1.
I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.
2.
3.
4.
I have personal experience with San Francisco Police Department officer Shawn
Ryan. In 2012, while I was detained at the Tenderloin Police Station, several
unknown female police officers attempted to conduct a vaginal cavity search of
my person. I resisted the search. Later, Officer Ryan came into the room where I
was being held and screamed at me, Quit fucking around Ms. Nash! While I
continued to be handcuffed, he turned me around and forcibly spread my legs
from behind. While another female officer held me down, Officer Ryan attempted
to remove a bag of drugs from my vagina. I screamed help me, help me!
Officer Ryan ultimately extracted the drugs from my vagina, but I felt extremely
violated in the process.
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I declare under penalty of perjury that the foregoing is true and correct.
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26
2015, at
(\AO V
California.
$AQtJITA NASH
27
CASE NOS. CR 13-00753, CR 14-643, CR 15-004, CR 15-005, CR 15-006, CR 15-027, CR 15-028,CR 15-043,
CR 15-049, CR 15-050, CR 15-052, CR 15-059, CR 15-070
Ex.02939
1
2
3
1.
I have personal experience interacting with and observing police officers in San
Francisco's Tenderloin neighborhood.
2.
3.
4.
I have personal experience with San Francisco Police Department officer Darren
Nocetti. I once observed him choke a man named Joe in the Tenderloin, who
Officer Nocetti suspected as having drugs inside of his mouth. Joe denied having
any drugs. In response, Officer Nocetti placed him in a chokehold until blood
vessels in his eyes appeared to pop, turning Joe's eyes red.
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I declare under penalty of perjury that the foregoing is true and correct.
EXECUTED thiD3 rd day of(DICt
, 2015, at
cr
, California.
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RON MATHEWS
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7R
DECLARATION OF AARON MATHEWS
495929.01
Ex.02941
I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.
2.
3.
4.
5.
I have personal experience with San Francisco Police Department officer Shawn
Ryan. In or around 200$, while being transported to San Francisco County Jail by
Officer Ryan, Officer Ryan said a comment to me like, I just got married and
you better be glad. or Ill take some black pussy.
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I declare under penalty of perjury that the foregoing is true and correct.
1$
2015, at
edSc&, California.
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ACACIA MCNEAL
Li
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2R
CASE NOS. CR 13-00753, CR 14-643, CR 15-004, CR 15-005, CR 15-006, CR 15-027, CR 15-02$,CR 15-043,
CR 15-049, CR 15-050, CR 15-052, CR 15-059, CR 15-070
Ex.02946
1.
I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.
2.
3.
4.
I have heard San Francisco Police officers refer to people as bitches and use
phrases such as sit your black ass down when speaking to African-American
people.
5.
In February 2013, San Francisco Police Department Officer Shaughn Ryan made
a comment to me during an arrest that You should be doing something else with
that body, you could making that money doing something else other than selling
drugs. This statement made me feel uncomfortable.
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I declare under penalty of perjury that the foregoing is true and correct.
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EXECUTED this jth day of OC_Sco\r)e Q
,2015, at 5teL,OCalifornia.
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CASE NOS. CR 13-00753, CR 14-643, CR 15-004, CR 15-005, CR 15-006, CR 15-027, CR 15-028,CR 15-043,
CR 15-049, CR 15-050, CR 15-052, CR 15-059, CR 15-070
Ex.02951
1.
I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.
2.
3.
4.
In 2014, I was arrested and detained at the Tenderloin Police Station located on
the corner of Eddy Street and Jones Street. While I was awaiting transport to the
San Francisco County Jail, I nodded off. In response, an unknown officer
stomped on my foot in order to wake me up when it was time to be transported. I
experienced substantial pain in my foot as a result and it was an excessive amount
of force to wake me up.
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I declare under penalty of perjury that the foregoing is true and correct.
iS
2015,
atLJ17t/P
ornia.
TA DIXON
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495929.01
CASE NOS. CR 13-00753, CR 14-643, CR 15-004, CR 15-005, CR 15-006, CR 15-027, CR 15-028, CR 15-043,
CR 15-049, CR 15-050, CR 15-052, CR 15-059, CR 15-070
Ex.02956
1
2
I have personal experience interacting with and observing police officers in San
franciscos Tenderloin neighborhood.
2.
3.
4.
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is
I declare under penalty of perjury that the foregoing is true and correct.
EXECUTED this th day of
2015, at
Ctalifornia.
Wk
j
CRYSTL ANTHONY
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CASE NOS. CR 13-00753, CR 14-643, CR 15-004, CR 15-005, CR 15-006, CR 15-027, CR 15-02$,CR 15-043,
CR 15-049, CR 15-050, CR 15-052, CR 15-059, CR 15-070
Ex.02961
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STEVEN G. KALAR
Federal Public Defender
GALIA AMRAM
Assistant Federal Public Defender
CANDIS L. MITCHELL
Assistant Federal Public Defender
DANIEL P. BLANK
Assistant Federal Public Defender
GABRIELA BI$CHOF
Assistant Federal Public Defender
19th Floor Federal Building
450 Golden Gate Avenue
San Francisco, CA 94102
Telephone: (415) 436-7700
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Counsel for Defendant Darrell Powell
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IN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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v.
DARRELL POWELL,
Defendant.
1$
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EMC
DECLARATION OF DARRELL
POWELL
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Daiiell Powell, declare as follows:
22
1.
I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.
2.
3.
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Ex.02962
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4.
In the fall of 2014, I parked a car near the intersection of Eddy Street and Post
Street. My sister and girlfriend were in the car with me. Shortly after parking the
car and exiting from it, I made contact with an unknown, Caucasian San Francisco
Police Department officer. I then began walking away from the car, while my
sister and girlfriend remained inside. As I walked away from the car and down
the street, several officers swarmed me and began physically assaulting me. At
least five or six officers hit me on various parts of my body. The officer that I had
made eye contact with stated that I had mugged him before they seized me.
5
I declare under penalty of perjury that the foregoing is true and correct.
at
D LL POWEt
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DECLAPJ\TION Of DARRELL POWELL
Ex.02963
1.
I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.
2.
3.
4.
5
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7
$
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I declare under penalty of perjury that the foregoing is true and correct.
EXECUTED thisq th day of
,2015, at
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LikL
EROUSE
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495929.01
CASE NOS. CR 3-OO753, CR 14-643, CR 5-OO4, CR 15-005, CR 15-006, CR 15-027, CR 15-028, CR 15-043,
CR 15-049, CR 15-050, CR 15-052, CR 15-059, CR 15-070
Ex.02968
3
1.
I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.
2.
3.
Since 2008, I have been personally been stopped by officers in the Tenderloin
approximately ten to twelve times. During such stops, officers have questioned
me about my presence in the Tenderloin. Notably, during one or more of those
stops, I was accompanied by wife, Juliette Biemeret, who is Caucasian. During
the times that we have been stopped while together, officers have never
questioned her in a similar manner.
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7
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I declare under penalty of perjury that the foregoing is true and correct.
12
16
lOB
2015, at
t4alifornia.
T LEE
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27
CASE NOS. CR 13-00753, CR 14-643, CR 15-004, CR 15-005, CR 15-006, CR 15-027, CR 15-028,CR 15-043,
CR 15-049, CR 15-050, CR 15-052, CR 15-059, CR 15-070
Ex.02973
2
3
I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.
2.
3.
4.
5.
San Francisco Police Department officer R. Crosby is one such officer. In 2013,
Officer Crosby, dressed in street clothing, approached me on Sixth Street and
said, I want to handcuff you to a bed and fuck you. On other occasions, he has
referred to me as his girlfriend and told other people to stop talking to my
girl. Officer Crosbys sexually inappropriate behavior has made me fearful of
him.
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I declare under penalty of perjury that the foregoing is true and correct.
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18
Oc.b k-ev
2015, at TA
I-, h
California.
KEYSHAWHITE
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Ex.02978
I
7
1.
I have personal experience interacting with and observing police officers in San
franciscos Tenderloin neighborhood.
2.
3.
4.
5.
Each time I have since seen the same two officers, they have verbally harassed me
and accused me of selling drugs. In response, I eventually filed a complaint
against both officers with the Office of Citizen Complaints.
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I declare under penalty of perjury that the foregoing is true and correct.
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EXECUTED
California.
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W MUMPHREY
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CASE NOS. CR 13-00753, CR 14-643, CR 15-004, CR 15-005, CR 15-006, CR 15-027, CR 15-028,CR 15-043,
CR 15-049, CR 15-050, CR 15-052, CR 15-059, CR 15-070
Ex.02983
2
3
I have personal experience interacting with and observing police officers in San
franciscos Tenderloin neighborhood.
2.
3.
4.
San Francisco Police Department officer Shawn Ryan is one such officer. In
addition to physically searching my person on occasions, rather than having a
female officer do so, Officer Ryan has repeatedly made comments to me like, Oh
yeah, you looking good today and Youve got a big butt.
5.
6
7
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I declare under penalty of perjury that the foregoing is true and correct.
16
EXECUTED this Qth day of
17
flJZ(
2015, at XM IiV1(itO
California.
1$
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A WILLIAMS
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CASE NOS. CR 13-00753, CR 14-643, CR 15-004, CR 15-005, CR 15-006, CR 15-027, CR 15-02$,CR 15-043,
CR 15-049, CR 15-050, CR 15-052, CR 15-059, CR 15-070
Ex.02988
I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.
2.
3.
4.
5.
Officer ShaugFm Ryan has made several sexually inappropriate comments to me.
On one occasion he told me, let me take you out. On another occasion he said,
you probably have some good stuff which I thought meant that he wanted to
have sex with me. Officer Ryan also requested to smell my hands because he
believed that I had placed drugs in my genital area and that my hands smelled like
my vagina. His comments were disgusting and it made me feel very
uncomfortable.
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I declare under penalty of perjury that the foregoing is true and correct.
EXECUTED this th day of
,2015, at
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5F
,California.
NIJAFtEED
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Ex.02990
1.
I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.
2.
3.
4.
I frequently have felt that officers have specifically singled me out because of my
race. On one occasion, Officer Hope was particularly rough. I was just going to
work as an in-home care worker in September 2014. At the time I was pregnant.
The officers detained me, grabbed my arms, and were forceful with me. They also
harassed my client, an African-American gentleman who was at the time using a
cane and recovering from a stroke who had come over to where I was. They
pushed him against a car and roughed him up. They used more force than
necessary in questioning both of us before they let both of us go. I felt that the
interaction was harassment targeted by race.
7
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I declare under penalty of perjury that the foregoing is true and correct.
1$
2015, at
California.
2ZsLiD
SHALNDA ADAMS
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495929.01
CASE NOS. CR 13-00753, CR 14-643, CR 15-004, CR 15-005, CR 15-006, CR 15-027, CR 15-028, CR 15-043,
CR 15-049, CR 15-050, CR 15-052, CR 15-059, CR 15-070
Ex.02995