GOVERNMENT CLAIM FORM ATTACHMENT

Claimant first learned of the existence of a video of a deputy under her command leaning on the
head of Inmate Enzo Escalante on August 16, 2021 on her first day assigned as a Captain to Court
Services Division - West Bureau at Chatsworth Courthouse. On this, her first date, Claimant sat
down with her Operations Lieutenant to review all open and outstanding cases.

On or about October 28, 2021, Sgt. Ben Grubb, an LASD Internal Affairs Bureau investigator,
contacted Claimant’s unit and stated they were ready to interview subject Deputy Douglas
Johnson, the Deputy involved in the kneeling video. At this point, there was no reference to any
Internal Criminal Investigation Bureau (“ICIB” or LASD criminal internal investigations) case in
relation to the video. IAB Sgt. Grubb relayed a request to Claimant’s unit that Claimant review
the video, prior to interviewing Subject Johnson, which she did so on that date. Once Claimant
reviewed the video, Claimant realized that the video reflected excessive force and/or unreasonable
force and misconduct by Deputy Johnson. Two Bonus Deputies who were also present, did not
properly intervene. Claimant then contemporaneously contacted ICIB Captain Jason Schreiner
about her concerns with the kneeling video. On the same date, Claimant also contacted
Commander Allen Castellanos, who was the Commander of Court Services Division - West
Bureau, and also shared her concerns about the kneeling video with Commander Castellanos.
Commander Castellanos indicated to Claimant that he believed that the video was already in the
custody and control of ICIB. Claimant explained that IAB’s Sgt. Grubb had called and said ICIB
was not in possession of the video, and he wanted to ensure claimant was prepared for IAB to
move forward with the interview of Deputy Johnson. Commander Castellanos indicated that the
video should already have been in the custody of both IAB and ICIB as stated he directed the
previous captains.

On or about November 2, 2021, Claimant caused her unit to provide a hyperlinked use-of-force
video incident and a completed use of force of the incident to Captain Schreiner and his admin
staff at ICIB.

On November 9, 2021 at 3:21PM, Lieutenant Donald Fitzpatrick, assigned to ICIB emailed

Claimant and CC’ed various other stakeholders which acknowledges receipt of the kneeling video,
and acknowledges that the force used by Deputy Johnson, “appeared to be unreasonable and/or
excessive,” and stated that further investigation by ICIB and a referral to the Los Angeles County
District Attorney’s office are both warranted in the opinion of ICIB. Claimant took this email to
be an indication that ICIB wanted the case to be referred from Chief Lujuana Haselrig who was
the Chief of Court Services Division. On the same date at 3:26PM, Claimant emailed her direct
superior Commander Castellanos and offered to type up the ICIB criminal referral the following
day, based upon his further instructions.

On November 10, 2021 at 7:15AM, Commander Castellanos responded to this email and
forwarded this email to Chief Haselrig in order to obtain her consent and approval to make the
criminal referral to ICIB. On this same date, at 9:36AM, Chief Haselrig responds to Commander
Castellanos and states that she has reviewed the underlying email and approved the transfer of the
investigation to ICIB, which result in the tolling of the IAB case. At this point, the case belonged
to ICIB for all investigatory purposes, pending receipt of formal paperwork from Court Services
Division. On the same date at 9:44AM, Commander Castellanos emails Claimant and CC’s other

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stakeholders including Chief Haselrig, instructing Claimant to relieve Deputy Johnson of duty,
however, Commander Castellanos recommended consulting with ICIB prior to doing so as to
ensure the division was not out-of-order as ICIB generally does not want subjects to be relieved
of duty prior to potentially making a compelled statement as part of the ICIB investigation.

In the avoidance of doubt, LASD ICIB was personally notified of the kneeling video by Claimant
no later than November 2, 2021, which was confirmed via email by ICIB Lieutenant Fitzpatrick
on November 9, 2021.

Sheriff Alexandro Villanueva has falsely claimed in the media that he first saw the video on
November 18, 2021, and that it was him who personally referred the matter to ICIB. Most recently,
Sheriff Villanueva has stated this to Fox 11 News on May 9, 2022. This is demonstrably false
based upon the existence of email correspondence and other evidence created by Claimant prior
to the date of this purported first referral to ICIB.

At all times, Claimant performed her duties with respect to the kneeling video with appropriate
and timely competence and in congruity with LASD policies and procedures. The referrals were
timely made, and emails regarding the management of the matter were responded to by Claimant
sometimes in mere minutes.

Claimant is the individual who made original contact with ICIB, referred Deputy Johnson
criminally to ICIB, and later relieved him of duty. Any claims by Sheriff Villanueva that he was
the Department employee who first undertook these steps is demonstrably false.

On December 7, 2021 at 2:45PM, Claimant proceeded to San Fernando Courthouse to relieve

Deputy Johnson of duty. Sheriff Villanueva’s claims that he personally directed the relief of
Deputy Johnson of duty on any prior date are false and impossible. Claimant memorialized this
act by sending an email to her Acting Chief and the ICIB Captain on this date.

On April 11, 2022, while claimant was off on an unscheduled leave, Claimant received a phone
call from Commander Joseph Williams, who was serving as Acting Chief of Court Services
Division after the retirement of Chief Haselrig. Commander Williams explained to Claimant that
the Sheriff’s Office wanted a timeline of the Escalante use-of-force investigation. Claimant
explained to Commander Williams that she had viewed Sheriff Villanueva’s public statements on
Facebook Live and elsewhere and that these public statements were inconsistent with the truth of
the matter, as set forth above. Claimant stated that Sheriff Villanueva’s statement that Deputy
Johnson had been immediately relieved of duty did not happen. Commander Williams requested
a timeline of these events, but Claimant protested that the truthful timeline did not track Sheriff
Villanueva’s publicly false timeline. Commander Williams then called back Claimant on the same
date and told her to disregard the request for a timeline, but reiterated his question, “are you sure
that the sheriff’s office did not call you and tell you to relieve him [of duty]?” Claimant reiterated
that she was never told to relieve Deputy Johnson of duty, but even if she had been so ordered,
Deputy Johnson was on unscheduled leave making this claim factually impossible.

Due to Claimant’s opposition to creating a false timeline in violation of the Los Angeles County
Sheriff’s Department Manual of Policies and Procedures, Pen. Code §§ 115, 116 & 118. These
were protected whistleblowing activities within the ambit of Lab. Code § 1102.5. Respondents

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subjected Claimant to an adverse employment action by removing and demoting her from her
current unit of assignment on April 18, 2022 in retaliation for her protected whistleblowing
activities, including, but not limited to, refusing to participate in Sheriff Villanueva’s fraudulent
kneeling video timeline. Other similarly situated LASD officials have been allowed to keep their
jobs while on leave such as Claimant, such as Commander Josie Woolum who has largely been
out of work injured for the past six months without having her duties, responsibilities, and
subordinates removed from her. That Claimant had her duties, responsibilities, and subordinates
so rapidly removed provides a clear temporal and factual nexus between Claimant’s protected
whistleblowing activities and the demotion as an adverse employment action emanating from such.

On April 11, 2022, Sheriff Villanueva attempted, by and through Commander Williams, to enlist
Claimant to aid in attesting to the authenticity of the fraudulent kneeling video memo. This attempt
was unsuccessful.

Subsequently, on May 1, 2022, Sheriff Villanueva released to the media a knowingly false timeline
of events of the kneeling incident.

On May 9, 2022, when Claimant first reviewed saw the May 1, 2022 memo, Claimant immediately
realized that the memo contained knowing falsities regarding the overview of the incident,
including but not limited to the fact that November 11, 2021 was an official court holiday, and
therefore Subject Deputy Johnson would not have been able to have signed the IAB notification
on this date as set forth in the false memo. Claimant refused to participate in this further obstruction
of justice and cover up by Villanueva.

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