Rodney Rouzan Final Complaint

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Rodney Rouzan 3109 Kilt Court Lancaster, California 93535 Phone (310) 387-4065 | E-mail: <[email protected]> January 27, 2015 TO: Los Angeles City Mayor Eric Garcetti Los Angeles City Counsel Los Angeles Employee Relations Board Los Angeles Civil Service Commission Los Angeles City Attorney Los Angeles World Airport Board of Commissioners Los Angeles Police Inspector General Alexander Bustamante Los Angeles World Airport Executive Director Gina Marie Lindsey Deputy Executive Director Samson Mengitsu Los Angeles Human Resources Director Paula Adams LAXPD Chief Patrick Gannon LAXPD Members Re: Notice of Complaint and Complaint for Retaliation and Harassment Against City of Los Angeles, Los Angeles World Airports et al vs LAXPD Officer Rodney Rouzan Introduction This complaint arises from the retaliatory and harassing conduct of various members of the Departments and Divisions of the City of Los Angeles World Airport. On October 18, 2011, I was the subject of a false personnel complaint, which resulted in my termination. The termination was not sustained upon the finding that the decision was not substantiated by any evidence, and the complainants were incredible. I had always maintained that the complaint was false. Because I believed the complainants instigated the complaint maliciously, and because of their conduct immediately after my termination, I initiated a Civil Rights action against them, the County of Los Angeles, and Deputy Sheriffs who invaded my home and assaulted my family, including my 10 year old son, based on a malicious 911 call initiated by the complainants. The deputies were parties because they failed or refused to do any reasonable investigation, and left the location of where the report was made and used an unreasonable show of force to coerce me and my son from our home. During the discovery phase it was discovered that someone from the Internal Affairs Division of the department called the complainants and disclosed to them that I had been terminated as discipline purportedly as a result of the complainants’ complaint, in violation of the Public Safety Officers Procedural Bill of Rights (POBAR). POBAR deems that act a misdemeanor.

description

This complaint was filed February of 2015 and noticed to all law enforcement leaders within Los Angeles and the LA city leadership. Rodney is trying to effect change in how they are abusing power within their ranks.

Transcript of Rodney Rouzan Final Complaint

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Rodney Rouzan 3109 Kilt Court

Lancaster, California 93535 Phone (310) 387-4065 | E-mail: <[email protected]>

January 27, 2015 TO: Los Angeles City Mayor Eric Garcetti Los Angeles City Counsel Los Angeles Employee Relations Board Los Angeles Civil Service Commission Los Angeles City Attorney Los Angeles World Airport Board of Commissioners Los Angeles Police Inspector General Alexander Bustamante Los Angeles World Airport Executive Director Gina Marie Lindsey Deputy Executive Director Samson Mengitsu Los Angeles Human Resources Director Paula Adams LAXPD Chief Patrick Gannon LAXPD Members Re: Notice of Complaint and Complaint for Retaliation and Harassment Against City of Los Angeles, Los Angeles World Airports et al vs LAXPD Officer Rodney Rouzan

Introduction

This complaint arises from the retaliatory and harassing conduct of various members of the Departments and Divisions of the City of Los Angeles World Airport. On October 18, 2011, I was the subject of a false personnel complaint, which resulted in my termination. The termination was not sustained upon the finding that the decision was not substantiated by any evidence, and the complainants were incredible. I had always maintained that the complaint was false. Because I believed the complainants instigated the complaint maliciously, and because of their conduct immediately after my termination, I initiated a Civil Rights action against them, the County of Los Angeles, and Deputy Sheriffs who invaded my home and assaulted my family, including my 10 year old son, based on a malicious 911 call initiated by the complainants. The deputies were parties because they failed or refused to do any reasonable investigation, and left the location of where the report was made and used an unreasonable show of force to coerce me and my son from our home. During the discovery phase it was discovered that someone from the Internal Affairs Division of the department called the complainants and disclosed to them that I had been terminated as discipline purportedly as a result of the complainants’ complaint, in violation of the Public Safety Officers Procedural Bill of Rights (POBAR). POBAR deems that act a misdemeanor.

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City of Los Angeles January 27, 2015 Page � of 2 2(Not including attached affidavit of Rodney Rouzan.)

From the events described above, a series of acts and omissions, and chain of events, have occurred which have been harassing and retaliatory in nature due because I sought accountability. Further, I have suffered from other acts and omissions by various members of the department that I believe were discriminatory in nature. Therefore, I submit the attached affidavit and records of those events in support of this complaint in which those events are more fully expounded upon.

Conclusion

I demand that all parties complained against, and each of them, and their agents, servants, and employees, and all persons acting under, in concert with, or for them, are prohibited from continuing, or maintaining retaliatory, harassing, and discriminatory conduct. And prohibit them from commencing, continuing, or maintaining said conduct acts against me. In the alternative, I demand whatever relief, remedy, or right I should be afforded, known, or unknown, in the interest of fairness, and equal protection. I swear under penalty of perjury that the foregoing, the affidavit, and the supporting exhibits attached to and associated with my attached affidavit are true and correct duplicates or copies of the originals. I know their contents. The same is true of my own knowledge. Notice to the principal is notice to the agent; notice to the agent is notice to the principal. Date: January 27, 2015 Sincerely, Rodney Rouzan Los Angeles World Airport Officer #00465

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AFFIDAVIT OF RODNEY ROUZAN

I, Rodney Rouzan, swear or affirm: 1. I am currently a police officer for the Los Angeles Airport Police Department

(“LAXPD”). I have served on the Board of Directors for the Los Angeles Airport

Peace Officers Association ("LAAPOA") since November 2005. As a director, part of

my duties are to represent and protect the rights and benefits of our members.

2. During the spring of 2011, I began to discuss with officers the importance of

understanding and upholding their "oath" to the public. I wrote an article entitled

"Oath of Office" in a quarterly magazine which is issued to all of our officers. (See a

copy of that article "Oath of Office" attached herein as Exhibit 1).

3. As a result of that publication referenced in paragraph 2, several members in

LAXPD supervision and management classified and labeled me as a

"constitutionalist" and "sovereign citizen". Based on my treatment, I believe LAXPD

used the following described events as the real reason for my termination, and the

present harassment that I'm being caused to suffer, which is the cause of this notice

and complaint.

4. On October 18, 2010, my neighbor, an estranged ex business partner, and

debtor to a civil judgment accompanied by two other men began chasing my wife's

vehicle as she left our home. After high speeds and multiple turns she was able to

evade them and safely park her vehicle inside of a friend’s garage. Approximately

15 minutes later the three men were at my front door for unknown reasons. I

verbally demanded they leave my porch, in which they complied. Approximately 5

minutes later two men returned and I immediately notified the Sheriff's department.

The Sheriff's department arrived on scene and determined no crime had occurred

and advised me to seek a restraining order.

5. On or about August 24, 2011, LAXPD Internal Affairs conducted an investigation

into false allegations made by my neighbor and his accomplices, alleging that

during the incident on October 18, 2010, that I had chased them down the street

with a firearm. The allegations were never disclosed to the Sheriff who was on

scene.

6. On May 22, 2012, the Internal Affairs investigation was "sustained" and I was

terminated from my employment without any supporting facts or evidence.

7. On May 23, 2012, six Los Angeles County Sheriff deputies unlawfully ordered me

and my 10 year old son out of our home at gunpoint and searched the property

based on confidential information which was illegally provided to them by the

LAXPD Internal Affairs unit in violation of the Public Safety Officers Procedural Bill of

Rights (POBAR) and Government Code 3300 et seq.

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8. On or about May 25, 2012, I appealed my wrongful termination to the Civil

Service Commission and was given a hearing date of September 12, 2012.

9. On June 27, 2012, William Cordero from the LAXPD training unit sent an email

to all sections of the LAXPD regarding special training regarding the "sovereign

citizen movement". (See a copy of the sovereign citizen movement training email

and flyer attached herein as Exhibit 2).

10. On September 7, 2012, Lieutenant Raymond Ingal, from the Los Angeles

General Services Police Department released an email with an attached "safety

bulletin" falsely describing me as having associations with the "sovereign nation"

and having a history of violence (See a copy of that safety bulletin attachment

attached herein as Exhibit 3).

11. On September 12, 2012, while processing through the magnetometers at Los

Angeles City Hall to attend my appeals hearing, I was grabbed and detained by

several members of the Los Angeles Police department who served me with a

temporary restraining order. In the TRO Chief Michael Hyams included a supporting

declaration describing me as having ties to the "sovereign nation". On September

26, 2012, after a hearing the Restraining Order was denied for lack of cause. (See a

copy of Chief Hyams' declaration attached herein as Exhibit 4).

12. The civil service hearings lasted three days and Judy Gust was assigned as the

hearing officer. After hearing all the facts and evidence she issued a report finding

that there was insufficient evidence to sustain any of the charges against me and

that I be returned to my former position with no loss of wages or benefits. (See a

copy of the Judy Gust LA Hearing Officer Report attached herein as Exhibit 5).

13. On February 28, 2013, I went before the Civil Service Board for a reinstatement

hearing at the Los Angeles personnel building located at 700 E Temple Street, LAPD

Metro officers were stationed around the entire building and setup a temporary

screening station directly outside the hearing room and hand waned all parties

entering the location. I have attended multiple hearings at the same location and

have never observed LAPD Metro anywhere in the vicinity. The Los Angeles World

Airports were represented by Christopher Garcia, “he stated that the "city" had

grave concerns regarding my ability to carry out my duties because the city believed

I was a "constitutionalist" or "sovereign citizen". Over Mr Garcia's objections the

Civil Service Board reinstated me to my former position with no loss of wages or

benefits. (See a copy of the appeal from discharge of Rodney J Rouzan transcripts

attached herein as Exhibit 6).

14. As a result of the unlawful entry into my home which occurred on May 23, 2012,

I initiated a civil rights lawsuit against the Los Angeles County Sheriff's department

and multiple deputies for unlawful entry into my home. During the discovery

process, I became informed of multiple violations of law, policy, procedure and

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falsification of the record committed by members of LAXPD Command Staff and

LAWA Human Resources who had worked in concert to terminate my employment.

The following information was obtained through discovery: 15. LAXPD Internal Affairs members disclosed confidential information to my neighbors in violation of the Peace Officers Bill of Rights and identified me as a "sovereign citizen". Each identified member was advised of the violation of law, given an opportunity to dispute but refused or failed to respond to the misconduct (See one of the copies of the Notice of a Violation of Peace Officer Bill of Rights attached herein as Exhibit 7.) 16. Assistant Chief Michael Hyams disclosed to Sergeant Jeff Shelton that he terminated me based on his belief that I was a "sovereign citizen". (See a copy of Jeff Shelton affidavit attached herein as Exhibit 8). 17. Human Resources Director, Paula Adams falsified the facts in her Disciplinary Recommendation for Discharge of Airport Police Officer Rodney Rouzan, in that she asserted that I had admitted to displaying a weapon in the internal affairs interview however no such admission was ever made. 18. Los Angeles International Airport Federal Bureau of Investigation resident agent, David Gates identified me as a "sovereign citizen" to LAXPD security officer Gregory Leibscher. (See a copy of the deposition of Gregory Leibscher attached herein as Exhibit 9). 19. On October 2, 2013, I initiated an internal affairs complaint about members of the internal affairs that disclosed to my neighbors’ and the Los Angeles Sheriff's department that I had been terminated from my employment in a violation of the POBAR. (See a copy the POBAR Complaint attached herein as Exhibit 10). 20. On October 28, 2013, I began searching for my Oath of Allegiance within my training folder, my search revealed that the department failed or refused to file the Oath as required by the California Constitution and Government Code. As a board member of police officers union, it is the duty of the board to represent and protect the rights and benefits of our members., I requested an audit of all members training folders which revealed approximately 390 officers have no oath of allegiance on file. I sent multiple requests to the Chief of the Los Angeles International Airport Police, Patrick Gannon. As of today's date those officers are still working in the public without an oath (See a copy of "Request for Oath" attached herein as Exhibit 11). 21. On March 10, 2014, I advised my direct supervisor Sergeant Martha Hall of my desire to conduct roll call training. She advised me to contact the day watch commander Lieutenant Chavez and schedule a date for the presentation. On March 12, 2014, at the request of Lieutenant Chavez I sent over an outline for my presentation (See a copy of the roll call training outline attached herein as Exhibit

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12). Lieutenant Chavez denied my roll call request and for the first time in my 14 year career the city attorney attended roll call and provided roll call training on the issues I proposed (See a copy of email regarding LAWA City attorney attached herein as Exhibit 13). I contacted six other LAXPD employees who had all conducted roll call training within the past few months and none of them had to produce an outline or go through the scrutiny that I was subject too. I contacted LAXPD training unit and they did not have a single request from any officer to conduct roll call training outside of the one I submitted. Based on the events just described, and believing my treatment to be disparate, I filed an Equal Employment Opportunity complaint against all parties involved. (See a copy of the EEO complaint attached herein as Exhibit 14). 22. On March 11, 2014, I initiated a formal complaint to Executive Director Samson Mengitsu against Human Resources Director Paula Adams for falsification of the record (See a copy of Notice of Misconduct and Ethics violation by Human Resources Director Paula Adams attached herein as Exhibit 15). Mengitsu subsequently dismissed my complaint on the grounds that Paula Adams falsification of the record was an "error" and he further alleged that it had no bearing on my termination, which was based on multiple "factors" (See a copy of Samson Mengitsu's closure letter attached herein as Exhibit 16). 23. I sent a Public Records Request to the Los Angeles World Airports requesting any records describing or defining "factors" LAWA responded that there are no records (See a copy of LAWA's Public Records Request Reply attached herein as Exhibit 17). 24. On April 14, 2014, I was contacted by Lieutenant Vern Williams of Internal Affairs who served me with a closure notice to my compliant, which I submitted on October 2, 2013, regarding POBAR violations. (See a copy of the POBAR complaint closure notice attached herein as Exhibit 18). In that notice Chief Patrick Gannon purports that, "no evidence was found that anyone from the Airport Police Department Internal Affairs communicated to the Elmaksouds that I had been terminated from my employment with LAWA”. I met Chief Gannon in person and he admitted that he dismissed my complaint without ever reading it and then quickly exited the room. (See a copy of declarations of Rodney Rouzan and Julius Levy attached herein as Exhibit 19). On December 5, 2014, I gave notice to Chief Gannon that the representations made in his notice of closure of my complaint were negligent misrepresentations. He has failed or refused to respond, dispute, or correct. (See a copy of Negligent Misrepresentations attached herein as Exhibit 20). 25. On April 23, 2014, I submitted a formal complaint to LAXPD internal affairs against Chief Patrick Gannon (See a copy of the Patrick Gannon complaint attached herein as Exhibit 21). The complaint was not investigated and the city attorney who represents the chief arbitrarily sent me a response alleging that she was dismissing my complaint. I requested her lawful authority to dismiss a complaint against the Chief of Police and she provided none. (See Deputy City Attorney Patricia Mor email

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responses attached herein as Exhibit 22). 26. On July 23, 2014, I went to the Los Angeles city personnel building to attend a hearing, after checking in with my LAXPD credentials with the security guard, I was stopped and detained by three LAPD officers regarding the safety bulletin which the city still maintains in their computer system. (See email to LAXPD command staff regarding LAPD detainment attached herein as Exhibit 23). 27. On July 31, 2014, I was contacted and had a meeting with Mariella Freire-Reyes, LAWA EEO coordinator regarding my EEO compliant for retaliation against members of LAXPD supervision, Paula Adams and Samson Mengitsu, who are Mariella's supervisors. Mariella told me she was dismissing the complaint because a "sovereign citizen" is not a protected class. I told Mariella that I believed her to be intentionally misclassifying my compliant because at all times I have maintained that I am not a "sovereign citizen" and that members of LAXPD and LAWA had arbitrarily. classified me as such then used that classification as the grounds to retaliate and harass me. Two weeks later, I received a written response from Mariella's supervisor Peter Hernandez who dismissed my compliant but omitted all references to a "sovereign citizen".(See a copy of the EEO dismissal attached herein as Exhibit 24). 28. I contacted Peter Hernandez and Mariella Freire Reyes via telephone and email and advised them that I believed that they were intentionally falsifying, misconstruing my allegations and unlawfully dismissing my complaint against their direct line supervisors which is a conflict of interest. (See a copy of the email communication with Peter Hernandez and Mariella Freire Reyes attached herein as Exhibit 25). 29. On August 4, 2014, I requested an emergency transfer from LAX to Van Nuys airport due to the the disparate treatment that I was receiving from LAXPD and LAWA supervision and management.(See a copy of the emergency transfer request attached herein as Exhibit 26). 30. On August 19, 2014, I was notified by multiple parties that personal mail addressed to me had been returned as undeliverable. I contacted my local post office and discovered that postal employees, without lawful authority had stopped delivering mail to my address. After multiple phone conversations with postal supervisors they refused to deliver, release, or provide lawful authority for their actions. On August 20, 2014, I drafted a notice and had it served on postal employees and went to the post office to claim my personal mail (See a copy of Notice of Unlawful Delivery of Mail attached herein as Exhibit 27). Postal employees refused to release my mail in violation of Title 18 section 1703 (See a copy of Title 18 section 1703 attached herein as Exhibit 28) and subsequently contacted the Sheriff's department to have me removed from the location. Deputies arrived on scene and I was contacted by Deputy Cindy Prather, who was a defendant in my civil rights lawsuit. I advised her that the Postal employees were detaining my mail which contained important and timely trial instructions in which she was a defendant. She ordered me to leave the post office without my mail in what I believe was an attempt

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to retaliate and harass me for bringing an action against her, other deputies and her department. I left the location without my mail or further incident. Later that evening, I filed a complaint against all deputies for aiding in the commission of a felony and requested that the watch commander Lieutenant Martinez, have a unit meet me at the post office the next morning to assist me with a private persons arrest. 31. On August 21, 2014, at 7:30 am I initiated a compliant with the United States Postal Service Consumer Affairs. At 0830 hours I spoke to the Deputy Post Master for the Antelope Valley, Ray Bryant who advised me that all of the mail which was being detained had been released and delivered as of 0800 hours. 32. On November 13, 2014, the Los Angeles County Sheriff paid me in settlement for the unlawful entry into my home which occurred on May 23, 2012. (See a copy of the Los Angeles County settlement agreement attached herein as Exhibit 29). 33. On October 27, 2014, I sent an email request to Lieutenant Joaquin Mendez to inquire regarding the status of my internal affairs complaint against Chief Patrick Gannon, he failed or refused to respond. On November 17, 2014, I sent a second request via email, regarding the status of my complaint and the policy and procedure for handling this issue., Without responding to my request he conveyed to me that Sergeant Valencia needed to serve me with two Notice of Interviews (See a copy of Memo of Discussion, Notice of Reply and Rebuttal and Notice of Memo of Issues, attached herein as Exhibit 30 (a)(b)(c)). 34. On November 18, 2014, I was served with two Notice of Interviews (See a copy of that Notice of Interviews attached herein as Exhibit 31.) I believe both notices were served on me in direct retaliation for filing complaints and lawsuits against LAXPD, LAWA and Los Angeles County Sheriff's who continue to violate the law then act in concert to cover up their criminal acts. I initiated grievances regarding both notice of interviews on the grounds that I believe them to be retaliatory and harassing in nature. (See a copy of both grievances attached herein as Exhibit 32). The grievances have been denied at all levels, the 1st and 2nd levels have all refused or failed to meet with me to resolve the grievance as required by LAWA Admin Manuel section 3.50. 35. On January 15, 2015, Lieutenant Joaquin Mendez, Officer In Charge of LAXPD internal affairs unit accompanied by his "advocate" Mariella Freire-Reyes, EEO Coordinator, attended a small claims civil action for defamation of character in which Mendez brought personal suit against Sergeant Jeff Shelton after his extensive criminal history had been produced to LAXPD management. The matter was settled during mediation and Ms. Reyes signed the dismissal agreement. (See a copy of Jeff Shelton declaration attached herein as Exhibit 33) Mendez and Reyes also have been observed eating lunch in the city cafeteria and traveling together in their city and personal vehicles on multiple occasions. I believe their personal relationship is a conflict of interest and further reason why all of my complaints have been dismissed.

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36. On January 21, 2015, I reported to Internal Affairs regarding the Notice of Interviews. During the interview, Sergeant Ralph Valencia read the complaint which contained new allegations which were not listed on the Notice I had received. I asked for clarification as to the new allegations, Valencia replied, “that he made an "error" and omitted the additional charges”. He exited the interview and drafted an amended Notice of Interview. (See a copy of the original and revised notice attached herein as Exhibit 34). 37. Later that day, I filed a complaint via my chain of command against the Internal Affairs investigators for falsifying city documents and what I believe to be the intentional violation of due process and POBAR. 38. I have exhausted all administrative remedy and based on the facts and events described above believe that members of LAXPD, LAWA, LAPD, and the Los Angeles County Sheriff are colluding or conspiring to again cause my termination on the arbitrary and unfounded opinions, and classifications of me as a "sovereign citizen." Those certain members include those referenced in this declaration, and directly associated or connected to the events I've described, some known, others unknown. 39. As of this date, I am uncertain what exactly a "sovereign citizen” is, I was referred to a Wikipedia URL by my supervisor Sergeant Robert Richardson. 40. It is my belief and understanding that Wikipedia can be created and updated by anyone with internet access and a computer. 41. I have only performed my duties to the best of my abilities and training, and have no motives outside of that. I have not been subject of any discipline, progressive or otherwise with respect to any of the events at present issue. 42. I believe I am being harassed and targeted in retaliation for exposing the arbitrary, and unlawful misconduct of those involved, the resulting embarrassment, and for making grievances regarding those acts.

Further affiant saith not.

I SWEAR OR AFFIRM THAT THE ABOVE AND FOREGOING

REPRESENTATIONS ARE TRUE AND CORRECT AND TO THE BEST OF MY

KNOWLEDGE INFORMATION AND BELIEF.

Date: January 27, 2015 ___________________________

Rodney Rouzan

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SECRETARY OF STATE

I, ALEX PADILLA, Secretary of State of the State of California, hereby certify:

That, Steve J. Dheming was, on January 27, 2015, a duly commissioned, qualified and acting NOTARY PUBLIC, in the State of California, empowered to act as such Notary in any part of this State and authorized to take the acknowledgment or proof of powers of attorney, mortgages, deeds, grants, transfers, and other instruments of writing executed by any person, and to take depositions and affidavits and administer oaths and affirmations in all matters incident to the duties of the office or to be used before any court, judge, officer, or board.

I FURTHER CERTIFY that the seal affixed or impressed on the attached document is the official seal of said Notary Public and it appears that the name subscribed thereon is the genuine signature of the person aforesaid, his (or her) signature being of record in this office.

In Witness Whereof, I execute this certificate and affix the Great Seal of the State of California this 27th day of January 2015.

Secretary of State

NP-24 A (REV. 1-07) BY --- OSP 12 128262

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ACKNOWLEDGMENT

A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.

State of California x County of 1-0 5 f

On ° 1- ( 2-° before me, V4' 3. Dkeion in (LCY-V, It? P14/fC./ (insert name and titiz of the officer)

personally appeared (--c'etAt sqln who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

WITNESS my hand and official seal. I — STEVE J. DHEMING E I comm. #1945064 z a . ; Notary Public - California ;1 . — z -;* Los Angeles County •-• 1

- Mt Comm. Expires Jul4,22 ., 20151 Signature

(Seal)

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DISTRIBUTION LIST

1. Los Angeles City Mayor, Eric Garcetti 2. Los Angeles City Council, Members: Joe Buscaino Jose Huizar Mitch O' Farrell Mitchell Englander Mike Brown Herb J Wesson Jr Curren D Price Jr Bernard Parks Felipe Fuentas Nury Martinez Paul Koretz Tom Labonge Bob Blumenfiled Paul Krekorian Gilbert Cedillo 3. Los Angeles Civil Service Commission, Members: Suzanne M Steinke Jeanne Fugate Jonathan Weiss Gabriel J Esparza Nancy P McClelland 4. Los Angeles Employee Relations Board, Members: Rhonda L Hilyer Rosalinda Lugo Christopher Cameron Anthony Miller Douglas Collins 5. Office of the Inspector General, Alexander Bustamante 6. Los Angeles City Attorney, Mike Feuer 7. California Department of Fair Employment and Housing 8. LAX Board of Airport Commissioners, Members: Cynthia A Telles Matthew M. Johnson Beatrice C Hsu Gabriel Eshaghian

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Valeria C Velasco Sean O. Burton 9. Los Angeles World Airport, Members: Gina Marie Lindsey Samson Mengitsu Peter Hernandez Mariella Freire Reyes 10.LAXPD, Members: Patrick Gannon Brian Walker Fernando Castro Henry Acosta Robert Richardson Imer Chavez Joaquin Mendez Ralph Valencia Aleda Iraldo Clint Beacom William Handley

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AFFIDAVIT OF RODNEY ROUZAN ATTACHED EXHIBITS

(SEE ENCLOSED DVD)

TABLE OF CONTENTS

1. OATH OF OFFICE ARTICLE 2. SOVEREIGN CITIZEN TRAINING MOVEMENT 3. SAFETY BULLETIN 4. CHIEF MICHAEL HYAMS DECLARATION 5. JUDY GUST LA HEARING OFFICER REPORT 6. APPEAL FROM DISCHARGE OF RODNEY J ROUZAN 7. NOTICE OF VIOLATION OF PEACE OFFICER BILL OF RIGHTS 8. JEFF SHELTON AFFIDAVIT 9. DEPOSITION OF GREGORY LEIBSCHER 10. POBAR COMPLAINT 11. REQUEST FOR OATH 12. ROLL CALL TRAINING OUTLINE 13. LT CHAVEZ EMAIL 14. EEO COMPLAINT 15. NOTICE OF MISCONDUCT AND ETHICS VIOLATION BY HUMAN RESOURCES

DIRECTOR PAULA ADAMS 16. SAMSON MENGITSU CLOSURE LETTER 17. LAWA'S PUBLIC REQUEST REPLY 18. POBAR COMPLIANT CLOSURE NOTICE 19. RODNEY ROUZAN & JULIUS LEVY DECLARATION 20. NEGLIGENT MISREPRESENTATIONS 21. PATRICK GANNON COMPLAINT 22. DEPUTY CITY ATTORNEY PATRICIA MOR EMAIL 23. LAPD DETAINMENT 24. EEO DISMISSAL 25. PETER HERNANDEZ AND MARIELLA FREIRE REYES EMAIL COMMUNICATION 26. EMERGENCY TRANSFER REQUEST 27. NOTICE OF UNLAWFUL DELIVERY OF MAIL 28. TITLE 18 SECTION 1703 29. LOS ANGELES COUNTY SETTLEMENT 30. (A)NOTICE OF MEMO OF DISCUSSION (B) NOTICE OF REPLY REBUTTAL (C) NOTICE OF MEMO OF ISSUES 31. NOTICE OF INTERVIEWS 32. GRIEVANCES 33. JEFF SHELTON DECLARATION 34. ORIGINAL AND REVISED NOTICE OF INTERVIEWS