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Statement of Facts (cont.)
24. On or about June 1998, PLAINTIFF was asked to work on the PEREZ investigation (later identified as the Rampart Task Force).
25. On or about July 1998, PLAINTIFF was assigned to another officer involved investigation regarding Rampart LAPD Officers Brian Hewitt ("HEWITT"), Daniel Lujan Jr.("LUJAN"), and Ethan Cohan ("COHAN"), and the beating up of and the civil rights violations of Ismael Jiminez, while in custody. The date of incident ("DOI") was on or about February 1998. However, the investigation did not commence until July 1998.
26. Shortly thereafter, Detective Ron Ito (hereinafter referred to as "DET. ITO") was assigned as a supervisor to the investigation. PLAINTIFF complained considering DET. ITO'S previous attempts to falsely discredit him; however, nothing was ever done.
27. PLAINTIFF alleges that this is another pattern and practice of the LAPD with the deliberate intent to suppress complaints about LAPD officers. This is accomplished by holding back cases against fellow officers for a while, letting leads and information get stale and/or the statute of limitations run. This makes any citations, reprimands, and/or convictions difficult or impossible to achieve.
28. During the course of PLAINTIFF'S investigation of PEREZ and HEWITT PLAINTIFF discovered several civil rights violations and criminal behavior by LAPD officers within the Rampart Division. Moreover, connections between GAINES, MACK, and PEREZ and LAPD gang affiliation with the Bloods were resurfacing. These affiliations were confirmed after PLAINTIFF, with other officers, served a search warrant on PEREZ' girlfriends' home and found pictures of PEREZ wearing gang colors and flashing gang signs (namely the Bloods).
29. PLAINTIFF reported his concerns to his superiors and again requested to write it up in order investigate further leads, since it was becoming apparent that additional LAPD officers were involved. For example, PLAINTIFF discovered that several police reports contained boilerplate language almost identical to one another, and were approved by division supervisors. Also, the search warrant served on PEREZ' home resulted in the seizing of a cardboard box marked "CRASH, Secret, Confidential", and containing more than a dozen replica toy and pellet guns that accurately portrayed real guns.
30. Due to the above, PLAINTIFF'S HEWITT investigation, he reported his concerns to his superiors and again requested to write it up in order investigate at least five (5) or six (6) more cases.
31. PLAINTIFF also complained about the HEWITT subpoena issued during that investigation. His fellow officers indicated that the Board of Rights stated that there was no probable cause; however, PLAINTIFF knew that the Board was not given all the facts, and if given all the facts, would have been sufficient. PLAINTIFF assisted the Board of Rights on future subpoenas of HEWITT and COHAN.
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