1 PAGES: 1-24 EXHIBITS: 0 STATE OF NEW HAMPSHIRE HILLSBOROUGH SS SUPERIOR NORTH DOCKET NO. 216-2016-CV-821 Sanjeev Lath vs., NH DEPOSITION OF This deposition held pursuant to the New Hampshire Rules of Civil Procedure, at the New England Executive Center, 264 South River Road, Bedford, New Hampshire, on Friday, February 10, 2017, commencing at 10:02 a.m. DUFFY & McKENNA COURT REPORTERS P.O. Box 1658 Dover, NH 03821-1658 (603) 743-4949
1 APPEARANCES 2 3 4 Sanjeev Lath, Pro Se 5 PO Box 162 6 Hooksett, NH 03106 7 603 461-4936 8 Slath1676@gmail.com 9 10 Page 2 11 McDONOUGH, O'SHAUGHNESSY, WHALAND & MEAGHER, PLLC 12 BY: Robert J. Meagher, Esq. 13 42 West Brook Street 14 Manchester, NH 03101 15 603 669-8300 16 Rmeagher@lawfirmnh.com 17 For the 18 20 21 Court Reporter: 22 P. Jodi Ohnemus, LCR #91, RPR, RMR, CRR 1 I N D E X 2 Page 3 3 TESTIMONY OF: PAGE 4 5 6 (By Mr. Lath) 5 7 8 9 10 11 12 13 14 15 16 17 18 20 21 22 Page 4 1 E X H I B I T S 2 EXHIBIT DESCRIPTION PAGE 3 4 Choi Exhibit previously marked 5 5 1 6 Choi Exhibit previously marked 7 7 2 8 Choi Exhibit previously marked 9 9 3 10 Choi Exhibit previously marked 10 11 5 12 Choi Exhibit previously marked 13 13 6 14 Choi Exhibit previously marked 12 15 4 16 Choi Exhibit previously marked 15 17 9 18 20 21 22 (There were no new exhibits marked.) Page 5 1, 2 having first been duly sworn, was 3 examined and testified as 4 follows 5 BY MR. LATH: 6 Q. Thank you, Officer. 7 A. Yes. 8 Q. Could you please state your full name for the 9 record. 10 A. Sure. My name is Austin R. Goodman, A-u-s-t-i-n 11 R. G-o-o-d-m-a-n. 12 Q. Could you please state your employer's name. 13 A. Sure. Manchester, New Hampshire, Police 14 Department. 15 Q. And how long have you been working for the 16 Manchester Police Department? 17 A. Since October 2011, sir. 18 Q. Do you know what this deposition is regarding? A. I do, sir. 20 Q. I'm going to introduce Exhibit 1. I have it right 21 here, officer. 22 (Choi Exhibit 1, previously marked.) Q. And it's previously marked. (1) Pages 2-5
Page 6 Page 7 1 A. Okay. 2 Q. Please take a few moments to review this, and 3 please let me know when you're done. 4 MR. MEAGHER: And that was previously 5 marked as Choi No. 1. 6 A. (Witness reviews document.) Okay, sir. 7 Q. Do you recall this incident at all? 8 A. I do. 9 Q. Could you just describe in your own words what 10 happened during this incident when you responded? 11 A. Basically we were dispatched to this address, 7 12 Northbook Drive, for a neighbor complaint. Prior 13 to arrival, the caller -- obviously it says here 14 "Gail," and I remember it from the report -- 15 Q. Yeah. 16 A. -- that there was some yelling going on, and that 17 her neighbor in apartment 710 had -- was doing 18 some kicking in the hallway; and that you guys were arguing, basically. 20 Q. Did you witness any of this incident -- incidents 21 yourself? 22 A. I did not. Q. So it was all narrated to you by the caller, Gail 1 Labuda? 2 A. Correct. And her -- what she told us when we got 3 there. 4 Q. Sure. And as this call report states -- that the 5 neighbor in apartment 710 kicked her door, would 6 that be correct? That's what she alleged? 7 A. Yes. 8 Q. Okay. 9 MR. LATH: I'm going to do previously 10 marked Exhibit 2, Choi. 11 (Choi Exhibit 2, previously marked.) 12 Q. You don't have to read the whole document, just -- 13 I want to focus on the interrogatory V-8, which is 14 on page 9. 15 MR. MEAGHER: And if I can just explain 16 to him what this is. 17 MR. LATH: Absolutely. 18 MR. MEAGHER: This is from another case that Mr. Lath has, where he sent written questions 20 under oath -- 21 THE WITNESS: Okay. 22 MR. MEAGHER: -- to all these people. THE WITNESS: Okay. Page 8 1 MR. MEAGHER: And so it looks like these 2 were answered by a Dorothy Vachon on the last 3 page. 4 So they're not something from this case. 5 THE WITNESS: Okay. 6 MR. MEAGHER: Just to make it clear. 7 And he wants you to take a look at V -- as in 8 Victor -- 8. 9 A. Okay. (Witness reviews document.) Okay, sir. 10 Q. Yes. Now, these interrogatories were answered by 11 my neighbor, Dorothy Vachon, who lives in unit 12 712. 13 Do you recall speaking with anyone named 14 Dorothy Vachon at any time? 15 A. I don't. 16 Q. Don't. In her interrogatories she swears that 17 "Officer Chow [verbatim] and Goodman of the 18 Manchester Police Department came to my unit on November 25th and mentioned to me that Mr. Lath 20 had mental issues." 21 Do you recall anything -- speaking with 22 her on 11/25 of 2015? A. I do not. Page 9 1 Q. No. So would that be an incorrect statement? 2 A. The part of us speaking to them -- 3 Q. Yes. 4 A. -- since I don't recall? 5 I don't remember speaking with her. 6 Q. And you did not state to anyone that I had mental 7 health issues? 8 A. I did not -- no, I do not. 9 Q. Okay. That would be all I need from Exhibit 2. 10 Exhibit 3, which is an affidavit in the 11 case 15-507, previously marked as Choi Exhibit 12 3. 13 (Choi Exhibit 3, previously marked.) 14 Q. Please take a few minutes to review that -- 15 A. Sure. 16 Q. -- and let me know when you're done. 17 A. No problem. (Witness reviews document.) 18 Okay, sir. Q. Did you see Ms. Labuda the day of -- which is 20 November 22nd of 2015? 21 A. Yes. 22 Q. And did you speak with her? A. I didn't personally. I was just present. (2) Pages 6-9
Page 10 Page 11 1 Q. Okay. And did any of the incidents that's 2 described in the affidavit -- was witnessed by you 3 or your fellow officer? 4 A. Well, we didn't see what was being reported. 5 Obviously, what was being reported had already 6 occurred prior to our arrival. 7 So the answer to your question, no. 8 Q. Okay. And as it states in the affidavit that 9 "Cindy Camp watched him --" which would be me -- 10 A. Sure. 11 Q. "-- through the peephole of Labuda's door." 12 Now, I'm going to introduce previously 13 marked Exhibits 4, 5, and 6. 14 (Choi Exhibit 5, previously marked.) 15 Q. Now, that would be Exhibit 5. 16 Now, would that be unit 709? You've 17 been to my unit a few times. 18 A. Yes. Q. So you recall -- 20 A. Yes, sir. 21 Q. -- this hallway? 22 A. Yes. Q. Would that be the peephole, unit 709? 1 A. Yes. Yes. 2 Q. Okay. And previously marked Exhibit 6, could you 3 just state which wall is being referred to in this 4 affidavit -- in this picture? 5 (Choi Exhibit 6, previously marked.) 6 A. From my recollection, I believe it was the one 7 with the handrailing. 8 Q. Okay. In your opinion, can somebody see somebody 9 kick the wall through this peephole? 10 MR. MEAGHER: I'll object to the form. 11 Question's calling for speculation. 12 But you can go ahead and answer it if 13 you can. 14 A. I have no idea. 15 Q. Okay. 16 A. I mean, maybe if they were standing, looking at an 17 angle from inside, they may be able to see a 18 person. I mean, I have a peephole in my own apartment door. I can -- kind of -- see a little 20 perspective left and right, but it's limited. 21 Q. But, in your opinion, could anybody see their 22 feet? MR. MEAGHER: Same objection. Page 12 1 Go ahead and answer if you can. 2 A. Maybe. 3 MR. LATH: Previously marked Exhibit 4. 4 (Choi Exhibit 4, previously marked.) 5 Q. Now, would this be the hallway? 6 Now, you've been to my unit a couple of 7 times. 8 A. I have sir. 9 Yes, that's it. 10 Q. How many people can -- this hallway -- at the same 11 time walk through? A couple? 12 A. Yeah, probably a couple. 13 MR. MEAGHER: You mean side by side on 14 the stairs? 15 MR. LATH: Side by side -- 16 MR. MEAGHER: On the stairs? 17 MR. LATH: Yeah. 18 A. Depending on their height and build. Q. Yeah. 20 A. I mean, if they were -- maybe two. You know, 21 maybe adult and a child. 22 But I would, again, say that height and build of the people -- to be fair. 1 Q. Thank you. 2 A. No problem. Page 13 3 Q. Did -- when you responded to the incident, did you 4 go inside Ms. Labuda's unit? 5 A. No, we didn't. We just spoke outside. 6 Q. And did you see any kind of camera recording 7 equipment inside her unit? 8 A. I did not. 9 Q. No. Did she mention anything about a camera or 10 recording device? 11 A. No. 12 Q. Besides Ms. Labuda, did you speak with anyone 13 else? 14 A. I did not. 15 Q. Did you see anybody else with Ms. Labuda on that 16 day? 17 A. I believe her family members, the Camps. 18 Q. The Camps. Did they provide any other name they 20 have used beside "Camps"? 21 A. Not to my knowledge. 22 Q. Okay. Do you recall if they provided a name called Cindy Shadler? (3) Pages 10-13
Page 14 Page 15 1 A. I do not remember that. 2 Q. Did they state where they lived or resided? 3 A. Not to me personally. 4 Q. Okay. Have you received any other calls from 5 Cindy Camp or Michael Camp regarding any other 6 harassment? 7 A. No, not since we were at your residence for that 8 specific call. 9 Q. Okay. One quick question from this exhibit is -- 10 does Cindy Camp in the -- in the Exhibit 1, the 11 caller states that I kicked her door, and this 12 affidavit refers to kicking the wall. 13 So do you recall the narration of events 14 after you responded? 15 Was it the -- did Camp allege that I 16 kicked the door or the wall? 17 A. The wall. 18 Q. The wall? A. Near -- near the door. 20 Q. Near the door. 21 A. Yes. 22 MR. LATH: Okay. I'm going to do Exhibit 9, previously marked. 1 (Choi Exhibit 9, previously marked.) 2 Q. Just take a few minutes to review this. 3 A. Sure. (Witness reviews document.) 4 Okay, sir. No problem. 5 Q. And on page 4 -- 6 A. Sure. 7 Q. -- just above where the names are written, 8 "Barbara Belware" -- 9 A. Uh-huh. 10 Q. -- it states "It should be noted that another 11 neighbor opened his door, saw who we were speaking 12 to, and gave us a thumb's up." 13 Do you recall -- or have you seen that 14 neighbor anytime after this incident or spoken 15 to -- 16 A. No, sir. 17 Q. All right. Do you know if it was on the same side 18 of my building, or the other side? A. I don't remember. 20 Q. Don't remember? 21 A. I'm sorry. 22 Q. And it talks about a note in the second paragraph on the top -- 1 A. Uh-huh. Page 16 2 Q. -- that "Lath has been placing notes of defamation 3 around the apartment building and on common 4 hallway billboards. 5 Did you happen to see any of those 6 notes? 7 A. I did not. 8 Q. No. Would that, in your opinion -- a note, unless 9 it's threatening -- would that be protected, or 10 would that be considered a criminal offense? 11 MR. MEAGHER: By that you mean protected 12 speech? 13 MR. LATH: Protected, yeah. You're 14 right. 15 Q. Would that be considered a criminal offense? 16 A. If it was nonthreatening? 17 Q. Yeah. 18 A. Probably not. Q. Did Ms. Labuda mention anything historically about 20 me harassing her, allegedly? 21 A. To me, no. 22 To Officer Choi, yes. Q. Okay. Do you recall what she stated? Page 17 1 A. I don't, but obviously what's notated in the 2 report. 3 Q. Okay. Did Officer Choi ask me for my shoes? 4 A. He did; yes. 5 Q. And at any point during the incident was I 6 disrespectful to either you or Officer Choi? 7 A. Are you asking for my personal opinion, or 8 professional opinion, or just in the totality of 9 the incident? 10 Q. Let me ask you your professional opinion: Was I 11 disrespectful? 12 A. Well, I certainly didn't take it personally. 13 Me personally, no. 14 Officer Choi, I can't speak for him. 15 In a law enforcement setting, I think 16 that maybe you could have cooperated a little bit 17 better. 18 Q. Okay. A. That's the best way I'll say that. 20 Q. Okay. 21 A. But I don't think you were -- I think you could 22 have cooperated better. I'll just leave it at that. (4) Pages 14-17
Page 18 Page 1 Q. Okay. Do I have a right to refuse my property 2 without a warrant? 3 MR. MEAGHER: Which property? Rather 4 than -- 5 MR. LATH: Any property that I own. 6 MR. MEAGHER: You mean shoes or... 7 MR. LATH: Shoes or anything I'm 8 wearing. 9 MR. MEAGHER: Refuse to hand over or... 10 MR. LATH: Yes. 11 A. You do in certain circumstances; yes. 12 Q. Okay. And did I assert that, that I would have 13 Officer Choi give me a warrant? 14 A. You did mention that; yes. 15 Q. Okay. And did Officer Choi enter my unit? 16 A. No, he did not. 17 Q. Did I ask him to leave; do you recall? 18 A. Well, we weren't inside, so I don't really recall. Since we weren't inside, you didn't really say to, 20 Get out of my unit. I don't think you wanted us 21 present in the hallway anymore. 22 Q. Just a few general questions: So after that incident, have you seen me before -- again? 1 A. I have, sir. 2 Q. Okay. And have I been disrespectful? 3 A. No, you weren't disrespectful. 4 Q. And have you spoken to any of my neighbors after 5 this incident regarding any other incidents? 6 A. Since I last saw you? 7 Q. Yes. 8 A. No, I have not. 9 Q. When was the last time you saw me? 10 A. The night of the fire in your apartment unit. I 11 don't remember the exact date, but... 12 Q. December 15th, 2016. 13 A. Yes. 14 Q. I remember. They haven't fixed it yet. 15 A. Yeah, I understand. 16 Q. Did any of my neighbors mention anything regarding 17 the fire to you? 18 A. That night? I did not speak with any neighbors. Q. Following that night, did any of the neighbors 20 allege that I tried to burn the place down? 21 MR. MEAGHER: Allege to Austin Goodman? 22 MR. LATH: Yeah. Q. Or any of your fellow officers. Page 20 1 A. I can only speak for myself. I was the responding 2 officer. I took the initial report. So they 3 didn't say anything to me that night, and I 4 haven't been back, since I'm assigned to a 5 different part of the city now. 6 Q. Okay. And did you make a report of the fire 7 incident? 8 A. I did, sir. Yes, I did. 9 MR. LATH: Would you be willing to 10 produce that? 11 MR. MEAGHER: Yeah. At some point, 12 yeah; I guess. Yeah. 13 MR. LATH: Okay. 14 Q. Regarding the November 22nd, 2015 incident, was 15 there an arrest warrant issued? Are you aware? 16 A. Yes. 17 Q. Yeah. Did you petition for the arrest warrant? 18 A. I did not, sir. Q. Okay. Do you know who did? 20 A. I do. 21 Q. Okay. Can you please state the name of the 22 person? A. Sure. Officer Andrew Choi. Page 21 1 Q. Do you know if I was ever arrested? 2 A. I actually don't. 3 Q. Did you go inside my unit on the day of the fire? 4 A. Did I, sir? 5 Yes. I was with you, if you remember. 6 Q. Yes. 7 Did you notice any holes -- anything 8 strange? 9 A. Besides that it was completely covered in smoke? 10 Q. Yeah. 11 A. Not to my recollection. 12 MR. LATH: Okay. I think that's all I 13 have. 14 THE WITNESS: No problem. 15 (Whereupon the deposition ended at 16 10: a.m.) 17 18 20 21 22 (5) Pages 18-21
1 ERRATA SHEET 2 Page 22 3 I, Patrol Officer Austin R. Goodman, wish 4 to document the following corrections: 5 6 7 PAGE LINE 8 9 REASON: 10 REASON: 11 REASON: 12 REASON: 13 REASON: 14 REASON: 15 REASON: 16 REASON: 17 REASON: 18 REASON: REASON: 20 REASON: 21 REASON: 22 REASON: REASON: 1 SUBSCRIPTION OF DEPONENT 2 State of 3 County of 4 5 6 Page 7 I, Patrol Officer Austin R. Goodman, do 8 hereby certify that I have read the foregoing 9 transcript of my testimony and further certify 10 that said transcript (with/without) suggested 11 corrections on the Errata Sheet is a true and 12 accurate record of said testimony taken at the 13 time and place designated. 14 15 16 17 Signed under the pains and penalties of 18 perjury this day of, 2017. 20 21 22 Patrol Officer Austin R. Goodman 1 C E R T I F I C A T E 2 Page 24 3 I, Patricia Jodi Ohnemus, a Licensed Shorthand Reporter for the State of New Hampshire, 4 do hereby certify that the foregoing is a true and accurate transcript of my stenographic notes of 5 the proceeding taken at the place and on the date hereinbefore set forth to the best of my skill and 6 ability under the conditions present at the time. 7 I further certify that I am neither attorney or counsel for, nor related to or 8 employed by any of the parties to the action in which this proceeding was taken, and further that 9 I am not a relative or employee of any attorney or counsel employed in this case, nor am I 10 financially interested in this action. 11 The foregoing certification of this transcript does not apply to any reproduction of 12 the same by any means unless under the direct control and/or direction of the certifying 13 reporter. 14 15 16 17 18 20 Patricia Jodi Ohnemus LCR #91, RMR, RPR, CRR 21 22 (6) Pages 22-24
[verbatim] (1) 8:17 [ A able (1) 11:17 above (1) 15:7 Absolutely (1) 7:17 actually (1) 21:2 address (1) 6:11 adult (1) 12:21 affidavit (5) 9:10;10:2,8;11:4;14:12 again (2) 12:22;18: ahead (2) 11:12;12:1 allege (3) 14:15;:20,21 alleged (1) 7:6 allegedly (1) 16:20 Andrew (1) 20: angle (1) 11:17 answered (2) 8:2,10 anymore (1) 18:21 apartment (5) 6:17;7:5;11:;16:3; :10 arguing (1) 6: around (1) 16:3 arrest (2) 20:15,17 arrested (1) 21:1 arrival (2) 6:13;10:6 assert (1) 18:12 assigned (1) 20:4 AUSTIN (3) 5:1,10;:21 A-u-s-t-i-n (1) 5:10 aware (1) 20:15 back (1) 20:4 Barbara (1) 15:8 Basically (2) 6:11, Belware (1) 15:8 beside (1) 13:20 Besides (2) 13:12;21:9 best (1) 17: better (2) 17:17,22 billboards (1) 16:4 bit (1) 17:16 build (2) 12:18, building (2) 15:18;16:3 burn (1) :20 B C call (2) 7:4;14:8 called (1) 13: caller (3) 6:13,;14:11 calling (1) 11:11 calls (1) 14:4 came (1) 8:18 camera (2) 13:6,9 Camp (5) 10:9;14:5,5,10,15 Camps (3) 13:17,18,20 can (9) 7:15;11:8,12,13,;12:1, 10;20:1,21 case (3) 7:18;8:4;9:11 certain (1) 18:11 certainly (1) 17:12 child (1) 12:21 Choi (17) 5:22;6:5;7:10,11;9:11,13; 10:14;11:5;12:4;15:1; 16:22;17:3,6,14;18:13,15; 20: Chow (1) 8:17 Cindy (4) 10:9;13:;14:5,10 circumstances (1) 18:11 city (1) 20:5 clear (1) 8:6 common (1) 16:3 complaint (1) 6:12 completely (1) 21:9 considered (2) 16:10,15 cooperated (2) 17:16,22 couple (3) 12:6,11,12 covered (1) 21:9 criminal (2) 16:10,15 D date (1) :11 day (3) 9:;13:16;21:3 December (1) :12 defamation (1) 16:2 Department (3) 5:14,16;8:18 Depending (1) 12:18 deposition (2) 5:18;21:15 describe (1) 6:9 described (1) 10:2 device (1) 13:10 different (1) 20:5 dispatched (1) 6:11 disrespectful (4) 17:6,11;:2,3 document (5) 6:6;7:12;8:9;9:17;15:3 done (2) 6:3;9:16 door (8) 7:5;10:11;11:;14:11, 16,,20;15:11 Dorothy (3) 8:2,11,14 down (1) :20 Drive (1) 6:12 duly (1) 5:2 during (2) 6:10;17:5 E either (1) 17:6 else (2) 13:13,15 employer's (1) 5:12 ended (1) 21:15 enforcement (1) 17:15 enter (1) 18:15 equipment (1) 13:7 events (1) 14:13 exact (1) :11 examined (1) 5:3 Exhibit (18) 5:20,22;7:10,11;9:9,10, 11,13;10:14,15;11:2,5;12:3, 4;14:9,10,;15:1 Exhibits (1) 10:13 explain (1) 7:15 F fair (1) 12: family (1) 13:17 feet (1) 11:22 fellow (2) 10:3;: few (5) 6:2;9:14;10:17;15:2; 18:22 fire (4) :10,17;20:6;21:3 first (1) 5:2 fixed (1) :14 (1) [verbatim] - fixed
focus (1) 7:13 Following (1) : follows (1) 5:4 form (1) 11:10 full (1) 5:8 G Gail (2) 6:14, gave (1) 15:12 general (1) 18:22 GOODMAN (4) 5:1,10;8:17;:21 G-o-o-d-m-a-n (1) 5:11 guess (1) 20:12 guys (1) 6:18 H hallway (6) 6:18;10:21;12:5,10;16:4; 18:21 Hampshire (1) 5:13 hand (1) 18:9 handrailing (1) 11:7 happen (1) 16:5 happened (1) 6:10 harassing (1) 16:20 harassment (1) 14:6 health (1) 9:7 height (2) 12:18,22 historically (1) 16: holes (1) 21:7 idea (1) 11:14 incident (11) 6:7,10,20;13:3;15:14; 17:5,9;18:;:5;20:7,14 I incidents (3) 6:20;10:1;:5 incorrect (1) 9:1 initial (1) 20:2 inside (6) 11:17;13:4,7;18:18,; 21:3 interrogatories (2) 8:10,16 interrogatory (1) 7:13 introduce (2) 5:20;10:12 issued (1) 20:15 issues (2) 8:20;9:7 kick (1) 11:9 kicked (3) 7:5;14:11,16 kicking (2) 6:18;14:12 kind (2) 11:;13:6 knowledge (1) 13:21 K L Labuda (5) 7:1;9:;13:12,15;16: Labuda's (2) 10:11;13:4 last (3) 8:2;:6,9 LATH (18) 5:5;7:9,17,;8:;12:3, 15,17;14:22;16:2,13;18:5,7, 10;:22;20:9,13;21:12 law (1) 17:15 leave (2) 17:22;18:17 left (1) 11:20 limited (1) 11:20 little (2) 11:;17:16 lived (1) 14:2 lives (1) 8:11 long (1) 5:15 look (1) 8:7 looking (1) 11:16 looks (1) 8:1 M Manchester (3) 5:13,16;8:18 many (1) 12:10 marked (15) 5:22,;6:5;7:10,11;9:11, 13;10:13,14;11:2,5;12:3,4; 14:;15:1 may (1) 11:17 maybe (5) 11:16;12:2,20,21;17:16 MEAGHER (16) 6:4;7:15,18,22;8:1,6; 11:10,;12:13,16;16:11; 18:3,6,9;:21;20:11 mean (6) 11:16,18;12:13,20;16:11; 18:6 members (1) 13:17 mental (2) 8:20;9:6 mention (4) 13:9;16:;18:14;:16 mentioned (1) 8: Michael (1) 14:5 minutes (2) 9:14;15:2 moments (1) 6:2 myself (1) 20:1 N name (6) 5:8,10,12;13:,22;20:21 named (1) 8:13 names (1) 15:7 narrated (1) 6: narration (1) 14:13 near (3) 14:,,20 need (1) 9:9 neighbor (6) 6:12,17;7:5;8:11;15:11, 14 neighbors (4) :4,16,18, New (1) 5:13 night (4) :10,18,;20:3 nonthreatening (1) 16:16 Northbook (1) 6:12 notated (1) 17:1 note (2) 15:22;16:8 noted (1) 15:10 notes (2) 16:2,6 notice (1) 21:7 November (3) 8:;9:20;20:14 O oath (1) 7:20 object (1) 11:10 objection (1) 11: obviously (3) 6:13;10:5;17:1 occurred (1) 10:6 October (1) 5:17 offense (2) 16:10,15 OFFICER (13) 5:1,6,21;8:17;10:3;16:22; 17:3,6,14;18:13,15;20:2, officers (1) : one (2) 11:6;14:9 only (1) 20:1 opened (1) 15:11 opinion (6) 11:8,21;16:8;17:7,8,10 out (1) 18:20 outside (1) 13:5 over (1) 18:9 own (3) 6:9;11:18;18:5 page (3) P (2) focus - page
7:14;8:3;15:5 paragraph (1) 15:22 part (2) 9:2;20:5 PATROL (1) 5:1 peephole (4) 10:11,;11:9,18 people (3) 7:22;12:10, person (2) 11:18;20:22 personal (1) 17:7 personally (4) 9:;14:3;17:12,13 perspective (1) 11:20 petition (1) 20:17 picture (1) 11:4 place (1) :20 placing (1) 16:2 please (6) 5:8,12;6:2,3;9:14;20:21 point (2) 17:5;20:11 Police (3) 5:13,16;8:18 present (2) 9:;18:21 previously (15) 5:22,;6:4;7:9,11;9:11, 13;10:12,14;11:2,5;12:3,4; 14:;15:1 Prior (2) 6:12;10:6 probably (2) 12:12;16:18 problem (4) 9:17;13:2;15:4;21:14 produce (1) 20:10 professional (2) 17:8,10 property (3) 18:1,3,5 protected (3) 16:9,11,13 provide (1) 13: provided (1) 13:22 Question's (1) 11:11 quick (1) Q 14:9 R Rather (1) 18:3 read (1) 7:12 really (2) 18:18, recall (11) 6:7;8:13,21;9:4;10:; 13:22;14:13;15:13;16:; 18:17,18 received (1) 14:4 recollection (2) 11:6;21:11 record (1) 5:9 recording (2) 13:6,10 referred (1) 11:3 refers (1) 14:12 refuse (2) 18:1,9 regarding (5) 5:18;14:5;:5,16;20:14 remember (8) 6:14;9:5;14:1;15:,20; :11,14;21:5 report (5) 6:14;7:4;17:2;20:2,6 reported (2) 10:4,5 resided (1) 14:2 residence (1) 14:7 responded (3) 6:10;13:3;14:14 responding (1) 20:1 review (3) 6:2;9:14;15:2 reviews (4) 6:6;8:9;9:17;15:3 right (5) 5:20;11:20;15:17;16:14; 18:1 S Same (3) 11:;12:10;15:17 saw (3) 15:11;:6,9 second (1) 15:22 sent (1) 7: setting (1) 17:15 Shadler (1) 13: shoes (3) 17:3;18:6,7 side (6) 12:13,13,15,15;15:17,18 smoke (1) 21:9 somebody (2) 11:8,8 sorry (1) 15:21 speak (5) 9:22;13:12;17:14;:18; 20:1 speaking (5) 8:13,21;9:2,5;15:11 specific (1) 14:8 speculation (1) 11:11 speech (1) 16:12 spoke (1) 13:5 spoken (2) 15:14;:4 stairs (2) 12:14,16 standing (1) 11:16 state (6) 5:8,12;9:6;11:3;14:2; 20:21 stated (1) 16: statement (1) 9:1 states (4) 7:4;10:8;14:11;15:10 strange (1) 21:8 Sure (8) 5:10,13;7:4;9:15;10:10; 15:3,6;20: swears (1) 8:16 sworn (1) 5:2 T talks (1) 15:22 testified (1) 5:3 threatening (1) 16:9 thumb's (1) 15:12 times (2) 10:17;12:7 told (1) 7:2 took (1) 20:2 top (1) 15: totality (1) 17:8 tried (1) :20 two (1) 12:20 U under (1) 7:20 unit (12) 8:11,18;10:16,17,; 12:6;13:4,7;18:15,20; :10;21:3 unless (1) 16:8 up (1) 15:12 used (1) 13:20 V-8 (1) 7:13 Vachon (3) 8:2,11,14 Victor (1) 8:8 V W walk (1) 12:11 wall (6) 11:3,9;14:12,16,17,18 wants (1) 8:7 warrant (4) 18:2,13;20:15,17 watched (1) 10:9 way (1) 17: wearing (1) 18:8 weren't (3) 18:18,;:3 what's (1) 17:1 Whereupon (1) 21:15 whole (1) 7:12 willing (1) (3) paragraph - willing
20:9 without (1) 18:2 Witness (9) 6:6,20;7:21,;8:5,9; 9:17;15:3;21:14 witnessed (1) 10:2 words (1) 6:9 working (1) 5:15 written (2) 7:;15:7 yelling (1) 6:16 Y 1 1 (4) 5:20,22;6:5;14:10 10: (1) 21:16 11/25 (1) 8:22 15-507 (1) 9:11 15th (1) :12 2 6 (3) 10:13;11:2,5 7 (1) 6:11 709 (2) 10:16, 710 (2) 6:17;7:5 712 (1) 8:12 8 (1) 8:8 6 7 8 9 9 (3) 7:14;14:;15:1 2 (3) 7:10,11;9:9 2011 (1) 5:17 2015 (3) 8:22;9:20;20:14 2016 (1) :12 22nd (2) 9:20;20:14 25th (1) 8: 3 (3) 9:10,12,13 3 4 4 (4) 10:13;12:3,4;15:5 5 (3) 10:13,14,15 5 (4) without - 9