Evidence - Volume 3 - Green Earth Center v. City of Long Beach - Long Beach Medical Marijuana Raids (SACV 13-0002)

7/30/2019 Evidence - Volume 3 - Green Earth Center v. City of Long Beach - Long Beach Medical Marijuana Raids (SACV 13-0

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PLAINTIFFS EXHIBITS (VOL. 3)

MATTHEW PAPPAS (SBN: 171860)

CHARLES SCHURTER(SBN: 174261)

LEE H. DURST (SBN: 69704)

22762 Aspan Street, Suite 202-107

Lake Forest, CA 92630

Phone: (949) 382-1485

Facsimile: (949) 242-2605

Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

SOUTHERN DIVISION

GREEN EARTH CENTER, INC.; DANK

CITY PATIENTS GROUP INC.;

NATURECANN, INC.; INDUSTRY GREEN

COLLECTIVE, INC.; KAI KEM INC.;

CHRONIC COLLECTIVE; COMPLETE

ALTERNATIVE MEDICINE; PATIENTS

REPUBLIC COLLECTIVE; 562

COLLECTIVE; DEMITRI WOODARD andCHRIS WOODARD,

Plaintiffs,

v.

CITY OF LONG BEACH, CALIFORNIA;

DAVID STROHMAN; OSCAR

VALENZUELA; ALDO DECARVALHO;

CHRIS VALDEZ; DOUGLAS LUTHER; and

DOES 1 to 10,

Defendants.

No.: SACV 13-0002 AG (JPRx)

PLAINTIFFS EXHIBITS (VOL. 3)

IN SUPPORT OF APPLICATION

FOR T.R.O. AND O.S.C. RE:

PRELIMINARY INJUNCTION

Date: May 9, 2013

Time: N/A

Courtroom: D10, Judge Guilford

EXHIBIT VOLUME #3


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PLAINTIFFS EXHIBITS (VOL. 3) - II

TABLE OF EXHIBITS (VOLUME 3)

EX. #: DESCRIPTION PAGE

43 DECLARATION OF JOSE BUSTAMANTE 136

44 DECLARATION OF ADRIAN DIAZ (MAR. 8, 2013) 137

45 DECLARATION OF ADRIAN DIAZ (APR. 11, 2013) 138

46 DECLARATION OF A. GONZALEZ (MAR. 8, 2013) 140

47 DECLARATION OF A. GONZALEZ (APR. 11, 2013) 142

48 DECLARATION OF CAROLINA LOPEZ (MAR. 8, 2013) 144

49 DECLARATION OF C. SEGOVIA (APR. 11, 2013) 146

50 DECLARATION OF CLAUDIA PARRA (OCT. 31, 2012) 148

51 DECLARATION OF EDGAR SANCHEZ (MAR. 8, 2013) 150

52 DECLARATION OF MCCABE KAINOA (APR. 11, 2013) 152

53 WARRANT FOR SEARCH AND SEIZURE

CONDUCTED OCTOBER 4, 2012 (FOURTH ST. COLL.)

156


CONDUCTED MARCH 5, 2012 (FOURTH ST. COLL.)

164


CONDUCTED APRIL 12, 2013 (FOURTH ST. COLL.)

171


CONDUCTED APRIL 23, 2013 (FOURTH ST. COLL.)

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CONDUCTED OCTOBER 31, 2012 (WILLOW COLL.)

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PLAINTIFFS EXHIBITS (VOL. 3) - III

58 DECLARATION OF YVONNE SCHAFFER 195

59 DECLARATION OF JUAN HUIZAR 197

60 DECLARATION OF MARK MALAN 199

61 LONG BEACH WARNING THAT WATER WILL BE

SHUT-OFF TO FOURTH STREET COLLECTIVE

201

62 DECLARATION OF LARRY PARKS 202

63 LETTER FROM ATTORNEY MATTHEW PAPPAS TO

ATTORNEY PAUL VIOLAS RE: FOURTH STREETCOLLECTIVE MANAGING PATIENT LARRY PARKS

205

ADDITIONAL EXHIBITS ARE INCLUDED IN VOLUMES 1, 2, 4, 5, 6, & 7


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EXHIBIT #43


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DECLARATION OF JOSE BUSTAMANTE

1. I, JOSE BUSTAMANTE, declare as follows:

2. I am a resident of Los Angeles CA.

3. I volunteer at the 4th St. Collective

4. On March 5th, 2013 the Long Beach Police Department slammed

through our front door rushing into the second where they all

had weapons drawn pointing them at us. They demanded we open the

last door. As we opened it they rushed the security guard by

putting a handgun to his face and forcing him to the floor. The

second officer ran to me with a shotgun screaming to get on the

floor. As I got on the floor they handcuffed me and all of theother volunteers and patients in the room. They sat us on the

floor while they integrated the patients. They then brought in a

volunteer in from outside that was going home . They then stated

to take one by one out side so the undercover could verify us .

They then interrogated us and asked questions as they placed us

one by one in police cars. They then began to take us to the

station.

I declare under penalty of perjury under the laws of the State o

California that the aforementioned statement represents m

personal knowledge and is true and correct.

EXECUTED this 22nd day of October, 2012:

/S/

_____________________________________________JOSE BUSTAMANTE

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EXHIBIT #44


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DECLARATION OF ADRIAN DIAZ (APRIL, 2013) - 1

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DECLARATION OF ADRIAN DIAZ

I, Adrian Diaz, declare as follows:

1. I am a resident of Long Beach, CA.

2. I am a volunteer at The Willow Collective.

3. To whom it may concern; On March 8, 2013 LBPD rushed into The Willow Collective around

1:30 pm while I was volunteering. They came in with guns drawn very aggressively in an unlawful

manner. I was sweeping the floor when I seen the first officer get buzzed in through our secure door

yelling at the other volunteers and Patients we all put our hands up. Once I heard the officer say th

I quickly put my hands up in the air cooperating. Then the second officer behind him rushed towar

me because I was the nearest to him and forcefully threw me up against the wall handcuffing me rig

away. After the handcuffs were on the officer started screaming in my face asking me how long I've

been volunteering and also stated that I was going to a prison for a very longtime. When he told me

that I clearly stated to him that I was practicing my Fifth amendment rights and that I wasn't

comfortable answering any questions till my lawyer was present. That's when he took me to the lobb

to sit me down and take my information. He then took my id from my pocket with all my info on it

and started to question me after I stated that I was remaining silent. The officer asked me basic

questions like whats my name ? and address? and I just replied all my info is on my id and stood

silent. After that he kept harrassing me trying to get me to talk but I just stood quiet and then he state

out loud " OH YOU'RE ONE OF THOSE FUCKING GUYS". I felt like my rights were being

violated. Then they placed me in the back of one of the vehicles with two other volunteers with no

seat belts. On the way to the station I didn't feel safe the officer was speeding a little while on his

phone not keeping his eyes on the road. During the whole process I felt as of all my rights were

completely thrown out the window.

I declare under penalty of perjury under the laws of the State of California and United States that the

aforementioned statement represents my personal knowledge and is true and correct.

DATED: April 23, 2013

___________________________________________Adrian Diaz

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EXHIBIT #45


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DECLARATION OF ADRIAN DIAZ

1. I, Adrian Diaz, declare as follows:



4. To whom it may concern; On April 11th, 2013 LBPD burst into The

Willow Collective around 2:30pm in a disrespectful and unlawful

manner with guns drawn while I was volunteering. As the officers

were busting into the collective our security guard mentioned on

the walkie-talkie that we were getting raided. So knowing ahead o

time before the officers were inside I had already put my hands ithe air. Once the officers got inside they came in screaming for

all of us to put our fucking hands up and swearing a few other

words. Then they quickly put the handcuffs on me tight using

excessive force. I knew that I wasn't doing anything wrong becaus

I was cooperating with them they were being really disrespectful

and rude from the start. After that they sat me down and thats i

when one of the cops in uniform recognized me from the previous

raid and stated a little remark " you haven't learned your lesson

while laughing with other officers. Then one of the detectives in

street clothes took a patient that they had in custody and I to

the back outside in the alley for about 20 sec without saying

anything to us. I'm guessing they were trying to identify us or

take pictures of us but it seemed a bit weird. After that they

placed me in the backseat of a vehicle with another volunteer and

again with no seat belts I didn't feel safe on the ride to the

station. The officer was on his phone the whole way there. Then

after the officers finished booking me and were about to hand me

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over to the correctional officers a detective approached me to

read me my rights and tell me why I was being arrested.

I declare under penalty of perjury under the laws of the Statof California and United States that the aforementioned statemen

represents my personal knowledge and is true and correct.

EXECUTED this 23RD day of April, 2013:

___________________________________________Adrian Diaz

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EXHIBIT #46


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DECLARATION OF ALEJANDRO GONZALEZ (APRIL, 2013) - 1

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DECLARATION OF ALEJANDRO GONZALEZ

1. I, Alejandro Gonzalez, declare as follows:


3. I am a volunteer at The Willow Collective located at 72

W. Willow St. Long Beach Ca.

4. I was present at The Willow when it was raided by the

LBPD on Friday, March 8th 2013. It was between 1:20-1:30pm

when I was sitting at the front check-in window talking with

my friend Carolina when all of a sudden the police burst

through the front door into the waiting area flashing a

warrant and with their guns drawn and pointed at us, demandin

to get in through the second door or they would break the

door down. We were all being very cooperative. We faced the

wall and put our hands on our head before they even told us

to. They cuffed all five of us very tightly and with

excessive force and placed us into the front lobby. Once

we were all secured, all the officers were joking around

and talking down at us and calling us low-life drug dealers.

They brought us back one-by-one for questioning. The

detective asking me questions and reading my rights was

Detective Strohman. When I refused to answer Strohmans

questions and referred him to my lawyer, he gave me a dirty

look and then took me back to the lobby. After attempting to

question the rest of the detained he told us out loud that w

will be forced to sign a stay away order that came with a

three year probation. He said if we didnt sign it we would

be facing jail time. I was taken away with two others in

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EXHIBIT #47


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DECLARATION OF ALEJANDRO GONZALEZ

1. I, Alejandro Gonzalez, declare as follows:

2. I am a resident of Long Beach, CA.3. I am a volunteer at The Willow.

4. It was Thursday, April 11th 2013 around 2:20 to 2:30 pm. I was in the front

check in room and heard the walkie-talkie utter words very quickly. The next thing I

know, my buddy said we are being raided then the cops burst in the door with weapons

drawn yelling for us to put our hands up. They presented the warrant to the check in

window, so therefore they were allowed in guns drawn made us face the walls put our

hands behind our backs, then one by one they put on cuffs very tightly on each of us, then

walked us to the lobby where we had no vision of what they were doing, Then one of the

taller detectives in regular clothing walked three of us to the back as if he had somebody

identify us from a distance and he told me" i recognize you, you are on the stay away

order your fucked now" and i responded " I am under no stay away order what so ever i

did not sign anything" he responded almost yelling i will make sure your are this time "

and got all up in my face! Then they took us back to the front during so you could hear

that they started to tear the place up i have some pictures from when i returned they mad

a huge mess counters moved everywhere, phone and internet wires disconnected broken

jars on the floor, broken glassware as well, there was about five to six uniformed officer

and about 4 detectives in regular clothing, the whole time these police officers were jokin

around after they had secured us in cuffs, were making rude remarks about how they hav

seen us before, and that we do not learn our lessons, they were raising their voices as wel

they took 2 of the volunteers first, along with a member of ours, they had my security

guard outside, then they took about an extra half hour with me and my friend carolina

hand cuffed, they read three of us our rights, then tried to question us one by one, i did no

respond to any questions i told them to speak to my lawyer, i requested my single vehicle

key along with its key chain about 5 different times the subject was changed about 4 time

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and the 5th time, was when we were exiting the store about to be put in the vehicle i aske

again and they said no in a loud tone of voice, that they were not in my possession. then

they took us to the station and we were booked. they handled this arrest and raid very

poorly with no respect what so ever towards us, it was very unprofessional.

I declare under penalty of perjury under the laws of the State of California and Unite

States that the aforementioned statement represents my personal knowledge and is tru

and correct.


_____________________________________________

Alejandro Gonzalez

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EXHIBIT #48


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DECLARATION OF CAROLINA LOPEZ (APRIL, 2013) - 1

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DECLARATION OF CAROLINA LOPEZ

I, Carolina Lopez, declare as follows:



3. To whom it may concern

This is a statement describing my experience during two unlawful raids that occurred

on Friday March 8, 2013 and Thursday April 11, 2013.

On Thursday March 8, 2013 Long Beach PD busted into Willow Medical Solutions at

approximately 1:30pm demanding to be buzzed into the facility. Perhaps they had a signed

warrant; however I never saw it. They came through the security doors with guns drawn an

then came around the counter and instructed all of us to place our hands on our heads. A

Caucasian officer aggressively slapped on a pair of handcuffs tightly on my wrists. He then

grabbed me by my arm and led me to the patient lobby where they had four more voluntee

waiting in hand cuffs. The Sergeant stated that we where all going to have restraining orde

against us from the facility after we get bailed out. The officer who wrote down my

information was rude and disrespectful demanding me to give him my ID number and

personal information. When I refused to respond he replied "what, are you dumb too?! "

They looked through all of my belongings without asking for my consent" While I was waitin

in the lobby I could hear them rambling through all of the merchandise and looking to findhidden objects to confiscate. When we arrived to the booking facility I witnessed an officer

looking through Alejandro Gonzalez phone demanding for him to say his IPhone password

in order to turn it off. Alejandro responded that he could turn it off with out the password and

the officer furiously responded that he would use it as evidence. If I could briefly describe

the experience I would say it felt like a robbery by men in uniform because we returned to a

destroyed dispensary with all funds and merchandise gone and tape placed over our

surveillance cameras.

On April 11, 2013 Long Beach PD made a forceful entrance into Willow for the second time

at 2:30pm. Once again they demanded to be buzzed into the facility. The officers once

again came through our security doors with guns drawn and aggressively yelling instruction

for us to put our hands on our head just as they did the last raid, only that this time they had

three of us go to the back where an SUV was parked. The Sergeant asked if we where on

stay away, when we responded that we were not he stated that he would make sure we go

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DECLARATION OF CAROLINA LOPEZ (APRIL, 2013) - 2

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restraining orders from the facility this time around. We where then led to the lobby while

they took down our information. They selected three volunteers to be taken to Jail

immediately and I waited with Alejandro in the Lobby. An officer pulled me aside to read me

my Miranda rights and asked me how long I had been working at Willow and if I knew the

owner. After refusing to respond he told me to return to the lobby. I saw the officers going

through the register and collecting all of the merchandise. From the lobby I could hear their

disappointment; they could not find any hidden merchandise. After a few minutes I heard a

officer shout! "Ha Bingo! Display Cases, just like any other drug dealer. The only reason I

could imagine that willow has hidden items is because of the Unlawful raids that continue to

occur. I was never really told what it is that I am doing that is Illegal, the only thing I was tol

by the Officer was "you know what you are doing is illegal, now go sit down". Overall I woul

describe both raids as a traumatic experience because I was treated as a criminal and

aggressively detained.

I declare under penalty of perjury under the laws of the State of California and United State

that the aforementioned statement represents my personal knowledge and is true an

correct.


_____________________________________________Carolina Lopez

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EXHIBIT #49


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DECLARATION OF CHRISTOPHER ARTURO SEGOVIA (APRIL 2013)- 1

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DECLARATION OF CHRISTOPHER ARTURO SEGOVIA

I, Christopher Arturo Segovia, declare as follows:


2. I am a volunteer at The Willow.

3. It was Thursday 4/11/13 between 2:20 and 2:30pm. I was tending to a patient when

I heard raid on the radio. I stopped what I was doing and waited for LBPD to walk in. We

buzzed them in right away. With their guns out and pointed at the volunteers and patients w

were told to put our hands in the air. Already with my hands in the air, the officer starts to

search me and asks, " do you have any guns or grenades?" My response was unless we ar

in Iraq. I was arrested and took to the back of the dispensary to be asked if I have been

served? After the question I was taken to the lobby of the dispensary. That's when the

officers took down my info as well as the other volunteers. While taking down our info I

hear the detective and the other officers moving things around. I heard them making fun

of us. I would say it was four officers in uniform and two detectives not in uniform. They

didnt have enough cars for all of us to get booked at the same time. Adrian and I go in on

car in the back seat. I asked the officer to put my seatbelt on so Id feel safe but only

received a smart remark in response by the officer. I thought it was police officers job to

protect and to serve. So not only did I not feel safe without my seatbelt on but the office

was also swerving while driving while trying to run some license plates while driving.

During the ride I asked, " why did you guys not come with your whole team?" The officer

replied, " it was a low-key raid. " At booking its just Adrian and I. After about a half an

hour of being there the detective came and called out my name. He pulled me to the side an

quietly read me my rights. I believe he did this quietly because I was supposed to be read

these before I am actually arrested. He tried asking me question but I replied by saying

talk to my lawyer. On the way upstairs the other volunteers arrived about an hour after

Adrian and I got into the station. When upstairs one out the four officers in uniform stared

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EXHIBIT #50


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DECLARATION OF CLAUDIA PARRA (APRIL, 2013) - 1

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DECLARATION OF CLAUDIA PARRA

I, Claudia Parra, declare as follows:

1. I am a resident of Los Angeles County, CA.

2. I am a volunteer at The Willow

3. The Willow was raided on April 4th, 2013.

4. It was Wednesday, on October 31st around 12:30p.m. I was

volunteering at Willows Collective dispensary in Long Beach,

CA along with 3 other volunteers. While in the process of

helping out a patient, I glanced to the cameras/monitors and

saw a number of people, a majority of whom were in casual

clothing, rush into the dispensary through both entrances. I

stopped helping out the patient immediately and froze up,

because I didnt know what to do at the moment. The men walke

in and pointed their guns at us and told us to put our hands

up. From what I remember, they identified themselves as polic

officers. Afterwards, they put the volunteers in handcuffs an

searched each of us individually. They proceeded to move

everyone to the waiting room, as well as the patients and the

security guard. After a couple of minutes they allowed the

patients to leave, but kept the volunteers and the security

guard waiting for approximately 30 more minutes. Then one by

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DECLARATION OF CLAUDIA PARRA (APRIL, 2013) - 2

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one a private investigator called us to the next room to

question us. After questioning us they took us all in to the

Long Beach City Jail.

I declare under penalty of perjury under the laws of the Stat

of California and United States that the aforementioned

statement represents my personal knowledge and is true and

correct.

EXECUTED this 24th day of April, 2013:

___________________________________________Claudia Parra

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EXHIBIT #51


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DECLARATION OF EDGAR SANCHEZ (APRIL, 2013) - 1

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DECLARATION OF EDGAR SANCHEZ

I, Edgar Sanchez, declare as follows:


2. I am a volunteer at The Willow.

On Friday, March 8, 2013 at approximately 1:30 in the afternoon I was approached b

officers from the Long Beach Police Department who entered through Willow Street

with their guns drawn and proceeded to arrest me at a legal marijuana dispensary in th

City of Long Beach. I stood by my right to remain silent as they took me to the back

door where the officers made a phone call. The conversation was about me and it

seemed as though someone had pointed me out. The detectives, in particular, had

claimed that I was going to be forced to sign a "stay away order" stating that I could

not be within 200 yard of a medical marijuana dispensary, implying that I had no

choice. At approximately 1:45, I was taken into jail where I spent the rest of the day

until my bail was paid and was not released until 10:20pm.

My experience was an unpleasant one, considering that my treatment was that of an

immoral criminal. I did not feel as though my punishment was justified and felt my

stay in jail was uncalled for. Furthermore, having a loaded weapon pointed in my fac

was completely uncalled for, especially since I did not have a weapon on me, nor did

resist arrest, or make any threatening gestures at anytime to any of the officers. The

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DECLARATION OF EDGAR SANCHEZ (APRIL, 2013) - 2

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situation could have been handled in a more professional matter without the

overabundance of loaded firearms.

I understand that there are some protocols to be followed, but given the compliant,

non-threatening nature of my/our reaction, the police, in my opinion overreacted and

put our safety and lives in danger.

I declare under penalty of perjury under the laws of the State of California and United

States that the aforementioned statement represents my personal knowledge and is tru

and correct.

EXECUTED this 23RD

day of April, 2013:

_____________________________________________

Edgar Sanchez

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DECLARATION OF MCCABE KAINOA (APRIL, 2013) - 1

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DECLARATION OF MCCABE KAINOA

1. I, McCabe Kainoa, declare as follows:

2. I am a resident of Long Beach, CA.3. I am a volunteer at The Willow Collective located at 726 W. Willow St. Long Beach

Ca.

4. To whom it may concern, on April 11th, 2013, while I was outside in the front of the

collective talking with a patient's passenger from his car, I noticed in the corner of my eye

at least 6 police in raid gear and helmets. I immediately got on the radio to warn the

volunteers on the inside that we were about to get raided. After I shouted "raid raid raid!!

Were getting raided!" Into the radio I put my hands up and one of the cops had his gun in

my face and he said, "You think its real fuckin funny to warn them the boys are coming

dont you!" He then told me to get on the ground and as I was lowering to my knees he

kicks me in the back of my knee causing me to slam my knee on the ground and break

open the wound from a previous surgery on my leg. (See attached photos as further

exhibits A & B.) This wound would later get infected while I was in jail. He then said, "Pu

your chest on the ground and hands out in front of you," then he handcuffed me behind my

back and started violently ripping my belongings out of my pocket throwing them around

As he was doing that he was telling me Im going to spend the weekend in jail and Im

being charged with additional charges. At his point he stood next to me kicked me hard

into my upper thigh. The same officer then saw my car keys and said, "Oh you have a

Cadillac? How nice then he looked at his partner and yelled tow it!" Then looked at me an

smiled. Then I saw a man walking up to the shop with a confused look on his face and I

told him were getting raided not to go in and he smiled and pulled out a badge and said

"good job buddy for warning them we were coming, " and walked by me and slammed hi

hand on top of my head twice and said if I act like a donkey their going to treat me like a

donkey, thats why Im spending the most time in jail. He then walked in the collective an

the cop who first approached me and slammed me to the ground came back out as I was

now sitting on the concrete handcuffed and he was telling me Im going to be on a list to

not be allowed anywhere near a dispensary in long beach. Then another undercover came

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I

that the

_

out of th

in the ba

so they t

for a patr

us to the

declare un

forementi

XECUTE

_________

cCabe Kai

DEC

collective

k of a poli

en put Car

ol car to ge

booking ro

er penalty

ned statem

this 23RD

________

noa

LARATION O

and read m

e car. They

lina and A

there for

m and boo

of perjury

nt represen

ay of Apri

________

F MCCABE K

my Miran

didnt eve

ex in the b

e and they

ed us.

nder the l

ts my pers

l, 2013:

________

AINOA (APR

da rights as

bring eno

ck of anot

placed me

ws of the

nal knowle

_______

L, 2013) - 2

they were

gh cars to

er police c

n the front

tate of Cal

dge and is t

utting Chri

ake us all t

r and they

seat and th

ifornia and

rue and cor

s and Adri

the statio

then waited

n they took

United Sta

rect.

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EXHIBITS A & B

Exhibit A photo was taken by a friend of mine on April 14th

Exhibit B photo was taken by a friend of mine on April 17th

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MATTHEW S. PAPPASA T T O R N E Y

24611 SPADRA LANE(949) 371-7811 MISSION VIEJO, CA 92691 LEGAL ASSISTANT:

[email protected] DIVINA MAGARIFUCHI

August 24, 2010

VIA E-MAIL AND FIRST CLASS MAIL

Mr. Paul Violas

Attorney

100 Oceangate Ste 1200Long Beach, CA 90802

Re: Long Beach Medical Marijuana Ordinance 10-0007

Dear Paul:

Ive talked with my dad regarding the phone conversation he had with you last week. Several

months ago, I read a caustic unsolicited email sent by you to him.

First, my goal in regard to the medical marijuana issue is to ensure disabled and seriously ill

people who have been recommended medical marijuana by a physician have access to that

medication. While patients who have been prescribed drugs like Vicodin and Oxycontin are able tohave their prescriptions filled without worrying about police raids, arrests and inconsistent access,

medical marijuana patients are not so fortunate. Since 1996, medical marijuana patients have beenarrested, jailed, raided, and regularly worry about whether medication is available simply because

the medication they use is effective for them instead of more dangerous drugs. After nearly fifteen(15) years, these barriers continue to hamper patients. After countless legal and political efforts,

the disabled and seriously ill people who use medical marijuana to treat their conditions, many of

whom have, over the same period, died from cancer and other sicknesses, are still faced with policeraids, efforts by the cities to treat them differently, arrest, detainment, and a host of other obstacles.

Im writing because Im concerned about a comment you made to my dad in the abovereferenced phone conversation you had with him last week. Specifically, the comment that you

have contacts in City Hall and that you are not worried about eventual approval of your clients

application. Normally, I would not spend any time on the kind of baseless threats and commentshurled at me like those included in your first unsolicited email to my dad. I certainly think he

should have responded and I support his response -- especially in light of the threats of lawsuit and

State Bar complaints you included. Your attack and threats were certainly not the first Ive

received while working on behalf of the disabled and seriously ill. However, the comment youmade to my dad about having contacts in City Hall concerns me because there are thousands of

patients that belong to collectives that do not benefit from the type of special relationship

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Mr. Paul Violas

August 24, 2010Page Two

that apparently will ensure approval of your clients license application. I understand the vitriol

and positioning by attorneys that would prefer to maintain thestatus quo in order to keep extensive

and continuous medical marijuana related business flowing. I represent disabled plaintiffs in a case

that seeks to eliminate the vague rules and policies that provide this continuous flow of civil andcriminal cases for a number of lawyers. Naturally, those attorneys will do all they can to creatively

thwart our efforts and Im not going to deviate or lose focus as a result of rumors, attacks and

threats. However, if people have special political influence because of contacts or through othermechanisms, then it is not only appropriate but very necessary for me to address potential foul play.

If you are aware of any inappropriate influence peddling or special treatment by elected oradministrative officials, I believe you must notify state or federal authorities. If you are involved in

this kind of thing if the contacts are yours -- Im very concerned. On the other hand, there may

be some prohibition in terms of reporting because of the attorney-client privilege. Im researching

what my duties are in regard to this situation. It is very disconcerting that there is even anindication that something is awry in this area when such behavior affects people who are dying,

seriously ill or disabled.

Again, I am used to untrue statements made by people about me including rumors that I have

been disbarred twice, that I have been subject to continuous bar discipline, and that Ive been

disbarred in other states. Ive been subjected to attacks in the media alleging my clients case isfrivolous and that the subject matter was already decided many times. I have been threatened by

city politicians as well as by lawyers. I expect those kinds of comments, innuendo, threats and

rumors. I did not expect to hear that special political access is being used in a way that ensures one

group of patients will have access while other groups will be denied.

Please clarify what special access and relationships exist in City Hall that will ensure license

application approval?

Thank you for your attention to this matter.

Very truly yours

Evidence - Volume 3 - Green Earth Center v. City of Long Beach - Long Beach Medical Marijuana Raids (SACV 13-0002)

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