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Statement of Facts (cont.)

16. Later 1997, MACK was later arrested of bank robbery, and one of his first visitors was a man by the name of Amir Muhammad (aka Harry Billups ["BILLUPS"]). BILLUPS gave false information, and matches the description of the SMALLS shooter. Again, PLAINTIFF reported suspicions and desired to follow up leads. More evidence was surfacing showing the connection between MACK, PEREZ, GAINES, and KNIGHT.

17. When PLAINTIFF commented on the possible police criminal activity, and requested for time to investigate the matter. He was told, `we're not going to get involved in that', `Mack has already gone down for bank robbery. Let's not get involved in more controversy.'

18. PLAINTIFF repeatedly complained to his supervisors regarding the SMALLS shooting investigation, claiming that it was incomplete, and insufficient considering the involvement of fellow LAPD officers. He sought to report his complaints so that further investigations could be done however, he was ordered `to leave it alone'.

19. PLAINTIFF prepared his investigation report regarding the SMALLS murder, detailing this evidence; however, three (3) pages of text were redlined or ordered deleted by his superiors.

20. In 1997-1999, PLAINTIFF also complained about the investigation of GAINES. Moreover, GAINES had an intimate relationship with KNIGHT'S ex-wife. More evidence was surfacing regarding the lavish financial means by which several LAPD officers were living with, including, but not limited to, MACK, GAINES and PEREZ, and their gang affiliation.

21. Again, PLAINTIFF complained about the LAPD officer's and specifically sought to investigate GAINES further. In fact, LAPD officers were interfering with the investigation in that they were interviewing witnesses before investigators. PLAINTIFF was prevented from writing it up, and he was ordered to `leave it alone.' More specifically, he was told that `Gaines is dead, we don't need to know anything more.'

22. PLAINTIFF was starting to feel ostracized, and to feel as if he was being prevented from doing his job. Originally, PLAINTIFF transferred to RHD as a Detective I with hopes and affirmations that he would get promoted to Detective II. However, after making his complaints, PLAINTIFF was slowly ostracized.

23. However, on or about May 1998, before PLAINTIFF flew to Chicago in a follow-up investigation of the SMALLS murder. When he found, a picture on his desk, illustrating the underground pipes connected to a toilet, with an arrow pointing to excrement saying "You are here; D-I's [Detective I] position". Given the picture, and the fact that he was the only Detective I, he took this to mean that his fellow officers were referring to him as a `piece of sh*t.' PLAINTIFF also felt this was in regard to his complaints on the SMALLS investigation and fellow LAPD officers.

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