sudden in-custody death, to the

California Association of Force lnstructors (CAFI), Beverly Hills, California
(1 ee7)
"
Met with the Director, Science and Technology Division, National

Institute of Justice, on concepts and issues surrounding development of
improved nonlethalweapons policy and technology (1994)
"
Participant in the RAND Corporation's meeting on transfer of lessthan-lethal military technology to civilian law enforcement arena;
and attended the House Armed Services Committee, Research and
Technology Subcommittee hearing on that subject (1994)
Updated
08125114
Pagc 21
MEYER
OOO41

GREG MEYER
Consultant to California Peace Officer Association, Standards and

Ethics Committee on nonlethalweapons policy, tactics and training
issues (1993)
*
*
Consultant to Galifornia Peace Officer Standards and Training

Commission's round table on pepper spray policy and training
standards (1993)
Conducted nonlethalweapons demonstrations and presentations to
the following during 1980-81 :
.
*
California Peace Offcers Association, Admin lnstitutes

California Highway Patrol Academy, including numerous law
enforcement agency and media representatives from the
Sacramento area
: :::::: ::#:iiliiiJii;":i:""T:,,,,"
*
Rio Hondo Police Academy, Whittier
- :rri:Hi*i:li"::"'""'
Chief of Police, Los Angeles
Updaied
08125114
Page 22
MEYER
OOO42

GREG MEYER
lnterviewed by local and national media (1980 - present):
Time
US News & World Report
Police Chief (magazine of lnternational Association of Chiefs of Police)
Los Angeles Times (multiple occasions)
Los Angeles Herald Examiner (multiple occasions)
Los Angeles Daily News
Money Magazine
Good Housekeeping
Grand Junction (CO) Sentinel
Aspen Daily News
Miami Daily Business Review
The Mountain Enterprise
Court-TV
FOX News (Tampa, FL)

POLICE Magazine (multiple occasions)
San Francisco Chronicle
National Public Radio (NPR)
Austin American-Statesman (multiple occasions)
a
a
c
a
)
'a
a
a
a
a
t
a
a
o
.
r
.
r
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
o
.
.
.
.
o
.
.
.
.
Updated 08125114
Police & Security News

Force Science News (multiple occasions)
Law Enforcement Management Bulletin
Nick Berardini (documentary flm on TASERS)
PoliceOne.com
Discovery Channel
KNBC-TV, KABC-TV, KCBS-TV, KTLA-TV, KTTV-TV (Los Angeles)
St. Petersburg Times
Las Vegas Sun Times
The Capital (Anne Arundel, MD)
WNYC Radio (New York)
San Francisco Examiner
Slate
Las Vegas Review Journal
Discovery Channel Canada
KLAS-TV Channel B (Las Vegas)
The Daily (New York)
Fox News 11, 'Studio 11 LA" (Los Angeles)
Tampa Bay Times (multiple occasions)
Columbus (GA) Ledger-Enquirer
Salt Lake Tribune
Associated Press (AP) (multiple occasions)
Baltimore Sun
Longview News-Journal (TX)
The Daily Breeze (CA)
Charlotte (NC) Observer
Tallahassee Democrat
Long Beach (CA) Register
The Today Show (NBC)
RT.com
The News Hour (PBS)
Pagc 23
MEYER
OOO43

GREG MEYER
LAPD
ASSIGNMENT
HISTORY:
Specialist Volunteer, LAPD Training Group

Consultant to the Commanding Officer, Personnel and Training
Bureau, regarding police training issues; member, LAPD Tactics
Training Review Committee
2013 -
2006
2012
Reserve Officer, Los Angeles Police Department

Consultant to the Chief of Police re use of force issues; consultant
to the Director, Police Training and Education re training issues;
experl resource for LAPD Media Relations and Professional
Standards Bureau re use-of-force issues.
2004
-2006 Captain, Training Division (Captain ll)

Line command in partnership with one other captain, more than
300 employees assigned to the three major facilities of the
Los Angeles Police Academy, including nonlethalweapons,
tactics, firearms, pursuit driving, curriculu m development, recruit
coordination (est. 600+ recruits annually), in-service course
coordination (more than B0 courses annually), e-learning
development and implementation. Chairman, Tactics Training
Review Committee. Manage the training of Department
employees and perform a variety of administrative and
coordination functions. Review/adjudicate police pursuits, use of
force and internal affairs cases. Serue as chairman or associate
member of numerous Boards of Rights (internal discipline
tribunals to conduct de novo hearings of internal affairs cases).
Speaker at supervisor, detective, leadership and other schools at
the Police Academy. Work closely with the Police Commission,
the Chief of Police and other high-ranking officials on use-of-force
policy, training, equipment, tactics and post-incident procedures,
including policy and training changes for use of the flashlight as
an impact device, and shooVdon't shoot at moving vehicles, PIT
maneuvers and spike strips. Manage the 2005 re-write of the
LAPD Use of Force Sourcebook. Manage the Revolving Training
Fund ($1.5 million annually). Manage the Police Academy's
relationship with the College of Canyons. Manage the Police
Academy's relationship with the California Peace Officers
Standards and Training Commission (POST) and attend
numerous POST Commission meetings. Manage the LAPDMest
Point Leadership Program. Manage the LAPD Personal
Protection Equipment and Weapons of Mass Destruction
(PPE/VVMD) training program, including liaison with the Los
Angeles County Sheriff's Department and the California
Specialized Training lnstitute (CSTI).
(Retired from active service May 31, 2006;
Updated 08125114
Pagc 24
MEYER
OOO44

GREG MEYER
Reserve Officer 2006

1
999
2004
2012; Specialist Volunteer 2013 - present)
Commanding Officer, Valley Traffic Division (Captain ll)

Line command of more than 200 employees assigned to enforce the
traffic laws, investigate traffic collisions, conduct follow-up
investigations of major injury and fatal collisions, hiUrun collisions,
and arrests, and educate the public about traffic collision prevention
issues. Review/adjudicate police pursuits, use of force and internal
affairs cases. Expert resource for LAPD on pursuit reviews. Serve
as chairman or associate member of numerous Boards of Rights
(internal discipline tribunals to conduct de novo hearings of internal
affairs cases). Review and approve probationary officer rating
reports. Liaise with community groups, politicians, the insurance
industry, transportation engineers, surrounding police agencies, and
others to reduce deaths and injuries on our highways. Deploy field
forces to perform the traffic safety, enforcement and collision
investigation mission in a manner that simultaneously assists patrol
divisions with their crime control activities. Task Force coordinator
for crime-suppression operations throughout the San Fernando
Valley (2002-2004\.
1998-1999
Commanding Officer, North Hollywood Operations Support

Division (Captain l)
Line command of 95 employees assigned to detectives, vice,
CRASH, bikeihype detail, career criminal apprehension,
n-service trai ni ng coordination, probationary officer traini ng
coordination including approval of probationary rating reports and
cou n sel i n g u nsati sfactory probati onary offi cers, personnel
investigations, and crime analysis. Review/adjudicate pursuits, use
of force, and internal affairs cases. Serve as chairman or associate
member of numerous Boards of Rights (internal discipline tribunals to
conduct de novo hearings of internal affairs cases). Area liaison to
the North Hollywood business and security communities. Act for the
Area Commanding Officer in his absence. Creator of the 'Sprke
Busfers/"crime-control program in supportof the FASTRAC
command-accountability process. Act for the Area commanding
officer in his absence.
i
1996
- 1998
Watch Commander, West Traffic Division (Lieutenant)

Line supervision of 90 employees, including 10 sergeants assigned
to collision investigation, traffic enforcement, community traffic
services. Act for the commanding offcer in his absence. Oversee
implementation and effectiveness of goals and expectations for
employee prod uctivity and work qual ity. Review/adj udicate pursuits,
use of force, and internal affairs cases. Monitor and rate the work of
supervisory employees. lnstrumental in development and
implementation of the division's Vision and Mission Statements, and
the Strategic Plan.
Updated
08125114
Pagc25
MEYER
OOO45

GREG MEYER
1994 - 1996
Assistant Commanding Officer, Wilshire Detective Division

(Lieutenant)
Line supervision of 90 employees, and coordination responsibilities for

follow-up investigations including murder, manslaughter, rape, robbery,
aggravated assault, burglary, auto theft, juvenile matters, and other
crimes. Act for the commanding officer in his absence. Monitor and
evaluate the work of supervisory employees. Leader of the OperationsWest Bureau Detective Mobile Field Force during emergency operations.
Review/adjudicate pursuits, use of force, and internal affairs cases.
1993 - 1994
Patrol Watch Gommander, Wilshire Area (Lieutenant)

Line supervision for patrol sergeants and officers responding to
emergencies and handling basic calls for service. Take field command
of major tactical incidents. Supervise the division's probationary officer
training coordinator, approve probationary rating reports and conduct
feedback and counseling to satisfactory and unsatisfactory probationary
officers. Monitor and rate the work of supervisory employees.
Review/adjudicate pursuits, use of force, and internal affairs cases. Act
for the commanding offcer in his/her absence.
1991
- 1993
AdjutanUAide to the Commanding Officer and the Assistant

Commandin g Officer, Operations-Headquaers Bureau
(Senior Sergeant)
Perform administrative functions (including review of internal affairs, use
of force, and pursuit investigations) for the command that includes
specialized detective functions, narcotics, SWAT, Metropolitan Division,
Air Support Division, Tactical Planning Section, and Traffc Coordination
Section.
1989
1991
Adjutant to the Commanding Officer, Detective Support

Division (Senior Detective)
Perform administrative functions (including review of internal affairs and
use of force investigations) for the command that includes Special
lnvestigation Section, Criminal Conspiracy Section, Gang lnformation
Section, FugitiveMarrant Section, and Asian Crime lnvestigation
Section.
1988 - 1989
Field Detective, Hollywood Area (Detective)

Conduct follow-up investigations on reports of crime.
1986 - 19BB
Assistant Officer-in-Charge, Traffic Coordination Section (Senior

Sergeant)
Line supervision for the Traffic Legislation and Special Projects Unit. Act
for the officer-in-charge in his absence. Monitor and rate the work of
supervisory employees. Supervised work on LAPD pursuit policy revisions.
Supervised the Specialized Collision lnvestigation Detail (SCID) re major
accidents involving the Police and Fire Departments, including pursuits.
Updated 08125114
Pagc 26
MEYER 00046

GREG MEYER
Authored the Office of Operations Management Paper, "1987-The Year of

Traffic Enforcement" and several articles for the Chief of Police.
985 -
1986
Officer-in-Gharge, Prostitution Enforcement Detail,

Hollywood Vice (Sergeant)
Line supervision and performance evaluation for personnel assigned to
suppress street prostitution in Hollywood Area.
1984 -
1985
Officer-in-Charge, Hollenbeck Footbeats; and
Patrol
Supervisor
(Sergeant)
Line supervision and performance evaluation for uniformed personnel

assigned to footbeat patrols in several housing projects and business
districts; and perform general patrol supervision. Officer-in-chargeof field
transportation detail in the ColiseumiUSC/Exposition Park venue during the
1984 Olympic Games.
1982
1984
Detective Trainee, Hollywood Area (Police Officer Ill)

Gonduct follow-up investigations on reports of crime (robberies, sexual
assaults, auto-related crimes, burglaries and thefts). Honored as the 1983
Hollywood Detective of the Year.
1981 -
1982
Researcher, Tactical Planning Section (Police Officer lll)

Author of LAPD's Watch Commander's Guide for Control of Disasters and
Other Emergencies, as well as numerous other staff research projects. Field
command post equipment driver.
1980 -
1981
Field Training Officer, Venice Area (Police Officer lll)

Train, evaluate and document the performance of probationary police
officers, respond to calls for service and conduct general patrol functions.
1979 -
1980
Staff Researcher/Adjutant, Planning and Research Division

(Police Officer ll and lll)
Primary researcher and field-test coordinator, LAPD's nonlethal
weapons program including TASER, teargas sprays, other devices.
Demonstrate these devices to police managers, political officials, and the
media. Write LAPD policy and training material on nonlethal weapons.
Train front-line supervisors as users of these devices. Author of numerous
other staff projects. Perform administrative functions for the commanding
officer.
1978 -
1g7g
Patrol Officer, Southwest Area (Police Officer I and ll)

Respond to calls for service and conduct general patrol functions.
1978
1977 -
1978
Recruit Officer ( Police Officer l)

Patrol Officer, Long Beach Police Department (Police Officer)
Updated 08125114
Pagc27
MEYER
OOO47

GREG MEYER
1976
1977
Reserve Police Officer, Wilshire Area (Line Reserve Officer)

PARTIAL
BIBLIOGRAPHY: [redacted to most recent
10 years]
"Tactics and science of TASER deployment," article, PoliceOne.com

(January 2014)
"Lessons from the Onion Field," article, POLICE Magazine online
(March 2013)
"Latest Medical Research on TASERs," article, PoliceOne.com

(October 2012)
"Video Evidence lssues: Conflict and ControVt'S," article,
PoliceOne.com (June 2012)
"The L.A. Riot
- 20 Years
Later," article, POLICE website (April 2012)
"Training Crisis," editorial, ghost-written for the publisher, POLICE

magazine (April2012)
"TASER Drive-Stun Heading to US Supreme Court?" article,

PoliceOne.com (Februa ry 2012)
"The 'Occupy' Movement and Your Agency Response," article,

POLICE website (December 2011) and magazine (January 2012)
"TASER ECW Basics," article, PoliceOne.com (November 2011)
"Tactical Ghallenge: Suicidal Person with a Knife," article,

PoliceOne.com, (June 201 1)
"PERF Updates lts Electronic ControlWeapons Guidelines," article,

PoliceOne.com (April 201 1)
"Rodney King: 20 Years Later," article, PoliceOne.com (March 2011)
"Two Major TASER Cases on Appeal at the 9th Circuit," article,

PoliceOne.com (January 201 1)
"Analysis of the BART Cop's 2-Year Prison Sentence," article,

PoliceOne.com (November 201 0)
Updated 08125114
Pagc 28
MEYER
OOO48

GREG MEYER
"The BART Shooting Tragedy: Lessons to be Learned," article,

PoliceOne.com (July 201 0)
"Getting lt Off My Chest: TASER's New Aiming Guidelines," article,

PoliceOne.com (Oct. 2009)
"Why History Makes the Case for Less Lethal," article, PoliceOne.com
(Sep. 2009)
"The AMA Takes on TASER Tactics," article, PoliceOne.com (Aug.

200e)
"The UCLA Library lncident-Revisited," article, PoliceOne.com (Jun.

200e)
"Emergency Room Doctor Survey re Police 'Excessive Force' . . .

Ouch!" article, PoliceOne.com (Apr. 2009)
"Conducted Energy Weapons: A User's Perspective," chapter for
TASER@ Electronic Control Devices: Physiology, Pathology, and
Law, in collaboration with numerous doctors and medical examiners, a

32-chapter book (published by Springer, Mar. 2009) ******
"TASER lnventor Jack Cover, Rest in Peace," article, PoliceOne.com
(Mar.2009)
"The Latest Amnesty lnternational Report on Electronic Weapons,

article, PoliceOne.com (Dec. 2008)
"Another Federal Court Supports Officers in TASER Lawsuit,"

article, PoliceOne.com (Oct. 2008)
"TASER lncidents in the News," article, PoliceOne.com (Sept. 2008)
"Telling Your Story," article, PoliceOne.com (August 2008)
"A Ghecklist to Enhance Your Nonlethal Weapons Program," journal

article, California Peace Officer, (Fall 2008)
"Nonlethal Weapons: The Promise and the Challenge," journal article,

Law Enforcement Executive Forum (July 2008)
"Little Words, Big Consequences," article, PoliceOne.com (June 2008)

"Court Backs TASER Use," article, PoliceOne.com (April 2008)
"Taking on the Media," article, PoliceOne.com (February 2008)
Updated
08125114
Pagc29
MEYER
OOO49

GREG MEYER
"Tons of TASER News," article, PoliceOne.com (October 2007)

"TASER Tactics, Training lnjuries, and the Kitchen Sink," article,
PoliceOne.com (August 2007)
"Do Away with the Anyways," article, PoliceOne.com (June 2007)

"They're Still Out There," article, PoliceOne.com (April 2007)
"One-on-One, in the Backyard," article, PoliceOne.com (Feb. 2007)
"The Gap: How Loss of the Neck Restraints Led to the Rodney King
lncident," article, PoliceOne.com (January 2007)
"Rodney King Revisited," article, PoliceOne.com (December 2006)
"Police Force, in Golor," article, published on the LAPD website blog

(mentioned by the Los Angeles Times 11-14-06), also published under
various titles by PoliceOne.com, American Police Beat, and The Beat
(LAPD) (November-December 2006)
"TASER Tactics Update," article, PoliceOne.com (October 2006)
"Caught on Tape . . . Nice Save!" article, PoliceOne.com (September

2006)
"Resources for Sudden ln-Custody Deaths," article, PoliceOne.com

(August 2006)
"Tactical Hindsight: Tactics and equipment have improved in the last

30 years, but the job of law enforcement remains the same," article,
POLICE magazine's 30th anniversary issue (October 2006)
"Horsing Around and Weapons Retention," article, PoliceOne.com (July

2006)
"Hands-on versus Nonlethal Weapons," article, PoliceOne.com (June

2006)
"Nonlethal Weapons: Early use means fewer deaths and injuries,"

article, PoliceOne.com (May 2006)
"Nonlethal or Less-Lethal: Does it matter?" article, PoliceOne.com (April
2006)
"NonlethalWeapons: What's Up?" article, PoliceOne.com (March 2006)

"Train to Win Quickly," article, "Police" magazine (November 2004)
Updated 08125114
Pagc 30
MEYER
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GREG MEYER
LITIGATION
ACTIVITIES:
CASES:223
Shooting
ARD**
DEPOSED:43
Excessive
TASER
ESTIFIED:40
False
Pursuit
Jail/Prison
Other
11
17
Arrest
Force
CIVIL
For Pltf
11
For Deft
34
23
134
79
t6
CRIMINAL
For Pros
For Deft
ADMIN
tJ
For Deot
For Ofcr
163
98
Grand Jurv
TOTAL
46
24
* Numerous cases involved multiple
lssues
28
12
27
*" ARD arrest-related death, non-shooting

=
[redacted to list testimony of past 4 years]

Fowler v. State of Galifornia (CA) (2013) (Federal)
Expert witness for the defense, civil suit alleging excessive force during a DUI
arrest (Testifed.)
Atencio v. Arpaio, et al. (AZ) (2013) (Federal)

Expert witness for the defense (City of Phoenix defendants), civil suit excessive
force, arrest-related death, TASER issues (Deposed)

Tatro v City of Paso Robles (CA) (2013)
Expert witness for the defense, civil suit alleging employee harassment,
retaliation, imposition traffic citation quotas by a police agency (Deposed)
Bieg v. Gity of Springfield (MO) (2013) (Federal)

Expert witness for the defense, civil suit alleging excessive force, TASER
involved (Deposed)
Gonzales-Guerrero v. Gity of San Jose (CA) (2013) (Federal)

Expert witness for the defense, civil suit alleging excessive force, nonfatal officerinvolved shooting (Deposed)
Coto and Molina v. County of Los Angeles (CA) (2012) (Federal)

Expert witness for the defense, civil suit alleging excessive force resulting in
arrest-related death, TASER involved (Deposed)
Sparks and Murr Administrative Appeal (CO) (2012)

Expert witness for the City of Denver, administrative appeal of discipline imposed
on two offcers in a use-of-force incident (Testifed)
Updated
08125114
Pagc
3I
MEYER
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GREG MEYER
(2012) (Federal)
Expert witness for the defense, civil suit alleging excessive force during arrest,
TASER issues (Deposed)
Tapia v. Skarupinski (lL)
Travis Gounty Grand Jury (TX) (2012)

Grand Jury testimony on officer-involved shooting policy, training, tactics, and
force-science issues while it reviewed a fatal officer-involved shooting case

(Testified)
Bravo v. City of Santa Maria (CA) (2012) (Federal)

Expert witness for the defense, civil suit alleging deficiencies in a search warrant
(Deposed)
Moore v. Desert Hot Springs Police Department (CA) (2011)

Expert witness for the plaintiff and the defense: civil case involving police pepperspray use and excessive force; my role was merely to explain pepper-spray
basics to the jury. (Testifed)
United States v. Sclafani (CA) (2011)

Expert witness for the prosecution and the defense, criminal case involving police
TASER use and excessive force; my role was merely to demonstrate TASER and
explain to the jury how it works. (Testifie.)
Wasilchen v. Snohomish County (WA) (2011) (Federal)

Expert witness for the defense, civil suit alleging wrongful death arising out of a
fatal officer-involved shooting (Deposed)
(M) (2011) (Federal)

Expert witness for the defense, civil suit alleging excessive force, nonfatal
officer-involved shooting (Deposed)
F.G. v. City of Phoenix
Pixley v. Tavallodi (CA) (2011)

Expert consultant for the defense, civil suit alleging wrongful death, fatal
security-offcer-involved shooting (Deposed; testifed)
Madrigal v. City of Santa Maria and Gounty of Santa Barbara (CA) (201 1) (Federal)
Expert witness for the defense of the city and the county, civil case alleging
excessive force and false arrest by personnel from both agencies. (Testified)
(M) (2011) (Federal)

Expert witness for the defense, civil suit alleging malicious prosecution and civil
rights violations stemming from alleged false arrest and perjury by a police
detective (Deposed)
Rehkow v. City of Phoenix
Guizan v. Town of Easton (CT) (2011) (Federal)

Expert witness for the defense of a police chief, captain, and offcer, civil suit
alleging deficiencies in a search warrant; and excessive force regarding
management decision-making during a multi-agency crisis entry with flash-bangs
deployed, fatal offcer-involved shooting (Deposed)
Maclntosh v. Gounty of Ventura (CA)(2010) (Federal)

Expert witness for the defense, civil suit alleging excessive force during arrest
(Deposed)
Updated
08125114
Page32
MEYER
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GREG MEYER
Deputy Dobbins admin appeal(WA) (2010)

Expert witness for the officer in an administrative hearing related to
discipline resulting from a TASER weapons-confusion incident. (Testified)
Shreve v. Franklin County (OH) (2010) (Federal)

Expert witness for the defense, civil suit arising out of TASER uses in the jail,
multiple plaintiffs (Deposed in 2010;deposed in2012)
Remato v. City of Phoenix (AZ) (2010) (Federal)

Expert witness for the defense, civil suit arising out of a fatal officerinvolved shooting (Testifed)
Arambula v. City of Phoenix (AZ) (2010) (Federal)

Expert witness for the defense, civil suit arising out of a nonfatal offcerinvolved shooting (Deposed.)
Oakes v. DeKalb County (GA) (2010)(Federal)

Expert witness for the defense, civil suit arising out of a fatal officerinvolved shooting (Deposed)
Salinas v. Gity of San Jose (CA) (2010) (Federal)

Expert witness for the defense, civil suit arising out of an arrest-related death,
TASER issues (Testified)

Wozniak v. State of Arizona, City of Glendale, et al (AZ) (2010)
Expert witness for the defense, civil suit arising out of an excessive force claim,
TASER issues (Deposed)

People v. Hanafi and Liggins (CA) (2010)
Expert witness for the defense on the issue of an alleged assault by use of a
stun-gun (Testified)
Williams v. Gity of Mesa (AZ) (2010)(Federal)

Expert witness for the defense, civil suit alleging excessive force (Deposed,
settled.)
Vasquez v. City of Santa Paula (CA) (2010) (Federal)

Expert witness for the defense, civil suit alleging excessive force, TASER
issues (Testified)
Ahmad v. State of Arizona (AZ) (2010)

Expert witness for the defense, civil suit arising out of a fatal pursuit
(Deposed, testified)
Former Orange Gounty Sheriffls Deputy Hibbs arbitration (GA) (2010)

Expert witness for the appellant who was terminated from employment
following a use-of-force incident, TASER issues. (Testified)
Gomez v. City of Torrance (CA) (2009) (Federal)

Expert witness for the defense, fatal offcer-involved shooting. (Deposed)
Updated 08125114
Pagc 33
MEYER
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GREG MEYER
Hirschfield v. San Diego Unified Port District (CA) (2009) (Federal)

Expert witness for the defense, fatal offcer-involved shooting, TASER issues.
(Deposed)
Dill v. City of Shreveport (LA) (2009) (Federal)

Expert witness for the defense, fatal offcer-involved shooting. (Deposed)
State of Louisiana v. Christopher Marlowe (LA)2009
Expert witness for the defense, security offcer accused of attempt murder
(shooting). (Testified)
People v. Orange Gounty (GA) SherifPs Deputy Hibbs (2009)
Expert witness for the criminal defense, deputy accused of excessive force,
TASER issues. (Testified)

People v. Former BART Officer Mehserle (CA) (2009)
Expert witness for the criminal defense, fatal offcer involved shooting, offcer
accused of murder, TASER issues. (Testified)
(AZ) (2008) (Federal)

Expert witness for the defense, use of force involving fleeing burglary suspect
(Deposed; testifed)
La Voie v. City of Mesa
Verna v. Gounty of Orange, CA (2008)

Expert witness for the defense in a civil suit arising out of use of a TASER in the
jail. (Deposed, testifed)
Updated 08125114
Pagc 34
MEYER
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Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 1 of 61

R. BLAKE HAMILTON, Utah Bar No. 11395

UNITED STATES DISTRICT COURT

United States of America,

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

Town of Colorado City, Arizona; City of

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

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 2 of 61

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

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

Ordinances and Resolutions, intergovernmental agreements, Twin City Improvement

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

Specifically, his testimony is expected to conform to his deposition

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

interactions with Jethro Barlow and Willie Jessop.

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

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

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

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

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

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 4 of 61

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

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

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

that religion is not a motivating factor for Defendants.

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 5 of 61

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

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

that religion is not a motivating factor for Defendants.

(including water) to residents of Colorado City.

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 6 of 61

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

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

decision to terminate his employment; and all related issues.

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

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

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 7 of 61

not a motivating factor for Defendants.

Marshals Department, Colorado Citys investigation into allegations against former

meetings, and all related issues.

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 8 of 61

communications and interactions with Bruce Wisan and employees or representatives of

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 9 of 61

knowledge and observations of FLDS Church directives regarding new building

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 10 of 61

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

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

not a motivating factor for Defendants.

education, and experience as an officer.

He is also expected to testify about his

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

observations of the Marshals Departments policies and practices regarding locating

whereabouts; his knowledge and investigation of missing persons complaints and

Marshals Department conducted investigations, or assisted with the on-going

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

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

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

not a motivating factor for Defendants.

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

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

not a motivating factor for Defendants.

Case 3:12-cv-08123-HRH Document 770 Filed 11/12/15 Page 13 of 61

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

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