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Adelman, Page 1
April 10, 2015
Dallas Police Department Office of Internal AffairsJack C. Evans
Building1400 S. LamarDallas, Texas 75215
This letter shall serve as my formal and official complaint
against a number of Dallas Police Department officers for their
actions on March 27, 2015, approximately 4pm, at the scene of the
officer down incident on the Santa Fe Trail in East Dallas.
The officers engaged in unprofessional conduct by taking actions
to prevent this Correspondent from taking photographs of the
emergency care of the down officer, either through verbal orders,
physical intimidation, threats to arrest and other harassing
activities. this is completely unacceptable by any stretch of the
imagination or legal actions.
Each officer engaged in an activity which violated this
Correspondents First Amendment right to freedom of the press
(collecting information on a news event), as well as violated
various Dallas Police Department General Orders regarding contact
with the public, crime scenes and public access to police
activities. Some officers issued orders to others which in and of
themselves were illegal and should have been disregarded by the
officers.
The names of these officers are unknown. The attached summary of
actions includes photographs of these officers (identified by
nicknames or other descriptions). A complete set of the nearly 100
photographs taken at the incident by this Correspondent is included
on the enclosed DVD.
If you have any questions, please do not hesitate to contact
me.
Regards,
Avi S. Adelman5620 East Side AvenueDallas TX 75214
[email protected]
214-923-3562
cc Mickey H. Osterreicher, General Counsel National Press
Photographers Association
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Adelman, Page 2
Summary of events
On March 27, 2015, at approximately 4 pm, Correspondent was
listening to a police scanner, when he heard a report of someone
having a medical emergency on the Santa Fe Trail near Henderson
Avenue.
This report included an Assist Officer comment, and a comment We
need an ambulance here right now!
Correspondent lives approximately three blocks from this
location. He immediately grabbed his camera and camera bag, and
went to the scene.
On his arrival, he parked his vehicle about 500 feet from the
scene and ran up the berm towards the incident.
This series of photographs includes commentary describing
approximately what was said by the officers, or a description of
their actions. It is not a verbatim repitition of statements made
by the officers.
Avi S. Adelman
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Adelman, Page 3
Photo 1258, 401pm, March 27th
This photo was shot from about 300 feet from the scene.
Note that two officers - the female on the left and the black
male standing close to the squad car - are waving their hands at
the photographer, indicating he was not to approach the scene.
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Adelman, Page 4
Photo 1263, 401pm, March 27th
Upon arriving at the trail path, two officers are continuing to
approach Correspondent. The female officer was in the first
photogaph.
The second bicycle patrol officer is standing next to the black
officer, pointing towards the photographer.
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Adelman, Page 5
Photo 1270 402pm, March 27th
This officer knows Correspondent by name from his work on Lowest
Greenville Avenue.
The officer verbally instructed Correspondent, by name, to stop
taking photographs and to leave the area immediately.
This order was repeated at least twice.
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Adelman, Page 6
Photo 1280 402pm, March 27th
The white male officer leaves, to be replaced by another black
male officer (nickname Rugby Player).
Rugby Player was the most hostile of the officers on the scene.
He verbally harassed Correspondent, stood directly in front of the
camera, and followed Correspondent as he walked to his vehicle with
notebook in hand in an attempt to collect personal information
about the Correspondent.
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Adelman, Page 7
Photo 1293, 402pm, March 27th
Prior to this photograph, Correspondent had been told by another
officer to not cross an imaginary boundary indicated by a crack in
the sidewalk on the path (a legal order). This boundary was
approximately 100 feet from the incident.
Correspondent then walked down the berm in order to walk around
the scene, still staying at least 100 feet away.
The Rugby Player than followed Correspondent down the berm and
around the path.
The white male officer pointing at Correspondent again repeated
his order to stop taking photographs. The Bicycle Patrol officer,
identified as Earnest Sherman, was telling someone (not sure whom)
to keep the Correspondent away from the scene.
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Adelman, Page 8
Photo 1295, 402pm, March 27th
Rugby Player is getting closer to Correspondent and making some
kind of (unintelligible) comments.
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Adelman, Page 9
Photo 1296, 402pm, March 27th
Rugby Player is now standing directly in front of
Correspondent.
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Adelman, Page 10
Photo 1297, 402pm, March 27th
Rugby Player is now standing directly in front of
Correspondent.
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Adelman, Page 11
Photo 1298, 402pm, March 27th
Rugby Player is now standing directly in front of
Correspondent.
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Adelman, Page 12
Photo 1299, 402pm, March 27th
Rugby Player is now standing directly in front of Correspondent,
making comments to Correspodnent. Note Bicycle Patrol officer on
left and white male officer on right continuing to monitor
situation.
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Adelman, Page 13
Photo 1301, 402pm, March 27th
Correspondent has moved to the other side of incident
approximately same distance as first defined boundary (100 feet.)
Rugby Player begins verbal harassment of Correspondent, to wit
- Dont you have somewhere else to be??
- Why are you taking these photographs?
- You were told to stop taking photos. Why are you still
here?
(These are not exact quotes)
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Adelman, Page 14
Photo 1303, 402pm, March 27th
Correspondent has moved to the other side of incident
approximately same distance as first defined boundary (100 feet.)
Rugby Player begins verbal harassment of Correspondent, to wit
- Dont you have somewhere else to be??
- Why are you taking these photographs?
- You were told to stop taking photos. Why are you still
here?
(These are not exact quotes)
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Adelman, Page 15
Photo 1305, 402pm, March 27th
Correspondent has moved to the other side of incident
approximately same distance as first defined boundary (100 feet.)
Rugby Player begins verbal harassment of Correspondent, to wit
- Dont you have somewhere else to be??
- Why are you taking these photographs?
- You were told to stop taking photos. Why are you still
here?
(These are not exact quotes)
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Adelman, Page 16
Photo 1306, 403pm, March 27th
Bicycle Patrol officer instructs Rugby Player to keep
Correspondent back at imaginary line.
Due to noise level of Rugby Player yelling at Correspondent, it
is not clear if Bicycle Patrol Officer told him to make sure
Correspondent did not take any more photographs.
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Adelman, Page 17
Photo 1312 403pm, March 27th
Rugby Player is joined by Asian Officer, and verbal harassment
continues unabated.
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Adelman, Page 18
Photo 1313 403pm, March 27th
As Correspondent moves to berm on left side of trail, Rugby
Player follows while continue verbal harassment and attempts to
block photography.
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Adelman, Page 19
Photo 1314, 403pm, March 27th
As Correspondent moves to berm on left side of trail, Rugby
Player follows while continue verbal harassment and attempts to
block photography.
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Adelman, Page 20
Photo 1315, 403pm, March 27th
As Correspondent moves to berm on left side of trail, Rugby
Player follows while continue verbal harassment and attempts to
block photography.
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Photo 1316, 403pm, March 27th
As Correspondent moves to berm on left side of trail, Rugby
Player follows while continue verbal harassment and attempts to
block photography.
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Photo 1317, 403pm, March 27th
Correspondent has returned to trail and continues to walk over
berm along imaginary boundary line. Rugby Player and Asian Officer
follow Correspondent.
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Photo 1321, 403pm, March 27th
In addition to officers, a teenage male now joins the queue to
block Correspondent. He tells Correspondent he is helping the
officers block photography.
The officers do not attempt to prevent this person from
participating, thereby setting a negative role model of police
activities as legitimate behavior.
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Adelman, Page 24
Photo 1335, 404pm, March 27th
As Correspondent circles around the scene and heads to his
vehicle. Rugby Player and Asian Officer continue to follow, along
with unidentified male.
Prior to this photo, Correspondent had walked to base of berm by
street, followed by Asian Officer. This officer pushed
Correspondent into street, in an attempt to force him to walk into
right of way and risk a ticket. Correspondent confirms he asked
this officer - Did you just fucking touch me? The officer replied -
Yes, I did.
As Correspondent starts to return to his vehicle, Rugby Officer
follows with a notebook in hand, in an attempt to get
Correspondents vehicle information. Rugby Officer tells
Correspodent - Hey, if you did not do anything wrong, what are you
worried about?
Correspondent stops walking to vehicle. After a few moments,
Rugby Player leaves area.