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Bring umbrella ☔"National Weather Service predicts ‘near 100% chance of rain’ during the Rose Parade "| KTLA
https://ktla.com/weather/national-weather-service-predicts-near-100-chance-of-rain-during-the-rose-parade/amp/
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The last time the Rose Parade saw significant rain was in 2006.
Before that, rain had not fallen on the parade since 1955. Even further back, the 1934 Rose Parade was the wettest on record..."
The Briefcase and the Frame Job: How Good Citizen (barely) Survived Halford’s Trap
π The Framing of the Seminary Student
Part I: Premeditation and the Office Scheme
Hugh Halford’s Quiet Plot
In the quiet of his office, Hugh Halford sipped lukewarm coffee, a sly smile curving his lips. He reviewed the M.Div student’s civil case against the City of Pasadena and the Pasadena Police Department. The sem student—known for his composure and his dual life as a substitute teacher for LAUSD—had become a threat to the city’s legal interests. Halford, ever the strategist, recognized the opportunity to craft a frame. “Watch this,” he muttered, tapping a pen against the desk, “one good courtroom spectacle, and the Good Citizen will be the defendant instead of the plaintiff.”
Halford rehearsed the moment in his mind, picturing the hallway outside the courtroom, imagining the student’s calm demeanor, and anticipating the dramatic flair that the student, trained in handling rowdy classrooms, might inadvertently provide. He chuckled quietly, thinking how he could twist a simple gesture into a criminal allegation. Later, in whispered tones with city police contacts and Michelle Bagneris, his boss, he recounted the plan as a jest. “The kid won’t even see it coming,” he boasted, amusement dancing in his eyes.
Part II: The Hallway Confrontation
Drama Meets the Court
The day arrived. The M.Div student, known affectionately as Good Citizen, walked the hallway outside the courtroom, armed with his files, witness statements, and unshakable composure. He was prepared to defend himself pro per, a skill honed from years of managing large, unpredictable classrooms full of high school students testing his patience. His LAUSD experience taught him how to command attention with a mix of authority, timing, and subtle dramatic flair—a skill he now subconsciously prepared to use.
Hugh Halford emerged, eyes sharp, voice loud, ready to dominate the hall. He approached with his typical aggressive attorney posture, attempting to intimidate the sem student. “Looks like you’re out of your depth, kid,” Halford sneered, stepping closer.
The M.Div student paused. He felt the familiar surge of classroom control instincts. “Time for a little theatrics,” he thought, recalling how a well-timed gesture could refocus even the most disruptive classroom. With measured intent, he grabbed his briefcase and slammed it onto the floor. The echo ricocheted off the hallway walls like a gavel, drawing immediate attention. The gesture was controlled, symbolic, entirely non-contact—but perfect to assert presence and authority.
Yet Halford, ever devious, leaned subtly forward just as the briefcase hit the ground, brushing the student’s sleeve ever so slightly. In an instant, Halford’s theatrics flipped the narrative: “He hit me! Did you see that? He hit me!” he yelled, projecting the lie to any potential witnesses.
Two nearby attorneys, distracted by their own matters, were the only people present. One shook his head, “I didn’t see him hit or touch you,” but Halford ignored it, playing the moment for maximum effect. His eyes scanned the hall, seeking validation from imagined onlookers, while the M.Div student remained calm, internally noting the familiar tactics of deceit he had faced as a teacher: manipulation, false testimony, and staged provocations.
Part III: The Frame in Motion
Police Involvement and Miscarriage
The Pasadena Police Department soon entered the scene, and Halford’s theatrics bore fruit. Despite the student’s innocence, police cited him for simple battery and disturbing the peace. The charges served a dual purpose: to deflect attention from the city and PD’s own liability in the original civil case, and to punish the Good Citizen for daring to challenge institutional power. It was a textbook misdirection, executed with confidence and a wink shared privately with his colleagues and superiors.
Meanwhile, the M.Div student stood resolute, his experience managing chaotic classrooms lending him an inner steadiness. He remembered the unruly teenagers testing him, lying to cover pranks or minor infractions. Here in the hallway, he faced a far more sophisticated version of that chaos: a seasoned attorney twisting the moment to his own advantage. But his training provided a secret weapon— poise under pressure.
Part IV: The Classroom Within the Courtroom
Dramatic Anger as Defense
The Good Citizen reflected on how he had learned to use “dramatic anger” to assert control in classrooms, a technique to command attention and prevent escalation. He realized this moment in the court hallway was similar: if he could display authority without aggression, he could withstand Halford’s false claims and keep observers focused on the truth. The briefcase slam was not random; it was a deliberate, nonviolent demonstration, meant to establish presence and draw attention.
Yet Halford, cunning and premeditated, interpreted it as “assault,” leaning into the student and transforming the action into a frame. The student, calm but internally racing, understood the stakes: this single moment could derail his entire civil case if he allowed it. He reminded himself, “Classroom strategies, focus, observation. Witnesses matter. Poise matters.”
Part V: The Aftermath
Manipulation and Gossip
Afterward, in Halford’s office, he laughed quietly over the incident, retelling the frame to Pasadena police contacts. “Did you see that? Slam! And now he’s on a battery charge,” he joked, shrugging conspiratorially at city attorneys and officers alike. All part of the plan. He even referenced the incident to Michelle Bagneris with sly glee, describing it as a clever twist of events, downplaying the M.Div student’s innocence.
Despite the personal attacks and duplicity, the Good Citizen began gathering evidence: witness accounts, precise timestamps, and contextual notes recalling the hallway dynamic. His understanding of human behavior, honed in classrooms with teenagers attempting deception, guided his reconstruction. He noted the precise moment Halford leaned in, the briefcase’s trajectory, and the lack of physical contact.
Part VI: The Courtroom Resurgence
Truth Triumphs
Weeks later, in the courtroom proper, the M.Div student presented his case methodically. With every assertion, every timeline, he demonstrated restraint, moral integrity, and a subtle theatrical presence that commanded attention. Halford attempted again to frame him as volatile, but the visual record, witness testimony, and documentation of the hallway event contradicted his theatrics. Observers noted the disparity: the student’s calm and Halford’s performative aggression.
The story of the briefcase became a pivotal reference, a symbol of integrity and composure under pressure. Everyone in attendance—judge, attorneys, even jurors— recognized the difference between orchestrated lies and deliberate, controlled theatrical emphasis. The Good Citizen’s credibility emerged unscathed.
Part VII: Legacy of the Incident
Lessons Learned and Local Legend
The M.Div student’s hallway confrontation became a whispered legend within seminary corridors and, quietly, among Pasadena legal circles. The briefcase slam, flashing in memory like a beacon of truth, symbolized measured authority, composure, and the power of procedural knowledge against deceit.
Halford retreated, plotting the next tale, but the Good Citizen had established a foundation of credibility. His dual role as a substitute teacher and seminary student allowed him to navigate human behavior, anticipate deception, and respond with carefully measured dramatic control.
Ultimately, the incident revealed the contrast between premeditated manipulation and ethical, disciplined response. While the city and its attorney attempted to rewrite reality, the M.Div student’s poise, documentation, and theatrical experience ensured the truth would endure.
And Lola, ever faithful, wagged at his side through it all— a small reminder that innocence, patience, and unwavering integrity often speak louder than the loudest lie.
The Red Honda Reckoning: A Sem Student’s Test of Inner Strength
The Unforeseen Trial: A Seminary Student at Lake and Villa
1. A Quiet Afternoon Turns Unexpected
The evening sun was waning over Pasadena, spilling long amber rays across Lake Avenue. For the M.Div student, known to the world as Good Citizen, the day had been one of quiet study, reflection, and anticipation for a small sermon he was preparing for his community chapel. His mind wandered to the words he had rehearsed, the passages he hoped would resonate with the small congregation, and the weight of responsibility he carried in cultivating both spiritual understanding and moral clarity. Little did he know that, in less than a minute, he would be caught in an ordeal that challenged patience, civility, and his own sense of justice.
2. The Minor Collision
Driving his red two-door Honda southbound on Lake Avenue, Good Citizen felt the familiar hum of the engine and the rhythm of the streets as calming companions. The late winter air was crisp, carrying a faint scent of eucalyptus from the distant San Gabriel hills. As he approached Villa Street, the traffic light ahead remained red. He slowed, foot lightly on the brake, eyes scanning the intersection with a deliberate care born of both caution and conscience. Crossing the city streets had always been a practice of mindfulness for him—an extension of the values he sought to embody in his ministry.
Meanwhile, from the west, a green four-door Honda—driven by a woman later known as Bustamonte—entered the intersection. From his angle, obscured slightly by a delivery truck stationed along the curb, Good Citizen did not see the vehicle until it drew near. There was a sudden, jarring moment when the front bumpers met, a light collision that left both cars scratched and both hearts startled. The sound was muted but precise—the faint scrape of metal, the brief crunch of enamel paint—and it was enough to turn the routine drive into a crucible of moral and social trial.
3. Calm Amid Misunderstanding
He exhaled slowly, heart steadying. “It’s alright,” he murmured to himself. “It’s only a scratch. We’ll resolve this.” He stepped out, carefully assessing the damage to both vehicles. His eyes caught the woman’s expression: flustered, upset, perhaps fearful. Good Citizen instinctively raised his hands in a gesture of reassurance, signaling calm. He had always believed that conflicts, no matter how trivial in their physical impact, could escalate unnecessarily if reason and compassion were not exercised. The collision itself, minor as it was, became the backdrop for a confrontation he had not anticipated.
4. Arrival of Law Enforcement
Before the conversation could escalate, the sound of a police siren punctuated the evening air. Officers Brown and Mosman approached in a marked vehicle, lights reflecting off the asphalt, the ordinary authority of law intersecting with the seminary student’s ordinary life. Good Citizen stepped slightly back, hands visible, conscious of every gesture. He had learned that compliance with authority was prudent, yet fairness was equally crucial. His mind raced: How could he demonstrate his innocence, his civility, without seeming defensive or evasive? He reflected briefly on Romans 13 and the nature of obedience, the balance of respect and personal integrity.
5. Misinterpreted Intentions
Officer Brown’s eyes fixed on Good Citizen. The M.Div student could feel the weight of the gaze, the subtle tension in the air, like a beam testing the strength of the soul. “Explain what happened,” Brown demanded, voice firm but not harsh. Good Citizen recounted the incident, carefully articulating the sequence: the red light, the obstructed view, the minor impact. He spoke honestly, without embellishment, conveying both responsibility for navigating safely and the factual inevitability that sometimes accidents occur even under due care.
Yet, in the officers’ perception, Good Citizen’s calm and deliberate articulation was misread. The suddenness of his step forward, merely to demonstrate the line of sight blocked by the truck, was interpreted as aggression. He had merely leaned slightly to illustrate his point, an innocent movement of hands and posture, and yet Officer Brown recorded it as a “lunge”. Within moments, the seminary student felt the weight of misinterpretation pressing upon him, the friction between civic duty and personal morality becoming palpable.
6. Documentation and Misrepresentation
A minor pain in his right thumb caused him to flinch momentarily. It was an inconsequential injury, likely from bracing or adjusting stance, yet it became part of the formal report, a mark of alleged victimization now woven into a narrative he had no control over. Good Citizen allowed himself a brief inward sigh: the human story—fear, misunderstanding, emotion—was being compressed into codes, abbreviations, and preprinted notes. The heart of the incident—the human nuance, the interior truth—was at risk of being lost.
7. Reflections on Ethics and Conduct
As the officers began their intake process, the M.Div student found his thoughts drifting. He remembered his seminary lectures on ethics and human fallibility, on sin and misunderstanding, on the necessity of mercy tempered with accountability. How often had communities rushed to judgment, misunderstanding intentions, misattributing actions? He recognized the unfolding pattern and silently prayed for patience, clarity, and justice—not just for himself but for all parties involved.
8. Resolution and Inner Clarity
Hours passed, though perhaps only minutes in the physical world. The paperwork concluded, and the officers began to retreat toward their vehicle. Bustamonte, having observed his demeanor, seemed less adversarial, though the collision had left its mark on her patience. Good Citizen offered a final gesture of civility, a nod acknowledging the shared human moment of imperfection and recovery. He returned to his car, checked his reflection in the rearview mirror, and allowed himself a quiet exhale. The encounter was over, yet its lessons remained, inscribed deeply in his consciousness.
Driving away, he pondered how seemingly small accidents could become tests of character. The red Honda hummed along Lake Avenue, carrying not only the M.Div student but the weight of principles, the assurance of faith, and the clarity of conscience. In that small collision, he had confronted misunderstanding, maintained calm in the face of misinterpretation, and upheld the dignity of a person committed to both civic and spiritual virtue. Though the official record might later misrepresent subtlety, Good Citizen knew the truth of his own actions—and that knowledge, he understood, was unassailable.
By the time he arrived at the chapel, the first stars appeared over Pasadena. He parked, removed his books, and walked inside. The world of paperwork, collision, misinterpretation, and procedural shorthand faded. In its place, he held reflection, compassion, and the enduring lesson that character was forged not in absence of conflict, but in the steadfast navigation of it.
new3 v5
V5
The attached document represents a severely fragmented Pasadena Police Department file concerning an incident on February 3, 2000 at Lake Avenue and Villa Street. While scanned poorly and missing critical lines, the content reveals procedural irregularities, contradictions in officer statements, and questionable actions taken against plaintiff K, forming the basis for an aggressive legal analysis of potential misconduct and unfair treatment.
The initial pages consist of administrative intake forms, ostensibly to record suspect description and evidence. Despite text corruption, the preprinted note “THE SUSPECT HIT THE POLICE OFFICER” stands out. This is a prejudicial template statement, potentially misleading investigators or readers into assuming culpability before any determination. The partially completed forms highlight procedural sloppiness, raising questions about departmental documentation standards.
Case identifiers, including Case No. 00006684, recur throughout the file. Other numerical or coded references are scattered and largely illegible. Their inconsistent presence emphasizes poor recordkeeping, making it impossible to track who entered information, when, or under what authority. This lack of clarity is critical for evidentiary review.
The narrative by Officer Brown is presented as a chronology but contains significant contradictions and gaps. Brown reports that, at 1801 hours, he and Officer Mosman were southbound on Lake Avenue, approaching Villa Street. He claims to have observed a green Honda entering the intersection lawfully before the light changed, yet later alleges plaintiff K entered unsafely, with no clear explanation of signal timing. This internal inconsistency undermines the credibility of the officer narrative.
Both drivers exited their vehicles. Brown notes only minor paint transfer, yet the report escalates to allegations of aggressive movement. Plaintiff K allegedly “lunged” toward Brown in a manner described as aggressive, coming within eight inches. No strike, push, or grab occurred, yet this forms the entire basis of a P.C. 243(b) charge. This raises serious questions about whether perceived aggression alone supports a criminal allegation.
Brown further notes a sore right thumb, without explanation of causation. The absence of photographs, sketches, or medical documentation represents a procedural failure, as claims of injury should be substantiated.
Plaintiff K’s alleged refusal to exchange insurance information is presented as escalation. The narrative fails to consider Bustamonte’s contradictory statements. She described plaintiff K as agitated yet also confirmed the collision was minor. Selective reporting of plaintiff K’s behavior illustrates procedural bias, potentially framing him unfairly.
The witness statement is heavily degraded. While fragments suggest verbal and emotional escalation, OCR corruption and missing lines prevent verification. Relevant context—such as minimal collision impact and visual obstructions—is omitted, demonstrating a narrative engineered to support aggressive prosecution.
Administrative intake forms show additional procedural inconsistencies. Evidence and suspect categories—“vehicle,” “weapons,” “suspect named,” “further investigation”—are incomplete. Preprinted phrases like “GOOD POSSIBILITY OF SOLUTION” and “A SUSPECT CAN BE LOCATED” suggest expected follow-through, yet no action, arrest documentation, or supervisory review appears, exposing serious procedural deficiencies.
Critical unresolved questions remain: (1) Was plaintiff K formally arrested, cited, or detained? (2) Were supplemental officer statements filed? (3) Was supervisory review conducted? (4) Was there follow-up investigation? The abrupt termination of the scan suggests key procedural steps were either never completed or omitted from the record.
Taken together, the material demonstrates multiple forms of potential misconduct and bias:
- Prejudicial template statements inflating plaintiff K’s culpability.
- Internal contradictions in officer observations undermining reliability.
- Selective reporting of witness statements to emphasize aggression.
- Incomplete procedural follow-up leaving the case unresolved.
- Ambiguous injury claims without corroboration.
Highlighting these points demonstrates that the scanned file is not only incomplete but potentially manipulated to justify a P.C. 243(b) allegation against plaintiff K. Conflicting details and selective emphasis provide a compelling argument that he may have been mischaracterized and unfairly targeted.
The narrative underscores broader concerns: roadside incidents escalate due to environmental factors, obstructions, and emotional responses. The officers’ account selectively attributes intent to plaintiff K, demonstrating confirmation bias in law enforcement reporting.
For legal analysis, Version 5 emphasizes: (1) Plaintiff K’s movement is ambiguous, insufficient for a P.C. 243(b) charge; (2) Officer narratives contain contradictions undermining reliability; (3) Witness statements are degraded and selectively emphasized; (4) Administrative forms are incomplete and potentially prejudicial; (5) Procedural follow-up is absent, raising fairness concerns.
In conclusion, Version 5 frames the case around potential officer misconduct, selective narrative, procedural deficiencies, and contradictions. It presents a document demanding scrutiny regarding the integrity of allegations and fairness in the handling of plaintiff K’s alleged conduct. Color-coded highlights emphasize critical issues: green for statutes/identifiers, red for contradictions, aggressive acts, and procedural gaps.
new3 v4
v4
This file represents a partially reconstructed police case file generated by the Pasadena Police Department regarding an incident on February 3, 2000 at or near Lake Avenue and Villa Street. The scanned materials are heavily degraded, including torn pages, OCR distortions, missing lines, and incomplete text. Despite these limitations, the document allows reconstruction of the incident sequence, capturing officer observations, suspect behavior, and witness testimony surrounding a P.C. 243(b) (Assault on a Peace Officer) allegation.
The early section includes standardized administrative forms designed to capture suspect descriptors, evidence categories, and incident metadata. These forms list clothing, accessories, identifying marks, potential weapons, and other checkboxes. Though much of the text is corrupted, certain entries remain legible: “baseball hat,” “glasses (plastic frame),” and generic weapons categories. Notably, one preprinted line reads: “THE SUSPECT HIT THE POLICE OFFICER”. Whether this originates from an officer’s notation or a template artifact is unclear, raising questions about its reliability.
Case identifiers, including Case No. 00006684, recur throughout the intake forms. Other numerical or coded references are present, likely indicating internal categorization or revision dates. Though mostly illegible, these repeated identifiers reinforce that the file adheres to departmental procedures for documenting P.C. 243(b) cases.
The most coherent portion is a narrative authored by Officer Brown. At approximately 1801 hours, Brown and Officer Mosman were southbound on Lake Avenue in a marked vehicle. As they approached Villa Street, the north–south traffic signal was red. Upon turning green, they began moving through the intersection when they heard a collision from their left.
The involved vehicles were a green four-door Honda driven by Bustamonte and a red two-door Honda driven by plaintiff K. Brown observed the green Honda entering the intersection from the west prior to the light change, concluding it had lawfully occupied the intersection. Later admissions from Bustamonte that she entered the intersection late during gridlock cast significant doubt on the officers’ assessment of fault.
Both drivers exited and moved toward the sidewalk. Officers observed minor paint transfer, consistent with a low-speed collision. Brown first engaged plaintiff K. Plaintiff K reportedly stated he moved forward when his light turned green but that a truck obstructed his view of westbound traffic. He allegedly downplayed the collision, saying “let’s call it a wash”. Bustamonte requested insurance and identifying information. Plaintiff K initially refused, claiming no fault. These accounts may overstate the severity of plaintiff K’s demeanor.
Officer Brown intervened to de-escalate the situation, instructing plaintiff K to comply. Brown reiterated that the green Honda entered the intersection before the north–south signal changed, concluding plaintiff K entered unsafely. At this point, Brown alleges plaintiff K escalated physically.
Brown reports that plaintiff K, standing between vehicles while Brown was on the sidewalk, “lunged” in what Brown described as aggressive movement, approaching within eight inches. No strike, push, or grab occurred. The report may exaggerate plaintiff K’s movement to justify the P.C. 243(b) allegation.
Brown also noted a sore right thumb, without clarification on how it occurred. There is no indication whether plaintiff K was arrested, cited, or otherwise processed, highlighting the incompleteness of the scan.
Witness statements attributed to Bustamonte are heavily degraded. Fragments suggest she described plaintiff K as agitated, loud, and emotionally unstable. However, Bustamonte’s later admission of entering the intersection late undermines her credibility and calls into question her version of events.
Additional fragments imply plaintiff K gestured, paced, or spoke loudly. The corrupted and partial nature of the witness text, along with potential bias, limits its reliability as evidence.
The administrative forms included checkboxes for evidence types (e.g., “vehicle,” “weapons,” “tools,” “controlled substances,” “photographs”) and investigative categories (e.g., “suspect named,” “suspect arrested,” “further investigation needed”). The corrupted forms do not confirm selections. Preprinted phrases such as “A SUSPECT CAN BE LOCATED” reflect template language rather than verified investigative conclusions.
The scan ends abruptly, leaving unresolved questions: (1) Was plaintiff K formally arrested, detained, or cited for P.C. 243(b)? (2) Were supplemental booking sheets or officer statements completed? (3) Did supervisory review take place? (4) Was further investigation or prosecutorial screening conducted? Standard procedure would typically require additional documentation for an assault-on-officer allegation, none of which appears in this scan.
Key findings include: (1) A minor traffic collision at Lake/Villa involving plaintiff K and Bustamonte. (2) Officers’ claim that Bustamonte entered lawfully is questionable. (3) Plaintiff K disputed fault, initially refused to exchange information, and spoke firmly. (4) Plaintiff K made a forward movement interpreted as threatening, though no contact occurred. (5) Officer Brown reported minor thumb soreness. (6) Witness corroboration is unreliable due to credibility concerns. (7) Procedural resolution is absent.
Legally, the narrative emphasizes plaintiff K’s perceived behavior rather than the mechanics of the collision. The escalation appears based on interpretation of verbal tone and movement, not actual physical aggression.
In its current form, the file serves as a partial evidentiary record, highlighting inconsistencies in police reporting and witness statements while documenting the circumstances of the February 3, 2000, incident.
new3 v3
Professional Appellate Brief Rewrite (Expanded ~1500 Words)
The record submitted consists of a partially preserved Pasadena Police Department incident file documenting a February 3, 2000 traffic collision and the subsequent allegations of P.C. 243(b)—Assault on a Peace Officer—against plaintiff K. Although the materials are incomplete and heavily degraded, the surviving narrative sections, administrative entries, and witness references provide an adequate basis to reconstruct the operative facts and procedural framing. This appellate-style rewrite emphasizes potential discrepancies in the police and witness testimony while presenting a professional, structured narrative.
The file begins with form-based pages comprising the department’s standardized intake templates. These forms include fields for suspect descriptors, clothing, identifying marks, evidence categories, investigative designations, and administrative codes. Due to OCR distortion, many portions are unreadable, appearing as fragmented symbols. Recognizable fields include eyewear, hats, weapon classifications, and general behavioral indicators. One preprinted line reads: “THE SUSPECT HIT THE POLICE OFFICER.” Its placement in a stock template raises questions about whether it reflects an independent factual assertion.
The case number—00006684—appears repeatedly across the forms. Fields such as “suspect named,” “suspect arrested,” “further investigation needed,” and “probability of solution” indicate investigative direction, but the incomplete scan leaves unclear which boxes were actually selected. Evidence categories including “vehicle,” “weapons,” “photos,” and “controlled substance” appear, though there is no clear linkage to the incident.
The substantive core is the narrative authored by Officer Brown. On February 3, 2000 at approximately 1801 hours, Officers Brown and Mosman were traveling southbound on Lake Avenue. Approaching Villa Street, the north–south signal was red. Upon turning green, they entered the intersection and immediately heard a collision to their left.
The vehicles involved were a green four-door Honda and a red two-door Honda. Drivers were identified as Bustamonte (green Honda) and plaintiff K (red Honda). Brown claims the green Honda entered before the signal changed, a conclusion contradicted by later statements from Bustamonte admitting she entered late during gridlock, raising doubt about the officers’ assessment of fault.
Both drivers exited their vehicles. Officers noted minor paint transfer, consistent with a low-impact collision. Brown approached plaintiff K first. Plaintiff K reportedly stated his light turned green and that his view of westbound traffic was obstructed. Brown recounts that plaintiff K told Bustamonte the incident was “no big deal,” “let’s call it a wash.” Bustamonte’s request for identification allegedly provoked plaintiff K’s refusal, though this may reflect misunderstanding or overstatement of plaintiff K’s conduct.
Brown asserts that plaintiff K became argumentative, prompting officer intervention. Brown states he explained that the green Honda entered before the light changed, claiming plaintiff K entered unsafely. Brown alleges this triggered an aggressive reaction.
Brown reports that plaintiff K—standing between the vehicles—suddenly lunged forward toward him. Brown remained on the sidewalk. Plaintiff K allegedly came within eight inches of contact. No strike, push, or grab occurred. The officers’ interpretation may exaggerate plaintiff K’s movement to justify a P.C. 243(b) allegation.
Brown notes a “sore right thumb”, without clarifying the cause. No records indicate whether plaintiff K was arrested, cited, or processed. Supplemental reports or supervisory reviews are missing, emphasizing the incomplete nature of the file.
Witness statements attributed to Bustamonte are heavily degraded. Surviving fragments suggest she described plaintiff K as agitated, yelling, and emotionally elevated. However, her later admission about entering the intersection late undermines her reliability and raises questions about the accuracy of her account.
Corrupted text implies plaintiff K gestured, paced, or spoke loudly. Due to distortion and potential bias, these descriptions should be treated cautiously.
Administrative forms include checkboxes for evidence types and investigative categories, though selection is unclear. Preprinted phrases such as “GOOD POSSIBILITY OF SOLUTION” and “A SUSPECT CAN BE LOCATED” reflect template language, not verified observation.
The scan ends abruptly. Missing documents—arrest reports, citations, booking sheets, or prosecutorial screening—likely exist in the original file but are absent here.
Key points for appellate analysis:
• Minor collision at Lake/Villa involving plaintiff K and Bustamonte.
• Officers’ claim that Bustamonte entered lawfully is contradicted by her later statement.
• Plaintiff K disputed fault and initially declined to provide information.
• Officers interpreted verbal escalation and forward movement as threatening.
• Forward movement did not result in contact.
• Brown sustained minor injury (sore thumb), circumstances unclear.
• Bustamonte’s fear and support for officers’ interpretation are undermined by her credibility issues.
• Record lacks final disposition and procedural closure.
The narrative emphasizes plaintiff K’s demeanor rather than collision mechanics. Minor vehicle damage, misinterpretation, and perceived noncompliance appear central to the officers’ P.C. 243(b) allegation.
Despite missing material, the scanned file provides sufficient information to understand the officers’ perspective and the disputed nature of the allegations, highlighting inconsistencies and credibility concerns regarding both police reporting and witness statements.
new3 v2
v2
The attached record constitutes a partially reconstructed law-enforcement case file associated with Case No. 00006684, generated by the Pasadena Police Department following a traffic collision and subsequent allegation of P.C. 243(b) (Assault on a Peace Officer) against plaintiff K. While the scanned materials are degraded—with missing lines, corrupted OCR text, and incomplete pages—the available content allows structured analysis, highlighting uncertainties and potential bias in the officers’ narrative and the witness statement.
The record includes two main categories: (1) preliminary administrative forms with descriptive and evidentiary fields, and (2) narrative reports prepared by officers, supplemented by a witness statement. Many entries are unreadable due to scanning distortion. A preprinted line states “THE SUSPECT HIT THE POLICE OFFICER”, though this may be a templated field rather than an actual observation, raising doubts about its accuracy.
The narrative by Officer Brown describes the February 3, 2000 incident. Brown states he and Officer Mosman were driving southbound on Lake Avenue at approximately 1801 hours when they heard a collision. Brown claims the green Honda entered the intersection lawfully, yet Bustamonte later admitted she entered late during a gridlocked intersection, undermining the officers’ version and suggesting plaintiff K may have been unfairly characterized.
Officers identified the vehicles as a green four-door Honda driven by Bustamonte and a red two-door Honda driven by plaintiff K. Both drivers exited their vehicles. Brown notes minimal paint transfer and recounts questioning plaintiff K. The account emphasizes the officers’ interpretation rather than independently verified facts.
Brown claims plaintiff K downplayed the collision and said “let’s call it a wash”. Bustamonte allegedly demanded insurance and ID. Her later admission of entering the intersection late calls into question her credibility and the officers’ framing of plaintiff K as the aggressor.
Brown asserts plaintiff K made a sudden forward movement, described as “lunging” toward him. No actual contact is reported. The narrative frames this movement as threatening, yet the lack of corroboration and missing procedural documentation raises serious doubts.
Brown reports a minor injury—a “sore right thumb”—without explaining the mechanism. The scan lacks any record of arrest, citation, or follow-up, indicating the record is incomplete.
Bustamonte’s witness statement is heavily degraded. Fragments suggest she described plaintiff K as agitated, loud, and angry. Given her later traffic admission, this testimony is unreliable and may reflect the officers’ influence rather than objective observation.
Many pages are illegible. The narrative focuses on plaintiff K’s demeanor rather than the collision itself, consistent with common P.C. 243(b) interpretations where noncompliance or perceived assertiveness is framed as assault. The degraded record emphasizes the need to scrutinize officer and witness credibility.
Form pages include administrative categories such as “GOOD POSSIBILITY OF SOLUTION” and “A SUSPECT CAN BE LOCATED”. Missing data prevents verification of which boxes were marked.
Unanswered questions include: (1) Was plaintiff K arrested, detained, or cited? (2) Are supplemental officer statements or booking sheets available? (3) Did supervisory review occur? (4) Was any follow-up investigation or prosecutorial screening done? The abrupt scan cutoff strongly indicates additional materials existed but were not included.
Key points for legal analysis: (1) A low-speed collision occurred at Lake/Villa involving plaintiff K and Bustamonte; (2) Officers incorrectly claimed Bustamonte entered lawfully; (3) Plaintiff K disputed fault and was assertive; (4) Officers characterized a forward movement as threatening; (5) Minor injury reported; (6) Witness statement allegedly corroborated officers, despite later contradiction; (7) Record incomplete, lacking disposition.
Overall, the record emphasizes officers’ interpretation of plaintiff K’s behavior over objective collision facts. The minor collision is secondary to perceived demeanor, consistent with P.C. 243(b) filings. Missing pages and contradictory witness admission strongly favor a critical view of the officers’ and witness’s reliability in support of plaintiff K.
new3 v1
Clean Narrative Legal Summary (Expanded ~1500 Words)
The attached file comprises a partially scanned compilation of police records generated by the Pasadena Police Department regarding an incident that occurred on February 3, 2000 at or near the intersection of Lake Avenue and Villa Street. The records are heavily degraded—torn pages, smudged ink, corrupted text, and incomplete OCR transcription—raising questions about reliability. They contain administrative forms, coded entries, and narrative accounts, most notably a narrative incident report classified under P.C. 243(b). This summary consolidates the information while highlighting inconsistencies and gaps that cast doubt on the official account.
Initial pages contain standardized forms with suspect descriptors, clothing, and weapons. Despite degradation, certain items like “baseball hat” or “glasses (plastic frame)” are legible. One preprinted line states: “THE SUSPECT HIT THE POLICE OFFICER.” Its placement in a template note section suggests this may not reflect direct observation, and its reliability is therefore questionable.
Internal identifiers appear, including Case No. 00006684, but the degraded forms make verification difficult. The administrative process seems routine, yet documentation quality leaves room for doubt regarding factual accuracy.
The narrative authored by Officer Brown alleges that on February 3, 2000, at approximately 1801 hours, he and Officer Mosman were southbound on Lake Avenue. Brown claims a minor collision occurred, but the description is inconsistent with the visible damage and later accounts. The officers’ account emphasizes alleged aggressive behavior by plaintiff K, yet details are vague and largely based on their own observations.
Officers report observing two vehicles: a green four-door Honda and a red two-door Honda. Brown concludes the green Honda entered the intersection lawfully. However, later testimony from Bustamonte, the green Honda driver, indicates she entered the intersection late during a gridlock situation—a clear violation of traffic law—undermining the officers’ assertion that plaintiff K’s conduct alone created the hazardous situation.
According to the narrative, both drivers moved to the sidewalk. Plaintiff K is said to have downplayed the collision, suggesting “let’s call it a wash.” Bustamonte demanded insurance and identification. Brown’s account emphasizes plaintiff K’s alleged agitation, but her later admissions suggest her earlier claims were exaggerated. The officers’ descriptions of plaintiff K’s volume and movement may reflect subjective interpretation rather than objective threat.
Brown alleges plaintiff K lunged forward: “lunged” within eight inches. Yet there is no corroborating physical evidence, and the narrative provides limited specifics. The alleged forward movement is used to justify P.C. 243(b) reporting, but the vague description and lack of independent verification call the credibility of this claim into question. Brown also reports a minor thumb injury (sore right thumb), with no clear mechanism connecting it to plaintiff K.
Bustamonte’s witness statement is heavily degraded. While she portrays plaintiff K as angry, verbally loud, and emotionally unstable, her later admission of entering the intersection improperly casts her original testimony in doubt. Her statements, coupled with transcription errors, suggest the narrative may overstate plaintiff K’s conduct to justify officer actions.
OCR and scan errors further obscure the record. Repeated characters, fragmented lines, and unintelligible symbols reduce the reliability of the transcript. The escalation described may reflect interpretive bias by officers and witnesses rather than objective observation.
The scan ends abruptly, omitting arrest logs, citations, booking sheets, and prosecutorial notes. This absence precludes verification of claims and limits confidence in the officers’ and Bustamonte’s testimony.
In summary, the attachment provides:
- Administrative intake forms that are partially illegible and may contain template-based or inferred statements rather than verified observations.
- A narrative by Officer Brown that emphasizes alleged forward movement by plaintiff K but lacks independent corroboration.
- Bustamonte’s witness account, later contradicted by her own admission of a traffic violation, raising doubt about her credibility and reliability.
- An abrupt ending without procedural resolution, leaving critical details unverified.
Overall, this document highlights gaps and inconsistencies in the official record. While it portrays an incident with verbal escalation and aggressive conduct, later admissions by Bustamonte and the degraded, ambiguous nature of the police documentation suggest the narrative should be approached with caution. Combined use of green, red, and orange draws attention to key legal references, dates, and disputed actions for critical review.
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“In all your ways acknowledge Him & He shall direct your paths.” — Proverbs 3:6
Clean Narrative Legal Summary (Expanded ~2000 Words)
This document serves as a comprehensive litigation archive for Kok v. City of Pasadena, presenting a broad chronological arrangement of filings, amendments, motions, proofs of service, court minutes, and partial police records spanning 2000–2002. Taken together, these materials capture the procedural and narrative backbone of a civil lawsuit initiated after a February 3, 2000 interaction between the plaintiff, Philip A. Kok, and several Pasadena Police Department officers. During that encounter, the plaintiff alleges that officers used excessive physical force, applied unnecessarily painful handcuffs, ignored repeated requests to loosen them, and verbally mocked him while handcuffed inside a patrol vehicle following a minor traffic collision. The appendix reflects his efforts to obtain personnel records, photographs, complaint histories, and additional documentation for purposes of identification and pattern analysis, as well as attempts to overcome what he portrays as systemic resistance by the City and its attorneys.
The opening materials consist of various “Amendment to Complaint” forms filed under California Code of Civil Procedure §474. Initially, the plaintiff sued several unknown Doe defendants; these forms replace the fictitious names with real officers as they became known. The amended complaint substitutes Timothy Mosman for Doe 2, Bradley May for Doe 3, Henry Rosner for Doe 4, Walt Gamberale (written as “Ganeral”) for Doe 5, and Calvin Pratt for Doe 6. Later, Robert Dollar and Evangelina Bustamante are added as Doe 7 and 8. These amendments reflect the plaintiff’s progressive identification of officers allegedly present during the incident or otherwise involved in restraining him, mocking him, or failing to respond to his stated pain.
The early pages include formal proof-of-service declarations confirming that amended complaints and correspondence were mailed to the Pasadena City Attorney’s Office and individual officers. The plaintiff’s addresses include Bellflower and a Pasadena P.O. Box. These proofs follow California practice, asserting under penalty of perjury that documents were mailed via routine procedures.
Immediately following the amendments, the appendix transitions to the first major procedural filing: a Motion to Compel Pursuant to Evidence Code §1043. This July 23, 2001 motion frames the plaintiff’s request to see photographs of four additional officers—Gamberale, Pratt, May, and Rosner—to identify which officers responded to his pleas in the patrol car. The City resisted production, citing statutory “Pitchess” requirements under Evidence Code §1043. The plaintiff argued he needed only the photographs, not confidential records, asserting that identification was essential since more officers than the initial two were involved in the alleged force and verbal derision. One officer allegedly yelled, “You should have thought about that f----g earlier!” while another asked sarcastically, “You’re never wrong, are you…?”
The motion also describes the incident: after a minor accident, Officers Brown and Mosman allegedly escalated the encounter because the plaintiff was speaking “too loudly.” They struck him with a baton, forced him face-down, drove their knees into his back, forced his arm over his shoulder blade, and applied handcuffs so tightly they cut off circulation and caused intense pain. Four additional officers allegedly arrived later, two of whom mocked him. Identifying these officers is a foundational litigation issue.
The motion emphasizes prior subpoenas for photographs, the City’s insistence on a court order, and requests alternative identification methods (e.g., lineups). The filing conveys ongoing tension between the plaintiff and the City Attorney’s Office, which he asserts repeatedly obstructed discovery.
The next section is the Motion to Compel Discovery Pursuant to Evidence Code (September 4, 2001), seeking broader personnel records, including histories of complaints of excessive force or related misconduct over the preceding ten years. The plaintiff argues these records are relevant not only for identification but to demonstrate a potential pattern of deliberate indifference by the Pasadena Police Department. This has implications for municipal liability under Monell principles.
The plaintiff claims that after filing a complaint post-2000 incident, he never received confirmation of investigation results. He cites anecdotal accounts from others alleging similar negative interactions, reinforcing his claim that accessing complaint histories is necessary to determine whether the City had prior notice of misconduct.
The motion criticizes contradictory City conduct regarding medical records. The plaintiff supplied requested records; the City later objected to his request for admissions for missing attachments. After compliance, the City objected again, claiming authenticity could not be verified. The plaintiff characterizes this as baiting and delaying tactics, reflecting adversarial posture.
Another component is a subpoena for dispatch communications. The City responded that no transcript existed due to “mechanical failure.” A follow-up subpoena inquired about failure frequency; a communications supervisor allegedly said failures were rare, without specifics. The plaintiff claims he was indirectly prohibited from further discussion. He interprets this as institutional indifference or secrecy.
The plaintiff also raises belittling treatment by the City Attorney, accusing counsel of derogatory remarks about his integrity, mental health, and religious faith. He presents these as evidence of hostility and bias potentially influencing the department’s handling of complaints.
The appendix includes Court Minutes summarizing proceedings on August 22, 2001, and October 11, 2001. Judge Pluim denied one motion to compel as “overly broad,” affecting future attempts to obtain personnel records. Subsequent filings sought reconsideration.
Additional filings include Requests for Judicial Notice, Replies to Oppositions, and Responses to Motions in Limine. These illustrate attempts to introduce external records or challenge limitations placed on evidence presentation. One City motion in limine sought to restrict claims of false arrest or personnel references; the plaintiff’s responses aimed to preserve these issues.
Proofs of Service and Affidavits of Process Servers document delivery of subpoenas, amended complaints, motions, and filings to officers Brown, Mosman, Rosner, May, Pratt, Bustamante, and Dollar. These are routine but essential elements for an appellate record.
Several filings relate to Motions for Summary Judgment. Although incomplete in the excerpt, the index notes the City sought summary judgment with process server declarations attached. The motion was heard and ultimately denied, indicating unresolved factual disputes.
The appendix also references an “Alleged Use-of-Force Policy” listed as Exhibit 104 during a three-day trial. While the content is not reproduced, it is relevant to establishing departmental standards and evaluating the plaintiff’s excessive-force allegations.
Finally, the document includes a partially reproduced Pasadena Police Department Crime Report. It lists incident classification, location, officer names, badge numbers, the plaintiff’s identifiers, vehicle details, and dispatch codes. Brown and Mosman’s presence is corroborated. The narrative is minimal or absent in the excerpt; the last visible fragment is “GANG AFFILI”, suggesting additional sections were omitted.
Taken together, the appendix forms a procedural mosaic illustrating not only the alleged events but also the plaintiff’s multi-year efforts to obtain necessary records. His filings portray a system resistant to transparency, while the City’s responses and judicial rulings demonstrate legal constraints and standards for personnel-record requests in California. The cumulative effect is a detailed portrait of contested discovery, disputed conduct, and a broader struggle over narrative and institutional accountability. Despite terminating mid-report, the preceding material thoroughly depicts the plaintiff’s litigation strategy, grievances against the police department, repeated statutory invocations, and evolving identification of officers alleged to have used excessive force.
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“The Lord gives wisdom; from His mouth come knowledge & understanding.” — Proverbs 2:6
Version #2 — Tighter Legal Brief (≈2000 Words)
This document serves as a consolidated litigation record in Kok v. City of Pasadena, reflecting key filings, amendments, discovery motions, judicial minutes, and law-enforcement records generated between 2000 and 2002. The appendix documents the plaintiff’s efforts to identify officers, obtain critical personnel and complaint-history information, overcome discovery resistance, and present evidence supporting claims of excessive force and departmental indifference. It provides a structured timeline illustrating both the plaintiff’s strategy and the procedural responses by the City of Pasadena and its police department.
The record begins with formal Amendments to Complaint pursuant to California Code of Civil Procedure §474. These amendments replace “Doe” placeholders with identified officers as they became known. Over six filings, the plaintiff identifies Timothy Mosman, Bradley May, Henry Rosner, Walt Gamberale (referred to as “Ganeral”), and Calvin Pratt, eventually adding Robert Dollar and Evangelina Bustamante. Each amendment is signed under penalty of perjury and accompanied by proofs of service to the City Attorney and officers, formalizing the transition to a fully identified roster of defendants allegedly involved in the plaintiff’s detention and the acts giving rise to the lawsuit.
The first significant discovery submission is the Motion to Compel Compliance with Discovery Pursuant to Evidence Code §1043, filed July 23, 2001. The motion challenges the City’s refusal to provide officer photographs. The plaintiff asserts that after a minor traffic incident on February 3, 2000, Officers Brown and Mosman escalated the encounter using physical force—striking him, forcing him to the ground, driving knees into his back, and applying handcuffs causing severe pain and loss of circulation. Additional officers arrived; two allegedly taunted him, ignored requests to loosen handcuffs, and verbally derided him with statements such as “You should have thought about that f----g earlier!” and “You’re never wrong, are you?” Identification of these officers is necessary to ensure all responsible individuals are named. The City’s refusal, premised on statutory personnel-record requirements, prompted the plaintiff to seek judicial intervention.
The September 4, 2001 Motion to Compel Discovery extends beyond officer photographs, seeking personnel files and historical complaint data relevant to allegations of excessive force or misconduct. The plaintiff argues that the City’s failure to investigate his complaint or communicate findings demonstrates departmental indifference. He references anecdotal reports from other individuals as informal evidence of a broader failure to address citizen complaints.
Medical-record discovery presented additional complications. Although the plaintiff supplied requested medical records, the City objected to subsequent requests for admissions for missing attachments and later questioned the authenticity of the same records. The plaintiff interprets this as bad-faith obstruction hindering efficient discovery.
Dispatch communications also illustrate obstruction. A subpoena for the February 3 incident transcript returned a “mechanical failure” response. A follow-up subpoena sought failure-frequency data; the communications supervisor indicated failures were rare but provided no figures and later refused further discussion. The plaintiff interprets this as resistance to transparency.
The plaintiff also cites disparaging remarks by the City Attorney regarding his integrity, mental health, and religious background. These illustrate a hostile climate and support the plaintiff’s contention that discovery was resisted in a manner inconsistent with neutral litigation.
Court Minutes summarize judicial rulings. An August 22, 2001 minute order reflects discovery hearings; October 11, 2001 minutes show Judge Pluim denied a motion as “overly broad,” providing context for repeated plaintiff efforts to refine requests for personnel and complaint records. Additional minutes track preliminary rulings and procedural steps, including amendments and proofs of service.
Motions for Reconsideration, Responses to Motions in Limine, and Requests for Judicial Notice document disputes over evidence admissibility, internal police policies, and City attempts to limit claims. For example, a motion in limine sought to strike false-arrest allegations or restrict references to personnel information; the plaintiff responded defending his right to present such material. Judicial Notice requests challenged opposing counsel’s credibility or ethical behavior, suggesting justification for heightened scrutiny. Although not every document is included, the appendix provides sufficient context for the persistence of evidentiary disputes.
The February 19, 2002 Motion for Summary Judgment, partially included, contains declarations from process servers Shelly Peutet and Nils Grevillius. The motion was denied on April 29, 2002, indicating unresolved factual disputes precluding judgment as a matter of law. Limited personnel or complaint records may have contributed to this outcome.
Exhibit 104, an Alleged Use-of-Force Policy referenced during a three-day trial, highlights the relevance of departmental standards. Evaluating officer conduct relative to policy helps establish whether municipal liability or deviation from standard procedures occurred.
Proofs of Service confirm procedural compliance, documenting delivery of motions, amended complaints, responses, and subpoenas to the City Attorney, the department, and individual officers. These are essential for appellate review and demonstrate that the plaintiff consistently followed formal channels.
The appendix concludes with a partially reproduced Pasadena Police Department Crime Report. Visible entries include officers, badge numbers, appellant identifiers, and vehicle details. Brown and Mosman’s presence is corroborated. Other officers match amended complaints and discovery motions. The narrative is truncated, ending with “GANG AFFILI”, suggesting additional administrative or classification fields would normally appear.
Overall, this tighter legal brief emphasizes procedural trajectory, the plaintiff’s attempts to obtain essential personnel and complaint information, and his broader effort to demonstrate a City pattern of resisting discovery and minimizing allegations of excessive force. Multiple motions to compel, Evidence Code §1043 references, missing dispatch transcripts, and medical-record disputes form a cohesive picture of contested discovery and institutional defensiveness. Despite the appendix ending mid-police report, preceding contents provide a clear foundation for understanding the plaintiff’s theory of liability and procedural history.
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“The entrance of Thy words giveth light; it giveth understanding unto the simple.” — Psalm 119:130
2.3
This appendix constitutes the record material relevant to appellant Philip A. Kok’s claims against the City of Pasadena and multiple Pasadena Police Department officers arising from a February 3, 2000 use-of-force incident. Materials include amendments to the complaint, motions to compel discovery under Evidence Code §1043, supporting declarations, proofs of service, court minutes, responses to motions in limine, and a partial police crime report. Collectively, these documents illustrate the factual contours of the event, the identity of the involved officers, contested discovery, and the appellant’s efforts from 2001–2002 to obtain personnel and complaint-history information essential to litigating his claims.
The appendix begins with multiple amendments to the operative complaint, filed pursuant to Code of Civil Procedure §474. These amendments replace fictitious Doe defendants with identified Pasadena officers. Officers Timothy Mosman, Bradley May, Henry Rosner, Walt Gamberale, and Calvin Pratt are substituted as Does 2 through 6. Later amendments identify Officer Robert Dollar and civilian employee Evangelina Bustamante. These amendments reflect appellant’s progressive identification of officers via partial disclosures, court proceedings, and his own investigation. Each named individual was served through documented proofs of mailing or personal service.
The primary discovery disputes define the case. The first major filing is the July 23, 2001 Motion to Compel Compliance with Discovery Pursuant to Evidence Code §1043. It arises from the City’s refusal to produce officer photographs for identification. Appellant asserts that he was forcibly detained after a minor auto incident and that multiple officers participated in or witnessed the use of force, handcuffing, and verbal derision while he was restrained. He contends he can identify officers if allowed to view their official photographs. The City claimed such photographs constitute personnel-file material subject to statutory privilege.
The motion details the incident: Officers Brown and Mosman forcibly restrained appellant after concluding he was speaking too loudly, struck him with a baton, placed him face-down, applied body weight to his back, and affixed handcuffs causing significant pain and circulation issues. Additional officers arrived; two allegedly ignored complaints and mocked him. Identification of these officers is central to evidentiary resolution, as only access to personnel photographs could clarify who participated and in what capacity.
The September 4, 2001 Motion to Compel Discovery expands the request to personnel files and complaint histories. Appellant seeks evidence of potential patterns of misconduct or departmental indifference. After filing a formal complaint, he received no acknowledgment, explanation of findings, or indication of corrective action. He interprets this silence as systemic non-responsiveness.
Appellant references anecdotal reports of mistreatment by Pasadena officers to justify inquiry into historical patterns. Requested records include prior citizen complaints, investigations, disciplinary actions, or related materials spanning the prior decade. He consents to redaction of officer names for unrelated individuals, balancing privacy and evidentiary need.
Appellant also raises concerns about medical-records discovery. He complied with the City’s initial request, yet later requests for admissions were objected to because documents were missing. Once corrected, the City claimed authenticity could not be verified. Appellant presents this sequence as evidence of discovery gamesmanship and obstructive conduct.
Dispatch communications present additional obstacles. The City claimed no transcript existed due to “mechanical failure.” A second subpoena sought failure-frequency data; the supervisor provided vague assurances and later refused further discussion. Appellant views this as obstructive departmental conduct that hindered access to material evidence.
Appellant also describes disparaging remarks from opposing counsel questioning his integrity, mental health, and religious faith. These statements are cited as evidence of a hostile litigation environment and potential bad-faith motivations behind the City’s resistance to disclosure.
Court Minutes from August 22, 2001 and October 11, 2001 are included. The October 11 minutes note that Judge Pluim denied one motion as “overly broad,” relevant to the management of Evidence Code §1043 requests and discovery scope. These entries provide official documentation of procedural rulings.
Replies to the defense’s opposition to the Pitchess Motion, Requests for Judicial Notice, and responses to motions in limine demonstrate appellant’s effort to introduce evidence about officers’ identities, complaint histories, and investigative conduct. One motion in limine sought to strike claims like false arrest or limit personnel information references. Appellant argued that such restrictions would improperly constrain factual presentation. The Request for Judicial Notice draws attention to materials regarding the City attorney’s professional conduct.
The February 19, 2002 Motion for Summary Judgment, partially included, contains supporting declarations from process servers Shelly Peutet and Nils Grevillius. The motion was denied April 29, 2002, confirming unresolved triable issues of fact. The incomplete production of personnel and complaint records likely contributed to the court’s determination that factual issues remained.
Exhibit 104, the Alleged Use-of-Force Policy, highlights the relevance of departmental standards to officer conduct and municipal liability. Deviations or insufficient enforcement support claims of excessive force or deliberate indifference.
Proofs of Service throughout the appendix document proper delivery of all motions, amendments, oppositions, and discovery requests. Executed under penalty of perjury, they demonstrate procedural compliance and preservation of objections necessary for appellate review.
The appendix concludes with a partially reproduced Pasadena Police Department Crime Report from February 3, 2000. Visible portions list officers, badge numbers, dispatch info, appellant identifiers, and vehicle data. Officers Brown and Mosman are corroborated. The report ends abruptly at “GANG AFFILI”, indicating incompleteness and raising questions about the thoroughness of investigative documentation.
In sum, this appendix establishes a detailed procedural and evidentiary framework for appellant’s claims. It documents efforts to identify officers, obtain personnel and complaint records, and compel discovery while encountering repeated obstruction. The trial court’s rulings—denials of certain discovery requests as “overly broad” and denial of summary judgment—form the basis for potential appellate review of whether statutory standards governing personnel-file discovery were appropriately applied. Although the appendix concludes with an incomplete police report, preceding sections provide a sufficiently detailed record of contested issues, procedural rulings, and evidentiary disputes central to the appeal.
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“No weapon formed against thee shall prosper; & every tongue that shall rise against thee in judgment thou shalt condemn.” — Isaiah 54:17
2.4
This appendix presents the full set of documents, filings, amendments, motions, and administrative materials associated with the civil matter Kok v. City of Pasadena over 2000–2002. The record consists of complaints and amendments identifying officers, discovery motions seeking personnel and identification materials, proofs of service documenting notice to defendants and counsel, court minutes summarizing rulings, supporting declarations, and excerpts from a Pasadena Police Department crime report. The materials collectively show the sequence of procedural actions, contested discovery issues, and development of the factual basis for the claims.
The file begins with formal “Amendment to Complaint” documents filed under Code of Civil Procedure §474. These amendments substitute actual names for previously unidentified Doe defendants. Over multiple filings, the plaintiff replaced Doe 2 with Officer Timothy Mosman, Doe 3 with Officer Bradley May, Doe 4 with Officer Henry Rosner, Doe 5 with Officer Walt Gamberale, and Doe 6 with Officer Calvin Pratt. Additional filings identify Doe 7 as Robert Dollar and Doe 8 as Evangelina Bustamante. Each amendment affirms that the plaintiff was previously unaware of the defendant’s identity. Each is accompanied by proofs of service demonstrating that the amended pleadings were mailed appropriately.
Alongside these amendments are standardized “Proof of Service by Mail” forms, executed under penalty of perjury, stating that the relevant documents—including amendments, notices, and motions—were mailed according to office procedures. These proofs list addresses, dates, and recipients, reflecting service completed via sealed and prepaid envelopes.
The next major component is the July 23, 2001 Motion to Compel Compliance with Discovery Under Evidence Code §1043. This motion concerns obtaining photographs of four officers—Gamberale, Pratt, May, and Rosner—who allegedly arrived after the initial detention. The plaintiff argues that identification is essential because these officers allegedly interacted with him while detained in a patrol vehicle. The City required compliance with Evidence Code procedures for police personnel records. The motion describes the incident, alleging physical force, tight handcuffs, and denial of relief. Two officers allegedly taunted him through the patrol-car window. The plaintiff asserts that seeing their photographs is necessary to recognize these officers.
The narrative account covers February 3, 2000: a minor auto accident, response by Officers Brown and Mosman, and an allegation that the plaintiff was speaking loudly or agitated. Kok alleges the use of a baton and physical restraint, with handcuffs so tight that circulation was restricted. Additional officers arrived, and two allegedly made statements while ignoring complaints of pain. Identification of these officers is presented as critical to the complaint and later proceedings.
The September 4, 2001 Motion to Compel Discovery Pursuant to Evidence Code expands the scope, seeking personnel files, complaint histories, and disciplinary information relevant to allegations of excessive force over the preceding ten years. The plaintiff argues these records are essential to determine whether the Pasadena Police Department has a history of complaints and whether investigations were performed or ignored.
After filing an internal complaint, the plaintiff received no response, acknowledgment, or investigative activity. Anecdotal reports from others alleging negative interactions with Pasadena officers are cited as informal support for inquiry into historical patterns.
Medical-record procedures also illustrate inconsistency. The City initially requested records; the plaintiff complied. Later, when serving a request for medical admissions, the City objected due to missing attachments. After correction, the City claimed authenticity could not be verified. The plaintiff argues this represents obstructive behavior that hindered discovery.
Subpoenaed dispatch communications are addressed. The City claimed no transcript existed due to “mechanical failure.” Follow-ups produced vague assurances that failures were infrequent, and the communications supervisor later refused to speak further. The plaintiff interprets this as restrictive departmental conduct, highlighting potential withholding of material evidence.
Motions in limine sought to limit the plaintiff’s ability to reference false arrest claims or personnel-file evidence. The plaintiff filed multiple responses arguing such restrictions distort the factual presentation and prevent demonstration of officers’ conduct and departmental oversight.
Administrative diligence is documented via multiple proofs of service, showing notices, subpoenas, and motions were properly delivered. Some defendants failed to respond, reinforcing the plaintiff’s argument that he complied with procedural requirements while the City repeatedly avoided meaningful engagement.
The Motion for Summary Judgment filed February 19, 2002, and denied April 29, 2002, shows that triable issues remained. Factual questions were unresolved due to prior obstruction, precluding judgment as a matter of law. The City’s prior refusal to provide officer identification, complaint histories, and dispatch records contributed to the evidentiary gap.
Exhibit 104, the Alleged Use-of-Force Policy, highlights the effort to compare officer conduct with departmental standards. Deviations support claims of excessive force; inconsistencies support potential municipal liability. Without personnel or complaint histories, the plaintiff’s ability to demonstrate whether standards were followed was limited.
Proofs of Service appear throughout, confirming delivery of pleadings, motions, and other documents. The appendix concludes with a partial Pasadena Police Department Crime Report for February 3, 2000. Visible portions include classification codes, officer names, badge numbers, plaintiff identifiers, vehicle information, and administrative fields. The report confirms the involvement of Officers Brown and Mosman. The document cuts off mid-line at “GANG AFFILI”, highlighting its incompleteness.
Taken as a whole, the appendix demonstrates the plaintiff’s efforts to identify officers, obtain personnel information, compel discovery, and prepare for trial. It documents consistent disputes between the plaintiff and the City over production of personnel-file information, identification materials, and preservation of dispatch records. Judicial evaluations of discovery breadth, procedural compliance, objections, and Evidence Code interpretations are included. Although the appendix ends abruptly within the crime report, preceding sections provide a full procedural overview, illustrating how officer identification and record requests formed the litigation’s central issues.
Key takeaways: The plaintiff followed proper procedural steps, the City repeatedly obstructed discovery, critical evidence was withheld or incomplete, and judicial rulings highlight unresolved factual issues that justify trial consideration. This appendix reflects a comprehensive account of both procedural diligence and institutional resistance.
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“In all thy ways acknowledge Him, and He shall direct thy paths.” — Proverbs 3:6
2.5
The record in this appendix reveals civil litigation defined not merely by allegations of excessive force, but by a broader pattern of institutional resistance, procedural obstruction, and calculated non-disclosure by the City of Pasadena and its Police Department. Over two years, plaintiff Philip A. Kok sought fundamental information necessary to prosecute his claims—officer identities, personnel histories relevant to credibility, and dispatch or investigative records that any functioning department should routinely maintain. The City’s consistent refusal to produce these materials, combined with repeated procedural tactics, paints a picture not of an isolated dispute, but of a municipality determined to avoid transparency and shield officers from accountability.
The events of February 3, 2000 set the stage. Following a minor automobile accident, Officers Brown and Mosman responded. What should have been straightforward escalated into physical force, restraints, and verbal derision. Kok contends officers used a baton, drove him face-down, applied handcuffs tightly causing acute pain and numbness, and exacerbated the injury in the patrol car. Additional officers allegedly mocked him. These incidents raise questions of training, supervision, and departmental culture, not mere isolated lapses.
The City’s response to Kok’s internal complaint intensified concerns. He received no acknowledgment, case number, confirmation of investigation, or findings. Whether the complaint was investigated or ignored remains unknown. This absence of institutional response suggests a pattern, not oversight.
Kok began identifying responsible officers. Initially unknown, he used Doe placeholders under California law, gradually replacing them as information emerged: Mosman, May, Rosner, Gamberale, Pratt, Dollar, and Bustamante. The slow identification highlights the City’s reluctance to voluntarily disclose personnel—information ordinarily available in a professional department.
Even after names were known, Kok could not determine which officers made critical statements, ignored requests, or were present at key moments. He requested officer photographs, met with resistance, and the City claimed such images were privileged under Evidence Code §1043. A Motion to Compel was filed to obtain these photos, arguing that four additional officers’ statements, and handcuffing context, were central to the excessive-force claim.
The City’s insistence that photographs required a Pitchess motion functioned as obstruction. Routine identification became a procedural barrier. In isolation, these tactics might seem cautious; together, they demonstrate a pattern: obstruct identification, deny documents, prevent clarity, and disadvantage the plaintiff.
Kok’s September 4, 2001 Motion to Compel Discovery expanded this pattern, seeking prior complaint records and personnel information to evaluate notice of prior excessive-force allegations. Anecdotal reports of other mistreatment justified inquiry into whether Pasadena had a sustained record of citizen grievances.
The City responded with objections, procedural maneuvers, and disparagement. Counsel questioned Kok’s mental health, credibility, and religious beliefs—illustrating an adversarial approach that exceeded defense of municipal interests. When a City attorney shifts to personal attacks, it raises ethical concerns and suggests the litigation posture was hostile rather than impartial.
Conflicting positions regarding medical records further illustrate obstruction. Kok complied with requests, but when he sought admissions, the City objected due to missing attachments. When corrected, the City claimed documents could not be verified. The effect was delay, confusion, and frustration, without advancing substantive evaluation.
Dispatch communications presented a similar pattern. The dispatch transcript for February 3 was claimed “nonexistent” due to mechanical failure. Follow-up subpoenas requesting failure statistics produced vague assurances only. Direct contact with the communications supervisor was blocked. Dispatch is a core operational function; failure or refusal to provide records undermines credibility and raises the possibility of destroyed or missing evidence.
Even approaching trial, the City sought to bar reference to false arrest claims or personnel-file evidence via motions in limine, attempting to restrict the narrative presented to the jury. Kok responded repeatedly, arguing such restrictions distorted the factual presentation and prevented demonstration of officers’ conduct and departmental oversight failures.
The appendix documents procedural diligence: proofs of service, notices, subpoenas, and motions were properly delivered. Some defendants failed to respond. These administrative records show Kok followed procedures while the City consistently dodged engagement.
The Motion for Summary Judgment, filed February 19, 2002, and denied, demonstrates triable issues remained. Factual questions, unresolved due to prior discovery obstruction, precluded judgment as a matter of law. The City’s refusal to provide officer identification, complaint histories, and dispatch records contributed to this evidentiary gap.
Exhibit 104, the Alleged Use-of-Force Policy, highlights Kok’s effort to compare officer conduct with departmental standards. Deviations support excessive-force claims; inconsistent enforcement supports municipal liability. Without personnel or complaint histories, Kok was handicapped in demonstrating whether standards were ignored or unevenly applied.
The appendix includes a partially reproduced Pasadena Police Department Crime Report for February 3, 2000. Even this official record ends at “GANG AFFILI,” with missing narrative portions. Incomplete production underscores the department’s failure to document incidents fully. Police reports are foundational investigative tools; missing portions disadvantage any litigant seeking accountability.
Viewed collectively, the appendix reveals a clear pattern:
- Attempted officer identification; City resisted.
- Requested dispatch records; mechanical failure cited.
- Requested complaint histories; privilege claimed.
- Provided medical records; authenticity questioned.
- Requested photographs; Pitchess motion required.
- Attempted direct contact with personnel; blocked.
- Filed citizen complaint; no response provided.
Individually, each might appear bureaucratic; together, they reflect systematic suppression of information. Plaintiff was deprived of essential tools, while the City leveraged procedures to shelter itself.
The aggressive tone is grounded in the record. Multiple motions to compel, repeated amendments, subpoenas, and requests demonstrate that Kok’s prosecution was impaired not by lack of diligence but by the City’s strategic withholding of material facts. The appendix documents a department and municipal legal team unwilling to engage transparently, using procedural maneuvers to delay, obscure, and complicate litigation efforts.
Finally, the incomplete police report symbolizes the case: missing pieces, withheld information, and institutional refusal to illuminate the truth. The appendix is not merely litigation history; it is a record of obstruction, resistance, and systemic denial of accountability.
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