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Rodney Rouzan

3109 Kilt Court


Lancaster, California 93535
Phone (310) 387-4065 | E-mail: <constitutionlaw2012@gmail.com>

January 27, 2015

TO:










Los Angeles City Mayor Eric Garcetti


Los Angeles City Counsel
Los Angeles Employee Relations Board
Los Angeles Civil Service Commission
Los Angeles City Attorney
Los Angeles World Airport Board of Commissioners
Los Angeles Police Inspector General Alexander Bustamante
Los Angeles World Airport Executive Director Gina Marie Lindsey
Deputy Executive Director Samson Mengitsu
Los Angeles Human Resources Director Paula Adams
LAXPD Chief Patrick Gannon
LAXPD Members

Re:

Notice of Complaint and Complaint for Retaliation and Harassment Against


City of Los Angeles, Los Angeles World Airports et al vs LAXPD Officer
Rodney Rouzan

Introduction


This complaint arises from the retaliatory and harassing conduct of various members of
the Departments and Divisions of the City of Los Angeles World Airport.


On October 18, 2011, I was the subject of a false personnel complaint, which resulted in
my termination. The termination was not sustained upon the finding that the decision was not
substantiated by any evidence, and the complainants were incredible. I had always maintained
that the complaint was false.


Because I believed the complainants instigated the complaint maliciously, and because
of their conduct immediately after my termination, I initiated a Civil Rights action against them,
the County of Los Angeles, and Deputy Sheriffs who invaded my home and assaulted my family,
including my 10 year old son, based on a malicious 911 call initiated by the complainants. The
deputies were parties because they failed or refused to do any reasonable investigation, and left
the location of where the report was made and used an unreasonable show of force to coerce
me and my son from our home.


During the discovery phase it was discovered that someone from the Internal Affairs
Division of the department called the complainants and disclosed to them that I had been
terminated as discipline purportedly as a result of the complainants complaint, in violation of the
Public Safety Officers Procedural Bill of Rights (POBAR). POBAR deems that act a
misdemeanor.

City of Los Angeles


January 27, 2015
Page 2 of 2
(Not including attached affidavit of Rodney Rouzan.)


From the events described above, a series of acts and omissions, and chain of events,
have occurred which have been harassing and retaliatory in nature due because I sought
accountability.


Further, I have suffered from other acts and omissions by various members of the
department that I believe were discriminatory in nature. Therefore, I submit the attached affidavit
and records of those events in support of this complaint in which those events are more fully
expounded upon.

Conclusion


I demand that all parties complained against, and each of them, and their agents,
servants, and employees, and all persons acting under, in concert with, or for them, are
prohibited from continuing, or maintaining retaliatory, harassing, and discriminatory conduct.
And prohibit them from commencing, continuing, or maintaining said conduct acts against me.


In the alternative, I demand whatever relief, remedy, or right I should be afforded, known,
or unknown, in the interest of fairness, and equal protection.


I swear under penalty of perjury that the foregoing, the affidavit, and the supporting
exhibits attached to and associated with my attached affidavit are true and correct duplicates or
copies of the originals. I know their contents. The same is true of my own knowledge.



Notice to the principal is notice to the agent; notice to the agent is notice to the principal.

Date: January 27, 2015



Sincerely,





Rodney Rouzan
Los Angeles World Airport
Officer #00465

AFFIDAVIT OF RODNEY ROUZAN

I, Rodney Rouzan, swear or affirm:

1. I am currently a police officer for the Los Angeles Airport Police Department
(LAXPD). I have served on the Board of Directors for the Los Angeles Airport
Peace Officers Association ("LAAPOA") since November 2005. As a director, part of
my duties are to represent and protect the rights and benefits of our members.

2. During the spring of 2011, I began to discuss with officers the importance of
understanding and upholding their "oath" to the public. I wrote an article entitled
"Oath of Office" in a quarterly magazine which is issued to all of our officers. (See a
copy of that article "Oath of Office" attached herein as Exhibit 1).

3. As a result of that publication referenced in paragraph 2, several members in


LAXPD supervision and management classified and labeled me as a
"constitutionalist" and "sovereign citizen". Based on my treatment, I believe LAXPD
used the following described events as the real reason for my termination, and the
present harassment that I'm being caused to suffer, which is the cause of this notice
and complaint.

4. On October 18, 2010, my neighbor, an estranged ex business partner, and


debtor to a civil judgment accompanied by two other men began chasing my wife's
vehicle as she left our home. After high speeds and multiple turns she was able to
evade them and safely park her vehicle inside of a friends garage. Approximately
15 minutes later the three men were at my front door for unknown reasons. I
verbally demanded they leave my porch, in which they complied. Approximately 5
minutes later two men returned and I immediately notified the Sheriff's department.
The Sheriff's department arrived on scene and determined no crime had occurred
and advised me to seek a restraining order.

5. On or about August 24, 2011, LAXPD Internal Affairs conducted an investigation


into false allegations made by my neighbor and his accomplices, alleging that
during the incident on October 18, 2010, that I had chased them down the street
with a firearm. The allegations were never disclosed to the Sheriff who was on
scene.

6. On May 22, 2012, the Internal Affairs investigation was "sustained" and I was
terminated from my employment without any supporting facts or evidence.

7. On May 23, 2012, six Los Angeles County Sheriff deputies unlawfully ordered me
and my 10 year old son out of our home at gunpoint and searched the property
based on confidential information which was illegally provided to them by the
LAXPD Internal Affairs unit in violation of the Public Safety Officers Procedural Bill of
Rights (POBAR) and Government Code 3300 et seq.

8. On or about May 25, 2012, I appealed my wrongful termination to the Civil


Service Commission and was given a hearing date of September 12, 2012.

9. On June 27, 2012, William Cordero from the LAXPD training unit sent an email
to all sections of the LAXPD regarding special training regarding the "sovereign
citizen movement". (See a copy of the sovereign citizen movement training email
and flyer attached herein as Exhibit 2).

10. On September 7, 2012, Lieutenant Raymond Ingal, from the Los Angeles
General Services Police Department released an email with an attached "safety
bulletin" falsely describing me as having associations with the "sovereign nation"
and having a history of violence (See a copy of that safety bulletin attachment
attached herein as Exhibit 3).

11. On September 12, 2012, while processing through the magnetometers at Los
Angeles City Hall to attend my appeals hearing, I was grabbed and detained by
several members of the Los Angeles Police department who served me with a
temporary restraining order. In the TRO Chief Michael Hyams included a supporting
declaration describing me as having ties to the "sovereign nation". On September
26, 2012, after a hearing the Restraining Order was denied for lack of cause. (See a
copy of Chief Hyams' declaration attached herein as Exhibit 4).

12. The civil service hearings lasted three days and Judy Gust was assigned as the
hearing officer. After hearing all the facts and evidence she issued a report finding
that there was insufficient evidence to sustain any of the charges against me and
that I be returned to my former position with no loss of wages or benefits. (See a
copy of the Judy Gust LA Hearing Officer Report attached herein as Exhibit 5).

13. On February 28, 2013, I went before the Civil Service Board for a reinstatement
hearing at the Los Angeles personnel building located at 700 E Temple Street, LAPD
Metro officers were stationed around the entire building and setup a temporary
screening station directly outside the hearing room and hand waned all parties
entering the location. I have attended multiple hearings at the same location and
have never observed LAPD Metro anywhere in the vicinity. The Los Angeles World
Airports were represented by Christopher Garcia, he stated that the "city" had
grave concerns regarding my ability to carry out my duties because the city believed
I was a "constitutionalist" or "sovereign citizen". Over Mr Garcia's objections the
Civil Service Board reinstated me to my former position with no loss of wages or
benefits. (See a copy of the appeal from discharge of Rodney J Rouzan transcripts
attached herein as Exhibit 6).

14. As a result of the unlawful entry into my home which occurred on May 23, 2012,
I initiated a civil rights lawsuit against the Los Angeles County Sheriff's department
and multiple deputies for unlawful entry into my home. During the discovery
process, I became informed of multiple violations of law, policy, procedure and

falsification of the record committed by members of LAXPD Command Staff and


LAWA Human Resources who had worked in concert to terminate my employment.


The following information was obtained through discovery:

15. LAXPD Internal Affairs members disclosed confidential information to my


neighbors in violation of the Peace Officers Bill of Rights and identified me as a
"sovereign citizen". Each identified member was advised of the violation of law, given
an opportunity to dispute but refused or failed to respond to the misconduct (See one
of the copies of the Notice of a Violation of Peace Officer Bill of Rights attached
herein as Exhibit 7.)

16. Assistant Chief Michael Hyams disclosed to Sergeant Jeff Shelton that he
terminated me based on his belief that I was a "sovereign citizen". (See a copy of Jeff
Shelton affidavit attached herein as Exhibit 8).

17. Human Resources Director, Paula Adams falsified the facts in her Disciplinary
Recommendation for Discharge of Airport Police Officer Rodney Rouzan, in that she
asserted that I had admitted to displaying a weapon in the internal affairs interview
however no such admission was ever made.

18. Los Angeles International Airport Federal Bureau of Investigation resident agent,
David Gates identified me as a "sovereign citizen" to LAXPD security officer Gregory
Leibscher. (See a copy of the deposition of Gregory Leibscher attached herein as
Exhibit 9).

19. On October 2, 2013, I initiated an internal affairs complaint about members of the
internal affairs that disclosed to my neighbors and the Los Angeles Sheriff's
department that I had been terminated from my employment in a violation of the
POBAR. (See a copy the POBAR Complaint attached herein as Exhibit 10).

20. On October 28, 2013, I began searching for my Oath of Allegiance within my
training folder, my search revealed that the department failed or refused to file the
Oath as required by the California Constitution and Government Code. As a board
member of police officers union, it is the duty of the board to represent and protect
the rights and benefits of our members., I requested an audit of all members training
folders which revealed approximately 390 officers have no oath of allegiance on file.
I sent multiple requests to the Chief of the Los Angeles International Airport Police,
Patrick Gannon. As of today's date those officers are still working in the public
without an oath (See a copy of "Request for Oath" attached herein as Exhibit 11).

21. On March 10, 2014, I advised my direct supervisor Sergeant Martha Hall of my
desire to conduct roll call training. She advised me to contact the day watch
commander Lieutenant Chavez and schedule a date for the presentation. On March
12, 2014, at the request of Lieutenant Chavez I sent over an outline for my
presentation (See a copy of the roll call training outline attached herein as Exhibit

12). Lieutenant Chavez denied my roll call request and for the first time in my 14
year career the city attorney attended roll call and provided roll call training on the
issues I proposed (See a copy of email regarding LAWA City attorney attached herein
as Exhibit 13). I contacted six other LAXPD employees who had all conducted roll
call training within the past few months and none of them had to produce an outline
or go through the scrutiny that I was subject too. I contacted LAXPD training unit and
they did not have a single request from any officer to conduct roll call training outside
of the one I submitted. Based on the events just described, and believing my
treatment to be disparate, I filed an Equal Employment Opportunity complaint against
all parties involved. (See a copy of the EEO complaint attached herein as Exhibit
14).

22. On March 11, 2014, I initiated a formal complaint to Executive Director Samson
Mengitsu against Human Resources Director Paula Adams for falsification of the
record (See a copy of Notice of Misconduct and Ethics violation by Human
Resources Director Paula Adams attached herein as Exhibit 15). Mengitsu
subsequently dismissed my complaint on the grounds that Paula Adams falsification
of the record was an "error" and he further alleged that it had no bearing on my
termination, which was based on multiple "factors" (See a copy of Samson
Mengitsu's closure letter attached herein as Exhibit 16).

23. I sent a Public Records Request to the Los Angeles World Airports requesting
any records describing or defining "factors" LAWA responded that there are no
records (See a copy of LAWA's Public Records Request Reply attached herein as
Exhibit 17).

24. On April 14, 2014, I was contacted by Lieutenant Vern Williams of Internal Affairs
who served me with a closure notice to my compliant, which I submitted on October
2, 2013, regarding POBAR violations. (See a copy of the POBAR complaint closure
notice attached herein as Exhibit 18). In that notice Chief Patrick Gannon purports
that, "no evidence was found that anyone from the Airport Police Department Internal
Affairs communicated to the Elmaksouds that I had been terminated from my
employment with LAWA. I met Chief Gannon in person and he admitted that he
dismissed my complaint without ever reading it and then quickly exited the room.
(See a copy of declarations of Rodney Rouzan and Julius Levy attached herein as
Exhibit 19). On December 5, 2014, I gave notice to Chief Gannon that the
representations made in his notice of closure of my complaint were negligent
misrepresentations. He has failed or refused to respond, dispute, or correct. (See a
copy of Negligent Misrepresentations attached herein as Exhibit 20).

25. On April 23, 2014, I submitted a formal complaint to LAXPD internal affairs
against Chief Patrick Gannon (See a copy of the Patrick Gannon complaint attached
herein as Exhibit 21). The complaint was not investigated and the city attorney who
represents the chief arbitrarily sent me a response alleging that she was dismissing
my complaint. I requested her lawful authority to dismiss a complaint against the
Chief of Police and she provided none. (See Deputy City Attorney Patricia Mor email

responses attached herein as Exhibit 22).

26. On July 23, 2014, I went to the Los Angeles city personnel building to attend a
hearing, after checking in with my LAXPD credentials with the security guard, I was
stopped and detained by three LAPD officers regarding the safety bulletin which the
city still maintains in their computer system. (See email to LAXPD command staff
regarding LAPD detainment attached herein as Exhibit 23).

27. On July 31, 2014, I was contacted and had a meeting with Mariella Freire-Reyes,
LAWA EEO coordinator regarding my EEO compliant for retaliation against members
of LAXPD supervision, Paula Adams and Samson Mengitsu, who are Mariella's
supervisors. Mariella told me she was dismissing the complaint because a
"sovereign citizen" is not a protected class. I told Mariella that I believed her to be
intentionally misclassifying my compliant because at all times I have maintained that I
am not a "sovereign citizen" and that members of LAXPD and LAWA had arbitrarily.
classified me as such then used that classification as the grounds to retaliate and
harass me. Two weeks later, I received a written response from Mariella's supervisor
Peter Hernandez who dismissed my compliant but omitted all references to a
"sovereign citizen".(See a copy of the EEO dismissal attached herein as Exhibit 24).

28. I contacted Peter Hernandez and Mariella Freire Reyes via telephone and email
and advised them that I believed that they were intentionally falsifying, misconstruing
my allegations and unlawfully dismissing my complaint against their direct line
supervisors which is a conflict of interest. (See a copy of the email communication
with Peter Hernandez and Mariella Freire Reyes attached herein as Exhibit 25).

29. On August 4, 2014, I requested an emergency transfer from LAX to Van Nuys
airport due to the the disparate treatment that I was receiving from LAXPD and LAWA
supervision and management.(See a copy of the emergency transfer request
attached herein as Exhibit 26).

30. On August 19, 2014, I was notified by multiple parties that personal mail
addressed to me had been returned as undeliverable. I contacted my local post
office and discovered that postal employees, without lawful authority had stopped
delivering mail to my address. After multiple phone conversations with postal
supervisors they refused to deliver, release, or provide lawful authority for their
actions. On August 20, 2014, I drafted a notice and had it served on postal
employees and went to the post office to claim my personal mail (See a copy of
Notice of Unlawful Delivery of Mail attached herein as Exhibit 27). Postal employees
refused to release my mail in violation of Title 18 section 1703 (See a copy of Title 18
section 1703 attached herein as Exhibit 28) and subsequently contacted the Sheriff's
department to have me removed from the location. Deputies arrived on scene and I
was contacted by Deputy Cindy Prather, who was a defendant in my civil rights
lawsuit. I advised her that the Postal employees were detaining my mail which
contained important and timely trial instructions in which she was a defendant. She
ordered me to leave the post office without my mail in what I believe was an attempt

to retaliate and harass me for bringing an action against her, other deputies and her
department. I left the location without my mail or further incident. Later that evening,
I filed a complaint against all deputies for aiding in the commission of a felony and
requested that the watch commander Lieutenant Martinez, have a unit meet me at
the post office the next morning to assist me with a private persons arrest.

31. On August 21, 2014, at 7:30 am I initiated a compliant with the United States
Postal Service Consumer Affairs. At 0830 hours I spoke to the Deputy Post Master
for the Antelope Valley, Ray Bryant who advised me that all of the mail which was
being detained had been released and delivered as of 0800 hours.

32. On November 13, 2014, the Los Angeles County Sheriff paid me in settlement for
the unlawful entry into my home which occurred on May 23, 2012. (See a copy of the
Los Angeles County settlement agreement attached herein as Exhibit 29).

33. On October 27, 2014, I sent an email request to Lieutenant Joaquin Mendez to
inquire regarding the status of my internal affairs complaint against Chief Patrick
Gannon, he failed or refused to respond. On November 17, 2014, I sent a second
request via email, regarding the status of my complaint and the policy and procedure
for handling this issue., Without responding to my request he conveyed to me that
Sergeant Valencia needed to serve me with two Notice of Interviews (See a copy of
Memo of Discussion, Notice of Reply and Rebuttal and Notice of Memo of Issues,
attached herein as Exhibit 30 (a)(b)(c)).

34. On November 18, 2014, I was served with two Notice of Interviews (See a copy
of that Notice of Interviews attached herein as Exhibit 31.) I believe both notices
were served on me in direct retaliation for filing complaints and lawsuits against
LAXPD, LAWA and Los Angeles County Sheriff's who continue to violate the law then
act in concert to cover up their criminal acts. I initiated grievances regarding both
notice of interviews on the grounds that I believe them to be retaliatory and harassing
in nature. (See a copy of both grievances attached herein as Exhibit 32). The
grievances have been denied at all levels, the 1st and 2nd levels have all refused or
failed to meet with me to resolve the grievance as required by LAWAAdmin Manuel
section 3.50.

35. On January 15, 2015, Lieutenant Joaquin Mendez, Officer In Charge of LAXPD
internal affairs unit accompanied by his "advocate" Mariella Freire-Reyes, EEO
Coordinator, attended a small claims civil action for defamation of character in which
Mendez brought personal suit against Sergeant Jeff Shelton after his extensive
criminal history had been produced to LAXPD management. The matter was settled
during mediation and Ms. Reyes signed the dismissal agreement. (See a copy of Jeff
Shelton declaration attached herein as Exhibit 33) Mendez and Reyes also have
been observed eating lunch in the city cafeteria and traveling together in their city
and personal vehicles on multiple occasions. I believe their personal relationship is a
conflict of interest and further reason why all of my complaints have been dismissed.

36. On January 21, 2015, I reported to Internal Affairs regarding the Notice of
Interviews. During the interview, Sergeant Ralph Valencia read the complaint which
contained new allegations which were not listed on the Notice I had received. I
asked for clarification as to the new allegations, Valencia replied, that he made an
"error" and omitted the additional charges. He exited the interview and drafted an
amended Notice of Interview. (See a copy of the original and revised notice attached
herein as E xhibit 34).

37. Later that day, I filed a complaint via my chain of command against the Internal
Affairs investigators for falsifying city documents and what I believe to be the
intentional violation of due process and POBAR.

38. I have exhausted all administrative remedy and based on the facts and events
described above believe that members of LAXPD, LAWA, LAPD, and the Los
Angeles County Sheriff are colluding or conspiring to again cause my termination on
the arbitrary and unfounded opinions, and classifications of me as a "sovereign
citizen." Those certain members include those referenced in this declaration, and
directly associated or connected to the events I've described, some known, others
unknown.

39. As of this date, I am uncertain what exactly a "sovereign citizen is, I was referred
to a Wikipedia URL by my supervisor Sergeant Robert Richardson.

40. It is my belief and understanding that Wikipedia can be created and updated by
anyone with internet access and a computer.

41. I have only performed my duties to the best of my abilities and training, and have
no motives outside of that. I have not been subject of any discipline, progressive or
otherwise with respect to any of the events at present issue.

42. I believe I am being harassed and targeted in retaliation for exposing the
arbitrary, and unlawful misconduct of those involved, the resulting embarrassment,
and for making grievances regarding those acts.


Further affiant saith not.

I SWEAR OR AFFIRM THAT THE ABOVE AND FOREGOING


REPRESENTATIONS ARE TRUE AND CORRECT AND TO THE BEST OF MY
KNOWLEDGE INFORMATION AND BELIEF.

Date: January 27, 2015

___________________________
Rodney Rouzan

SECRETARY OF STATE

I, ALEX PADILLA, Secretary of State of the State of California, hereby certify:


That, Steve J. Dheming was, on January 27, 2015, a duly commissioned,
qualified and acting NOTARY PUBLIC, in the State of California, empowered to act as
such Notary in any part of this State and authorized to take the acknowledgment or
proof of powers of attorney, mortgages, deeds, grants, transfers, and other instruments
of writing executed by any person, and to take depositions and affidavits and administer
oaths and affirmations in all matters incident to the duties of the office or to be used
before any court, judge, officer, or board.
I FURTHER CERTIFY that the seal affixed or impressed on the attached
document is the official seal of said Notary Public and it appears that the name
subscribed thereon is the genuine signature of the person aforesaid, his (or her)
signature being of record in this office.
In Witness Whereof, I execute
this certificate and affix the
Great Seal of the State of
California this 27th
day of January 2015.

Secretary of State

NP-24 A (REV. 1-07)

BY

--- OSP 12 128262

ACKNOWLEDGMENT
A notary public or other officer completing this
certificate verifies only the identity of the individual
who signed the document to which this certificate is
attached, and not the truthfulness, accuracy, or

validity of that document.


State of California x
County of 1-0 5 f

On

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before me,

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(insert name and titi

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personally appeared (-- c'etAt
who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are
subscribed to the within instrument and acknowledged to me that he/she/they executed the same in
his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the
person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.
I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing
paragraph is true and correct.

WITNESS my hand and official seal.

a.; .
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Signature

(Seal)

I
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STEVE J. DHEMING

comm. #1945064 z

Notary Public - California ;1


Los Angeles County
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Mt Comm. Expires Jul4,22 ., 20151

DISTRIBUTION LIST
1. Los Angeles City Mayor, Eric Garcetti

2. Los Angeles City Council, Members:


Joe Buscaino
Jose Huizar
Mitch O' Farrell
Mitchell Englander
Mike Brown
Herb J Wesson Jr
Curren D Price Jr
Bernard Parks
Felipe Fuentas
Nury Martinez
Paul Koretz
Tom Labonge
Bob Blumenfiled
Paul Krekorian
Gilbert Cedillo

3. Los Angeles Civil Service Commission, Members:


Suzanne M Steinke
Jeanne Fugate
Jonathan Weiss
Gabriel J Esparza
Nancy P McClelland

4. Los Angeles Employee Relations Board, Members:


Rhonda L Hilyer
Rosalinda Lugo
Christopher Cameron
Anthony Miller
Douglas Collins


5. Office of the Inspector General, Alexander Bustamante

6. Los Angeles City Attorney, Mike Feuer

7. California Department of Fair Employment and Housing

8. LAX Board of Airport Commissioners, Members:
Cynthia A Telles
Matthew M. Johnson
Beatrice C Hsu
Gabriel Eshaghian

Valeria C Velasco
Sean O. Burton

9. Los Angeles World Airport, Members:


Gina Marie Lindsey
Samson Mengitsu
Peter Hernandez
Mariella Freire Reyes

10.LAXPD, Members:
Patrick Gannon
Brian Walker
Fernando Castro
Henry Acosta
Robert Richardson
Imer Chavez
Joaquin Mendez
Ralph Valencia
Aleda Iraldo
Clint Beacom
William Handley

AFFIDAVIT OF RODNEY ROUZAN ATTACHED EXHIBITS


(SEE ENCLOSED DVD)




TABLE OF CONTENTS

1. OATH OF OFFICE ARTICLE


2. SOVEREIGN CITIZEN TRAINING MOVEMENT
3. SAFETY BULLETIN
4. CHIEF MICHAEL HYAMS DECLARATION
5. JUDY GUST LA HEARING OFFICER REPORT
6. APPEAL FROM DISCHARGE OF RODNEY J ROUZAN
7. NOTICE OF VIOLATION OF PEACE OFFICER BILL OF RIGHTS
8. JEFF SHELTON AFFIDAVIT
9. DEPOSITION OF GREGORY LEIBSCHER
10. POBAR COMPLAINT
11. REQUEST FOR OATH
12. ROLL CALL TRAINING OUTLINE
13. LT CHAVEZ EMAIL
14. EEO COMPLAINT
15. NOTICE OF MISCONDUCT AND ETHICS VIOLATION BY HUMAN RESOURCES
DIRECTOR PAULA ADAMS
16. SAMSON MENGITSU CLOSURE LETTER
17. LAWA'S PUBLIC REQUEST REPLY
18. POBAR COMPLIANT CLOSURE NOTICE
19. RODNEY ROUZAN & JULIUS LEVY DECLARATION
20. NEGLIGENT MISREPRESENTATIONS
21. PATRICK GANNON COMPLAINT
22. DEPUTY CITY ATTORNEY PATRICIA MOR EMAIL
23. LAPD DETAINMENT
24. EEO DISMISSAL
25. PETER HERNANDEZ AND MARIELLA FREIRE REYES EMAIL COMMUNICATION
26. EMERGENCY TRANSFER REQUEST
27. NOTICE OF UNLAWFUL DELIVERY OF MAIL
28. TITLE 18 SECTION 1703
29. LOS ANGELES COUNTY SETTLEMENT
30. (A)NOTICE OF MEMO OF DISCUSSION
(B) NOTICE OF REPLY REBUTTAL
(C) NOTICE OF MEMO OF ISSUES
31. NOTICE OF INTERVIEWS
32. GRIEVANCES
33. JEFF SHELTON DECLARATION
34. ORIGINAL AND REVISED NOTICE OF INTERVIEWS

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