Second Supplemental Declaration of Christine Jackson

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THE HONORABLE ROBERT S. LASNIK
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
JOSEPH JEROME WILBUR, a
Washington resident; JEREMIAH RAY
MOON, a Washington resident; and
ANGELA MARIE MONTAGUE, a
Washington resident, individually and on
behalf of all others similarly situated,
No. C11-01100 RSL
SECOND SUPPLEMENTAL
DECLARATION OF CHRISTINE
JACKSON
Plaintiffs,
v.
CITY OF MOUNT VERNON, a
Washington municipal corporation; and
CITY OF BURLINGTON, a Washington
municipal corporation,
Defendants.
CHRISTINE JACKSON states as follows:
1.
My qualifications as an expert, including my training and experience, were
described in my original Declaration, which was filed with the Court on October 17, 2011; in my
Rebuttal Expert Declaration, which was served on Defendants’ counsel on May 4, 2012; and in
my First Supplemental Declaration, which was served on Defendants’ counsel on September 6,
2012. Since September 6, 2012, the following updates to my qualifications have occurred: I
have served as a supervisor for TDA’s Kent office from October 1, 2012 to the present. In that
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 1
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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position, I supervise one misdemeanor lawyer practicing in King County District Court’s DV
court, seven felony lawyers, one paralegal, and one staff person. I also continue to supervise the
RALJ practice and carry a partial caseload of felony cases.
2.
This Second Supplemental Declaration will not repeat the points I made or the
opinions I gave in my prior Declarations. Instead, it will set forth additional points and opinions
based on documents and information I have reviewed since the date of my earlier Declarations.
3.
Since the time of my prior Declarations, I have received and reviewed the
documents listed in Exhibit A to this Declaration.
The Public Defense System of Mount Vernon and Burlington During the Time of Richard
Sybrandy and Morgan Witt
4.
The closed case reports that Richard Sybrandy and Morgan Witt produced in this
matter are unclear as to whether the attorneys were reporting case credits or attorney hours. In
light of this and other evidence, it is apparent that the Cities were not monitoring the number of
cases assigned to the public defenders.
5.
The client files provided by Sybrandy and Witt contained only discovery and
court documents. No attorney notes or timesheets were included, and there was zero evidence of
any investigation, motion work, consultation with immigration attorneys, or consideration of
alternative dispositions such as compromise of misdemeanors. Likewise, there were zero records
obtained from the Department of Licensing independent of the ADR (abstract of driving record)
or certified copy of driving record (CCDR) provided in discovery, or any indication that the
attorney provided factual or legal analysis to the client in each individual case. The attorney
hours reflected in the closed case reports are generally insufficient to have completed such work
or have provided such information to the client.
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 2
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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6.
For example, in the Cerrillo case there was a legal defense to the charge of
violation of a no-contact order that was missed, because the order was in the court file and did
not make clear whether the defendant’s daughter was a protected party for purposes of text
messages to her being prohibited.
7.
Sybrandy’s negotiation emails to the prosecutor appear to unnecessarily disclose
privileged information, and he refers to his clients in pejorative language that is unprofessional.
8.
Based on my review of the evidence for the time period during which Sybrandy
and Witt served as public defenders for the Cities, it is my opinion that Mount Vernon and
Burlington failed to implement, monitor, evaluate, supervise a public defense system that met the
minimum Sixth Amendment requirements for assistance of counsel.
The Public Defense System of Mount Vernon and Burlington During the
Time of Mountain Law
9.
Based on my review of the evidence for the time period during which Mountain
Law’s attorneys have served as public defenders for the Cities, it is my opinion that Mount
Vernon and Burlington have failed and are continuing to fail to implement, monitor, evaluate,
and supervise a public defense system that meets the minimum Sixth Amendment requirements
for assistance of counsel.
10.
Mountain Law is using DefenderData for its case management and docketing
system. My office has used the DefenderData service for years, and I am familiar with the
reports and functions of this system. Mountain Law had only two attorneys working on the
Mount Vernon and Burlington cases from April 2012, when the firm first started the contract, to
September 2012. During the first eight weeks of that period, Mountain Law’s attorneys opened
more than 1,200 cases (630 for Michael Laws and 582 for Mr. Collins). It appears that
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 3
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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approximately 1,100 of those cases transferred from Richard Sybrandy and Morgan Witt, the
previous public defenders. This shows that the caseloads of both Sybrandy/Witt and Mountain
Law have been excessive and well beyond rates that correspond with the maximum of 400
annual misdemeanor cases per attorney set forth in the WSBA standards.
11.
After receiving all of the open cases of Richard Sybrandy and Morgan Witt,
Mountain Law’s attorneys continued to open more than 135 cases per month on average during
2012.
12.
From September 2012 to the present, Mountain Law has had only three attorneys
working on indigent defense cases in Mount Vernon and Burlington. The caseloads that the
Cities assigned to Mountain Law’s attorneys during this period exceeded rates that corresponde
with the maximum limit of 400 annual misdemeanor cases per attorney set forth in the WSBA
standards.
13.
The caseloads carried by Mountain Law’s attorneys are particularly excessive
when you consider that Jesse Collins and Sade Smith had no experience with criminal defense at
the time they started and that Michael Laws was the only person responsible for supervising the
two of them.
14.
The average number of hours that Mountain Law’s attorneys are spending on
misdemeanor cases in Mount Vernon and Burlington is less than two hours per case. This is
quite low. By comparison, the average time that TDA attorneys spend on misdemeanor cases is
five hours per case.
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 4
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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15.
In particular, Mountain Law appears to spend inadequate time on misdemeanor
cases that should take longer, such as cases with DUI charges and cases where it is likely the
client has a language barrier or low education level or mental health or disability issue.
16.
In my opinion, the average amount of hours that Mountain Law’s attorneys are
spending on misdemeanor cases in Mount Vernon and Burlington is insufficient to meet
minimum Sixth Amendment requirements for assistance of counsel.
17.
The Cities of Mount Vernon and Burlington have failed to conduct any
meaningful monitoring or systematic oversight and evaluation of Mountain Law and its attorneys
to ensure that the public defenders are in compliance with their contractual requirements or
applicable standards for indigent defense, including caseload limitations. Indeed, the Cities
chose to award the public defense contract to Mountain Law even though the Cities knew
Mountain Law would only provide two attorneys to handle an anticipated 1,700 cases per year.
18.
Though they have handled more than 1,600 cases since taking over the public
defense contract for Mount Vernon and Burlington, the attorneys at Mountain Law have utilized
an investigator in only “5 [to] 15” of those cases, which is fewer than one percent. Furthermore,
Michael Laws, the supervising attorney, testifies that he has personally contacted a total of only
“three or four witnesses” in his cases. Mr. Laws says that the number of witness contacts for the
other two attorneys is similarly minimal.
19.
Since taking over the public defense contract for Mount Vernon and Burlington,
Mountain Law’s attorneys have filed only one suppression motion.
20.
In my review of the 50 randomly selected Mountain Law case files, I did not see
that any investigation was conducted (even for cases where such investigation may have resulted
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 5
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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in the development of exculpatory information). I did not see evidence of any legal research into
issues that were apparent from the discovery. Investigation of possible defenses beyond the
evidence provided by the prosecution, and consideration and research of possible legal defenses,
is required by case law interpreting the constitution and established professional standards and
performance guidelines. See, e.g., In re Brett, 142 Wn.2d 868, 16 P.3d 601 (2001); State v. Jury,
19 Wn. App. 256, 576 P.2d 1302 (2005); Rios v. Rocha, 299 F.3d 796 (9th Cir. 2002).
21.
For example, a failure to investigate was evident in the McFadden case, where it
appeared the defendant had a complete defense to all three charges (resisting arrest, trespass and
obstructing) as he was authorized to be in the home and the officers had no legal authority to
either arrest him or issue him orders. Also, the prosecutor disclosed potential Brady or
exculpatory material, but there was no evidence in the file that this information was obtained,
reviewed, or discussed with the client. Given the complete defense to all of the charged
offenses, there appeared to be little benefit to the client in pleading guilty to the obstruction
charge.
22.
A failure to investigate was also apparent in the Castellano case, where it did not
appear that the officer had legal authority to order or detain the client to have his picture taken.
Indeed, there appeared to be no individualized reasonable suspicion to detain him for further
investigation. Similarly, in the Crawford case, there appeared to be no discussion as to whether
the client’s conduct or language actually constituted disorderly conduct. While calling the
convenience store clerk a “fucking Hindu” and “infidel” is certainly distasteful, it may well be
protected speech. Additionally in the Crawford case, law enforcement described this young
African-American male as a troublemaker, and there may have been some improper motivations
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 6
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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or targeting of this individual by law enforcement. While it appears that this client (Crawford)
pled to get out of jail, it is not evident that these issues were raised with the prosecutor or that a
motion to dismiss for lack of a prima facie case was brought. Given the amount of time spent on
the case (.7 total, including staff time), it is doubtful that any of these steps that should have been
taken by Mountain Law were taken. Even if the clients do not want to take the time to come to
court for a trial, investigation of these issues may lead to a Knapstad motion to dismiss.
23.
Also, I saw no evidence in the Mountain Law case files of consultation with the
immigration resource attorneys at the Washington Defender Association or regular reference to
or inquiry into the immigration status of clients (though in one case it appears that the client’s
immigration lawyer contacted the assigned defender and provided input into the resolution of the
case).
24.
There were Mountain Law case files where the client’s criminal history (DCH)
was not provided or obtained.
25.
In the Mountain Law files I reviewed where the defendant lacked any significant
criminal history, I saw little or no evidence of an effort to obtain pretrial diversions or other
dispositions that might result in dismissals as opposed to convictions (e.g., Phillips, Bromels).
Rather, at least one individual with no criminal history pled guilty to a theft. In many courts, this
person would have been eligible for some kind of first-time-offender pretrial diversion or other
opportunity to have her case dismissed. This was also evident in the Nieblas case, where it was
unclear why the client pled to the charged offense (disorderly conduct) instead of proceeding to
trial on that charge or obtaining an alternative disposition such as an immigration-safe stipulated
order of continuance.
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 7
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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26.
In theft cases that were part of the Mountain Law files, I did not see any evidence
showing the attorneys considered alternative dispositions, such as compromises of misdemeanors
or stipulated orders of continuances that would help clients avoid convictions altogether.
27.
For the driving-while-license-suspended cases in the Mountain Law files, I did
not see any attempt to obtain client files from the Department of Licensing independent of the
ADR (abstract of driving record) or certified copy of driving records (CCDR) that were provided
in discovery. To assess whether the underlying suspension complied with due process, which is
an important issue in DWLS cases, the attorney needs to obtain the client’s address history from
DOL and the entire DOL file or at least the documents relevant to the address history.
28.
In many of the Mountain Law files, there is little or no indication that the
attorneys provided factual or legal analysis to the clients in each individual case. The hours
reflected in the closed case reports would generally not be sufficient to have completed such
work, particularly when you consider that those hours include staff time as well as attorney time.
29.
In one DUI case that was part of the Mountain Law files (Spielman), the client
apparently pled to a “no test” in a refusal case, thereby avoiding the increased penalties
associated with the refusal. Nonetheless, the client told the arresting officer that she was
diabetic and took insulin. This information raised the question of whether she was sick and
experiencing insulin shock or other adverse reaction to the alcohol she consumed as opposed to
being intoxicated. In this case, a consultation with an expert or merely pointing this proof
problem out to the prosecutor may have convinced the prosecutor to offer a Reckless Driving or
Reckless Endangerment charge (which may fit the nature of this one-car accident where the
client is acting very strangely), thus permitting the client to avoid the mandatory minimum
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 8
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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penalties on this first time DUI and the licensing consequences –particularly the 1 year IID
requirement. There is no indication that this issue was identified and discussed with the client.
30.
In the Mountain law case files, there was no indication that the attorneys
recognized that many DV misdemeanor convictions (where the DV designation is pled and
proved after August 2011) count as a point on any subsequent DV felony sentence. In light of
these recent changes in the law and the difficulties in proving DV cases, accused have a greater
incentive to set cases for trial and avoid these convictions altogether, perhaps by having the
prosecutor drop the DV “tag” in exchange for a plea on a reduced more innocuous charge or
dismissal when the prosecutor cannot proceed at trial.
31.
In addition to the small amount of documented client conference time listed in the
Mountain Law timesheets, it appears the lack of communication with clients is persisting with
the new public defense providers. Mountain Law is using the same opening letter to clients that
contains legally inaccurate advice and discourages early contact between the client and the
assigned attorney. In addition, Mountain Law’s supervising attorney has testified that it is
“pointless” to meet with a client unless the attorney has the police report or a plea offer.
32.
The declarations from current Mountain Law clients indicate that the municipal
court defenders spend little time with their clients, even clients who are in-custody. On the
ICRAP form filled out for in-custody clients in the Mountain Law files I reviewed, there is no
place to record information that would be helpful to obtaining the client’s release or discussing
an analysis of the case or obtaining other helpful information from the client, such as evidence
that might become unavailable (video tapes, etc.). The foregoing is the type of information
generally gathered at an early visit with an in-custody client.
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 9
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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33.
The $500 fine which seems commonly imposed in the municipal courts of Mount
Vernon and Burlington is troubling for an indigent population, and there is no apparent effort on
the part of the public defenders to challenge this practice.
34.
The amount of time Mountain Law is spending on cases and the lack of evidence
of any meaningful individualized factual and legal analysis or investigation in each case and little
communication with the client demonstrates constitutionally inadequate representation is being
provided.
35.
In the 50 Mountain Law cases I reviewed there were only a few cases set for trial.
Furthermore, I understand that Mountain Law’s attorneys have conducted only six jury trials and
one bench trial since taking over the contract in April 2012. Part of the value of the
constitutional right to jury trial, particularly in misdemeanors, is that there is often little risk of a
“trial penalty,” the result is often the same after a trial if a defendant is convicted than if the
accused pleads to the charge. Setting multiple cases for trial, where the offer is plead as
charged, forces the prosecutor to choose which cases merit his or her efforts and time to take to
trial and which cases to dismiss or offer non-conviction resolutions or pleas to reduced charges.
Cases where witnesses fail to appear or do not want to participate are often dismissed. Cases
that proceed to trial are decided by members of the community and make the criminal justice
system more transparent. Setting cases for trial gives the defense more leverage over the
prosecutor for all cases and does not sacrifice one client’s rights for another. That leverage
should not be so easily relinquished. This is the approach recommended by Professor William
Stuntz in his final book The Collapse of American Criminal Justice (Harvard University Press
2011).
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 10
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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36.
It is my opinion that the cities of Mount Vernon and Burlington continue to
operate an unconstitutional public defense system in violation of the Sixth Amendment. The
Cities knew or should have known that excessive caseloads, inadequate client contact, and lack
of individual investigation and representation of clients were occurring under pre-Mountain Law
public defense contracts. Despite this, the Cities have failed to monitor Mountain Law’s
compliance with contractual and constitutional requirements and applicable standards for
indigent defense, which has the result of those constitutional deficiencies continuing to plague
the Cities’ public defense system.
37.
My review of the Mountain Law case files demonstrates that the Cities are failing
to do anything to stop the unconstitutional practices that have been occurring for years with the
Cities’ knowledge. There are established practices which enable cities to monitor and audit
public defense contracts to ensure compliance with the contract, standards and constitutional
requirements. I have extensive experience with those practices in my work involving The
Defender Association and the City of Seattle, and I am submitting documents describing those
practices in response to the subpoena which the cities served on me in connection with my
February 1 deposition.
38.
In particular, cities are obligated to have a system for accurately monitoring the
public defender caseloads, and the Cities of Mount Vernon and Burlington appear to have never
done that. Some form of monitoring, audit or oversight of contract and constitutional
compliance by the cities with respect to the public defense function is essential in order to have a
constitutional system. The certifications required by the new court rule are not enough. In
addition, there are systems for client complaints which do not require revealing privileged
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 11
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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information to persons outside the scope of the privilege, unlike the Cities’ current complaint
system.
39.
Because the Cities of Mount Vernon and Burlington are operating an
unconstitutional public defense system, it is certain that actual harm will result to indigent
defendants. Some of the forms that this harm may take are as follows: being deported as a result
of guilty pleas to crimes and sentencing dispositions that trigger immigration consequences;
years of debt from excessive fines; loss of rights due to domestic violence conviction; increased
imprisonment and extended supervision due to guilty pleas where there is inadequate
consideration of the client’s record and other pending cases; being convicted of a crime and
suffering the consequences of a criminal record when the person was not legally guilty of that
crime, or the charge should have been dismissed, or a non-conviction disposition should have
occurred. DVs, DUIs, and theft convictions are the kind of misdemeanors that destroy people’s
lives because they can lead to deportation without any chance to return, or lack of housing and
employment for a lifetime.
40.
Based on the documents I reviewed regarding the Cities’ current public defense
system, there is a grave risk that this harm to the indigent defendants will continue unless Court
orders the cities to submit to a monitoring and audit system designed to ensure compliance with
the Constitution.
41.
I understand that there may be additional documents Plaintiffs have been
attempting to obtain which were delayed in production by others and were not possible for me to
review in time for this Declaration. I will supplement this Declaration if necessary based on
those additional documents.
JACKSON SECOND SUPPLEMENTAL
DECLARATION
(No. C11-01100 RSL) – 12
Perkins Coie LLP
1201 Third Avenue, Suite 4800
Seattle, WA 98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
I
I CERTIFY LINDER PENALTY OF PERruRY under the laws of the United
States
of
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J
America that the foregoing is true and correct.
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DATED
at
Zc,l,rnruotz
, Washington, this 25th day of January, 2013,by
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CHRISTINE JACKSON.
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CHRISTINE JAC
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Perkins Coie LLP
JACKSON SECOND SUPPLEMENTAL
DECLARATION
Q.{o. C11-01100 RSL) - 13
1201 Third Avenue, Suite 4800
Seattle,
WA
98101-3099
Phone: 206.359.8000
Fax: 206.359.9000
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CERTIFICATE OF SERVICE
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I, Toby J. Marshall, hereby certify that on March 5, 2013, I electronically filed the
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foregoing with the Clerk of the Court using the CM/ECF system which will send notification of
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such filing to the following:
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Kevin Rogerson, WSBA #31664
Email: [email protected]
CITY OF MOUNT VERNON
910 Cleveland Avenue
Mount Vernon, Washington 98273-4212
Attorneys for Defendant City of Mount Vernon, Washington
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Scott G. Thomas, WSBA #23079
Email: [email protected]
CITY OF BURLINGTON
833 South Spruce Street
Burlington, Washington 98233-2810
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Attorneys for Defendant City of Burlington, Washington
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Andrew G. Cooley, WSBA #15189
Email: [email protected]
Jeremy W. Culumber, WSBA #35423
Email: [email protected]
Adam L. Rosenberg, WSBA #39256
Email: [email protected]
KEATING, BUCKLIN & MCCORMACK, INC., P.S.
800 Fifth Avenue, Suite 4141
Seattle, Washington 98104-3175
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Attorneys for Defendants Cities of Burlington, Washington and Mount Vernon,
Washington
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JACKSON SECOND SUPPLEMENTAL
DECLARATION - 14
CASE NO. 2:11-CV-01100 RSL
TERRELL MARSHALL DAUDT & WILLIE PLLC
936 North 34th Street, Suite 400
Seattle, Washington 98103-8869
TEL. 206.816.6603  FAX 206.350.3528
www.tmdwlaw.com
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DATED this 5th day of March, 2013.
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TERRELL MARSHALL DAUDT & WILLIE PLLC
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By:
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/s/ Toby J. Marshall, WSBA #32726
Toby J. Marshall, WSBA #32726
Email: [email protected]
936 North 34th Street, Suite 400
Seattle, Washington 98103-8869
Telephone: (206) 816-6603
Attorneys for Plaintiffs
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JACKSON SECOND SUPPLEMENTAL
DECLARATION - 15
CASE NO. 2:11-CV-01100 RSL
TERRELL MARSHALL DAUDT & WILLIE PLLC
936 North 34th Street, Suite 400
Seattle, Washington 98103-8869
TEL. 206.816.6603  FAX 206.350.3528
www.tmdwlaw.com
EXHIBIT A
JACKSON SECOND SUPPLEMENTAL
DECLARATION - 16
CASE NO. 2:11-CV-01100 RSL
EXHIBIT A
TO THE SECOND SUPPLEMENTAL DECLARATION OF CHRISTINE JACKSON
FILE NO
BATES RANGE
DESCRIPTION
01
MT-LAW_000853-1097
Attorney files for 50 random Mountain
Law cases
02
n/a
Court case files of:
(1) Cerillo, Josue
(2) Johnson, Tina
(3) Carrano, Esther
(4) Carrasco, Adalberto
(5) Cook, Valerie
(6) Derbyshire, David
(7) Finsland, Ian
(8) Garcia-Maclovios, Ramon
(9) Hernandez, Antonio
(10) Munoz, Juan
(11) Ortiz Sanchez, Bernardo
(12) Sepulveda, Edgar
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DEFS_002762-2766
September 20, 2012 email from Eric
Stendal regarding, “Documents to
prepare in Spanish” and attaching the,
“City of Mount Vernon Notice for
Public Defender” and “City of Mount
Vernon Public Defender Complaint
Form”
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DEFS_002960-2973
Ordinance No. 3584
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n/a
Mountain Law August 2012 Case
Credit Report
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DEFS_002825-2826
September 24, 2012 email from
Michael Laws regarding, “In Custody
Clients”
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DEFS_002830-2840
August 2, 2012 email from Jon Lewis
regarding, “July 2012 Reports”
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DEFS_002850-2853
June 28, 2012 email from Bryan
Harrison regarding, “Caseload
Statistics and reports”
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DEFS_002907-2926
Mountain Law Case Credit Reports
1
JACKSON SECOND SUPPLEMENTAL
DECLARATION - 17
CASE NO. 2:11-CV-01100 RSL
EXHIBIT A
TO THE SECOND SUPPLEMENTAL DECLARATION OF CHRISTINE JACKSON
FILE NO
BATES RANGE
DESCRIPTION
10
MT-LAW_000514-522
Mountain Law Case Credit Reports
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DEFS_000874-1022
Richard Sybrandy case reports
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n/a
Collection of emails between Richard
Sybrandy, city prosecutors and
administrators
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n/a
August 24, 2011 email from Richard
Sybrandy regarding discovery requests
in this matter
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n/a
Collection of emails between Richard
Sybrandy, city prosecutors and
administrators
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various
Attorney files of Richard Sybrandy:
(1) Cienfuegos-Rodriguez
(2) Boyd
(3) Borrego
(4) Baker
(5) Adee
(6) Diaz
(7) Fisher
(8) Flagg
(9) Flaton
(10) Garcia, A.
(11) Green
(12) Lopez-Gonzalez
(13) Galindo-Ramirez
(14) Garcia, V.
(15) Hernandez
(16) Sepulveda
(17) Ortiz-Sanchez
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Witt 001850-3752
Attorney files for cases of Morgan
Witt:
(1) Barrera
(2) Carrano
(3) Carrasco
(4) Cavanagh
(5) Cook
(6) Derbyshire
2
JACKSON SECOND SUPPLEMENTAL
DECLARATION - 18
CASE NO. 2:11-CV-01100 RSL
EXHIBIT A
TO THE SECOND SUPPLEMENTAL DECLARATION OF CHRISTINE JACKSON
FILE NO
BATES RANGE
DESCRIPTION
(7) Finsland
(8) Flores-Rodriguez
(9) Fuentes
(10) Guerrero-Lopez
(11) Munoz
(12) Osias
(13) Purcell
(14) Racine-Santos
(15) Reavis, Bobby
(16) Reavis, Martin
(17) Whitney
(18) Willis
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n/a
Declaration of Carlos E. Aguilar
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n/a
Declaration of Steven Osborn
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n/a
Declaration of Mark Reyna
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n/a
Declaration of Shawn Delacruz
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n/a
Declaration of Jacob C. Norman
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n/a
Deposition of Stephen Skelton
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n/a
Deposition of James Feldman
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n/a
Deposition of Jon Aaarstad
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DEFS-BURL_000469-472
Mountain Law Memorandum to All
Assigned Counsel Defendants
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BURL_PDR-000233-235
Certifications of Michael D. Laws,
Sade A. Smith and Jesse G. Collins of
Compliance with Standards Required
by CrR3.1/CrRLJ 3.1/JuCR 9.2 filed
with the City of Burlington
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n/a
Mountain Law July 2012 Case Credit
Report - Withdrawn
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n/a
Mountain Law July 2012 Case Credit
Report
23
3
JACKSON SECOND SUPPLEMENTAL
DECLARATION - 19
CASE NO. 2:11-CV-01100 RSL
EXHIBIT A
TO THE SECOND SUPPLEMENTAL DECLARATION OF CHRISTINE JACKSON
FILE NO
BATES RANGE
DESCRIPTION
30
n/a
Mountain Law discovery for case no.
MC0026861
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MV_PDR-000400-402
Certifications of Michael D. Laws,
Sade A. Smith and Jesse G. Collins of
Compliance with Standards Required
by CrR3.1/CrRLJ 3.1/JuCR 9.2 filed
with the City of Burlington
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n/a
Deposition of Eric Stendal
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n/a
Deposition of Richard Sybrandy (rough
transcript)
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n/a
Deposition of Morgan Witt
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WITT-GONZALEZRODRIGUEZ_000001-21
Morgan Witt’s attorney file for Leirha
Gonzalez-Rodriguez
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WITT-HAYES_000001-74
Morgan Witt’s attorney file for Dramon
Hayes
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n/a
30(b)(6) deposition of Mountain Law
(Michael Laws)
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JACKSON SECOND SUPPLEMENTAL
DECLARATION - 20
CASE NO. 2:11-CV-01100 RSL

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