Attachment A

 

A copy of any and all parts of the personnel records of Officer JOHN DOE, Star XXX, which reflect any complaints, supervisory complaints or reprimands, disciplinary action, etc. related to honesty, integrity, racial bias, or conduct unbecoming an officer.

 

Included within this request are any allegations that the officer fabricated facts, evidence, events, or description of  conduct within any incident report, oral report, or testimony.

 

Also included within this request are any allegations that the officer has acted with racial animus, has used racially derogatory or insensitive terms in the officer=s contact with the public or with co-workers, has made racial slurs or jokes, or has targeted suspects because of their race, national origin, or ethnic background.

 

This request includes any allegations that the officer has acted with gender or sexual-orientation animus, has used gender or sexual-orientation derogatory or insensitive terms in the officer=s contact with the public or with co-workers, has made gender-based or sexual-orientation-based slurs or jokes, or has targeted suspects because of their gender or sexual orientation.

 

Further included in this request are all allegations of improper searches or seizures or any conduct inconsistent with the Fourth Amendment of the United States.  This includes but is not limited to arrests, stops, or seizures without cause, Apat-downs@ and searches of suspects without probable cause or reasonable suspicion, entry into residences or business without knock-notice, intrusion onto private property without a search warrant, and the use of excessive force in arrests, seizures, and searches.

 

The request includes all allegations of improper interrogation, including but not limited to failure to Mirandize suspects, failure to permit suspects to make a call, continued interrogation despite requests for counsel, and interrogation of suspects who are mentally incapable of making an informed and knowing waiver of their Miranda rights.

 

The request seeks all documents reflecting the officer=s use of controlled substances, on-duty use of alcohol, mental impairment or psychiatric impairment apparent during the performance of his duties, and allegations of inappropriate displays of anger or emotion while in the course of duty.

 

This subpoena compels disclosure of all materials described above, including information which is more than five years old, if that material or information is in the custody or possession of the recipient of this subpoena.  It compels disclosure of citizen complaints as well as documents relating to the resolution of these complaints.

 

This subpoena is not limited to only Asustained@ citizen complaints, but includes materials and information containing any of the allegations described above.