Notice of Claim by Brandon Patrick Re Pima County Supervisor Ally Miller

VINCE RABAGO LAW OFFICE PLC
2135 E. Grant Road, Tucson, AZ 85719

(520) 955-9038 www.VinceRabagoLaw.Com Fax: 888-371-4011
October 26, 2016
Robin Brigode, Clerk of the Board

Pima County Board of Supervisors
115 N. Church Avenue
Tucson, AZ 85701
Hon. Sharon Bronson
Hon. Ray Carroll
Hon. Richard Elas
Hon. Ally Miller
Hon. Ramn Valadez
Ally Miller, Pima County Supervisor, Dist. 1

Pima County District 1
115 N. Church Avenue
Tucson, AZ 85701
(hand-delivery to above addresses & via email, via certified mail & via the Clerk of the Board)
Notice of Claim by Brandon Patrick re: Pima County Supervisor Ally Miller &
Pima County Pursuant to A.R.S. 12-821.01. Ariz. R. Evid. 408 communication.
Dear Pima County Board of Supervisors and Supervisor Ally Miller:
I represent Mr. Brandon Patrick and I am authorized to present this Notice of Claim on
his behalf. This is a Notice of Claim against Pima County Supervisor Ally Miller and Pima
County for the amount of $75,000.00, filed by Air Force veteran Brandon Patrick for violating
his First Amendment free speech rights protected by the U.S. and Arizona Constitutions. Ally
Miller's intentional and shocking actions of defiantly and spitefully censoring free speech
protected by the First Amendment, especially the free speech expressed by a military veteran
willing to give his life to protect the freedom enshrined in the Constitution, is outrageous.
After all Board of Supervisor members were expressly informed that deleting social
media comments and blocking followers violates Arizona public record laws and could violate
Constitutional rights, Pima County Supervisor Ally Miller was verbally and publicly defiant,
mocked the warning that cautioned against such behavior, and then acted in accordance with her
expressed derision by spitefully and defiantly censoring and deleting free speech and blocking
any future free speech from Mr. Patrick. Supervisor Miller's conduct was intentionally designed
to stomp out and suppress viewpoints that were unflattering or unfavorable to her, or simply
different from her own. Ally Miller intentionally made a mockery of the First Amendment and
of the responsibility that government officials should exercise.
An action against a public entity or employee may proceed only if the claimant files a
notice of claim that includes (1) facts sufficient to permit the public entity to understand the
basis upon which liability is claimed, (2) a specific amount for which the claim can be settled,
and (3) facts supporting the amount claimed. Havasupai Tribe of Havasupai Reservation v.
Arizona Bd. of Regents, 220 Ariz. 214, 204 P.3d 1063 (App. 2008), review denied.
This claim relates to Supervisor Ally Miller's blatant, spiteful and intentional violations
of Mr. Brandon Patricks guaranteed First Amendment free speech rights protected by the U.S.
Constitution and Article 6 of the Arizona Constitution, in relation to Ally Miller's deletion of
his comments on a public forum on Facebook and her continued restraint of his free speech.
BACKGROUND OF THE FIRST AMENDMENT VIOLATIONS
Mr. Patrick is a military veteran who believes in and supports the freedom of speech as
protected by the First Amendment of the U.S. Constitution and the Arizona Constitution. Mr.
Patrick has been involved in local political and ballot campaigns in Pima County, including at
least one political campaign opposed by Pima County Supervisor Ally Miller. Mr. Patrick
participates in social media and expresses his political viewpoints on mediums like Facebook.
Pima County Supervisor Ally Miller is the elected County Supervisor for District 1 and
sits on the Pima County Board of Supervisors. On January 1, 2013, Pima County Supervisor
Ally Miller established a Government Official Facebook page which she titled Supervisor
Ally Miller. (https://www.Facebook.com/SupervisorAllyMiller/?fref=ts) The page also states
it is: The official Facebook Page of Supervisor Ally Miller, representing District 1 on the Pima
County Board of Supervisors. (https://www.Facebook.com/SupervisorAllyMiller/about/?
entry_point=page_nav_about_item&tab=page_info) (Exhibit A.)
In the About section of this Government Official Facebook page, Supervisor Ally
Miller provides a link to her official county email address district1@pima.gov and government
office phone number. (Exhibit A-1.) The Facebook page also provides a link to her official
internet website page for Pima County Supervisor, Ally Miller, Representing District 1,
which lists her title and name Supervisor Ally Miller, her official government address and
government phone number as: 130 W Congress 11th Floor, Tucson, AZ 85701 520-7242738. (See http://allymillerdistrict1.com/Contact_Us.html) (Exhibit B.) The Contact page
on the website lists similar government contact information for herself and also for other
members of the Pima County Board of Supervisors. (Exhibit B-1). The website page also lists
Facebook and social media for Supervisor Ally Miller. (Exhibit B.) On the website there is a
link to a page titled Social Media, where Supervisor Miller states I believe transparency in
government is extremely important, and one of the ways I actively keep the public informed is
through the use of social media. Follow me on Facebook, Twitter, Instagram, and YouTube for
important video clips from meetings and daily updates on events and news in Pima County.
(http://www.allymillerdistrict1.com/Social_Media.html) (Exhibit B-2.) Supervisor Miller also
maintains her own different personal and political campaign Facebook accounts. (Exhibit B-3.)
2
Pima County Supervisor Ally Miller's Government Official Facebook page establishes
a First Amendment forum for public discourse about community, social and political issues.
Members of the public interact with Supervisor Miller and other individuals on Supervisor
Miller's Government Official Facebook page, providing comments and viewpoints about
political and social issues. Exchanges of opinions and comments occur on this forum.
On November 10, 2015, the Pima County Board of Supervisors adopted Pima County
policy 33.2 regarding Social Media, making it official Pima County policy to use social
media to communicate county policies, program information and general information to the
public. The policy recognizes the vital importance of participating in social media/social
networking communication and is committed to ensuring that the County participates and
listens in meaningful ways. Among various stated goals of the policy was the intent to
engage, listen to input, and participate in neighborhood, local, regional, state and/or
national conversations. The official Pima County policy specifically exempts elected officials
from being subject to the Administrative Procedure developed for Social Media, but stated that
Pima County elected officials shall, however, maintain all social media in accordance with all
public records retention and production laws, regulations and requirements. (Exhibit C.)
Previously, on April 6, 2012, the Pima County Administrator had established
Administrative Procedure 3-31 for all County Departments on the use of social media. It
included guidelines on managing social media, to address Pima County responsibilities
relating to public records, protection of free speech, and information privacy and security all
very important issues and unique to government entities in this new medium of social
networking. All Pima County Departments were encouraged to use social media for various
government activity, including customer service, news and information, and as ways to
communicate with elected and management officials. (Exhibit D.)
On January 21, 2016, Pima County Administrator Chuck Huckelberry sent a
Memorandum to the Board of Supervisors regarding the fact it had been discovered that some
County elected officials had been deleting comments from their County social media accounts
and also banning some members of the public from posting comments on their social media
accounts. These deletions may be in violation of the State's public records laws, ARS 39.121
and ARS 41.141.15. Furthermore, banning some persons from government social media may
be unduly constraining their First Amendment free speech rights. (Exhibit E, Memorandum
regarding Deletion of Social Media Comments and Adherence to State's Public Records Law,
dated Jan. 21, 2016, and Attachment 5 [article concerning First Amendment issues for deleting
Facebook comments], emphasis added.) The Memorandum included Attachments such as the
2012 and 2015 Pima County policies and administrative procedures, Secretary of State and
other training materials on social media and public record retention, and an article on First
Amendment issues in Oro Valley for deleting Facebook comments from an official page. (See
http://webcms.pima.gov/UserFiles/Servers/Server_6/File/Government/Administration/CHHme
mosFor%20Web/January%202016/January%2021,%202016%20-%20Deletion%20of
%20Social%20Media%20Comments%20and%20Public%20Records.pdf .)
3
On or about January 25, 2016, Supervisor Ally Miller posted a Facebook post on the
Government Official Supervisor Ally Miller Facebook page, stating:
You can't make this up:
Chuck Huckelberry has Bud Foster on the beat....coming after me for Facebook.
Aren't you happy we Pay Chuck $320 thousand dollars a year. I just received a
message from Bud requesting comment. I shall not comment on a news story
regarding Facebook! How ridiculous can this get? Stay tuned.
(Exhibit F.)
Pima County Supervisor Ally Miller's Facebook post related to the January 21, 2016
Memorandum by the Pima County Administrator, in that Bud Foster, a local television news
reporter from CBS News, was seeking comment from Supervisor Ally Miller about the issue.
On or about January 25, 2016, Mr. Patrick then engaged in protected First Amendment
activity by weighing in with his speech on the Facebook post written by Supervisor Ally Miller.
Mr. Patrick commented on Supervisor Miller's Facebook post, which itself was prompted by
the County Administrator warning officials that deletion of Facebook comments and blocking
individuals violated public record laws and could also violate the Constitutional rights of
individuals. Mr. Patrick not only commented with his speech on Pima County Supervisor Ally
Miller's Government Official Facebook post, but he also interacted with another commenter,
providing his viewpoint and exercising his free speech rights to comment in this public forum.
Specifically, Mr. Patrick made two separate Facebook comments in response to
Supervisor Miller's Facebook post and commentary.
One comment by Mr. Patrick noted the irony in Ally Miller's statement that she would
not comment on a news story regarding Facebook but that she was in fact using Facebook to
make a comment that she would not comment about a news story regarding Facebook. Mr.
Patrick's comment was satirical free speech commentary regarding the irony in an elected
official Ally Miller's Facebook post, and did not contain any rude or crude language of any
kind. This comment was part of the dialogue on the Government Official Supervisor Ally
Miller's Facebook page, but it was later deleted by Miller and is no longer visible. (Exhibit F.)
Another commenter (Keith Van Heynagan) then posted commentary, in apparent
direct response to Mr. Patrick's comment, by stating Brandon Patrick run for office.
(Exhibit F [highlighting added to identify the use of Mr. Patrick's name by this commenter].)
Mr. Patrick then commented in reply something to the effect of, I could run for office,
or I could start a youtube channel, because that is how real change is made, right? This
comment also was not offensive and was part of the overall dialogue on Supervisor Miller's
page, but was deleted later by Supervisor Ally Miller and is no longer visible. (Exhibit F.)
4
On January 27, 2016, Supervisor Ally Miller posted a comment on her own Facebook
page post on January 7, 2016, at 5:43 p.m. that Chuck Huckelberry is now attacking Kimberly
Varley-deMarco in Green Valley news. Interesting he is spending all this effort on Kim and
myself... I wonder why that could be? We really do live in his head. (Exhibit G.)
Mr. Patrick's comments resulted in another person (Jack Tamali) commenting, and
referring and linking Mr. Patrick into the conversation, and saying Brandon Patrick[:] Yes, it
would be nice if the bureaucracy that words for the elected officials stop trying to control their
ability to govern in a way their constituents would prefer. For example, stop wasting taxpayer's
resources on a 130+ 'memo' about how to handle trolls on their Facebook pages. (Exhibit G.)
On information and belief, sometime around January 25 and 27, 2016, Supervisor Ally
Miller deleted the comments Mr. Patrick posted to her Government Official Facebook page.
On information and belief, Supervisor Ally Miller has also blocked him from commenting on
Supervisor Ally Miller's Government Official Facebook page. In the past, Mr. Patrick had
clicked Like on this Facebook page, which was required in order to be able to engage and
comment on the Government Official Facebook page. However, Supervisor Miller has since
taken intentional action to affirmatively block Mr. Patrick, which thereby restrained and now
continues to restrict him today from ever posting comments on Ally Miller's Facebook page.
Mr. Patrick was not aware that his speech had been deleted and suppressed, and did not
know that he had been continuously restrained with a prior restraint of his free speech due to
Supervisor Ally Miller's decision and action to permanently block him from commenting.
On or about May 19th, 2016, Brandon Patrick first became aware that his comments had
been deleted and that he had been blocked from posting comments to Ally Miller's Facebook
page. This occurred because on that date, Mr. Patrick read a news story in the Tucson Sentinel
online newspaper suggesting that Timothy DesJarlais, an aide to Ally Miller, had created a fake
news outlet called the Arizona Daily Herald and masqueraded as a reporter to try to cover her
political campaign for re-election. (Exhibit I, Article by Dylan Smith titled Ally Miller aide
linked to imitation news website; alter ego posing as reporter, published on May 19, 2016, in
the Tucson Sentinel.) Upon reading these news accounts, Mr. Patrick went to Supervisor Ally
Miller's Government Official Facebook page in order to post comments and to express his
concern about the "AZ Daily Herald" situation. He discovered that he could no longer
comment or express opinion on that Facebook page or on any of the posts on the page.
Mr. Patrick attempted to Like her page so he could then post comments, but Facebook
informed him that he was not allowed to Like that page anymore. At that point, Mr. Patrick
then looked for his prior comments on the page, but his comments had been deleted. Mr.
Patrick also has been barred from future input or discussion on Supervisor Ally Miller's page.
Between May 19th through Oct. 25th 2016, Mr. Patrick has tried to comment on or Like
Supervisor Ally Miller's Government Official Facebook page, but he is still blocked by her.
5
On February 20, 2016, the Arizona Daily Star published an article noting that it appeared
that Arizona public records law was being violated by deletions of postings on Supervisor Ally
Miller's Facebook page, and similar conduct by unrelated county officials. (Exhibit H, Arizona
Daily Star article by Patrick McNamara titled County governments social media shows public
records violations, published Feb. 20, 2016.) Although Supervisor Ally Miller claimed that her
whole office had access to the Facebook account, Supervisor Miller's former Chief of Staff
Jeanine Davis contradicted this claim, and stated: Supervisor Miller was the only one to delete
comments and block individuals, according to the news story. (Exhibit H.)
The facts supporting the claim establish that Pima County Supervisor Ally Miller has
established a public forum with a Government Official Facebook page. The Pima County
Administration specifically advised and informed Supervisor Miller that this creates official
public records which cannot be deleted without violating Arizona Public Records law and
potentially violating First Amendment rights. This Government Official Facebook page is
represented to be the official Facebook page for an elected Pima County official, and thus
established a free speech forum by which she and members of the community engage in
discussions and commentary, discuss recent events, and discuss social and political issues.
Ally Miller's intentional, continued censoring of Mr. Patrick's free speech is outrageous.
FIRST AMENDMENT VIOLATIONS
The right to the freedom of speech is enshrined in the First Amendment to the United
States Constitution, which provides that Congress shall make no law ... abridging the freedom
of speech, or of the press[.] U.S. Const., Amend. I. This limitation on governmental
interference with free speech applies directly to the federal government, and has been imposed
on the states via the Fourteenth Amendment. See, e.g., First Nat'l Bank v. Bellotti, 435 U.S.
765, 779-80, 98 S.Ct. 1407, 55 L.Ed.2d 707 (1978). The Arizona Constitution similarly
enshrines protection of freedom of speech. Article 6, Arizona Constitution.
First Amendment protections extend to speech via the Internet. Through the use of the
Internet, any person with a phone line can become a town crier with a voice that resonates
farther than it could from any soapbox. Reno v. ACLU, 521 U.S. 844, 870, 117 S.Ct. 2329, 138
L.Ed.2d 874 (1997). Through the use of web pages, mail exploders and newsgroups, [any
person] can become a pamphleteer. Reno, 521 U.S. at 870, 117 S.Ct. 2329.
When speech touches on matters of public political life, such as debate over
the qualifications of candidates, discussion of governmental or political affairs,
discussion of political campaigns, and advocacy of controversial points of view,
such speech has been described as the core or essence of the First Amendment.
[See McIntyre v. Ohio Elections Comm'n, 514 U.S. 334, 346-347, 115 S.Ct. 1511,
131 L.Ed.2d 426 (1995)]. Governmental restrictions on such speech are entitled to
exacting scrutiny, and are upheld only where they are narrowly tailored to serve
an overriding state interest. Id. at 347, 115 S.Ct. 1511. However, even non-core
6
speech is entitled to First Amendment protection. First Amendment protections are

not confined to 'the exposition of ideas[.]' Id. at 346, 115 S.Ct. 1511, citing Winters
v. New York, 333 U.S. 507, 510, 68 S.Ct. 665, 92 L.Ed. 840 (1948).
Doe v. 2TheMart. Com Inc., 140 F. Supp. 2D 1088, 1093 (D.C. WA 2001) (quashing subpoena
and thus upholding right to make anonymous free speech commentary).
The Internet is a truly democratic forum for communication. It allows for the free
exchange of ideas at an unprecedented speed and scale. For this reason, the constitutional rights
of Internet users, including the First Amendment right to speak must be carefully
safeguarded. Id. at 1097.
Even just clicking Like on Facebook may constitute both substantive speech and
symbolic expression that is protected by the First Amendment. Bland v. Roberts, 730 F.3d 368,
380-388 (2013) (government retaliation for Facebook Like violated First Amendment
freedom of speech; Facebook 'like' literally causes to be published a substantive
statement [of approval] That a user may use a single mouse click to produce that message
instead of typing the same message with several individual key strokes is of no constitutional
significance. Aside from the fact that liking the Campaign Page constituted pure speech, it also
was symbolic expression. [emphasis added].)
A government official cannot arbitrarily censor messages and ban speakers simply
because they express disagreement with the official's policies. Banning speakers is also a form
of prior restraint preventing them from even speaking based on the content of their speech
and is the most egregious form of censorship. [P]rior restraints on speech and publication are
the most serious and the least tolerable infringement on First Amendment rights. Concerned
Citizens for Judicial Fairness, Inc. v. Yacucci, 162 So. 3d 68, 73 (Fla. 4th DCA 2014) (quoting
Neb. Press Assn v. Stuart, 427 U.S. 539, 559 (1976)).
It is shocking conduct for an elected official to intentionally seek to squelch a citizen's
free speech rights on a protected First Amendment forum created by that same government
official, and which allows others to present their unfiltered First Amendment views. It is also
outrageous for that elected official to seek to silence First Amendment views of a military
veteran willing to risk his life for this country, just because Supervisor Miller disagrees with
those views. Ally Miller engaged in intentional effort to not only suppress Mr. Patrick's
freedom of speech, but to permanently bar him from ever participating in this public forum
again. To add insult to injury, this was ironic because she did so on a Facebook post regarding
an article reflecting that the Pima County Administrator had warned about deleting such posts.
Liability undeniably exists for Supervisor Ally Miller violating federal Constitutional
rights under 42 U.S. 1983. Prevailing claims require attorney fees. 42 U.S. 1988. The
county has additional responsibility in light of the facts, including its expressed policies and
customs, and exclusions. In cases of government action to suppress free speech, compensatory
7
damages in a First Amendment deprivation case may include not only out-of-pocket loss and
other monetary harms, but impairment of reputation, personal humiliation, and mental anguish
and suffering. Memphis Community School District v. Stachura, 477 U.S. 299, 307 (1986).
Punitive damages are awardable when a defendant's conduct is shown to be motivated by evil
motive or intent, or by a reckless or callous indifference to federally protected rights. Smith v.
Wade, 561 U.S. 30, 56 (1983); see also Badia v. Casa Grande, 988 P. 2d 134, 141 (App. 1999).
REINSTATEMENT TO ENGAGE IN FREEDOM OF SPEECH
Supervisor Ally Miller should be required to unblock Mr. Patrick from this Facebook
page and allow for his First Amendment commentary. This should also extend to others who
have been similarly blocked and restrained from engaging in protected freedom of speech
commentary on Pima County Supervisor Ally Miller's Government Official Facebook page.
AMOUNT FOR WHICH CLAIM CAN BE SETTLED
The amount for which this claim can be settled out of court is $75,000.00, which is well
within the range of settlements for violations of Free Speech in a forum protected by the First
Amendment. (See Exhibits J, K, L and M.) The violation of Mr. Patrick's First Amendment
speech is undeniable and was intentional, outrageous, and pernicious in its intended effect.
In 2014, Roswell, New Mexico settled for $97,000.00 over the First Amendment claims
raised by two individuals for restricting their right to engage in speech (preaching) on public
sidewalks. (Exhibit K.) This case is similar in that Mr. Patrick was restricted from engaging in
free speech on a public forum created by Supervisor Miller on the Facebook page.
In cases involving restriction of free speech on public forums created on Facebook, such
censorship cases for deleting comments have resulted in amounts of over $40,000.00 for
deleting Facebook comments, but none of those cases involved such egregious conduct as Ally
Miller engaged in here directly flaunting express official warnings about possibly violating
First Amendment rights of citizens, and then censoring and deleting Free Speech and engaging
in prior restraint of free speech by permanently barring Mr. Patrick and others from engaging in
free speech in this public forum. (Compare Exhibit J, Tennessee county settles for $41,000 in
damages and attorney fees where Sheriff deleted unfavorable comments while leaving
favorable comments after a non-religious group posted an article about Sheriff using Facebook
to proselytize). Another case in New Mexico involved a former Mayor's deletion of Facebook
comments and public record violations of refusing to turn over such public records, but that
public records violation case is still pending, and involves settlement discussions in the range
of $60,000. (Exhibit K.) Other less egregious cases have involved the censorship of Facebook
comments and resulted in settlements of more than $20,000.00. (Exhibit L, San Diego Sheriff's
office sued for deleting Facebook comments by gun activist and settled for $23,020 for
attorneys fees and $20 symbolic amount demanded by activist). In Hawaii, the Hawaii Police
Department settled a Facebook comment censorship case for $31,000.00. (Exhibit M.)
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EXHIBIT A
Notice of Claim Exhibits: Page No. 001
Supervisor Ally Miller | Facebook
1 of 8
https://www.facebook.com/SupervisorAllyMiller/
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Supervisor Ally Miller

October 11 at 2:55pm
Just read the Monsanto article in the paper. Well now, another back room
deal being negotiated?? People are outraged? It is about time. These deals
need to be thoroughly researched and vetted. Let's see how many days
notice we get on this deal before it is served up for a rubber stamp!
Disgusting that I am hearing about this in the media as a County
administrator does the deal in the dark of night. Disgusting! Pima County
taxpayers deserve better!
The next board meeting is October 18th. Please attend.
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PEOPLE
1,264 likes
ABOUT
The official Facebook Page of Supervisor Ally

Miller, representing District 1 on the Pima County
Board of Supervisors.
http://allymillerdistrict1.com/
2 shares
Supervisor Ally Miller Just an update for all of you...I received a 135 page
memorandum from Chuck Huckelberry late Friday afternoon regarding
Monsanto. Some of the information was described as confidential. I will share
what information I am able to after reading this nex... See More
PHOTOS
October 23 at 4:50pm Edited

Supervisor Ally Miller He even had my facebook post above in the
attachment...apparently lots of time to troll my fb page but forgot to send
the information on Monsanto to me.
1 October 23 at 4:49pm
View more replies
Taylor Davidson How about waiting to see how the details emerge and what
they are before jumping on a negativity bandwagon? This could be an excellent
high tech addition to Pima's economy.
View previous replies
Supervisor Ally Miller Russ DeMarco is correct Taylor Davidson. For
an elected official to learn about this through the news media is wrong.
There are executive sessions if details need to be kept secret during
negotiations. People are calling me about this and I have to
... See More
1 October 13 at 5:21am Edited
VIDEOS
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Citizens also spoke out in opposition to Pima County's proposed deal with
10/25/2016 6:05 PM
2 of 8
Monsanto Corporation during the Oct. 18, 2016 Call to the Public.
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the video:
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30 people spoke during the Call to the Public at the Oct. 18, 2016 BOS
Supervisor Ally
Meeting.
Watch the video of citizens speaking out about the lack of road repairs in
Miller
their neighborhoods:
@SupervisorAllyMiller
https://www.youtube.com/watch?v=T2ZVCHUQ0S8
NOTES
About
Pima Animal Care Center $22 Million Bond Elect

March 20, 2014
Endorsements
Sharon Bronson says it is about the children but

March 17, 2014
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March 18, 2014, Agenda Item 14, $22 Million Spe

March 17, 2014
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PEOPLE ALSO LIKE
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Dan Mitchell No Volume
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Pima County
Government Organization
Supervisor Ally Miller This one is working for me as well.

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Marla Closen - for "We the People"

Community

October 16 at 5:48am
Pima County Sheriff's Department
Pima County Board of Supervisor meeting Tuesday, October 18th at 9am.

130 W. Congress.
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Frank Herran, Michael Aragon, Nicole Rox and 3 others like this.
Law Enforcement
LIKED BY THIS PAGE
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Supervisor Ally Miller Long day...and a huge agenda tomorrow. Millions in

contracts....on consent calendar. Hope to see you there.
Oro Valley Police Department
Anne Loftfield First time I've been to one of these meetings, very interesting.
Unfortunately I had to leave my glass water bottle with security, made me a little
fuzzy! I hope you all check out the GMO book, Melissa is careful with facts and
citations. Both Melissa and I are available to answer any questions. Would you
like to visit my son's farm?
Pima County Sheriff's Department
Pima County Republican Women
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October 8 at 3:07pm
The French consul for the state of Arizona awarded 3 Veterans with Legion
of Honor medal today. The award is France's highest military decoration for
contribution's to their country. Congratulations to:
Army Captain Robert McCormack of Sierra Vista
Staff Sgt. Albert Arreola
Sgt John Reitz
It was an Honor to be there. We will post pictures on Monday.
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Pima Animal Care Center officials will hold its first Construction Sale
starting Friday, Oct. 7. To help ease overcrowding during this time of
transition, all dog, cat, puppy and kitten adoptions will be $10 through
Sunday, Oct
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PageMiller added 5 new photos.
September 29 at 8:55am
Wonderful time yesterday at the Sahuarita State of the Town Luncheon.

Great things are happening in Sahuarita.
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this.
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Ann Bracco You look great, Supervisor Ally Miller. Handsome men with you
too!
1 September 29 at 2:11pm
10/25/2016 6:05 PM
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Supervisor Ally Miller Your hubby is looking good. Hope to see you
soon Ann.
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Noah S
wo councilmen (Bracco and Bloomberg) you
are pictured with both voted for a CFD that is essencsially an additional huge
property tax on future residents ( homes in the new areas will have about $1000
dollars
. See More
Septem
Supervisor Ally
Miller
Mexican baseball fever returns to Kino Sports Complex Sept. 29!
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September 23
Need help with your pets? This week Pima Animal Care Center launched a
Pet Support Center hotline dedicated to connecting local residents with the
resources they need to keep their pets and scheduling admission
appointments for healthy owned and stray pets.
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David Castro and Linda Felter like this.

September 22
Pima County officials will formally dedicate a northwest Tucson park in honor
of former Pima County District 1 Supervisor Ann Day. The ceremony begins
at 9 a.m. at Ann Day Community Park, 7601 N. Mona Lisa Road, located at
10/25/2016 6:05 PM
5 of 8
the southwest corner of Magee and Mona Lisa Roads. Please join us.
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Alan Lawson, Alison Myers Don and 13 others like this.
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Public Meeting
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Tucson International Airport will hold a Public Scoping Meeting regarding the
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environmental impact of proposed new runways and the release of airport
lands from federal control:
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Sept. 22nd at 6:00 pm

First Floor of Tucson Executive Terminal "Old Control Tower"... See More
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Sampson Ulysses Ramirez Whoever voted to make accommodations for

bicycles on the highways are beyond stupid. If this is how their mind works than
we have to assume that all future decisions are just as dumb.
September 21 at 7:54pm

September 9
The weekend is upon us...Just enjoy!

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Sandra Larriva, Mark Herbert, Linda Felter and 8 others like this.

September 9
Get your Pima County Library Card during National Library Card Sign Up
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as twenty SEVEN!!!
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September is National Preparedness Month Click Here to Learn more

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September 7
FREE Pet Adoptions Continue at PACC Though September 11

http://webcms.pima.gov/cms/One.aspx
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Supervisor Ally Miller They have alot of animals right now so it is a great time
to adopt.

September 7
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Video of the full Board of Supervisors meeting on 9-6-16 is posted on my

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Supervisor Ally Miller Video of the full Board of Supervisors meeting on
9-6-16 is posted: https://www.youtube.com/watch?v=ZSjDXPjZ9xw
Supervisor Ally
Miller
Pima County Board of
Supervisors, Full Meeting, 9-6-16

YOUTUBE.COM
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September
7 at 2:06pm Edited
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Honeybear Cotton Thank impossible if handicapped!
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Board of Supervisor meeting on September 6th at 9:00 am. 130 W.
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Congress. This will be the only meeting in September. There will be 1
meeting in October, October 18th.
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George Wilson Please tell me again why the Pima County B of S should be
asking for authorization to go "to the street" for millions to finance or refinance
charter schools in Maricopa County or any county other than Pima? Or better
yet, why would this even get on the agenda? Last question: I missed the live
meeting both in person and on line, is there a way to get a rerun on line??
Supervisor Ally Miller La Paz County recently held a study session
and here are some Q&A as a result of that meeting:
http://www.parkerpioneer.net/.../article_0ec8a940-9b59...
Q & A: What is an Industrial

Development Authority?
PARKERPIONEER.NET | BY JOHN GUTEKUNST P
1 September 7 at 7:17am
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September 2
Be safe in your travels and enjoy the long weekend.

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Sandra Larriva Congrats on your primary win!

Supervisor Ally Miller Thanks Sandra!
Sher King Also to You, Ally
10/25/2016 6:05 PM
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Thanks to everyone for sending good wishes.

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Mike T
reelected
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a very good Supervisor and deserve to be
3 August 30 at 3:51pm
Supervisor
Ally
Supervisor Ally Miller Thank you Mike Turner!
August 30 at 5:37pm
Miller
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Laura Taylor-Haines Hope the citizens of Pima County vote for truth, integrity,
and financial accountability. Good luck Ally.
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EXHIBIT A-1
Supervisor Ally Miller - About | Facebook
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Started on January 1, 2013
Pima County Board of Supervisors,

Arizona, District 1, Republican
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Supervisor Ally Miller is currently serving her first term as a
member of the Pima County Board of Supervisors representing
District 1. Supervisor Miller was e... See More
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ng District 1 on the Pima County Board of Supervisors.
10/25/2016 6:39 PM
EXHIBIT B
Home Page
HOME PAGE
ABOUT SUPERVISOR
MILLER
PRESS RELEASES
IN THE NEWS
VOTING RECORD
CONTACT US
SOCIAL MEDIA
Home Page
DISTRICT 1 STAFF
Next Board of Supervisors Meeting
IN THE COMMUNITY
August 15th, 2016 @ 9:00 AM

130 W. Congress, Tucson, 85701
WATCH LIVE | VIEW AGENDAS | VIEW PAST MEETING MINUTES
NEWSLETTERS
RESOURCES
Latest News and Press Releases

PRESS RELEASE:Supervisor Ally Miller Responds to the Passage of the Traffic Safety Ordinance
Supervisor Ally Miller Recognizes CRUSH 1011 During April 19th Board Meeting
Supervisor Ally Miller's Op-Ed in the Arizona Daily Star About How the County Administrator and
Supervisors Are Damaging the Brand
Pima County Attorney's Official Response to Goldwater Institute Letter Regarding World View
County Administrator Huckelberryreceivesa Legacy Award for Roads Despite Terrible Conditions
on Thornydale (Coverage by KVOA)
PRESS RELEASE: Supervisor Ally Miller Responds to Goldwater Institute Letter
Supervisor Ally Miller's Response to the Property Tax Oversight Commission
http://www.allymillerdistrict1.com/[8/10/2016 2:44:42 PM]
Home Page
County Administrator Huckelberry's response to the Property Tax Oversight Commission

PRESS RELEASE: Supervisor Ally Miller Seeks Applicants for the Neighborhood Reinvestment
Oversight Committee (3/9/2016)
Bond Advisory Committee to Hold March 11 Meeting (CLICK TO VIEW AGENDA)
March 11 Application Deadline for Pima County Summer Job Applicants (3/4/2016)
Have questions or County related concerns?

Call(520) 724-2738
Emaildistrict1@pima.gov
I strive to return your calls or emails within 24 hours.
Board of Supervisors Meetings

The Pima County Board of Supervisors meet on the first and third Tuesdayof
everyMonth in the meeting room
located at 130 W. Congress in
Downtown Tucson. The meetings
begin at 9:00am. Residents are
encouraged to attend meetings and
by completing a speakers card, you
are allowed to address the Board for
3 minutes at the Open Call to the
Public.
Link to Upcoming Meeting Dates

Where to Park - click here for your parking
options when attending a meeting
Pima County Statistics on Taxes and Debt
Content copyright 2016. Supervisor Ally Miller. All rights reserved.

Supervisor Ally Miller 130 W Congress 11th Floor, Tucson, AZ 85701 520-724-2738

Home Page

EXHIBIT B-1
Contact Us
1 of 2
http://allymillerdistrict1.com/Contact_Us.html
HOME PAGE
ABOUT SUPERVISOR
MILLER
PRESS RELEASES
IN THE NEWS
VOTING RECORD
CONTACT US
SOCIAL MEDIA
Contact Us
DISTRICT 1 STAFF
Contact Supervisor Miller
IN THE COMMUNITY
NEWSLETTERS
If you have any issues or concerns, fill out the form below, call (520)
724-2738 or email district1@pima.gov. I strive to return your call within 24
hours.
RESOURCES
First Name:
Last Name:
Address Street 1:
Address Street 2:
City:
Zip Code:
(5 digits)
State:
Daytime Phone:
Evening Phone:
Email:
Comments:
Contact the Board of Supervisors

8/10/2016 2:07 PM
Contact Us
2 of 2
http://allymillerdistrict1.com/Contact_Us.html
District
Supervisor
Phone #
Email
Ally Miller
(520) 724-2738
district1@pima.gov
Ramon Valadez
(520) 724-8400
district2@pima.gov
Sharon Bronson
(520) 724-8051
district3@pima.gov
Ray Carroll
(520) 724-8094
district4@pima.gov
Richard Elias
(520) 724-8711
district5@pima.gov
County Concerns/Issues
Pima County Pothole Hotline: (520) 740-2639
Current Road Closures: Click Here to View Current Road Closures
Traffic Incidents: Click Here to View Current Traffic Incidents
Current Projects: Click Here to View Current Roadway Projects
8/10/2016 2:07 PM
EXHIBIT B-2
Social Media
HOME PAGE
ABOUT SUPERVISOR
MILLER
PRESS RELEASES
IN THE NEWS
VOTING RECORD
CONTACT US
SOCIAL MEDIA
Social Media
DISTRICT 1 STAFF
IN THE COMMUNITY
NEWSLETTERS
RESOURCES
Follow Me on Social Media

I believe transparency in government is extremely important, and one of the ways I
actively keep the public informed is through the use of social media. Follow me on
Facebook, Twitter, Instagram, and YouTube for important video clips from meetings and
daily updates on events and news in Pima County. By clicking the logo's below, you will be
sent directly to my specific social media accounts.


http://www.allymillerdistrict1.com/Social_Media.html[8/10/2016 2:19:54 PM]
Social Media

http://www.allymillerdistrict1.com/Social_Media.html[8/10/2016 2:19:54 PM]
EXHIBIT B-3
Ally Miller | Facebook
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Thank You Connie Pellman!

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October 21 at 9:08pm ... See More
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Eileen Dillman, Donald Kerby, Kevin V Sinclair and 15 others like this.
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Ally Miller For Supervisor Connie Pellman

23 hrs
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Ally Miller, Republican candidate running for

re-election to the Pima County Board of
Supervisor's District 1.

3 hrs
http://allyforsupervisor.com/
It is always a great day at the Pima County Republican Club. It was a very
nice lunch meeting. Thank You Mike Ebert.
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Help Ally
It was great to be in studio with James T. Harris last week. Podcast is here if
you missed it.
http://www.1041kqth.com//pima-county-board-supervisor-ally
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Best Phil Ally what's up with Monsanto? Can they be STOPPED? You didn't
vote for the Death Dealers to come here did you?
Ally Miller For Supervisor I heard about via the media. Again....no
transparency. We will see when this comes up on agenda. No the vote
hasn't taken place.
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Ally Miller For Supervisor This deal is not on agenda until after
1 of 7
10/25/2016 6:28 PM
election....Bronson didn't want to make this call until after the election. I hope
folks understand that.
Ally Miller For Supervisor There are 2 more board meetings with the
current board.
NOTES
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Roads are the number 1 priority! I have not wav

March 11, 2012

We had a wonderful campaign event tonite and I want to thank AZ

Republican Party Chair Robert Graham, RNC Latino Outreach coordinator
Sergio Adalberto Arellanos for coming down to Tucson to support my
candidacy. And a big Thank you to Steve Christy and Kim DeMarco for the
kind words and support. I also want to thank John Backer for staying
engaged and helping us move this team to Victory! Special Thanks to Steve
Nanini for hosting and for all who came out tonight. Great Event!
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David Fossdal Sorry I missed it. I'm involved with an Estate Sale tomorrow. A
lot of work.
LIKED BY THIS PAGE
Ally Miller For Supervisor It is nice to see a candidate like John Backer for
Pima County who comes in after a loss to support the team. John was clearly in
this race for more than himself. It is a real honor to know him.
Turquoise Angel Gallery
1 October 16 at 9:04am
Lorraine C. Manley Art Gallery

Interesting article on the County Assessor:

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George Wilson Another incumbent that is not on my 'vote for' list.

Suzanne Droubie Ready for a change?

Exciting Endorsement!!
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Just read the Monsanto article in the paper. Well now, another back room
deal being negotiated?? People are outraged? It is about time. These deals
need to be thoroughly researched and vetted. Let's see how many days
notice we get on this deal before it is served up for a rubber stamp!
Disgusting that I am hearing about this in the media as a County
administrator does the deal in the dark of night. Disgusting! Pima County
taxpayers deserve better!
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Robert Anderson, Reagan Breitkreitz Lane, Randy Hannon and 16

others like this.
Chronological
2 shares
Best Phil We need Kim DeMarco to help you clean out the HOUND house....
Paul Cervantez Sooo not liking this disaster of a deal made

I will be appearing on the James T. Harris show this afternoon at 5pm. Hope
you can join us!
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Sebastian Scopellite, Roger Snapp, Mark Herbert and 7 others like this.
Chronological
1 share
Russ DeMarco You bet!
Best Phil Nice to hear you again:) Good luck on the 8th...I will be voting for Kim
DeMarco and praying you both WIN BIG:)

October 2 at 2:33pm
Are you tired of getting fleeced by the Pima County Board of Supervisors? I
stood against their backroom deals when I stood alone and I will continue
fighting against these sweetheart deals for those who prefer to use YOUR
money to finance these deals for their benefit!
https://arizonadailyindependent.com//pima-countys-most-in/
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Donald Kerby, Shane Dunn, Lyndon Johnson and 17 others like this.
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4 shares
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Ally Miller For Supervisor The current board majority has supported
Huckelberry's agenda for years....Are you ready for Ally Miller, Steve Christy and
Kim DeMarco? It will be a game changer!
Mike N Crystal Thorson Time to take the trash out.
October 2 at 6:57pm

September 25
I will be out on the campaign trail meeting with constituents all week and
hope to see you when I ring the doorbell! My absolute favorite campaign
3 of 7
10/25/2016 6:28 PM
activity is meeting directly with the voters of District 1. You are the ones who
matter.
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Kevin V Sinclair, Donald Kerby, Lyndon Johnson and 25 others like this.
Chronological

David Furrey You go girl! Thanks for all you have done!
Ally Miller For Supervisor Had a great time today...Just love knocking doors. I
was greeted by wonderful voters , lots of precious dogs, a calico kitty and one
Italian man gave me a cannolli! Oh my gosh...delicious. He said there is a gelato
store over by El Molinito on Oracle near the El Conquistador.
That is where he gets the cannolli and the gelato.

September 23
I am pleased to announce that I have been endorsed by the Three Sonorans!

It isn't about parties anymore...it is about right vs wrong. Thank You Three
Sonorans for the endorsement.
http://threesonorans.com/contact/candidate-endorsements/
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Norman Kubitskey, Mark Sorgatz, Rene Abril and 24 others like this.
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Eric Han Yip yip yahoo! You are a rock star
Sher King CONGRATULATIONS*** ALLY !!! KUDO'S

September 4
I want to extend my heartfelt thanks to the voters of District 1 who worked so

hard to support me and ultimately win the primary on August 30th. Your
phone calls, emails, texts and prayers empowered me every day on the
campaign trail. The dedication and hard work has paid off!
We won and we won big! Overall it was a 15% win in the district. This
wouldnt have happened without your support.
Now we are on the march to win the November general election.
We cant waiver o... See More
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Noelle Dorothy Fairweather, Dianne Schmidt Kelley, Larry Cocchiarella

and 33 others like this.
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4 shares
Sebastian Scopellite On reason I left my hometown Tucson was the corruption
of the elected officials and that Tucsonians kept electing the crooks back into
office! Seeing a person like Allison make a change and seeing folks demanding
that change makes me think Tucson has a chance.. Way to go!
Ally Miller For Supervisor Thanks Seb!!
Noelle Dorothy Fairweather what I wish Pima County would do, is STOP
buying empty schools, golf courses and land. STOP! my property taxes
increased $250. I am SICK of it. Oro Valley is Pima County's cash cow.

September 2
4 of 7
10/25/2016 6:28 PM
Have a great and restful weekend everyone! I know I will

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David Fossdal, Kevin V Sinclair, Suzanne Kaye and 11 others like this.

September 1
I am very optimistic about the future of Pima County and we must get a new
board elected in November!
https://arizonadailyindependent.com//steve-spain-onward-t/
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Carolyn Irwin, Jacqueline Jacqui Richardson Johns, Dorothy Prater

Niemi and 36 others like this.
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8 shares
Susan Sandoval Congratulations!!!!!
Long way from Honeywell days, huh? TGFT......

August 30
Thank You to everyone for your support and prayers. We did it!! As of 4 am I
am up by 14.5%.
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Norman Kubitskey, Brad Johns, Roger Shaw and 90 others like this.
Chronological
5 shares
Linda Kyle Thank YOU ALLEY MILLER for fighting the hard fight for us! Didn't.
Get all my conservative people, but you were most important. Love you and
congratulations.
Terence O'Rourke Good For You ... I Know You Are The Hardest Worker On
The Board ... You Work For Us ... So Thanks & Congratulations !

August 29
If you would like to know what your polling location is for the primary election
Aug 30, 2016, click here and put in your address and all the info will be there.
https://www.recorder.pima.gov/VoterStats/PollView
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Joe Seph, Eileen Dillman, Randy Hannon and 4 others like this.

August 29
Using campaign donations to pay your spouse?

https://arizonadailyindependent.com//winchester-family-ma/
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Julie Aday, Mark Herbert and 2 others like this.
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Ally Miller For Supervisor https://arizonadailyindependent.com

/.../winchester.../
Winchester Family Makes Out In Campaign

Cash | Arizona Daily Independent
ARIZONADAILYINDEPENDENT.COM
5 of 7
10/25/2016 6:28 PM
1 August 29 at 6:40am
Ally Miller For Supervisor shared their event.

August 28
I have reserved a room at Fox and Hound for election night. Please join us!
AUG
Ally Miller Election Night Party
30
Tue 6:30 PM MST 7625 N. LaCholla Blvd.

4 people interested 8 people going
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Ann M Knotts Holden We'll see you there later
Ally Miller For Supervisor Thank you for coming Ann...I really
appreciate it.
Susan Sims Smith Congratulations.

August 28
Ha! The "troll" has been outed.

https://arizonadailyindependent.com//pima-county-troll-su/
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like this.
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Ally Miller For Supervisor https://arizonadailyindependent.com/.../pimacounty.../
Pima County Troll: Sundays Comic |

Arizona Daily Independent
August 28 at 7:20am
Ted Haworth The contempt Huckelberry shows for tax payers and their elected
officials is unbelievable. He seems to think this is Huckelberry County and all of
our already high but continually increasing taxes are his to spend as he pleases.

August 27
Campaign Finance Reports for all candidates were due at midnight last night.
You can check results here:
http://electionfilings.pima.gov:8889/
6 of 7
10/25/2016 6:28 PM
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Michael Honeybear Cotton, Randy Hannon, Eileen Dillman and 5

others like this.
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Ally Miller For Supervisor Choose Wisely.
Ally Miller For Supervisor Winchester is also suing City of Tucson Taxpayers
for falling off his bike. I was taught to brush myself off and get back on the bike!
https://arizonadailyindependent.com/.../pima-county.../
Pima County Candidate Winchester Suing

Tucson | Arizona Daily Independent
1 Reply
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7 of 7
10/25/2016 6:28 PM
EXHIBIT C
PIMA COUNTY, ARIZONA

BOARD OF SUPERVISORS POLICY
Subject:
Social Media
Policy Number
Page
D 33.2
1 of 1
Policy
Pima County recognizes the vital importance of participating in social media/social
networking communication and is committed to ensuring that the County participates
and listens in meaningful ways.
Pima County shall endeavor to:
Publish, engage and provide customer service with relevant, timely and
actionable information, while promoting core services and key events.
Establish our voice to build confidence that we are a trusted source for
information, especially during emergencies.
Use social media aggressively during emergencies and emerging incidents to

empower information ambassadors, listen to community first informers and share
critical information.
Listen to input about government services and programs.
Participate in individual, neighborhood, local, regional, state and/or national

conversations.
Ensure the security of our social media accounts.

It is therefore the policy of the Board of Supervisors that all Appointing Authorities, and
Department Directors require their departments/divisions to adhere to the requirements
outlined by the Administrative Procedure developed for Social Media. Elected officials
are exempt from this policy. Pima County elected officials shall, however, maintain all
social media in accordance with all public records retention and production laws,
regulations and requirements.
Applicability
This policy applies to all Pima County departments and boards, commissions and/or
committees established by the Board of Supervisors, volunteers and interns.
Adoption Date:
Effective Date:
November 10, 2015

November 10, 2015
EXHIBIT D
EXHIBIT E
ATTACHMENT 5
EXHIBIT F
EXHIBIT G
EXHIBIT H
County government's social media use shows public records violations | Government and politics | tucson.com
County government's social media use shows public records

violations
By Patrick McNamara Arizona Daily Star
Feb 20, 2016
()
Some Pima County officials who use social media to communicate with constituents are blocking
users, deleting comments and failing to adequately maintain the exchanges as required by the
states public records law, a review shows.
For example, Supervisor Ally Miller did not provide documents that show critical comments were
deleted from her official Facebook account, which is funded by taxpayers.
When asked at a recent meeting why those records were not included among the information
provided to the Star under a public records request to the county, Miller was dismissive and denied
knowledge of any deleted comments. Im so glad we have such big issues, Miller said.
The Star requested social media records from the county after Administrator Chuck Huckelberry in
January told county elected officials that state records laws apply to social media communications.
The Star requested the records in an effort to identify deleted comments and the identities of
blocked or restricted users.
http://tucson.com/...y-government-s-social-media-use-shows-public-records-violations/article_75edc8d3-4020-5235-8ea4-1366312858b2.html[8/10/2016 3:47:47 PM]
Any Facebook or social media communication is a public record, just like an email, said Phoenixbased attorney Dan Barr, who has worked for the Star and handles First Amendment and public
records issues across Arizona.
He said the type of communication, whether its written or electronic, doesnt change its status as a
public record.
Failure to provide public documents opens a governmental body to lawsuits and potential civil
penalties.
For elected officials, general correspondence with the public typically have to be retained for two
calendar years. That includes written or digital communications.
What the content is determines the retention schedule, said Jerry Lucente-Kirkpatrick, a records
analyst with the Arizona Secretary of States Library, Archives and Public Records Division.
COUNTY DATA
When county officials fulfilled the Arizona Daily Stars request, the documents included lists of
blocked Facebook and Twitter accounts from the sheriffs, library, animal care, communications and
one comment that was deleted on the recorders Facebook page.
The Sheriffs Department provided a list of the accounts it had blocked from commenting on its social
media pages.
We do not delete comments from our Facebook account, Deputy Courtney Rodriguez said in a
follow-up interview. Persons banned from our account were found to have been in violation of our
Terms of Use. Each instance of these violations can be located and are maintained directly on the
platform.
Rodriguez said the department uses Facebooks hide function to prevent comments made in violation
of their terms of use invisible to the public.
Typically, violations include off-topic comments, offensive or threatening language or advertising.
Pima Animal Care Center also provided a list of numerous blocked users. PACC was unable to
provide the users deleted comments, however. I dont believe they were retained, Pima County
Communications Manager Mark Evans said.

In November, the Board of Supervisors unanimously approved a policy governing official county
social accounts.
The policy largely mirrors existing state laws, outlining reasons for using social media and
requirements and processes for retaining records.
Evans said many of the deleted comments from the PACC Facebook account were removed prior to
implementing the policy.
County elected officials, were exempted from the policy but are required to conduct their social
media accounts in accordance with state laws regarding production and retention of public records.
In response to the Arizona Daily Stars request, Pima County Recorder F. Ann Rodriguezs office
provided a print out of a single comment deleted from the offices Facebook page.
Except for Miller, each supervisors office said they had not deleted or blocked content from their
social media accounts.
Miller provided a single record, which was a cell phone photo of a computer monitor in her office
showing a post a staffer made to Millers Facebook account in error that later was removed.
While Miller maintains she is unaware of deleted comments or blocked users, the Pima County
Administrators Office provided printouts showing numerous comments that were either deleted or
removed from Millers official Facebook page. The records also showed an additional post the
supervisor made and later deleted.
Asked about the deleted comments at a Feb. 16 board meeting, Miller denied any knowledge.
I havent seen any of those, Miller said.
The Arizona Daily Star provided copies of the documents to Miller and requested comment. She did
not respond.
Miller also suggested that members of her staff could bear the responsibility for any deleted
Facebook content.
My whole office has access to that Facebook page, Miller said.

Millers former chief of staff, Jeannie Davis, who was abruptly fired in December, said it was
disappointing that the supervisor would attempt to blame employees.
Supervisor Miller was the only one to delete comments and block individuals, Davis said.
RECORDS RESPONSIBILITY
Modern social media platforms create challenges in retaining public records.
Facebook has no records management capability, said Lucente-Kirkpatrick, the state records
analyst.
In that case, the responsibility for maintaining the records ultimately lies with those who create them.
In May, Lucente-Kirkpatrick led a training session at Pima County on social media records retention
policies.
Attendees included representative from area governments, school districts and elected offices. A
representative from Supervisor Millers office also attended, a check-in sheet shows.
Some elected officials use software that sends an email of all their social media postings and
comments, Lucente-Kirkpatrick said. The emails then can be included on a governments servers and
archived.
No Pima County officials or departments currently use this type of software.
Despite the challenges in capturing the records, Barr said governments have a legal obligation to
retain social media records.
They cant just say Facebook doesnt do it, Barr said.
Contact reporter Patrick McNamara pmcnamara@tucson.com. On Twitter @pm929.
EXHIBIT I
Ally Miller aide linked to imitation news website; alter ego posing as reporter
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Ally Miller aide linked to imitation

news website; alter ego posing
asreporter
Site goes 'poof' after apparent editorquestioned
Posted May 19, 2016, 8:06 pm
Dylan Smith
TucsonSentinel.com
A communications aide for Pima County Supervisor Ally Miller has been linked to a pretend news
site whose "editor" is using a false name. Timothy DesJarlais, who is also running for the Marana
School Board, was apparently posting for the "Arizona Daily Herald" while being paid during
public meetings.
DesJarlais, a 19-year-old University of Arizona student who has frequently called himself "Jim
Falken" online, claimed Tuesday night that he was not behind the website. Although DesJarlais
said the site was "probably a prank" by a friend, he repeatedly refused to provide the name of the
supposed other person responsible.
Internet accounts connected to the "Herald" were scrubbed quickly after the interview, as were the
other accounts belonging to DesJarlais mentioned during our conversation.
The Twitter page of the 'Arizona Daily Herald.'
Categories
news , politics & government , media & journalism,
local, arizona , breaking
Read more about

ally miller, arizona daily herald , beth borozan , board of
supervisors , david cuillier , election , john winchester ,
marla closen, pima county , ramon valadez , ray carroll,
richard elias, steve christy, timothy desjarlais,
tucsonans for fair elections , ua
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3
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investigation
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Ally Miller's tales of enemies, real and imagined
Notice of
Exhibits:
Ally Miller may have broken
lawClaim
in ordering
staffPage
to No. 056
use personal email 'to be more secretive'
http://www.tucsonsentinel.com/local/report/051716_miller_herald/ally-miller-aide-linked-imitation-news-website-alter-ego-posing-as-reporter/[10/24/2016 6:14:33 PM]
A "Jim Falken" claimed to be the editor of the "Arizona Daily Herald," a purported news website,
and solicited comments via email on Miller's transportation plan from other candidates for the
Board of Supervisors, including Republicans John Winchester who is challenging Miller in the
primary and Steve Christy. The fictitious Falken also contacted sitting supervisors via email.
Miller did not respond to TucsonSentinel.com's request for her to comment on her employee's
apparent masquerading as a reporter.
DesJarlais, a Republican who lives on the Northwest Side near Thornydale and Magee, is also one
of the organizers gathering signatures for an initiative that would change Tucson's elections to
ward-only.
Heraldgate is needlessly spinning out of control on

2
Ally Miller
Ex-Ally Miller staffer 'confesses' he was behind
2
bizarre blog
Falken press: Ally Miller's ex-aide reactivates 'Az
Daily Herald' site
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DesJarlais was interviewed via phone Tuesday night, in a conversation filled with long pauses
before he responded.
He said first that he did not know what the "Arizona Daily Herald" was, and that he had not
registered that domain name.
I want to help TucsonSentinel.com offer a real news

alternative!
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"Oooh, I think I know what's going on here .... somebody is impersonating me," he said when
pressed about the website and the connections to his online identity. "That's what's happening."
He then said that one of his friends had been "talking about politics and becoming a reporter" and
had mentioned creating "his own news website."
"Oh, I wouldn't want to disclose that person's identity to a newspaper," he said when asked who
that friend might be.
When asked if the friend who he said he suspected of playing a prank on him could call me to
substantiate that claim as DesJarlais refused to provide a name the Miller aide asked for my
phone number (despite having already returned my calls several times in a game of phone tag)
and wrote it down, saying he would give it to the friend.
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No call was forthcoming.

DesJarlais acknowledged the many connections between him and his online persona of "Jim
Falken."
$5/mo. Printer's Devil

$10/mo. Cub Reporter
$20/mo. Stringer
$40/mo. Correspondent
He said that his alter ego wasn't common knowledge among his friends, but that "one of them
of amount
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monthly
(numberPage
only) No. 058
might have heard of it."
Websites scrubbed
Just moments after he was interviewed by me, the azdailyherald.com website was taken offline, as
was the Facebook page set up for the sham news outlet. Another website that DesJarlais
TucsonSentinel.com is an Arizona nonprofit organization fiscally

sponsored by FCIR.org, a 501c3 charity. Your contribution is tax deductible.
acknowledged was his was also immediately removed from the Internet, and a video he posted
posing as Falken was removed from public view. Other online postings that linked him with the
Falken persona were also quickly culled.
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Tweets from @TucsonSentinel/website-embed
Earlier, a photograph posted on the "Herald" Facebook page Tuesday showed that day's Board of
Supervisors meeting from the vantage point of the seats occupied by DesJarlais and another Miller
aide during the meeting. That posting was removed Tuesday afternoon.
District 4 Supervisor Ray Carroll, with whom Miller has repeatedly clashed despite their both
being Republicans, and others present at the meeting noted that DesJarlais was sitting with
Miller's executive assistant, Sherry Potter, throughout the meeting, and that the two were passing
a smartphone back and forth.
DesJarlais acknowledged taking a photograph during the supervisors' meeting.
"Was that taken down?," he said quickly when initially asked about the photo. "Do you have a
screenshot of it?"
After a pause, he said, "Yeah, I heard something earlier about a photo... but I don't really know
anything about that."
He then said that he had taken a photo on his phone during the meeting.
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He said he "sent it to my friend. He asked where I was and I texted it to him." DesJarlais said he
did not post it on the "Herald" Facebook page.
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Also pulled down Tuesday evening were a pair of

tweets from the "Herald" about the then-ongoing vote
count in Tuesday's special election. DesJarlais'
interview with TucsonSentinel.com began with a brief
conversation about the tallies being released. The
tweets vanished soon after.
The "Herald" website was hosted on WordPress.com,

and now redirects to a generic page on that site.
Although the website was pulled from the Internet,
the azdailyherald.com domain name remains
registered and is not for sale. Another of DesJarlais'
sites, "Tucson Trumpet," is also hosted on
WordPress.com. That site, which includes his real
name and phone number, is another purported news
website, with just a single post about a Northwest Side grocery store posted last September.
A Twitter account with the same name has only two
tweets: one linking to the grocery post and another
from May 2015 that referenced Supervisor Miller.
That account features the slogan, "Heralding the Right
Tucson News 4 You."
Neither Miller nor her staff responded to a request
for comment about the "Arizona Daily Herald." The
supervisor told Tim Steller of the Daily Star that
DesJarlais denied to her that he had sent out emails

as Falken.
DesJarlais, who recently attended Pima Community
College before beginning his studies at the UA in political science and communication, reportedly
did not show up for work at Miller's office Wednesday or Thursday, multiple sources said.
An extensive public records request that could show connections between Miller's office and the
"Herald" was filed by TucsonSentinel.com on Wednesday, but officials could not provide any of the
data we asked for on a quick timetable.
One of Miller's political opponents, fellow Republican Winchester, called the evident involvement
of her staffer "a new low."
The supposed editor of the sockpuppet website, Falken, messaged Pima County staff May 12,
asking to be added to a distribution list for press releases, saying, "I am the editor of newly
founded paper (sic)."
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Falken also asked to be added to the email lists of other supervisors last week, including Ramn
Valadez, Richard Elas and Ray Carroll.
Internet records show that the azdailyherald.com domain was registered on May 7, with that
registration updated on May 12, but the identity of the person behind the site was hidden from
public view by the registrant.
Falken sent emails to various political candidates on Sunday, asking for comment on Miller's road
plan, including Winchester, Christy and Marla Closen, a Republican who has been allied with Miller
who, like Christy, is seeking to fill Carroll's seat.
Beth Borozan, Christy's campaign manager, checked out the website.

"All I found was a empty WordPress shell ... with a cloaked owner," she said. "I advised Steve not
to reply."
The site's quick disappearance after DesJarlais was questioned about it "must be a record for a
local 'news' outlet," she said. "Poof!"
Falken flees the coop

DesJarlais, who has been a communications assistant
for Miller since February, has posted numerous times
on the Internet as Falken, mainly in conjunction with
his imaginary nation of the "Democratic Republic of
Dido Place," which is named after the street on which
DesJarlais lives. Under both names, DesJarlais has
blogged about the neighborhood-sized fantasy
country, posting about executive orders and other
actions by both "President DesJarlais" and "President Falken."
Those posts include a Youtube video of "President Falken's Thanksgiving Address - 2014,"
featuring DesJarlais speaking to the camera, as well as the country's inclusion in the "Cyber
Nations Wiki," a listing of other imaginary territories. That video was among the material quickly
pulled from the Internet after the aide to the Republican supervisor was interviewed.
DesJarlais told me that he used "Jim Falken" as an online identity numerous times, including on a
"Falken for Governor" website that he said was created for a class at Pima Community College.
That site was also taken down Tuesday after the interview.
'Deceptive'
Making up a country is fine for a hobby, but journalism experts raise their eyebrows when a
government employee conjures up a purported news site.
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"If he's creating a website and trying to hide his identity, while he's promoting an elected official
whom he's beholden to ... that's deceptive," said David Cuillier, the director of the University of
Arizona School of Journalism.
"If that's the case, he's not acting as a journalist," said Cuillier, the former head of the national
Society of Professional Journalists, which sets the ethical standards for the industry. "People have
a hard enough time deciding who to trust."
"We have a long history of people expressing themselves under pseudonyms," Cuillier said, "but
he's not being a journalist he's not independent if he's doing this for his boss."
Falken's online biography claimed that he studied
journalism at the UA.
Winchester, who's challenging Miller in the GOP
primary in District 1, said he was "not surprised" by
the evident connections between DesJarlais and the
impersonation of a reporter.
"The Miller camp has already taken actions like
threatening my volunteers and making false
accusations against me to the Attorney General's
Office, but this is a new low," he said Tuesday night.
Winchester is among the candidates who was emailed
by Falken, asking for responses to questions about
Miller's outline for a road repair plan.
That email, sent Sunday, asked in part, "do you agree
with Supervisor Miller's solution or do you have your own solution to fix Pima County roads, and
if so, what would that be?" It was signed with Falken's name, styling him as "Senior Reporter/Chief
Editor," and sent from editor@azdailyherald.com.
While it's not clear why a Miller staffer would set up a fake news website, Facebook page and
Twitter account, there also appears to be no motivation for a supposed friend of DesJarlais to
concoct the web of accounts. The website was taken down before any posts were apparently ever
made on it, one of the only posts on the Facebook page was deleted Tuesday afternoon, and the
"Herald" tweets were deleted directly after our interview.
Winchester and Carroll said the evidence points to the
Miller camp attempting to "catfish" political
opponents, but they were caught out.
A worked-up Carroll said, "You've got a fake reporter,
saying he's working for a fake newspaper."
"They're trying to distract the public from the
manipulation that's going on with the Republican
primary," said Carroll, who announced earlier this
year he wouldn't seek another term.
Winchester said he considered the situation to be
"using taxpayer-paid county employees to create an
elaborate scheme, pretending to be a journalist for
the purposes of deceitfully getting information
regarding my campaign. This is just the latest in a long line of bizarre Ally antics, such as
pretending to fall into a pothole, (and) calling 911 on real reporters."
have your say

- 30 -
Read all 4
Latest comments on this story
May 23, 2016, 2:04 pm

-1
+1
AZ voter: So you approve of your tax dollars paying someone to

A.J. Flick
20 comments
troll the internet and impersonate others (doesnt matter who)? He

was getting paid to do this by an elected official. It SHOULD kill his
-1 +2
future job prospects - unless Trump hires him as his

communications director then it might qualify him.
May 20, 2016, 3:36 pm

-1
+1
*a long
Mazefaze
3 comments
-0 +1
(auto-correct fail)
May 20, 2016, 3:35 pm

-1
+1
-1 +5
Dylan,
Mazefaze
3 comments
This comment is along time coming: You continue to do great work.

You serve a vital role within our community and we all are better
for it.
Thank you and please continue to keep setting the bar for
journalistic standards in Pima County.
To paraphrase Socrates, you are our Sonoran desert gadfly.
Best,
RM
Sorry, we missed your input...

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EXHIBIT J
American Atheists | Atheists Reach $41,000 Settlement with Tennessee Co... http://news.atheists.org/2016/08/11/atheists-reach-41000-settlement-with-...
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Atheists Reach $41,000 Settlement with Tennessee County Sheriff

Posted on: August 11, 2016
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August 2016
July 2016
Chattanooga, TNAmerican Atheists and Bradley County and the Bradley County Sheriffs Office have reached a
settlement in a federal lawsuit alleging First Amendment violations of the U.S. Constitution by Bradley County and
Bradley County Sheriff Eric Watson.
As part of settlement agreement, the new official Bradley County Sheriffs Department Facebook page will not be used
to promote or further any religion, religious organization, religious event or religious belief. Additionally, the sheriffs
office has decided to not allow any comments on this Facebook page, making it an informational Facebook page only.
The offices original Facebook page was deactivated earlier this year and will be permanently deactivated.
While the county and sheriff admit to no wrongdoing under the agreement, the county will pay a total of $15,000 in
damages to American Atheists and the local plaintiffs, Joshua Stevens and Jane Doe, and $26,000 in attorneys fees.
Plaintiffs were represented by attorney Perry Craft of Nashville.
June 2016
May 2016
March 2016
February 2016
January 2016
December 2015
November 2015
September 2015
August 2015
July 2015
This settlement is a clear win for the plaintiffs, whose First Amendment rights to free speech and to be free of
government establishment of religion were infringed upon, said Amanda Knief, National Legal and Public Policy
Director of American Atheists. We are pleased the sheriff has agreed to do the right thing by no longer using this official
government social media account to promote religion.
What is unfortunate, is that it took a lawsuit and more than $40,000 in taxpayer money for the county and sheriff to
put this common sense policy in place, Knief said. We would have preferred that the sheriff allow citizens the
freedom to comment and interact with the sheriffs office on the Facebook page, but we were not able to reach
agreement on that during mediation.
The anonymous Bradley County resident represented by American Atheists added, I have always said that
Constitutional rights are worth fighting for, and I am proud that when tested, I stood by that principle. It was not easy
June 2015
to stand up to the county sheriff and some people in my community who disagreed with me. Despite some negative
backlash, I do not regret taking action against government censorship. If you dont stand up for yourself, you risk
May 2015
losing your rights.
April 2015
March 2015
Sheriff Watson will be allowed to maintain a personal Facebook page that is clearly marked as containing only his
personal opinions and not those of the department.
February 2015
January 2015
December 2014
November 2014
October 2014
September 2014
The lawsuit arose in May after Sheriff Watson posted an explicitly religious Easter message on the sheriffs offices
official Facebook page. American Atheists sent a letter to the sheriff advising against such religious messages on a
government-sponsored social media site. The sheriff responded by telling a local newspaper that he intended to use his
position as sheriff to proselytize. After posting the local newspaper article on the sheriffs offices Facebook page,
commenters began criticizing the sheriffs statements. The sheriff and employees of the sheriffs department began
deleting and blocking critical comments and users who were critical of the sheriff while leaving favorable comments on
the governmental Facebook page.
August 2014
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Atheists Sue PA House of

Representatives Over Discriminatory
Invocation Policy
Atheists Reach $41,000 Settlement
with Tennessee County Sheriff
Atheists Sue Kansas City Over
$65,000 Handout to Baptist
Convention
prinefan 2 months ago
Man I love this stuff! Shame tax $ were wasted. The sheriff should have had
to pay out of his own pocket. We are suing Levy County Fla. over 10 Comm.
monument on courthouse lawn. Hope we win.
Reply Share
21
Atheists: Trump Pledge to Allow

Church Politicking is a Disaster
Jeffrey Bradt prinefan 2 months ago
I hope so too!
Atheists Ask House Majority Leader

to Sponsor Humanist Invocation
Reply Share
fjpor 2 months ago
Great win for AA and for all of us.

Reply Share
13
disqus_mbkF20E77K 2 months ago
I'd expect this type of thing from a police officer in a country with Sharia law,
but I bet this sheriff can't even see the parallel.
Reply Share
10
prinefan disqus_mbkF20E77K 2 months ago
'Murca. Buybull belt goobers. No surprise.

3
Reply Share
Sukhamaya Bain 2 months ago
I am proud of my adoptive homeland, the USA, which is progressing, in spite

of some of the political correctness and appeasements involving religions and
religious groups that we need to work on.
5
Reply Share
TalesFacingUp 2 months ago
It's not just Bradley County

3
Reply Share
SkyGuy 2 months ago
You can bet that the Bradley County sheriff will not be treating Atheist with
respect now. This isn't a behavior that is solved by a lawsuit. He needs to be
removed.
2
Reply Share
Kirby Palm 2 months ago
I agree with other posters. It wasn't the Sheriff's Office or the taxpayers that
violated the Constitution, it was this jerkwad himself. He should have had
that settlement deducted from his pay. I know the Sheriff's Office probably
has a contractural stipulation that the Sheriff will be held harmless, meaning
the Sheriff's Office will shoulder costs and liabilities for damages and lawsuits
incurred in the course of his duties, but stomping all over citizens' rights was
NOT in the course of his duties.
1
Reply Share
Candice Kamencik 2 months ago
It's a shame that much tax money had to go to this cause, but I definitely
wouldn't say it was wasted. Defending constitutional law and upholding
citizens' rights is a great use of taxes in my opinion. I would love for it not to
have to be used for that purpose, but honestly, I think a lot more money
should be devoted to holding the people who do not follow the law of
10/18/2016 5:04 PM
3 of 3
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Copyright 2013 American Atheists
10/18/2016 5:04 PM
EXHIBIT K
Alamogordo, N.M., Heads Back to Court Over Mayors Facebook Page
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Alamogordo, N.M., Heads Back to Court Over

Mayors Facebook Page
After the mayor refused to turn over all of the interactions she had on Facebook, a resident sued her
for what she claimed was a denial to share public information: The matter will be decided in court.
BY TARA MELTON, ALAMOGORDO DAILY NEWS, N.M. / JUNE 2, 2016
FLICKR/MAGICCATWORK
(TNS)--The city of Alamogordo will head back to court after failing to agree on the proposed
monetary settlement over former Mayor Susie Galea's Facebook page.
In April, Galea and the city of Alamogordo were found in violation of New Mexico's Inspection of
Public Records Act after 12th Judicial District Judge Jerry H. Ritter Jr. ruled that Galea's
Facebook page was subject to inspection requests under the state's records act. According to 12th
Judicial District records, Wendy Irby filed a public records request with the city of Alamogordo
to inspect a Facebook page established by Galea, who was Mayor of Alamogordo at the time, and
the city denied her request.
Ritter concluded that Irby is entitled to a summary judgement including a finding that the
Mayor's Facebook page is a public document subject to inspection and disclosure, and that the
city's refusal of Irby's request is wrongful. The summary judgement also granted Irby an award
http://www.govtech.com/social/Alamogordo-NM-Heads-Back-to-Court-Over-Mayors-Facebook-Page.html[10/26/2016 8:43:04 AM]
of taxable costs and reasonable attorney fees.

Irby's attorney, Blair Dunn, submitted a settlement proposal to the
City of Alamogordo on May 17. The proposal indicated the cost of
RELATED
Are Public Officials

Text Messages Public
Record?
representing Irby is $41,115.25 and proposed damages amount to

$20,000.
"When it comes to denying someone their First Amendment rights
to petition the government or to engage in speech, that's a tough
thing to put a dollar amount on," Dunn said. "Ms. Irby would've
liked to petition her government regarding what was in the
Are Politicians
Facebook Comments
Public Record?
Michigan Bill Seeks
FOIA Exemption for
Energy Infrastructure,
Cybersecurity
Facebook page of the Mayor and she would've liked to be able to

speak about it, but they denied her the ability to engage in speech
by denying her access to those records."
In Dunn's proposed settlement to the City, he gave recent examples of restricting First
Amendment rights in Roswell and Albuquerque. Dunn said in 2014, the city of Roswell settled
the First Amendment claims of two individuals for $97,000 for restricting their First
Amendment right to preach on public sidewalks. Dunn also said in 2013, the city of Albuquerque
settled a case involving the prohibiting of public speech at a police oversight meeting of four
individuals by paying each of them $14,000.
City Attorney Stephen Thies met with commissioners in executive session on May 24 to discuss
the settlement and responded to Dunn on May 25 that the City could not agree to the proposed
settlement terms.
"The $20,000 was honestly, as is my firm's bill, negotiable," Dunn said. "I'm not in this to break
the City or do anything like that and neither is Ms. Irby. We just want to be fairly compensated
and all they had to do was make a counteroffer. Instead of making a counteroffer and saying we'll
pay you so much on fees and so much for the infringement on speech and getting the City out
cheaper, they said no we're going to fight this out so let's go to trial."
Thies, who said he shouldn't comment on the case, said they will now go back to court and a
judge will make the determination on the settlement. Thies said the City has not turned over
Galea's Facebook page and are waiting on the judge to sign the order before they do so.
"I believe the order provided that we had a certain amount of days in which to turn the contents
over," Thies said. "There's a provision where if we want to submit it to the judge, we have that
ability to submit the contents of the page to him and he'll review the contents and then make a
decision on if there's any private information that should be withheld."
Thies said he would like to move on and address other issues but if the City can't agree on the
amount of attorney's fees and damages, they are not going to just write a check.
"We want our governments to be transparent," Dunn said. "When they won't or they don't and
we have to file a lawsuit like this, don't make it worse by after you lose continuing to waste more
money continuing to fight when you screwed up. I think that's the biggest problem with what the
city of Alamogordo is doing is instead of owning they were wrong, they want to continue to fight
forward and don't have any regard for the fact that they violated the law and should pay for it."
2016 the Alamogordo Daily News (Alamogordo, N.M.)Distributed by Tribune Content
Agency, LLC.
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EXHIBIT L
Man Successfully Sues San Diego After Sheriff's Department Censors Facebook Posts
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Man Successfully Sues San Diego

After Sheriffs Department Censors
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Man Successfully Sues San Diego After Sheriffs

Department Censors Facebook Posts
February 25, 2015 | Nick Bernabe
http://theantimedia.org/man-successfully-sues-san-diego-sheriffs-department-censors-facebook-posts/[10/24/2016 3:20:28 PM]
Nick Bernabe
February 25, 2015
(ANTIMEDIA) San Diego, CA Dimitrios Karras filed a
lawsuit against the County of San Diego after the
Sheriffs department censored his comments from
their Facebook page. Last week, it was announced that
Karras settled the lawsuit with the city for $23,000 in
legal fees and a symbolic $20.
Karras, owner of Ares Armor, is known locally and in

the gun rights community for standing up to ATF
agents who were trying to secure a list of all of his
companys client list. The ATF eventually raided his
business and secured a list of all of his clients.
According to Brian Doherty at Reason,
Karras tells me that I demanded at the very

beginning of the settlement talks that I only want to
be paid $20 for myself. I did not want the message
to be muddled with financial gain.
The original comments in question left by Karras on

the Facebook page referenced San Diegos highest

ranking Sheriff, William Gore. Gore has a controversial
past, which includes a leading role in the FBI team that
was responsible for the Ruby Ridge catastrophe that
left three dead.
He (Karras) thinks the attempt to censor discussion

of Gores role in Ruby Ridge is one of those things
where they are so afraid of actual truth that
attempting to hide it just got more people talking
about it. Karras thinks it likely their censorship
attempts on Facebook did more to spread that
information than merely letting the comments sit on
the page would have.
Documents show that FBI snipers were given shoot to

kill orders at Ruby Ridge, which is illegal.
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establishment doesn't want you to receive
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Under the law, police agents can use deadly force to

defend themselves and others from imminent attack,
but these snipers were instructed to shoot any adult
who was armed and outside the cabin, regardless of
whether the adult posed a threat or not. The next
morning, an FBI agent shot and wounded Randy
Weaver. A few moments later, the same agent shot
Weavers wife in the head as she was standing in the
doorway of her home holding a baby in her arms.
The FBI snipers had not yet announced their

presence and had not given the Weavers an
opportunity to peacefully surrender.
The exact role that Sheriff William Gore played in this

incident is unclear he plead the 5th and refused to
speak to investigators in the Congressional hearing
following the incident. However, he was the bureau
chief of the FBI office in charge at Ruby Ridge, and
likely played a prominent role in the decision making
process. The Sheriffs Departments abrupt and
aggressive censorship of Karras posts referencing the
Ruby Ridge connection makes us all the more
suspicious that he committed wrongdoing.
Gores past, as Karras suggests, may explain why he is
also a very trigger happy head Sheriff of San Diego. In
2013 Gores officers responded to what was initially a
domestic disturbance, which they quickly escalated and
resulted in the death of one man and two Sheriffs
injured. They were quick to deploy their newly acquired
armored Bearcat and a heavily militarized response,
even using tear gas against a man who was hiding in
his mothers home.
Gores San Diego Sheriffs department has no shortage
of militarized equipment in their hands thanks to all
the surplus gear flowing into local law enforcement
from the military. They have deployed an LRAD sound
cannon in the past and have also been pursuing
(possibly securing) surveillance drones.
According to Wikipedia, the San Diego Sheriffs
Department is one of the largest departments in the
United States: with over 4,000 employees, and an
annual budget of over $600 million.
The San Diego Sheriffs Facebook page remains closed
at the time of writing this article.

San Diego County has been been contacted about the
lawsuit, but we are still waiting to see if they will have
any comments for us and will update this article
accordingly.
This article is free and open source. You have permission
to republish this article under a Creative Commons license
with attribution to the author and TheAntiMedia.org.
Tune-in to The Anti-Media radio show Monday-Friday @
11pm EST, 8pm PST. Image credit: San Diego Sheriffs
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EXHIBIT M
HPD Ordered to Pay $31K over Censored Facebook Comments > Hawaii...
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Tuesday, August 16, 2016
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Friday, June 27, 2014
HPD Ordered to Pay $31K over Censored Facebook Comments

By Andrew Walden @ 4:10 AM :: 36585 Views :: Honolulu County, First Amendment, Law Enforcement, Second Amendment
by Andrew Walden
After two years of litigation, a Honolulu Federal Court is ordering the Honolulu Police
Department to pay $31K in attorneys fees to Second Amendment activists who sued alleging
First Amendment violations after the HPD allegedly removed plaintiffs Facebook comments
from an HPD Facebook page.
Here is the background and an excerpt from the Court order:
Today in the Federal District Court of Hawaii, the Hawaii Defense Foundation has
filed a lawsuit for violations of the First Amendment. The Defendants in this case
are the City and County of Honolulu and a Honolulu Police Officer, Capt. Andrew
Lum.
The complaint filed in the United States District Court by attorneys Richard
Holcomb, Alan Beck, and Brian Brazier alleges that the Honolulu Police unlawfully
administer their Facebook Fan page in violation of American citizens right to free
speech. The complaint asserts that the Honolulu police arbitrarily moderate the
page by deleting comments and banning users who post or make comments
unfavorable to the department. The complaint further asserts that online speech
is just as important as a citizen airing their grievance in a public park just
because the speech is virtual, doesnt mean it is not protected.
II. BACKGROUND
On August 21, 2012, Plaintiffs filed this action against Defendants City and
County of Honolulu (the City) and Andrew Lum (collectively, Defendants)
alleging violations of the First and Fourteenth Amendments when Plaintiffs posts
to the Honolulu Police Departments social media page on Facebook.com were
removed and Plaintiffs were blocked from making further posts. Doc. No. 1,
Compl. at 1, 11-13. That same day, Plaintiffs also filed a Motion for Temporary
Restraining Order and a Motion for Preliminary Injunction, which sought to
restore Plaintiffs deleted posts, permit Plaintiffs to post to the HPDs page, and
prohibit Defendants from banning people or removing posts based on political
content.
Following several status conferences, Defendants agreed to develop a policy,
through negotiations with Plaintiffs proxy, the American Civil Liberties Union,
governing public posting on HPDs Facebook page. Accordingly, the court deemed
the Motions for Temporary Restraining Order and Preliminary Injunction moot.
Thereafter, the parties engaged in settlement negotiations, reaching an
agreement in principle by January 2013, but failing to resolve the form of
dismissal documents and issues regarding payment of Plaintiffs attorneys fees
and costs.
On October 23, 2013, Plaintiffs filed a Motion for Summary Judgment and
Defendants filed a Motion for Judgment on the Pleadings as to claims against
Defendant Andrew Lum. On January 16, 2014, the parties reached a settlement
on all issues except payment of Plaintiffs attorneys fees and the pending motions
were terminated.
On January 21, 2014, the parties filed a Stipulation dismissing all claims, but
acknowledging Plaintiffs right to file a subsequent motion for attorneys fees. The
underlying Motion for Attorneys Fees followed, in which Plaintiffs sought an
award of $64,690.29. After the F&R recommended that Plaintiffs be awarded
attorneys fees of $22,064.39, Plaintiffs filed their Objections on May 5, 2014 and
an Errata on May 6, 2014. Defendants filed a Response on May 21, 2014, and
Plaintiffs filed a Reply on May 27, 2014. Pursuant to Local Rule 7.2(d), the court
finds this matter suitable for disposition without a hearing.
Background: HPD Sued Over 'Censorship' of Facebook Comments
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From Order of Federal Judge J Michael Seabright, June 19, 2014
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8/16/2016 10:59 AM

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