Culver City Clerk-Footage and Collective Bargaining Agreement

To Whom It May Concern:

Pursuant to the California Public Records Act, I hereby request the following records:

1. The CCPD's collective bargaining agreement(s) with any and all union for CCPD employees.
2. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the August 4, 2020 at approximately 6:00 p.m.-7:00 p.m. stop of individuals on Westbound CA-90, near the Slauson entrance ramp to the CA-90.
3. All documents identifying the name and title of the individual charged with maintaining police body camera footage
4. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports on the February 25, 2019, incident ID No. 71, wherein the CCPD used a carotid control hold on a Hispanic male.
5. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the January 25, 2019 incident ID No. 51, wherein the CCPD punched a man.
6. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the February 24, 2019 incident ID No. 70, wherein the CCPD tased a black woman.
7. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the April 24, 2019 incident ID No. 107, wherein a black, male citizen suffered head injury during an interaction with the CCPD.
8. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the May 3, 2019 incident ID No. 112, wherein the CCPD used "Pain compliance" on a black male.
9. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the May 18, 2019 incident ID No. 119, wherein the CCPD used "pain compliance" on a Hispanic male.
10. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the July 11, 2019 incident ID No. 213, wherein the CCPD used a carotid control hold on a black male.
11. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the July 21, 2019 incident ID NO. 223, wherein the CCPD punched a Hispanic male.
12. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the July 26, 2019 incident, ID No. 234, wherein the CCPD placed their hands on a male.
13. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the August 11, 2019 incident, ID No. 240, wherein the CCPD tased and punched a white male.
14. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the September 2, 2019, incident ID No. 315, wherein a male Hispanic complained of pain after an interaction with the CCPD.
15. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the September 16, 2019 incident ID No. 374, wherein a black man complained of pain after an interaction with the CCPD.
16. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the October 1, 2019 incident ID No. 384, wherein a white man complained of pain after an interaction with the CCPD.
17. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the October 18, 2019 incident ID No. 396, wherein the CCPD used "pain compliance" on a white man.
18. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the October 27, 2019 incident ID No. 423, wherein the CCPD used "pain compliance" on a Hispanic male.
19. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the December 8, 2019 incident ID No. 551, wherein the CCPD used "pain compliance" on a white man.
20. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the December 14, 2019 incident ID No. 564, wherein the CCPD used "pain compliance" on a Hispanic male.
21. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the of the December 29, 2019 incident ID No. 583, wherein a black female citizen complained of pain after an interaction with the CCPD.
22. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of Luis Martinez's shooting of Leroy Grissom.
23. All body camera, video camera, and/or dash camera footage, reports and/or findings of any and all traffic collisions from 2015 to the present, involving a CCPD employee.
24. Any report or spreadsheet showing the total number of rape cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared rape cases.
25. Any report or spreadsheet showing the total number of sexual assasult cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared sexual assault cases.
26. Any report or spreadsheet showing the total number of attempted kidnapping cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared attempted kidnapping cases.
27. Any report or spreadsheet showing the total number of homicide cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared homicide cases.
28. Any report or spreadsheet showing the total number of robbery cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared robbery cases.
29. Any report or spreadsheet showing the total number of assault cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared assault cases.
30. Any report or spreadsheet showing the total number of burglary cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared burglary cases.
31. Any report or spreadsheet showing the total number of theft cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared theft cases.
32. Any report or spreadsheet showing the total number of motor vehicle theft cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared motor vehicle theft cases.
33. Any report or spreadsheet showing the total number of arson cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared arson cases.
34. Any report or spreadsheet showing the total number of vandalism cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared vandalism cases.
35. Any report or spreadsheet showing the total number of property crimes other than vandalism cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared property crimes other than vandalism cases.
36. Any report or spreadsheet showing the total number of financial crimes cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared financial crimes cases.
37. Any report or spreadsheet showing the total number of stolen identity cases in Culver City, from 2015 to the present, and reports or spreadsheets showing the total number of solved or cleared stolen identity cases.
38. Any report or invoice showing the total amount of funds Culver City has spent on attorney's fees and costs, in defending lawsuits against CCPD employees or CCPD, between the years 2010 and the present.
39. Any report or spreadsheet, in native format, of the residence data (zip codes) of those stopped, detained, and/or arrested, by CCPD, between 2010 to the present.
40. Any report or investigation, from 2010 to the present, of CCPD's management of the Culver City jail.
41. The Complaint against CCPD, in the 2011 Davis case, case number SC110955.
42. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the incident between CCPD employees and Michael Earl Waters on November 27, 2009 at about 9:48 p.m.
43. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the incident between CCPD employees and Bryant Bracy, on or around September 16, 2020 at about 10:00 p.m.
44. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the incident between CCPD employees and Andrew Andrews, as reflected in Federal Case No. 2:14-cv-00774, Andrews v. CCPD.
45. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the incident between CCPD employees and Andreas Hernandez, as referred to in Federal Case No. 2:19-cv-01267, Hernandez v. CCPD.
46. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring at the Culver City Police Station on January 27, 2018, involving Dolly Kiosea, as reflected by her Federal Lawsuit Case 2;19-cv-02649.
47. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Sheliema Lewis, as referenced in Lewis v. City of Culver City, federal case no. 2:17-cv-07635.
48. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Bennie Dashon Story, as referenced in Story v. City of Culver City, state case No. BC525910.
49. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Gracie Thompson, as referenced in Thompson v. City of Culver City, state case No. SC110030.
50. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Terry Walton on February 4, 2017, as referenced in Walton v. City of Culver City, federal case no. 2:18-cv-02092.
51. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Alberta Jackson, as referenced in Jackson v. City of Culver City, federal case no. 2:11-cv-05258.
52. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Mary K. Jones, as referenced in Jones v. City of Culver City, federal case no. 2:11-cv-09196.
53. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the February 12, 2014 incident occurring with Gabriel Avina, as referenced in Avina v. City of Culver City, federal case no. 2:15-cv-01362.
54. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the November 8, 2008 incident occurring with Alejandro Jose Erazo, as referenced in the first amended complaint, federal case no. 2:09-cv-04029.
55. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the March 27, 2008 incident occurring with Dimitri Keyes, as referenced in Keyes v. City of Culver City, federal case no. 2:09-cv-03451.
56. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Dermot Smith, as referenced in Smith v. City of Culver City, federal case no. cv-12-3144.
57. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Douglas Pfingston, as referenced in Pfingston v. City of Culver City, federal case no. 2:13-cv-08172.
58. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, occurring from five minutes prior to CCPD employee, Carey Grant's March 10, 2018 interaction with Los Angeles Police Captain, Darnell Davenport. The videos and audio footage should last until 5 minutes after the interaction as well.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 calendar days, as the statute requires.

Sincerely,

Annette Morasch

On August 26, 2020, I requested documents which to this date have not been produced by the City. On September 11, 2020, the City responded in a 26-page letter, refusing to produce any video footage or documents concerning any use of force.

Over and over again, the City Attorney’s office stated my requests for this footage did not particularly describe the request, and that the footage is “exempt from disclosure under Government Code §6254(f),” and “SB 1421, which is codified at Penal Code §§ 832.7, or AB 748, which is codified at Government Code § 6254(f)(4).”
Many, many months ago, including on August 5, 2020, I sent an email communication to your office and the City Council, reflecting that these purported “exemptions” do not apply. See attached. I stated in part:
“As you very well know, 6254(f) has nothing to do with the requests here. Rather, 6254(f) concerns investigations conducted by, and complaints to, the Attorney General and the Department of Justice, and any state or local police agency…If we are pretending 6254 applies, the City must state, in writing, “the specific basis for” the failure to produce the requested information. Even if there is supposedly an ongoing investigation into the CCPD’s abusive handling of…[community members], the City must first show that releasing the footage would “substantially interfere with” the investigation, and the City must provide an estimated date for the disclosure of the video/audio recording. You have done neither. Mr. Perez has a right to see the body camera footage, the field investigation card, and dash cam footage, etc. This is clearly a matter of public interest. So please, state why the CCPD is not being transparent.
Also in my request, I asked for the same information concerning the CCPD’s detention of two young African American males on July 7, 2020 at approximately 10:30 or 11:00 a.m. at the U.S. Bank on Sawtelle and Sepulveda. You made the same baseless objection. If these individuals are minors, CCPD has a right to redact identifiable information, but you cannot completely withhold it. See National Lawyers Guild San Francisco Bay Area Chapter v. City of Hayward, 9 Cal.5th 488 (May 28, 2020). If these individuals are not minors, release the footage.
Moreover, the City is acting in a hypocritical manner and arbitrarily determining which body worn and dash camera footage it wants to release, likely for political purposes due to Culver City residents placing the CCPD’s actions under a microscope. The City released the footage of LAPD Captain Darnell Davenport. The City released footage of the double choking of Terry Walton. Explain, in writing, why the City is not releasing the body camera footage of the 30 minute handcuffing of a little old man riding his bicycle, and the detention of two African-American males. The City will have to release the information to me anyway in response to the discovery requests I sent over, as I am defending Mr. Perez in the CCPD’s sham citation for an infraction which you know will be dismissed.”
As I mentioned in my communication to you of today’s date in connection with a different public records act request, the Culver City community is highly engaged in racial justice, Police Chief Cid acknowledges the CCPD has a pattern and practice of engaging in behavior which disproportionately targets our community of color. A study commissioned and paid for by the City of Culver City has concluded the CCPD disproportionately targets minorities. And yet we have a City Attorney's office which says none of this is of public interest, and thus none of the information I have requested shall be produced in response to a public records act request.
Therefore, I again request the following records which your office has refused to produce, based on various, inapposite “exemptions.” The requests are specific, and I use your own identification numbers which you produced to me. You know exactly what videos I am requesting, and so your assertion that you do not know what I am talking about is ill-taken.
2. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the August 4, 2020 at approximately 6:00 p.m.-7:00 p.m. stop of individuals on Westbound CA-90, near the Slauson entrance ramp to the CA-90.
3. All documents identifying the name and title of the individual charged with maintaining police body camera footage. (The City produced an organizational chart, but did not identify the individual in charge of maintaining body camera footage.)
4. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports on the February 25, 2019, incident ID No. 71, wherein the CCPD used a carotid control hold on a Hispanic male.
5. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the January 25, 2019 incident ID No. 51, wherein the CCPD punched a man.
6. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the February 24, 2019 incident ID No. 70, wherein the CCPD tased a black woman.
7. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the April 24, 2019 incident ID No. 107, wherein a black, male citizen suffered head injury during an interaction with the CCPD.
8. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the May 3, 2019 incident ID No. 112, wherein the CCPD used "Pain compliance" on a black male.
9. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the May 18, 2019 incident ID No. 119, wherein the CCPD used "pain compliance" on a Hispanic male.
10. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the July 11, 2019 incident ID No. 213, wherein the CCPD used a carotid control hold on a black male.
11. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the July 21, 2019 incident ID NO. 223, wherein the CCPD punched a Hispanic male.
12. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the July 26, 2019 incident, ID No. 234, wherein the CCPD placed their hands on a male.
13. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the August 11, 2019 incident, ID No. 240, wherein the CCPD tased and punched a white male.
14. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the September 2, 2019, incident ID No. 315, wherein a male Hispanic complained of pain after an interaction with the CCPD.
15. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the September 16, 2019 incident ID No. 374, wherein a black man complained of pain after an interaction with the CCPD.
16. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the October 1, 2019 incident ID No. 384, wherein a white man complained of pain after an interaction with the CCPD.
17. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the October 18, 2019 incident ID No. 396, wherein the CCPD used "pain compliance" on a white man.
18. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the October 27, 2019 incident ID No. 423, wherein the CCPD used "pain compliance" on a Hispanic male.
19. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the December 8, 2019 incident ID No. 551, wherein the CCPD used "pain compliance" on a white man.
20. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the December 14, 2019 incident ID No. 564, wherein the CCPD used "pain compliance" on a Hispanic male.
21. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the of the December 29, 2019 incident ID No. 583, wherein a black female citizen complained of pain after an interaction with the CCPD.
23. All body camera, video camera, and/or dash camera footage, reports and/or findings of any and all traffic collisions from 2015 to the present, involving a CCPD employee.
38. Any report or invoice showing the total amount of funds Culver City has spent on attorney's fees and costs, in defending lawsuits against CCPD employees or CCPD, between the years 2010 and the present. (The City produced data up to July 14, 2018, but nothing subsequent to July 14, 2018. All documents from July 15, 2018 to the present should be produced.)
44. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the incident between CCPD employees and Andrew Andrews, as reflected in Federal Case No. 2:14-cv-00774, Andrews v. CCPD.
45. All body camera, video camera, and/or dash camera footage, field investigation cards, and arrest data, and/or use of force reports of the incident between CCPD employees and Andreas Hernandez, as referred to in Federal Case No. 2:19-cv-01267, Hernandez v. CCPD.
46. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring at the Culver City Police Station on January 27, 2018, involving Dolly Kiosea, as reflected by her Federal Lawsuit Case 2;19-cv-02649.
47. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Sheliema Lewis, as referenced in Lewis v. City of Culver City, federal case no. 2:17-cv-07635.
48. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Bennie Dashon Story, as referenced in Story v. City of Culver City, state case No. BC525910.
49. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Gracie Thompson, as referenced in Thompson v. City of Culver City, state case No. SC110030.
50. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the incident occurring with Terry Walton on February 4, 2017, as referenced in Walton v. City of Culver City, federal case no. 2:18-cv-02092.
(The City stated it will produce the video which has already been made public. That is not what was requested. I requested the entire video, and not just that selectively released to the public by the CCPD. The CCPD has waived any assertion of privilege by publicizing a portion of the video.)
53. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, and/or use of force reports of the February 12, 2014 incident occurring with Gabriel Avina, as referenced in Avina v. City of Culver City, federal case no. 2:15-cv-01362.
58. All body camera, video camera, and/or audio footage, field investigation cards, and arrest data, occurring from five minutes prior to CCPD employee, Carey Grant's March 10, 2018 interaction with Los Angeles Police Captain, Darnell Davenport. The videos and audio footage should last until 5 minutes after the interaction as well.
(The City stated it will produce the video which has already been made public. That is not what was requested. I requested the entire video, and not just that selectively released to the public by the CCPD. The CCPD has waived any assertion of privilege by publicizing a portion of the video.)
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 calendar days, as the statute requires.
Sincerely,
Annette Morasch
Law Office of Annette Morasch, APC
5701 W. Slauson Ave., #210
Culver City, CA 90230
annette@amoraschlaw.com
Tel: (323) 791-6276
Fax: (323) 617-5523
www.amoraschlaw.com