Statement of Facts
8. PLAINTIFF is a sworn peace officer with the LAPD. Plaintiff has been employed with the DEFENDANT CITY, through the LAPD since 1981.
9. Since 1996 PLAINTIFF has been assigned to the Robbery-Homicide Division ("RHD") and has held the title of Detective I. Prior to that he was a Homicide Detective at the South Bureau and Wilshire Division.
10. On or about April 1997, PLAINTIFF was assigned to investigate the murder of Notorious B.I.G. aka Biggie Smalls (hereinafter referred to as "SMALLS") that occurred in March 1997 in an area of Los Angeles patrolled by the Wilshire Division.
11. Two weeks later, PLAINTIFF was assigned to do a criminal investigation and report regarding LAPD Officer Kevin Gaines (hereinafter referred to as "GAINES"), including the assault with a deadly weapon on fellow Officer Lyga. PLAINTIFF was one of several officers assigned to do the investigation.
12. During the investigation of SMALLS and GAINES, PLAINTIFF, saw evidence suggesting the involvement of fellow LAPD officers in criminal activity and relationships with known felons. Including, but not limited to, evidence that fellow LAPD officers, David Mack ("MACK") and GAINES, were confidants of BIGGIE SMALLS and Suge Knight ("KNIGHT") (i.e. known gang members), and that MACK was seen at the SMALLS shooting and was seen leaving the SMALLS shooting, and that other off duty LAPD officers were acting as security guards for SMALLS. Evidence also suggested possible gang affiliation between an infamous L.A. gang, namely the Bloods, and LAPD officer, MACK and GAINES.
13. MACK is a good friend and former partner of (former) LAPD Officer Raphael Perez ("PEREZ"), who is the major subject and informant of what is commonly referred to as the LAPD Rampart Investigation. Evidence between their connection starts to surface.
14. PLAINTIFF reported his suspicions about the fellow officers and expressed his desire to write it up and to follow up leads. However, he was ordered to leave it alone.
15. DEFENDANT PARKS, who at that time, was deputy chief of police, and a supervisor to internal affairs, ordered PLAINTIFF to submit the report to the Los Angeles County District Attorney's office as is.
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