Justice Department witness list

8/20/2019 Justice Department witness list

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Steven H. Rosenbaum (NY Bar #1901958)Judy Preston (MD Bar)R. Tamar Hagler (CA Bar #189441)Christy E. Lopez (DC Bar #473612)Eric W. Treene (NY Bar #2568343)Sean R. Keveney (TX Bar #24033862)Jessica Clarke (NY Bar #4694972)Matthew J. Donnelly (IL Bar #6281308)Emily M. Savner (NY Bar #5214358)Sharon I. Brett (NY Bar #5090279)United States Department of Justice950 Pennsylvania Avenue, NWWashington, DC 20530Phone: (202) 305-4013Facsimile: (202) 514-1116

E-mail: [email protected]

Attorneys for the United States

IN THE UNITED STATES DISTRICT COURT FOR THEDISTRICT OF ARIZONA

United States of America,

Plaintiff;v.

Town of Colorado City, Arizona, et al.,

Defendants.

No. 3:12cv8123-HRH

UNITED STATES’ TRIAL

WITNESS LIST AND

DESIGNATION OF

DEPOSITION TESTIMONY

Pursuant to the Court’s order of July 24, 2015, ECF No. 626, the United States

submits the following list of witnesses it intends to call at trial.

1. Isaac Wyler

Mr. Wyler is a fact witness. He is a former member of the FLDS Church, a long-

time resident of the Colorado City/Hildale community, and works for the United Effort

Plan Trust (“UEP Trust”). He is expected to testify regarding claims and facts alleged in

the United States’ Complaint in this case, as well as the matters discussed in his

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 1 of 24


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deposition and trial testimony in Cooke v. Town of Colorado City, 3:10-cv-08105 (D.

Ariz.). In particular, his testimony will include: his excommunication from the FLDS

Church; tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS

Church; instructions and directives from FLDS leaders; consequences of losingmembership in the FLDS Church; the treatment of non-FLDS members living in the

community by Defendants’ city officials, FLDS Church Security, the CCMO, and other

community members; the FLDS’ opposition to Bruce Wisan and his administration of

the UEP Trust; the CCMO’s failure to enforce UEP Trust Occupancy Agreements;

FLDS leaders’ control over the Cities; the CCMO’s failure to respond to vandalism of

UEP Trust property; Defendants’ interference with the administration of the UEP Trust;

the CCMO’s refusal to investigate or arrest FLDS individuals for trespass; his

prosecution by the Cities for allegedly trespassing on UEP Trust property while working

for the UEP Trust at that time; his knowledge of Ron and Jinjer Cooke’s inability to

secure a water connection from the Cities; his knowledge of other homes and buildings

on UEP Trust property that received water connections; his knowledge of building

permits received for homes and businesses on UEP Trust property; and his knowledge of

homes, buildings, utilities, businesses, and individuals on UEP Trust property.

2. Richard Holm

Mr. Holm is a fact witness. He is a former member of the FLDS Church and a

long-time resident of the Colorado City/Hildale community. He is expected to testify

regarding claims and facts alleged in the Complaint, as well as the matters discussed in

his deposition and trial testimony in Cooke. In particular, his testimony will include: his

excommunication from the FLDS Church; tenets of the FLDS religion; how Warren

Jeffs became the leader of the FLDS Church; instructions and directives from FLDSleaders; consequences of losing membership in the FLDS Church; the treatment of non-

FLDS members living in the community by Defendants’ city officials, FLDS Church

Security, the CCMO, and other community members; his experiences as a Hildale City

councilmember and the control the FLDS Church had over the City; the CCMO’s

handling of a trespass complaint at a property for which Mr. Holm had a UEP Trust



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Occupancy Agreement; and his arrest by the CCMO for criminal trespass at a

commercial property to which he had title and the County Attorney’s subsequent

decision to decline to prosecute that charge.

3.

Robert Foster Mr. Foster is a fact witness. He is a FBI agent who helped search for and

apprehend Warren Jeffs. Agent Foster is expected to testify regarding claims and facts

alleged in the Complaint, as well as the matters discussed in his testimony in Cooke. In

particular, his testimony will include the law enforcement search for fugitive Warren

Jeffs; the CCMO and other Defendant employees’ resistance to capturing Warren Jeffs;

and foundational testimony to admit letters and other documents from that search,

including documents seized from Seth Jeffs’s vehicle and documents and items seized at

the time of Warren Jeffs’s arrest.

4.

Charlene Jeffs

Ms. Jeffs is a fact witness. She is a former member of the FLDS Church and the

ex-wife of FLDS Bishop Lyle Jeffs. Ms. Jeffs is expected to testify regarding claims

and facts alleged in the Complaint, as well as the matters discussed in her deposition. In

particular, her testimony will include: tenets of the FLDS religion; instructions and

directives from FLDS leaders; consequences of losing membership in the FLDS Church

and the United Order; the CCMO’s involvement in her child custody dispute and legal

proceedings involving Lyle Jeffs; FLDS Church directives regarding the selection of

CCMO officers; CCMO officers consecrating money for fugitive Warren Jeffs; CCMO

reporting law enforcement information to Lyle Jeffs; Lyle Jeffs’s phone calls requesting

license plate checks of vehicles; membership of CCMO officers and Defendants’ city

officials in the FLDS Church, United Order, and FLDS Church Security; former TownCouncil member Vergel Steed’s role in facilitating the separation of non-United Order

members from their United Order family members; ECO Alliance’s relationship to the

FLDS Church; then Town Council Member Kimball Barlow’s role in administering the

Bishop’s Storehouse; Isaac and Nephi Jeffs’s role as messengers between imprisoned



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Warren Jeffs and Bishop Lyle Jeffs; and Warren Jeffs’s role in directing the Church

from prison.

5.

Dowayne Barlow

Mr. Barlow is a fact witness. He is a former member of the FLDS Church and aformer aide to FLDS Bishop Lyle Jeffs. Mr. Barlow is expected to testify regarding

claims and facts alleged in the Complaint, as well as the matters discussed in his

deposition. In particular, his testimony will include: his departure from the FLDS

Church; tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS

Church; instructions and directives from FLDS leaders; consequences of losing

membership in the FLDS Church and United Order; the treatment of non-FLDS

members living in the community by Defendants’ city officials, FLDS Church Security,

the CCMO, and other community members; his knowledge and experience with FLDS

Church Security; the surveillance conducted by FLDS Church Security of non-FLDS;

the coordination between the CCMO and FLDS Church Security, including by sharing

surveillance equipment and information in law enforcement databases; harassment of

non-FLDS members by FLDS Church Security; participation by Defendants’ city

officials in FLDS Church Security; FLDS directives to separate family members,

including the families of Defendants’ city officials and CCMO officers; membership of

CCMO officers and Defendants’ city officials in the FLDS Church; the operation of the

Bishop’s Storehouse and illegal activity conducted out of the Storehouse; and

Defendants’ city officials and CCMO officers consecrating money for fugitive Warren

Jeffs.

6.

John Nicholas Hanna

Mr. Hanna is a fact witness. He is a Texas Ranger with the Texas Department ofPublic safety who was involved in the criminal investigations and conviction of Warren

Jeffs. Ranger Hanna is expected to testify regarding claims and facts alleged in the

Complaint, as well as the matters discussed in his testimony in Cooke. In particular, his

testimony will include the criminal investigation regarding Warren Jeffs, the conviction,

and Warren Jeffs’s communications and activities during his incarceration in Texas; the



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CCMO and other Defendant employees’ resistance to helping with the criminal

investigations of Warren Jeffs; and foundational and explanatory testimony to admit

FLDS priesthood records and other documents uncovered during the criminal

investigation of Warren Jeffs, including documents seized from the YFZ Ranch.7. Jennifer Smith

Ms. Smith is a fact witness. She is a mail room employee in prisons run by the

Texas Department of Criminal Justice. In particular, Ms. Smith will be asked to

authenticate documents sent to or from Warren Jeffs during his incarceration. Ms. Smith

will also testify about the amount of mail Warren Jeffs receives and how he selects the

mail he reads.

8.

Rosemarie Urbanski

Ms. Urbanski is an expert witness for the United States. She is a forensic

scientist and owner of The Drake Group. She has expertise in handwriting identification

and analysis. Her additional qualifications are attached. Ms. Urbanski is expected to

testify consistent with the expert opinions provided in her reports and deposition in this

case. In particular, her testimony will cover the authentication of documents signed by

Joseph Allred, George Barlow, and Vance Barlow.

9. Willie R. Jessop

Mr. Jessop is a fact witness. He is a former member of the FLDS Church, the

former Legal Coordinator for Church affairs, and the former head of Church Security.

Mr. Jessop is expected to testify regarding claims and facts alleged in the Complaint, as

well as the matters discussed in his deposition. In particular, his testimony will include:

his decision to leave the FLDS Church; tenets of the FLDS religion; how Warren Jeffs

became the leader of the FLDS Church; instructions and directives from FLDS leaders;consequences of losing membership in the FLDS Church; the treatment of non-FLDS

members living in the community by Defendants’ city officials, FLDS Church security,

the CCMO, and other community members; his knowledge and experience with FLDS

Church Security; the surveillance conducted by FLDS Church Security of non-FLDS;

the coordination between the CCMO and FLDS Church Security, including training



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FLDS Security and the sharing of surveillance equipment and information in law

enforcement databases; harassment of non-FLDS members by FLDS Church Security;

participation by Defendants’ city officials in FLDS Church Security; FLDS directives to

separate family members, including the families of Defendants’ city officials andCCMO officers; interactions with Defendants’ city officials and FLDS leaders at R&W;

the identification of signatures of Defendants’ city officials; the arrest of Harvey

Dockstader; Defendants’ city officials and FLDS leaders conspiring or agreeing to use a

water shortage as a pretext for discrimination; FLDS and CCMO involvement in the

burglary of R&W Construction, Inc. in 2011; FLDS and CCMO involvement in an

alleged burglary at ECO Alliance and an alleged home invasion at a home on Johnson

Ave.; and FLDS and CCMO involvement in the theft of two vehicles and their contents

from Mr. Jessop’s home.

10.

Gary Wilbanks

Mr. Wilbanks is a fact witness. He is an agent with the Texas Office of Inspector

General. His testimony will include: the authenticity of audio recordings of Warren

Jeffs taken at the Powledge Unit of the Texas Department of Criminal Justice; the timing

and frequency of various individuals’ visits with Warren Jeffs while Warren Jeffs has

been imprisoned at the Powledge Unit, including Isaac and Nephi Jeffs; Texas

Department of Criminal Justice policy concerning visitation with prisoners, including

dress code and jewelry; information concerning visitors of Warren Jeffs recording

conversations with him via wrist watch recorders; and Warren Jeffs’ violation of prison

rules regarding communications.

11.

Isaac Jeffs

The United States will offer Mr. Jeffs’ deposition testimony in lieu of livetestimony at trial. The United States designates the follow deposition testimony by page

and line numbers:

16:23-16:25

19:14-20:13

21:17-22:14

27:18-28:1

32:2-33:1

33:13-36:8



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38:2-38:7

38:19-47:5

47:12-48:13

48:20-48:25

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51:22-52:1

53:15-54:2

58:10-58:14

61:5-69:9

70:7-71:9

74:10-76:5

79:12-83:17

83:19-85:6

85:24-86:4

87:23-88:12

88:14-91:11

93:5-93:21

94:11-99:15

99:25-102:9

12.

Guy Timpson

Mr. Timpson is a fact witness. He is former member of the FLDS Church, a

former member of the Utility Board, a former member of FLDS Church Security, and

the former president of Pure Ph8, a water bottling company in Hildale. He is expected

to testify regarding his knowledge of claims and facts alleged in the Complaint, and

matters discussed in his depositions in this case and in Cooke and his trial testimony in

Cooke. In particular, his testimony will include: FLDS leaders’ control of the Cities,

TCWA, TCWW, Inc., and the CCMO; FLDS’s treatment of non-FLDS; his knowledge

and experience with FLDS Church Security; the surveillance conducted by FLDS

Church Security of non-FLDS; the coordination between the CCMO and FLDS Church

Security, including by sharing surveillance equipment and information in law


participation by Defendants’ city officials in FLDS Church Security; his knowledge of

Pure Ph8 and its water connection; his knowledge of the Cities’ discriminatory water

policy and the Cities’ enforcement of that policy; the Cities providing a new water

connection to Twin City Improvement Association; his experiences on the Utility Board;

consequences of losing membership in the FLDS Church and United Order; his

termination from the Utility Board after he was no longer a member of the FLDS

Church; and the Cities’ opposition to the administration of the UEP Trust.

13.

Thomas Jeffs

Mr. Jeffs is a fact witness. He is a former member of the FLDS Church and the

son of FLDS Bishop Lyle Jeffs. Mr. Jeffs is expected to testify regarding claims and



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facts alleged in the Complaint, as well as the matters discussed in his deposition. In

particular, his testimony will include: his excommunication from the FLDS Church;

tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS Church;

instructions and directives from FLDS leaders; consequences of losing membership inthe FLDS Church; the treatment of non-FLDS members living in the community by

Defendants’ city officials, FLDS Church Security, the CCMO, and other community

members; his knowledge and experience with FLDS Church Security; the surveillance

conducted by FLDS Church Security of non-FLDS; the coordination between the

CCMO and FLDS Church Security, including by sharing surveillance equipment and

information in law enforcement databases; harassment of non-FLDS members by FLDS

Church Security; participation by Defendants’ city officials in FLDS Church Security;

FLDS directives to separate family members, including the families of Defendants’ city

officials and CCMO officers; membership of CCMO officers and Defendants’ city

officials in the FLDS Church and United Order; the operation of the Bishop’s

Storehouse and illegal activity conducted out of the Storehouse; and Defendants’ city

officials and CCMO support for fugitive Warren Jeffs.

14. Lyle Mann

Mr. Mann is a fact witness. Mr. Mann is the Director of Arizona Peace Officer

Standards and Training Board. Mr. Mann is expected to testify regarding which CCMO

officers have been decertified since 2003, and the factual findings and reasons for each

decertification.

15.

Vincen Barlow

Mr. Barlow is a fact witness. His is a former member of the FLDS Church and

the former City Manager for Hildale. Mr. Barlow is expected to testify regarding claimsand facts alleged in the Complaint, as well as the matters discussed in his depositions

and Cooke testimony. In particular, his testimony will include: tenets of the FLDS

religion; how Warren Jeffs became the leader of the FLDS Church; instructions and

directives from FLDS leaders regarding city business and picking officials of the Cities;

Defendants’ city officials sharing information with FLDS leaders; intermingling of



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Church and Hildale records; consequences of losing membership in the FLDS Church

and United Order; treatment of non-FLDS members by Defendants’ city employees;

authentication of documents produced or created by Hildale and TCWA; knowledge of

and experience with Church Security, including coordination and training with theCCMO, participation by Defendants’ city officials, video surveillance and harassment

of non-FLDS members; the Bishop’s Storehouse and illegal activity conducted out of

the Storehouse; FLDS directives to cities to oppose efforts of UEP Trust Special

Fiduciary Wisan; the Cities’ water policy and water rights.

16.

Jethro Barlow

Mr. Barlow is a fact witness. He is a former member of the FLDS Church and an

employee of the UEP Trust. He is expected to testify regarding his knowledge of claims

and facts alleged in the Complaint, and matters discussed in his depositions and trial

testimony in Cooke. In particular, his testimony will include: his excommunication from

the FLDS Church; consequences of losing membership in the FLDS Church; the

treatment of non-FLDS members living in the community by Defendants’ city officials,

FLDS Church Security, the CCMO, and other community members; the Cities’

interference with non-FLDS members’ use and enjoyment of UEP Trust property; the

CCMO’s refusal to enforce UEP Trust Occupancy Agreements; his prosecution by the

Cities for allegedly trespassing on UEP Trust property even though he was serving as a

representative for the UEP Trust; Ron and Jinjer Cooke’s attempts to obtain housing

from the UEP Trust; Ron and Jinjer Cooke’s attempts to obtain utility service from the

Cities; UEP Trust’s attempts to work with the Cities regarding water rights and the

subdivision; the Cities’ changed building permit requirements; Twin City Water Works’

transfer of public money to the FLDS Church; his attempts to serve on Hildale’s CityCouncil; his knowledge of homes and buildings on UEP Trust property that received

water connections; his knowledge of building permits received for homes and businesses

on UEP Trust property; and his knowledge of homes, buildings, utilities, businesses, and

individuals on UEP Trust property.



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17.

Jerold N. Williams

Mr. Williams is a fact witness. He is a former member of the FLDS Church and a

former FLDS elder. Mr. Williams is expected to testify regarding claims and facts

alleged in the Complaint, as well as the matters discussed in his deposition. In particular, his testimony will include: his excommunication from the FLDS Church;

tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS Church;

instructions and directives from FLDS leaders; consequences of losing membership in

the FLDS Church and United Order; the treatment of non-FLDS members living in the

community by Defendants’ city officials; the authentication of Church records; the

marriage of his underage daughter to the Mayor of Colorado City; the CCMO’s decision

to arrest him for criminal trespass at a property that he built and for which he had a UEP

Trust Occupancy Agreement; the emotional distress, embarrassment, and humiliation he

suffered as a result of the CCMO’s conduct; the role of the Cities, their employees, and

the FLDS Church in constructing a compound for Warren Jeffs and the Bishop’s

Storehouse, including the Cities’ decision to permit a water connection at that

compound.

18. Timothy Rohbock

Mr. Rohbock is a fact witness. Mr. Rohbock is a former member of the FLDS

and former member of FLDS Church Security. He is expected to testify regarding his

knowledge of claims and facts alleged in the Complaint. In particular, his testimony will

include: tenets of the FLDS Church; directives from Warren Jeffs; the consequences of

losing membership in the FLDS Church and United Order; his knowledge and

experience with FLDS Church Security; the surveillance conducted by FLDS Church

Security of non-FLDS members; the coordination between the CCMO and FLDSChurch Security, including by sharing surveillance equipment and information in law


participation by Defendants’ city officials in FLDS Church Security; the CCMO’s

actions and the FLDS Church’s involvement in the arrest of Jerold N. Williams for

trespassing.



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19.

Elizabeth Wayman

Ms. Wayman is a fact witness. Ms. Wayman is a resident of the Twin Cities and

a former FLDS member. She is expected to testify regarding her knowledge of claims

and facts alleged in the Complaint. In particular, her testimony will include: the tenetsof the FLDS religion and structure of FLDS leadership; FLDS leaders’ control of the

Cities and the CCMO; her departure from the Church; the consequences of losing

membership in the FLDS Church and United Order; knowledge of the Bishop’s

Storehouse and illegal activity conducted out of the Storehouse; CCMO’s treatment of

her once she left the Church; the arrest of her husband, Jerold N. Williams, for

trespassing; and the emotional distress, embarrassment, and humiliation she experienced

as a result of that incident.

20. Helaman Barlow

Mr. Barlow is a fact witness. He is a former member of the FLDS Church and a

former Chief of the CCMO. Mr. Barlow is expected to testify regarding claims and facts

alleged in the Complaint and the matters discussed in his depositions in this case, as well

as the matters discussed in his depositions and trial testimony in Cooke. In particular,

his testimony will include: his excommunication from the FLDS Church; tenets of the

FLDS religion; how Warren Jeffs became the leader of the FLDS Church; instructions

and directives from FLDS leaders; consequences of losing membership in the FLDS

Church; authentication of documents produced or created by Defendants’ city officials

and the CCMO; the treatment of non-FLDS members living in the community by

Defendants’ city officials and the CCMO; the coordination between the CCMO and

FLDS Church Security, including training FLDS Security and the sharing of

surveillance equipment and information in law enforcement databases; membership ofCCMO officers and Defendants’ city officials in the FLDS Church and United Order;

CCMO efforts to interfere with outside law enforcement; the operation of the Bishop’s

Storehouse and illegal activity conducted out of the Storehouse; the CCMO handling of

alleged trespassing at various properties; the CCMO’s knowledge of underage

marriages; FLDS Church’s influence over the operations of the CCMO.



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21.

Joseph DeLopez

Mr. DeLopez is an expert witness for the United States. He is a consultant

regarding police practices and services and a former Chief of the Village of Winnetka,

Illinois, Police Department and former high-ranking Chicago Police Department officer.He has expertise in police policies, procedures, practices, and administration. His

additional qualifications are attached. Chief DeLopez is expected to testify consistent

with the expert opinions provided in his report and in his deposition. In particular, his

testimony will include expert opinions on the CCMO’s: administration; policies and

procedures; practices; training; accountability systems/practices; investigations; police

reports; coordination with the FLDS Church; and religiously biased policing.

22.

Steven Bateman

Mr. Bateman is a fact witness. Mr. Bateman is a former FLDS member. He is

expected to testify regarding his knowledge of claims and facts alleged in the Complaint,

and matters discussed in his deposition in this case and in Cooke. Mr. Bateman testified

in the Cooke trial by deposition. In particular, his testimony will include: his departure

from the Church; the treatment of non-FLDS members living in the community by

Defendants’ city officials, FLDS Church Security, the CCMO, and other community

members; the consequences of losing membership in the FLDS Church; the CCMO’s

search of his vehicle without probable cause; his interactions with CCMO during a

subsequent traffic stop.

23.

Randy Servis

Mr. Servis is a fact witness. He is employed by the Arizona Department of

Agriculture and investigated the CCMO’s euthanization of non-FLDS member Lydia

Cooke’s horse in 2011. He is expected to testify regarding matters discussed in hisdeposition. In particular, his testimony will include: his investigation of the horse

euthanization and his findings; and his review of CCMO records produced to him during

the course of his investigation.



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24.

Samuel Brower

Mr. Brower is a fact witness. He is a private investigator. Mr. Brower is

expected to testify regarding claims and facts alleged in the Complaint, as well as the

matters discussed in his deposition. In particular, his testimony will include: theCCMO’s discriminatory treatment of non-FLDS members; the CCMO’s efforts to

obstruct the service of process on FLDS members; the Cities’ assistance to the FLDS

Church in its surveillance of non-FLDS members; and the coordination of FLDS Church

Security personnel and the CCMO.

25.

Jesseca Jessop

Ms. Jessop is a fact witness. She is a resident of the Colorado City/Hildale

community and has never been a member of the FLDS Church. She is expected to

testify regarding claims and facts alleged in the Complaint, as well as the matters

discussed in her deposition. In particular, her testimony will include: the CCMO’s

failure to take action to enforce a valid UEP Trust Occupancy Agreement; harassment

(including acts of vandalism and property damage) by members of the community and

the CCMO’s response to and/or investigation of these incidents; employees or officials

Defendants’ threats, intimidation and interference with the Jessops’ use and enjoyment

of the property for which they received a UEP Trust Occupancy Agreement; treatment

as a non-FLDS person residing on UEP Trust land; various interactions with FLDS

Church Security, including incidents of monitoring and video surveillance and a hit-and-

run involving her son, Randy West, as well as the CCMO’s involvement in and response

to these incidents; and the emotional distress, embarrassment, and humiliation she

suffered as a result of the CCMO’s actions regarding her home.

26.

Christopher Jessop

Mr. Jessop is a fact witness. He is a former member of the FLDS Church and a

resident of the Colorado City/Hildale community. He is expected to testify regarding

claims and facts alleged in the United States’ Complaint in this case. In particular, his

testimony will include: his departure from the FLDS Church; the treatment of non-FLDS

members living in the community by Defendants’ city officials, FLDS Church Security,



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the CCMO, and other community members; consequences of losing membership in the

FLDS Church; his experiences growing up in the Colorado City/Hildale area; the

CCMO’s failure to take action to enforce a valid UEP Trust Occupancy Agreement;

harassment (including acts of vandalism and property damage) by members of thecommunity and the CCMO’s response to and/or investigation of these incidents;

employees or officials Defendants’ threats, intimidation and interference with the

Jessops’ use and enjoyment of the property for which they received a UEP Trust

Occupancy Agreement; treatment as a non-FLDS person residing on UEP Trust land;

various interactions with Church Security, including incidents of monitoring and video

surveillance and a hit-and-run involving his son, Randy West, as well as the CCMO’s

involvement in and response to these incidents; and the emotional distress,

embarrassment, and humiliation he suffered as a result of the CCMO’s actions regarding

his home.

27.

Darrell Cashin

Mr. Cashin is a fact witness. He is a Deputy with the Washington County

Sheriff’s Office (“WCSO”). He is expected to testify regarding claims and facts alleged

in the United States’ Complaint and will testify consistent with his deposition testimony.

In particular, Deputy Cashin’s testimony will include the CCMO’s lack of cooperation

with and lack of support of the WCSO; the CCMO’s coordination with FLDS Church

Security; the CCMO’s actions during UEP Trust Occupancy Agreement disputes; the

Holm School incident; and the Willie R. Jessop stolen generator incident.

28.

Lyle Jeffs

Mr. Jeffs is a fact witness. Mr. Jeffs is the Bishop of the FLDS Church and

brother of Warren Jeffs. He is expected to testify regarding the matters discussed in hisdeposition in this case. In particular, his testimony will cover: his communications with

Warren Jeffs; his role in the FLDS Church; Warren Jeffs’ control over FLDS Church

members, including Defendants’ city officials, from 2004 through the present;

Defendants’ city officials’ communication with Warren Jeffs while he was a federal

fugitive; FLDS Church instructions regarding non-members and membership in the



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United Order; Warren Jeffs’ dictations and edicts; the Cities’ opposition to the UEP

Trust and its subdivision efforts; the Bishop’s Storehouse and illegal conduct conducted

out of the Storehouse; directions he has given to the CCMO and Defendants’ city

officials regarding government business; the incident at Eco Alliance involving WillieJessop and theft of Mr. Jessop’s property; the role of FLDS Church Security and its

coordination with the CCMO and Defendants’ city officials; the CCMO enforcing

FLDS Church edicts or directives; the CCMO’s protection of FLDS Church leaders; the

FLDS membership status of Defendants’ employees; and interactions with Defendants’

city officials, and their counsel, at R&W. In lieu of live testimony, the United States

may present Mr. Jeffs’ deposition testimony at trial. As such, the United States

designates the follow deposition testimony by page and line numbers:

19:22-19:24

20:8-20:10

21:5-21:6

21:10-21:20

22:5-22:16

23:3-23:10

23:13-23:15

29:1-29:5

31:4-31:7

31:13-31:20

32:10-33:16

35:3-45:1

45:21-47:15

48:14-52:22

53:7-58:7

58:11-60:23

61:5-73:19

73:25-74:15

74:21-91:6

92:6-94:24

95:3-101:6

101:19-101:23

29. Zachary Renstrom

Mr. Renstrom is an expert witness for the United States. He is a Washington

County Commissioner and a licensed professional engineer. He has expertise in

municipal water systems. Prior to serving as a County Commissioner, he was the

President of Bush & Gudgell, Inc. His additional qualifications are attached. Mr.Renstrom evaluated the Colorado City/Hildale water system for the UEP Trust and as an

expert witness in Cooke. Mr. Renstrom is expected to testify consistent with the expert

opinions provided in his reports for the UEP Trust, Cooke, and the United States, his

depositions in this case and in Cooke, and his trial testimony in Cooke. In particular, his

testimony will include his expert opinions on: the water supply and distribution system



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in the Colorado City/Hildale area; the availability of water for new culinary water

connections; the incident that occurred with the water system in July 2007; the Cities’

failure to investigate or develop additional sources of water; the additional sources of

water reasonably available to the Cities; the effect on the water system of additionalwater connections to Ron and Jinjer Cooke, Patrick Barlow, and John Cook; Twin City

Improvement Association and other entity’s receipt of water; whether there were

additional ways for the Cities to conserve water other than instituting a moratorium; the

Cities’ impact fee study; and the opinions of Defendants’ expert witnesses.

30.

Ronald Cooke

Mr. Cooke is a fact witness. He is a former member of the FLDS Church and a

resident of the Colorado City/Hildale community. He is expected to testify regarding

claims and facts alleged in the United States’ Complaint in this case, as well as the

matters discussed in his deposition and trial testimony in Cooke. His testimony will

include: his experiences growing up in the Colorado City/Hildale area; his departure

from the FLDS Church; the treatment of non-FLDS members living in the community

by Defendants’ city officials, FLDS Church Security, the CCMO, and other community

members; consequences of losing membership in the FLDS Church; his accident,

disability and disability-related housing needs; his family’s application for and selection

of a property on UEP Trust land; his family’s efforts to obtain utilities for the that

property through Defendants; denial of water and obstruction and delays regarding other

utilities and municipal services, including a building permit, for that property by

Defendants; Defendants’ threats, intimidation and interference with the Cookes’ use and

enjoyment of the property for which they obtained a UEP Trust Occupancy Agreement;

treatment as a non-FLDS member residing on UEP Trust land; and the fair housingcomplaint the Cookes filed with the Arizona Attorney General and the subsequent

lawsuit.

31.

Jinjer Cooke

Ms. Cooke is a fact witness. She is a resident of the Colorado City/Hildale

community and has never been a member of the FLDS Church. She is expected to



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testify regarding claims and facts alleged in the United States’ Complaint in this case, as

well as the matters discussed in her deposition and trial testimony in Cooke. In

particular, her testimony will include: Ronald Cooke’s accident, disability, and

disability-related housing needs; her family’s application for and selection of a propertyon UEP Trust land; her family’s efforts to obtain utilities for the that property through

Defendants; denial of water and obstruction and delays regarding other utilities and

municipal services, including a building permit, for that property by Defendants;

Defendants’ threats, intimidation and interference with the Cookes’ use and enjoyment

of the property for which they obtained a UEP Trust Occupancy Agreement; treatment

as a non-FLDS person residing on UEP Trust land; interactions with the CCMO

involving the Stubbs’ farm; and the fair housing complaint the Cookes filed with the

Arizona Attorney General and the subsequent lawsuit.

32.

John Cook

Mr. Cook is a fact witness. He is a former member of the Colorado City/Hildale

community and has never been a member of the FLDS Church. He is expected to testify

regarding claims and facts alleged in the United States’ Complaint in this case and the

matters discussed in his deposition, as well as the matters discussed in his deposition and

trial testimony in Cooke. In particular, his testimony will include: his efforts to procure

water services in Colorado City; the Defendants’ actions to prevent him from living in

the Twin Cities; and the emotional distress, embarrassment, and humiliation he suffered

as a result of the above-described conduct by Defendants.

33.

Joseph Allred

Mr. Allred is a fact witness. He is the Mayor of Colorado City. He is expected to

testify regarding his knowledge of claims and facts alleged in the Complaint, andmatters discussed in his depositions in this case and in Cooke and his trial testimony in

Cooke. In particular, his testimony will include: FLDS leaders’ control of the cities,

TCWW, Inc., TCWA, and the CCMO; treatment of non-FLDS members; his knowledge

and experience with FLDS Church Security; Defendants’ efforts to discriminate against

Ron and Jinjer Cooke; membership in the United Order; Defendants’ use of an alleged



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water shortage as a pretext for discrimination; his marriage to an underage girl; and his

efforts, while serving as a city official, to embezzle money from TCWW, Inc. for the

benefit of the FLDS Church.

34.

Patrick BarlowMr. Barlow is a fact witness. Mr. Barlow is a former member of the FLDS

Church and a former member of FLDS Church Security. He is expected to testify

regarding his knowledge of claims and facts alleged in the Complaint, and matters

discussed in his deposition and trial testimony in Cooke. In particular, his testimony will

include: tenets of the FLDS Church; directives from FLDS leaders; the consequences of

losing membership in the FLDS Church and the United Order; his knowledge and

experience with FLDS Church Security; the surveillance conducted by FLDS Church

Security of non-FLDS members; coordination between the CCMO and FLDS Church

Security, including by sharing surveillance equipment and information in law


participation by Defendants’ city officials in FLDS Church Security; the water

connection provided to Espresso Creek; his failure to obtain a water connection from the

Cities at his home on Arizona Avenue; and the emotional distress, embarrassment, and

humiliation he suffered as a result of not receiving water to his home.

35. Claude Seth Cooke

Mr. Cooke is a fact witness. He is Ronald Cooke’s brother, a general contractor,

a former member of the UEP Trust Housing Board, a former FLDS member, and a

successful party in Jeffs v. Stubbs. He is expected to testify regarding claims and facts

alleged in the United States’ Complaint in this case, as well as the matters discussed in

his deposition and trial testimony in Cooke. In particular, his testimony will include: hisdeparture from the FLDS Church; the treatment of non-FLDS members living in the

community by Defendants’ city officials, FLDS Church Security, the CCMO, and other

community members; consequences of losing membership in the FLDS Church; FLDS

efforts to remove him and others from UEP Trust land and related litigation; the UEP

Trust under Wisan’s administration; Defendants’ changed policies regarding building



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permits, water connections, and subdivision after Wisan’s appointment as UEP Trust

Special Fiduciary, and the UEP Trust’s inability to complete unfinished homes on UEP

Trust land; Ronald Cooke’s disability and disability-related housing needs; the Cookes’

application for and selection of a property on UEP Trust land; the Cookes’ applicationsand efforts to obtain utilities and a building permit for the subject property through

Defendants, their agents, employees or officials; the CCMO’s enforcement of church

law against him and others, including intimidation and interference with the Cookes’ use

and enjoyment of the property for which they had obtained a UEP Trust Occupancy

Agreement and his arrest by the CCMO; and his interactions with the CCMO and arrests

at the Cottonwood Zoo in October 2015.

36.

Taylor Nelson

Mr. Nelson is a fact witness. He is a Sergeant with the Mohave County Sheriff’s

Office (“MCSO”). He is expected to testify regarding claims and facts alleged in the

United States’ Complaint in this case and the matters discussed in his deposition. In

particular, his testimony will include: the CCMO’s arrest of Patrick Pipkin and Andrew

Chatwin, on two occasions in October 2015, for allegedly trespassing on commercial

property that Mr. Pipkin and Mr. Chatwin had permission to access; the CCMO’s refusal

to cooperate with outside law enforcement; CCMO Chief Jerry Darger’s assault on Mr.

Pipkin; the CCMO’s handling of an incident involving Sabrina Tetzner, including that

CCMO officers stood by and provided insufficient police services regarding the

enforcement of Ms. Tetzner’s child custody orders.

37.

Patrick Pipkin

Mr. Pipkin is a fact witness. He is expected to testify regarding claims and facts

alleged in the United States’ Complaint in this case. He is a non-FLDS member whosetestimony will include: the CCMO’s arrest of him and Andrew Chatwin, on two

occasions, for allegedly trespassing on commercial property that he and Mr. Chatwin

had permission to access; the CCMO’s refusal to cooperate with outside law

enforcement; and CCMO Chief Jerry Darger’s assault on him.



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38.

Andrew Chatwin

Mr. Chatwin is a fact witness. He is a former FLDS member and has worked for

the UEP Trust. He is expected to testify regarding claims and facts alleged in the United

States’ Complaint in this case, as well as the matters discussed in his depositiontestimony in Cooke. In particular, his testimony will include: his knowledge of homes

and buildings on UEP Trust property that received water connections; treatment as a

non-FLDS person residing on UEP Trust land; Defendants’ interference with non-FLDS

individuals’ use and enjoyment of UEP Trust housing; and his interactions with the

CCMO and the arrests of him and Patrick Pipkin at the Cottonwood Zoo.

39.

Lorin Holm

Mr. Holm is a fact witness. He is a former FLDS member. He is expected to

testify regarding claims and facts alleged in the United States’ Complaint, as well as the

matters discussed in his deposition. In particular, his testimony will include:

consequences of losing FLDS membership; CCMO’s reports to FLDS leaders;

membership of CCMO officers and Defendants’ city officials in FLDS Church Security;

CCMO officers becoming FLDS Church Security members after being decertified; and

the CCMO’s traffic stop of him after FLDS Church Security was following him.

40. Ron Rohbock

Mr. Rohbock is a fact witness. He is a former member of the FLDS Church and a

former FLDS elder. Mr. Rohbock is expected to testify regarding claims and facts

alleged in the Complaint, as well as the matters discussed in his deposition. In

particular, his testimony will include: tenets of the FLDS religion; how Warren Jeffs

became the leader of the FLDS Church; instructions and directives from Warren Jeffs;

consequences of losing membership in the FLDS Church; the treatment of non-FLDSmembers living in the community by Defendants’ city officials; the CCMO’s failure to

investigate underage marriages; the CCMO’s actions regarding enforcement of his UEP

Trust Occupancy Agreement and harassment at his home; and the emotional distress,

embarrassment, and humiliation he suffered as a result of the CCMO’s actions regarding

his home.



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41.

Mark LoManto

Mr. LoManto is an expert witness. He is a CPA with expertise in auditing,

accounting, and tax issues. His expertise is in the area of accounting services related to

government and government contracts. His additional qualifications are attached. Histestimony is relevant to the existence and, more particularly, the scope of a conspiracy

among City officials, FLDS leaders, and employees of TCWW to cede control over their

operations to the FLDS Church and to divert funds improperly to the FLDS Church. He

is expected to testify regarding Colorado City Mayor Joseph Allred’s efforts to advance

FLDS Church interests by improperly diverting TCWW funds to a series of activities

unrelated to the business operations of TCWW. He is also expected to testify that the

value of the TCWW funds diverted to other than TCWW business operations totaled

$1,729,987.29.1

42.

R. Brian Jessop

Mr. Jessop is a Hildale City Council member. The United States may present Mr.

Jessop’s deposition testimony at trial. As such, the United States designates the follow

deposition testimony by page and line numbers:

6:14-7:18 9:8-9:10 25:20-27:16

1 The United States recognizes that this Court previously issued an order regarding Mr.

LoManto’s testimony. See Order, Hildale Defendants’ Motion in Limine; ProposedTestimony of LoManto at 2 (Mar. 17, 2015), ECF No. 606. However, “[i]t is well settledlaw that rulings on motions in limine are provisional. Such ‘rulings are not binding on thetrial judge [who] may always change his mind during the course of a trial.” BNS Ry. Co.v. Quad City Testing Laboratory, 7-CV-170, 2010 WL 4337827, at *1 (D. Mont. Oct. 26,

2010) (quoting Ohler v.United States, 529 U.S. 753, 758 n.3 (2000)). This Court’s earlierorder was based in part on the Court’s finding that the United States “has notdemonstrated . . . any connection between [the] alleged diversion of [TCWW] funds and”an alleged water shortage. Id . at 2. The United States intends to prove that connection attrial. The United States further intends to prove that Mayor Joseph Allred’s divertingfunds was in furtherance of a conspiracy with the FLDs Church. Proof of these facts willmake Mr. LoManto’s testimony relevant.



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29:8-29:24 33:20-34:16 38:6-40:2

41:14-44:17 47:5-49:2 49:12-50:18

54:19-57:3 60:1-62:8 64:3-65:12

70:14-70:19 76:19-88:23 88:24-89:2090:6-92:4 92:5-94:9 94:10-94:23

96:5-97:22 99:15-101:2 103:20-104:22

111:5-112:22

43.

Jack Harris

Mr. Harris is a rebuttal expert witness for the United States. He is the former

Chief of the Phoenix Police Department, the former Public Safety Manager for the City

of Phoenix, and is an expert in police policies, practices, procedures, and administration.

His additional qualifications are attached. He is expected to testify consistent with the

expert opinions provided in his report and in his deposition in this case. He reviewed the

expert report and opinions offered by the Defendants’ police-procedures expert, Greg

Meyer, and is prepared to rebut those opinions. He is prepared to testify, among other

things, that Greg Meyer: did not address appropriately all the police misconduct issues

involved in this case; did not address the extent to which CCMO policies and training

failed to address recurring policing issues associated with UEP Trust property; did not

consider adequately that the CCMO waited until 2007 to include non-discrimination

language in its policy manual; did not consider adequately the extent to which CCMO

officers omitted data from their reports; did not consider the extent to which CCMO

officers engaged in, ignored, or failed adequately to investigate illegal acts; did not

adequately consider evidence that the CCMO was taking direction from FLDS leaders or

sharing law enforcement resources with the FLDS Church; did not consider evidencethat the CCMO fails to cooperate with outside law enforcement; and did not adequately

consider the CCMO’s seizure of property without due process.

44.

Kenneth Spiers

Mr. Spiers is a rebuttal expert witness for the United States. He is the Vice

President of Bowen Collins & Associates, Inc., and he is a licensed professional



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engineer. He has expertise in municipal water systems. His additional qualifications are

attached. Mr. Spiers evaluated the report produced by Agua Southwest, LLC on

Defendants’ behalf. He is expected to testify consistent with the expert opinions

provided in his report and his deposition in this case. His testimony will include that:the Cities failed to act reasonably when they limited new water connections; the Cities

failed to timely improve and update their water system; and it is not sensible or

economically feasible for the UEP Trust to construct, operate, and maintain a separate

parallel water system.

The United States will also call records custodians, as necessary, to admit

documents produced during discovery, including custodians from the Mohave County

Sheriff’s Office, the Washington County Sheriff’s Office, South Central

Communications, American West Bank, and the State Bank of Southern Utah.

Respectfully submitted this 2nd day of November, 2015,

R. TAMAR HAGLERCHRISTY E. LOPEZ

Deputy Chiefs

ERIC W. TREENESpecial Counsel

SEAN R. KEVENEY/s/ Jessica Clarke

JESSICA CLARKEMATTHEW J. DONNELLYEMILY M. SAVNER

SHARON I. BRETTUnited States Department of JusticeCivil Rights Division950 Pennsylvania Avenue, NWWashington, DC 20530Phone: (202) 305-4013Facsimile: (202) 514-1116E-mail: [email protected]


mailto:[email protected]:[email protected]:[email protected]


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CERTIFICATE OF SERVICE

I certify that on November 2, 2015, I caused a copy of the foregoing to be sent bythe Court’s ECF system to the following:

Jeffrey C. Matura

Asha SebastianMelissa Jane EnglandGraif Barrett & Matura, P.C.1850 North Central Avenue, Suite 500Phoenix, Arizona 85004 Attorneys for Defendant Town of Colorado City

R. Blake HamiltonAshley M. Gregson111 East Broadway, Suite 900Salt Lake City, Utah 84111

Attorneys for Defendants City of Hildale and Twin City Water Authority

JESSICA CLARKE /s/ Jessica Clarke

Attorney for the United States



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Case 3:12-cv-08123-HRH Document 758-1 Filed 11/02/15 Page 1 of 18


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RESUME AND AMPLIFICATION

OF

JOSEPH A. DeLOPEZ



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ASSIGNMENT BACKGROUND

31 JANUARY 2011- Vice Chancellor, Safety and Security, City Colleges of

MARCH 2013 Chicago

25 MARCH 2002- Chief of Police, Village of Winnetka

JANUARY 2011

1 FEBRUARY 2000- Deputy Superintendent, Chicago Police Department

16 FEBRUARY 2002

30 JULY 1998- Deputy Chief, Patrol Administration

31 JANUARY 2000

26 MAY 1995- Commander, 23rd

District

29 JULY 1998

13 JULY 1992- Commander, Training Division

25 MAY 1995

20 MAY 1989- Commander, 10th

District

12 JULY 1992

26 JANUARY 1988- Deputy Chief, Patrol Division, Area 4

19 MAY 1989

12 JULY 1985- Commander, 14th

District

25 JANUARY 1988

16 AUGUST 1984- Youth Division, Commanding Officer, Area 5 Youth

11 JULY 1985

12 JULY 1984- 20th

District, Acting Watch Commander

15 AUGUST 1984

16 MAY 1984- 13th

District, Acting Watch Commander & Field Lieutenant

11 JULY 1984

3 MAY 1984- Promoted to the rank of Lieutenant, attended Pre-service

15 MAY 1984 Lieutenant’s Training School



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28 MAY 1981- Youth Division, Watch Commander and Field Supervisor,

2 MAY 1984 Area 4 Youth Section

2 APRIL 1981- 18th

District, Patrol Supervisor

27 MAY 1981

26 JUNE 1980- Traffic Division, Watch Commander, Public Vehicle and

1 APRIL 1981 Major Accident Investigations Section

16 JUNE 1980- Training Division Awaiting permanent assignment

26 JUNE 1980

13 SEPT 1979- Northwestern University Traffic Institute, 9 month Police

Traffic

14 JUNE 1980 Administration Training Program

OCTOBER 1978- Detailed to Training Division. Assisted in the coordination of

13 SEPT 1979 Cardiovascular Health Program for Police Department

JUNE 1977- 13th

District, District Supervisor

OCTOBER 1978

MAY 1977- Promoted to rank of Sergeant, attended Pre-service

JUNE 1977 Sergeant’s School

OCTOBER 1973- Special Operations Group, Tactical Section North

MAY 1977

NOVEMBER 1971- 14th

District, Patrol Officer

OCTOBER 1973

14 JUNE 1971- Basic Recruit Training

NOVEMBER 1971

14 JUNE 1971 Appointment Date to Chicago Police Department

(For Additional Information See Amplified Resume)



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EDUCATION

1988 - 1992 Lewi s Uni ver si t y, Cr i mi nal / Soci al J ust i ce Mast er ’ s Degr ee Progr amDegr ee: M. S. Cr i mi nal J ust i ce

June 1991 - Pol i ce Execut i ve Resear ch For um

July 1991 Seni or Management I nst i t ut e f or Pol i ce

Degr ee: Cer t i f i cat e, Execut i veSt r at egi es Management

1979 - 1980

1965 - 1969

Nor t hwest er n Uni ver si t y Tr af f i c I nst i t ut e Degr ee: Cer t i f i cat e, Tr af f i c Pol i ce

Admi ni st r at i on Tr ai ni ng Pr ogr amAct i vi t i es: Cl ass Soci al Co- Chai r man

Uni ver si t y of I l l i noi s at Chi cago Ci r cl e Degr ee: B. S. i n ManagementHonor s: Dean' s Li st Act i vi t i es: Uni ver si t y swi mmi ng and wat er

Pol o t eams, i nt r amur alwr est l i ng

1961 - 1965

Other Training

and

Certification:

DePaul Academy Gr aduat ed f r omPr e- Engi neer i ng Col l ege Pr ep Pr ogr am i n upper 5% of cl ass

Numer ous Chi cago Pol i ce Depar t ment Pr of essi onal Cer t i f i cat e Ext ensi on Cour ses

Bl ood Pr essure Techni ci an Tr ai ni ngand Cer t i f i cat e, Chi cago Hear t Assoc.

Car di opul monar y Resusci t at i on I nst r uctor Tr ai ni ng and Cer t i f i cat e

Pol i ce I nst r uct or Tr ai ni ng Cour se and Cert i f i cat e

I l l i noi s St at e Pol i ce Academy,Di mensi onal Management Tr ai ni ng



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Law Enf or cement Of f i cer s Tr ai ni ngSchool - Medi a Rel at i ons Cour se

One Mi nut e Managers Semi nar

Pr omot i onal Assessor Trai ni ng

Chi cago Pol i ce Depar t ment

Cook Count y Depar t ment ofPersonnel

I l l i noi s Stat e Pol i ce Met r o Dade Pol i ce Depar t ment I nt er nat i onal Associ at i on of

Chi ef s of Pol i ce



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PERSONAL

Born:

Physical:

Health:

Marital Status:

Residence:

Hobbies:

Additional Work Experience:

Affiliations:

Present and

Past

Civic:

19 May 1947, Chi cago, I l l i noi s

Hei ght : 5/ 10" , Wei ght 165

Excel l ent

Mar r i ed, 14 J une 1969 ( 5 Chi l dr en)

Own Home

Racquet bal l , swi mmi ng, r unni ng

Adj unct Pr of essor of Cr i mi nal

J ust i ce, Uni ver si t y of I l l i noi s at Chi cago, - 1994

I l l i noi s Pol i ce Associ at i on

I l l i noi s Associ at i on of Chi ef s of Pol i ce

I nt er nat i onal Associ at i on of Chi ef s of Pol i ce

Uni ver si t y of I l l i noi s Al umni Associ at i on

Seni or Management I nst i t ut e f or Pol i ce Al umni Associ at i on

Lat i n Amer i can Pol i ce Associ at i on

St . J ude Pol i ce League

Nor t hwest er n Uni ver si t y Tr af f i c I nst i t ut e Al umni Associ at i on

Hi spani c I nst i t ut e of Law Enf or cement

Hi spani c Amer i can Pol i ce Command Of f i cer ' s

Associ at i on

Former Advi sor y Boar d Member , Gener al Woods Boys Cl ub

Past Progr amChai r man I mmacul at e Concept i on Par ent ' s Cl ub



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Awards: Chi cago Cr i me Commi ssi on Publ i c Ser vi ce Awar e

Chi cago Par k Di st r i ct Recogni t i on Awar d

Cer t i f i cat e of Appr eci at i on, Logan Squar e

Li ons

Boar d of Educat i on Award of Appr eci at i on

Ameri can G. I . For umAward

Li t t l e Vi l l age Chamber of Commerce Outst andi ng Perf or mance Award

Pi l sen Nei ghbors Communi t y Counci l Publ i c Ser vi ce Leadershi p Award

12t h Ward Publ i c Ser vi ce Award

U. S. Post al Ser vi ce Awar d of Appr eci at i on

Concer ned Ci t i zens Awar d

Of Li t t l e Vi l l age Servi ce

La Mexi cana Radi o Ci t i zen of t he Week

La Tribuna de Chicago Newspaper Ci t i zen of t he Week

Chi cago Pol i ce Depart ment Yout h Di vi si on Rol e Model Recogni t i on Award

2 Chi cago Pol i ce Depar t ment Uni t Mer i t or i ous Awar ds

2 Chi cago Pol i ce Depar t ment Commendat i ons

Chi cago Pol i ce Depar t ment Fi t ness Award

Chi cago Pol i ce Depar t ment Appear ance Awar d

Numer ous Chi cago Pol i ce Depar t ment Honor abl e Ment i on Awar ds



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AMPLIFIED RESUME



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AMPLIFIED RESUME JOSEPH A. DeLOPEZ

31 January 2011-March 2013

Vice Chancellor, Safety and Security

City Colleges of Chicago

Hi r ed by Ci t y Col l eges of Chi cago to coor di nat e t hecent r al i zat i on and r e- or gani zat i on of t he Of f i ce of Saf et y andSecur i t y. The Ci t y Col l eges of Chi cago syst em i s compr i sed ofei ght pr i mar y l ocat i ons and si x sat el l i t e l ocat i ons ser vi ng ast udent popul at i on of appr oxi matel y 120, 000 and a f acul t y andst af f popul at i on of appr oxi mat el y 6000. The Of f i ce of Saf et yand Secur i t y pr ovi des al l of t he publ i c saf et y needs of t he

Ci t y Col l ege syst emt hr ough t he empl oyment of a combi nat i on of500 of f - dut y and ret i r ed member s of t he Chi cago Pol i ceDepar t ment , t he I l l i noi s Stat e Pol i ce Depar t ment and t he CookCount y Sher i f f ’ s Depar t ment . The annual oper at i ng budget f ort he Of f i ce of Saf et y and Secur i t y i s $11. 5 Mi l l i on.

25 March 2002 – January 2011

Chief of Police, Village of Winnetka

AS Chi ef of Pol i ce f or t he Vi l l age of Wi nnet ka, ser ved acommuni t y of 12, 500 r esi dent s. The Vi l l age of Wi nnet ka i sl ocat ed 14 mi l es f r omdownt own Chi cago al ong the shores of LakeMi chi gan. The Wi nnet ka Pol i ce Depar t ment had a compl ement of36 per sonnel and a t ot al budget of $6. 3 Mi l l i on. TheDepar t ment was nat i onal l y accr edi t ed by t he Commi ssi on onAccr edi t at i on f or Law Enf orcement Agenci es ( CALEA) . Dur i ng myt enur e as Chi ef i n Wi nnet ka, I r e- or gani zed t he Pol i ceDepart ment , enhanced t r ai ni ng of per sonnel t hr ough acol l aborat i ve ef f ort wi t h Oakton Communi t y Col l ege and t heNor t heast er n I l l i noi s Publ i c Saf et y Tr ai ni ng Academy (NI PSTA) ,wher e I ser ved i n t he r ol es of Pr esi dent , Vi ce- Pr esi dent and as

an Of f i cer of t he NI PSTA Foundat i on.



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1 February 2000 - 16 February 2002

Bureau of Technical Services

Assigned as Deputy Superintendent, Bureau of Technical

Services. This position coordinates one of the five

Bureaus that comprise the Police Department. The

Bureau consists of the Communications Division, the

Electronics and Motor Maintenance Division, Evidence

and Recovered Property Section, and the General Support Division.

Duties included coordinating police communications

issues and needs with the Chicago Office of Emergency Communications, which includes the Alternate Response

Program. Respondent was also responsible for

overseeing the maintenance and replacement of the

Department's vehicle and Marine Unit fleets, and establishing and implementing policy for management of the Central Detention Section, Evidence and Recovered

Property Section, Equipment and Supply Section and the

Reproduction and Graphic Arts Section.

Respondent also coordinated the Chicago Police

Department's Capital Development and Improvement

Programs, overseeing construction of and repairs to

Department facilities. Responsibilities also required

overseeing a personnel and non-personnel budget of

over 60 Million dollars.

30 July 1998 - 31 January 2000

Patrol Division Administration

Assi gned as Deput y Chi ef of Pat r ol Admi ni st r at i on. Responsi bi l i t i es i ncl uded t he coor di nat i on of al l admi ni st r at i ve f unct i ons f or t hi s 10, 000 member

Di vi si on. Thi s posi t i on ent ai l ed servi ng as a member of t he Depar t ment ' s l abor cont r act negot i at i on t eam, member of Chi cago' s Communi t y Pol i ci ng Management Team, member of t he I nf or mat i on Syst ems Devel opment Gr oup, and numerous ot her depar t ment al and i nt er - government al pl anni ng and oversi ght gr oups.



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26 May 1995 - 29 July 1998

23rd District:

Assi gned t o t he 23r d Di st r i ct , Town Hal l , as t he Di st r i ct Commander . Responsi bi l i t i es i ncl uded over seei ng t he i mpl ement at i on of an i nnovat i ve

comuni t y pol i ci ng i ni t i at i ve, known as Chi cago' s Al t er nat i ve Pol i ci ng St r at egy ( C. A. P. S. ) . I n addi t i on, di r ect i on and l eader shi p of appr oxi matel y 300 swor n and ci vi l i an per sonnel , adherence t o and i mpl ement at i on of l abor cont r act pr ovi si ons, and al l ocat i on of r esour ces t o ensur e t hat cri me condi t i ons and qual i t y of l i f e i ssues

wer e addr essed wer e pr i mar y r esponsi bi l i t i es.

Through use of j oi nt communi t y- pol i ce probl emsol vi ng meet i ngs, pr obl ems wer e i dent i f i ed and pr i or i t i zed and st r at egi es pl anned. Addr essi ng and sol vi ng pr obl ems i ncl uded l i ai son wi t h ot herci t y agenci es, chamber s of commerce, chur ches and communi t y groups as wel l as i ndi vi dual communi t y member s.

13 July 1992 - 25 May 1995

Training Division:

Assi gned as Commander of Trai ni ng Di vi si on. Responsi bi l i t i es i ncl uded managi ng and di r ect i ng t he i mpl ement at i on and per f ormance of t he pr ogr ams of t he Chi cago Pol i ce Depar t ment ' s Tr ai ni ng Di vi si on.

The Commander al so r epresent s t he Super i nt endent of Pol i ce when si t t i ng on t he I l l i noi s Law Enf or cement Tr ai ni ng and St andar ds Board l ocat ed i n Spr i ngf i el d, I l l i noi s. Dut i es al so ent ai l ed ser vi ng as Secret ar y

of t he Chi cago Pol i ce Depart ment ' s Academi c Sel ect i on Board.



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The undersi gned conf er r ed wi t h management and

super vi sory per sonnel t o det er mi ne t r ai ni ng needs; i mpl ement ed and moni t or ed new t r ai ni ng progr ams; managed and di r ect ed r esearch i nt o new t r ai ni ng met hods and t echni ques; super vi sed t he devel opmentof

t r ai ni ng pol i ci es and pr ocedur es and moni t or edt hei r i mpl ement at i on; over saw and i mpl ement edassessment of any t r ai ni ng or educat i onal needs andsubsequent progr ams.

As Commander of t he Tr ai ni ng Di vi si on, t he sel ect i on, t r ai ni ng and super vi si on of a st af f of appr oxi mat el y120 per sons, and the pr epar at i on and cont r ol of t he

Tr ai ni ng Di vi si on budget was a pr i mar y r esponsi bi l i t y.

20 May 1989 - 12 July 1992 10th District:

Assi gned t o t he l Ot h Di st r i ct , Mar quet t e, as the Di st r i ct Commander . Responsi bi l i t i es i ncl uded ensur i ng t he pr ovi si on of qual i t y pol i ce ser vi ces t o t he communi t y i n conf ormance wi t h the pol i ci es and pr ocedur es of t he Chi cago Pol i ce Depar t ment . The

r eport i ng subj ect was r esponsi bl e f or t he gui dance anddi r ect i on of over 300 swor n and ci vi l i an per sonnel i nan ef f or t t o maxi mi ze t he ef f i ci ency and ef f ect i veness of del i ver y of pol i ce ser vi ces t o a mul t i - r aci al and mul t i - et hni c popul at i on of appr oxi mat el y 140, 000per sons.

The under si gned ut i l i zed Mi ssi on- Or i ented Di r ect edPat r ol , Sel ect i ve Enf or cement Techni ques, and St r at egi c Foot Pat r ol i n or der t o deal wi t h cr i me condi t i ons and i mpr ove t he qual i t y of l i f e f or

communi t y r esi dent s.

Gui dance and t r ai ni ng of subordi nates by Watch Commanders, Fi el d Li eut enant s, and Sect or Ser geant swas assur ed, as wel l as ef f ect i ve t r ai ni ng and eval uat i on of Pr obat i onar y Pol i ce Of f i cer s by Pat r ol Speci al i sts .



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The r epor t i ng subj ect est abl i shed a l i ai son wi t h ot her

ci t y agenci es, Chamber s of Commerce, Chur ches, andCommuni t y Gr oups i n an ef f ort t o mi ni mi ze or el i mi nat e t he adver se i mpact of t he mul t i t ude of soci al , economi c, and cr i me pr obl ems af f ect i ng t he Lawndal e, Li t t l e Vi l l age, and t he Pi l sen Communi t i es whi ch compr i se the Mar quet t e Di st r i ct .

Dur i ng t he t i me assi gned as Di st r i ct Commander , t he undersi gned r ecei ved over 50 l et t ers of Commendat i on, 8 Awards of Appr eci at i on, and The Pi l sen Nei ghbors Communi t y Counci l Publ i c Servi ce Leadershi p Award.

26 January 1988 – 19 May 1989

Patrol Division:

Assi gned as Deput y Chi ef of Pat r ol , Ar ea 4. Ar ea 4 was compr i sed of t he l Ot h, 11t h, 12t h, and 13t h Di st r i ct s and cover ed appr oxi mat el y one- si xt h of t hegeogr aphi c area of t he Ci t y of Chi cago.Responsi bi l i t i es i ncl uded over seei ng t he act i vi t i es of f our Di st r i ct Commander s t o ensur e the ef f ect i ve and ef f i ci ent del i ver y of pol i ce ser vi ces to t hecommuni t y. The wr i t er was r esponsi bl e f or t he gui dance and di r ect i on of appr oxi matel y 1, 400personnel , and i mpl ement ed i nnovat i ve appr oaches t o deal wi t h cr i me and qual i t y of l i f e i ssues.

12 July 1985 - 26 January 1988

14th District:

Assi gned t o t he 14t h Di st r i ct , Shakespear e, as t he Di st r i ct Commander . Responsi bi l i t i es i ncl uded

ensur i ng t he pr ovi si on of qual i t y pol i ce ser vi ces t o t he communi t y i n conf ormance wi t h t he pol i ci es and pr ocedur es of t he Chi cago Pol i ce Depar t ment . Ther eport i ng subj ect was r esponsi bl e f or t he gui dance and di r ect i on of 266 swor n pol i ce per sonnel and two ci vi l i an empl oyees i n an ef f or t t o maxi mi ze t heef f i ci ency and ef f ect i veness of del i ver y of pol i ceser vi ces t o a mul t i - r aci al and mul t i - et hni c popul at i on



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of appr oxi mat el y 155, 000 persons. The undersi gned

assured t he i mpl ement at i on of mi ssi on- or i ent ed di r ect ed pat r ol , Super vi sor y gui dance and r esponsi bi l i t y f or subordi nates by Watch Commander s, Fi el d Li eut enant s, and Sect or Ser geant s, and a cont i nuous anal ysi s of t he ef f ect i veness of t he enf or cement ef f or t s

The r epor t i ng subj ect al so wor ked cl ose wi t h ot her Ci t y Agency heads as wel l as l eader s ofcommuni t y- based organi zat i ons and ser vi ce agenci es t o seek sol ut i ons t o, or pr event , t he many soci al , economi c, and cr i me pr obl ems af f ect i ng t he Shakespeare Communi t y.

Dur i ng the t enur e as Di st r i ct Commander of t he 14t h Di st r i ct , t he under si gned r ecei ved over 60 l et t er s ofcommendat i on, f i ve awards of appr eci at i on, and t he Chi cago Cr i me Commi ssi on Publ i c Ser vi ce Award.

16 August 1984 - 12 July 1985

Youth Division:

Assi gned t o t he Yout h Di vi si on, Ar ea 5 Yout h Sect i on, as t he Commandi ng Of f i cer . Dut i es consi st ed ofdeci si on maki ng, gui dance, and i mpl ement at i on at t he Ar ea l evel of pol i ci es and pr ocedur es adopt ed by t he Chi cago Pol i ce Depar t ment and t he Commander of t he Youth Di vi si on. The r epor t i ng subj ect was r esponsi bl e f or t he coor di nat i on of t he ef f or t s of sevenSer geant s, 40 Yout h Of f i cer s, and 11 School Pat r ol Of f i cer s so t hat t he gr eat est possi bl e ut i l i zat i on of personnel and equi pment was di r ect ed t oward t he basi c pol i ce f unct i ons of aggr essi ve and pr event i ve pat r ol

and pr ompt and ef f i ci ent r esponse to cal l s f r om ot her uni t s f or yout h ser vi ces.

The r eport i ng subj ect al so par t i ci pat ed act i vel y and posi t i vel y wi t h communi t y gr oups and agenci es i n pr ogr ams desi gned f or t he pr event i on of j uveni l e del i nquency and r el at ed yout h pr obl ems. To t hi s end, t he r epor t i ng subj ect has been a member of t he Mayor ' s Task For ce on Yout h Cr i me



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t hr ough t he Ar ea 9 Yout h Advi sor y Counci l , a member of

t he Board of Educat i on Di st r i ct 4 Gang Commi t t ee, a member of t he Mayor ' s Pol i ce Communi t y Rel at i ons Commi t t ee f or t he Four t eent h Di st r i ct , and r egul ar l y met wi t h t he Boar d of Educat i on Super i nt endent s and Pr i nci pal s and wi t h repr esent at i ves of communi t y based yout h agenci es.

Dur i ng t he t i me as Commandi ng Of f i cer of Ar ea 5 Yout h, t he under si gned r ecei ved numer ous l et t er s of commendat i on, a Recogni t i on Award f r omt he Chi cagoPar k Di st r i ct , a Ser vi ce Awar d f r omSchool Di st r i ct 4,

and a Cer t i f i cat e of Appr eci at i on f r omt he Nor t h Cent r al Management Associ at i on f or ser vi ng as an Eval uat i on TeamMember .

12 July 1984 - 16 August 1984 20th District:

Dut i es consi st ed of deci si on maki ng and coor di nat i on of ef f or t s of a compl ement of of f i cer s assi gned t o pat r ol and cl er i cal f uncti ons.

16 May 1984 - 12

July 1984 13th District:

Dut i es consi st ed of f i el d super vi si on and deci si on maki ng wi t h r egar d t o t he pat r ol f unct i ons of si x Ser geant s and 30 Pol i ce Of f i cer s. Dur i ng t he t i me assi gned, r epor t i ng subj ect al so commanded one- hal f of t he Spani sh Company ass i gned t o secur i t y at t he Humbol dt Par k Puert o Ri can Week Fest i val .

3 May 1984 - 16 May 1984:

Pr e- ser vi ce Li eut enant ' s Tr ai ni ng.



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28 May 1981 - 3 May 1984

Youth Division:

Assi gned t o t he Yout h Di vi si on, Ar ea 4 Yout h Sect i on,i n t he capaci t y of Watch Commander and Fi el dSuper vi sor . Dut i es consi st ed of deci si on maki ng, super vi si on and gui dance of Yout h Of f i cer s i nvol ved i n a br oad spect r um of j uveni l e r el at ed si t uat i ons. Ar ea of r esponsi bi l i t y was appr oxi mat el y one- si xth of t he Ci t y of Chi cago, encompassi ng f our pol i ce di st r i ct s. The r epor t i ng member was r esponsi bl e f or t he proper i nvest i gat i on, cl assi f i cat i on and coor di nat i on of mi ssi ng per sons, chi l d abuse, f ami l y r el at ed and

j uveni l e r el at ed case i nvest i gat i ons. Member workeddi r ect l y wi t h t he Yout h Ar ea Commander t o assure thatuni t goal s were met and that manpower was al l ocated ef f i ci ent l y and ef f ecti vel y.

Addi t i onal l y, t he r epor t i ng subj ect was a member of t he Ci t y of Chi cago Depar t ment of Per sonnel Pol i ce Of f i cer Screeni ng and Assessment Team.

Dut i es consi st ed of conduct i ng a one- day Assessment Cent er t o observe and eval uat e appl i cant s f or t he

posi t i on of Pol i ce Of f i cer . Thi s r epor t i ng subj ect has ser ved bot h as an Assessment TeamMember, and asAssessment TeamLeader . The opport uni t y al so arose t oser ve on t he Assessment cent er panel f or t he CookCount y Ci vi l Servi ce Commi ssi on dur i ng May, 1983.

2 April 1981 - 28 May

1981 18th District:

Tempor ary assi gnment . Dut i es consi st ed of f i el dsuper vi si on of uni f or med pat r ol of f i cer s and deci si on maki ng as a f i r st - l i ne super vi sor. Repor t i ng member was rout i nel y ut i l i zed i n t he capaci t y of Act i ngLi eut enant .



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AMPLIFIED

Documents

Justice Department witness list