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Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 113 of 182

DECLARATION OF SAQUITA NASH


I, Saquita Nash, declare as follows:

1.

I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin are also often sexually inappropriate
towards African-American females.

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.

5.

On other occasions, Officer Ryan has referred to African-American females as


bitches and has made comments that women who are confidential informants
for him are bitches that work for me.

6.

Another officer, Officer Ferguson, has attempted to recruit me as a


confidential informant on at least ten occasions. He has frequently said to me,
Give me three, get you free. This sort of repeated contact and unwelcome
attention from Officer Ferguson made me very uncomfortable.

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I declare under penalty of perjury that the foregoing is true and correct.

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EXECUTED this th day of

26

2015, at

(\AO V

California.

$AQtJITA NASH

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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.02939

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 116 of 182

DECLARATION OF AARON MATHEWS

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I, Aaron Mathews, declare as follows:

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1.

I have personal experience interacting with and observing police officers in San
Francisco's Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin are also often sexually inappropriate
towards African-American females.

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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DECLARATION OF AARON MATHEWS
495929.01

Ex.02941

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 122 of 182

DECLARATION OF ACACIA MCNEAL


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I, Acacia McNeal, declare as follows:


1.

I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

In addition to this, I have witnessed law enforcement officers in the Tenderloin


use racial slurs, such as referring to African-American females as black bitches.
I have been called bitch on many occasions by officers in the Tenderloin.

4.

Through my personal experience and observations, I am aware that male law


enforcement officers in the Tenderloin also improperly search female suspects, in
what I understand to be a violation of official San Francisco Police Department
policy. This happened to me on two separate occasions within the last five years.
On both occasions, the most recent having occurred approximately two years ago,
a male officer searched me, touched my breasts and unclasped my bra. I objected
to the search, but the officer continued.

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$

EXECUTED thisZZth day of

2015, at

edSc&, California.

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ACACIA MCNEAL

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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.02946

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 128 of 182

DECLARATION OF ANGELA JONES

I, ANGELA JONES, declare as follows:

1.

I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

On November 11,2013,1 was in the Tenderloin in violation of a stay away order.


After I was detained by San Francisco Police Department Officers, a fight broke
out between two white men close to where I was being arrested. The officers were
more concerned with arresting me for not complying with a stay-away order and
they ignored two white men getting into a fist fight. The officers failed to separate
them or stop the fight from happening, and just put me in the back of the police
car and drove away.

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

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 134 of 182

DECLARATION OF ANITA DIXON


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I, Anita Dixon, declare as follows:

1.

I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

In addition to this, I have witnessed law enforcement officers in the Tenderloin


use racial slurs, such as referring to African-American females as black bitches.

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

EXECUTED thith day of

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

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 140 of 182

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DECLARATION OF CRYSTAL ANTHONY

I, Crystal Anthony, declare as follows:


1.

I have personal experience interacting with and observing police officers in San
franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

In addition to this, I have witnessed law enforcement officers in the Tenderloin


refer to females as bitches. I have been called bitch on many occasions by
officers in the Tenderloin. Once such occasion occurred when San Francisco
Police Department Officer R. Crosby made a comment to me like you stuffing
shit in your pussy bitch.

4.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin are also often sexually inappropriate
towards African-American females.

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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

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 142 of 182

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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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UNITED STATES OF AMERICA,


Plaintiff,

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v.
DARRELL POWELL,
Defendant.

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Case No.: CR 15-

EMC

DECLARATION OF DARRELL
POWELL

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Daiiell Powell, declare as follows:
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1.

I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to African
Americans than individuals of other races.

3.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin use excessive force.

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DECLARATION OF DARRELL POWELL

Ex.02962

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 143 of 182

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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.

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I declare under penalty of perjury that the foregoing is true and correct.
at

EXECUTED this th day of

D LL POWEt
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DECLAPJ\TION Of DARRELL POWELL

Ex.02963

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 149 of 182

DECLARATION OF DARLENE ROUSE

I, Darlene Rouse, declare as follows:

1.

I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin are also often sexually inappropriate
towards African-American females.

4.

Officer Shaughn Ryan has made sexually inappropriate comments to women.


Ive heard him make statements such as, I like big titties and you look just like
my wife. Hes made these kinds of statements to my friends and bystanders in
the neighborhood.

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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

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 155 of 182

DECLARATION OF HOBERT LEE


I, Hobert Lee, declare as follows:

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1.

I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

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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I declare under penalty of perjury that the foregoing is true and correct.

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EXECUTED this Pth day of

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lOB

2015, at

t4alifornia.

T LEE

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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.02973

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 161 of 182

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DECLARATION OF LAKEYSHA WHITE

I, Lakeysha White, declare as follows:


1.

I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

In addition to this, I have witnessed law enforcement officers in the Tenderloin


use racial slurs, such as referring to African-Americans as niggers. I have
personally been called nigger and black bitch by police officers in the
Tenderloin on multiple occasions.

4.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin are also often sexually inappropriate
towards African-American females.

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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EXECUTED this th day of

Oc.b k-ev

2015, at TA

I-, h

California.

KEYSHAWHITE
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CASENOS. 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.02978

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 167 of 182

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DECLARATION OF MATTHEW MUMPUREY

I, Matthew Mumphrey, declare as follows:

1.

I have personal experience interacting with and observing police officers in San
franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin are also often sexually inappropriate
towards African-American females.

4.

In 2014, while walking in the Tenderloin neighborhood, I was stopped by trwo


unknown police officers. One of the officers was Caucasian, while the other was
Latino. The officers questioned me about wearing a bulletproof vest and I
responded to their questions and showed them my security license, which enables
me to wear a bulletproof vest as part of my employment. The officers then
searched my person and located Oxycontin pills. They accused me of possessing
the pills for sale, which I denied. The officers then placed me under arrest. They
then drove me through the Tenderloin and located my car to search for drugs.
Over my objection and without a warrant, they searched my car and damaged it in
the process. No drugs were located and hours later, I was released from custody.

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

day of____________ 2015, at

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

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 173 of 182

DECLARATION OF MELLINA WILLIAMS

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I, Mellina Williams, declare as follows:


1.

I have personal experience interacting with and observing police officers in San
franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin are also often sexually inappropriate
towards African-American females.

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.

On other occasions, Officer Ryan has searched me because he suspected I was in


possession drugs, while refusing or failing to search a non-black companion, who
I knew to actually be in possession of drugs.

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I declare under penalty of perjury that the foregoing is true and correct.

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EXECUTED this Qth day of
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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

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 176 of 182

DECLARATION OF NIJAH REED

I, Nijah Reed, declare as follows:


1.

I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

In addition to this, I have witnessed law enforcement officers in the Tenderloin


refer to African-American females as bitches. I have been called bitch on
several occasions. Officer Goff is one of several officers who has called me
bitch.

4.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin are also often sexually inappropriate
towards African-American females.

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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,California.

NIJAFtEED

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DECLARATION Of Nijah Reed


495929.01

Ex.02990

Case 3:14-cr-00643-EMC Document 119-1 Filed 12/02/15 Page 182 of 182

DECLARATION OF SHALONDA ADAMS

I, SHALONDA ADAMS, declare as follows:

1.

I have personal experience interacting with and observing police officers in San
Franciscos Tenderloin neighborhood.

2.

Through my personal experience and observations, I am aware that law


enforcement officers in the Tenderloin routinely give more attention to AfricanAmericans than individuals of other races.

3.

San Francisco Police Department Officer Shaughn Ryan is known in the


Tenderloin neighborhood for harassing African-Americans. Officer Ryan makes
me feel uncomfortable because he has made comments to me that have made me
feel that he was speaking to me in a sexually inappropriate manner.

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.

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I declare under penalty of perjury that the foregoing is true and correct.

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EXECUTED this th day of

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

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