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CITY OF DALI.AS ETHICS ADVISORY COMMISSION COMPLAINT FORM
ClTy OF DALLAS Pleasegpe or print legibly in blue or black ink. For Official Use

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FILING A COMPLUNT TIHAT FALSELY ACCUSES SOMEONE NOTE: OF THE ETHICS CODE T[T\Y RESULT IN CRIMINAL OF A VIOI,{TION ANYONE WHO KNOWINGLY MAKES A FALSE OF PROSECUTION ACCUSATION. PART A- COMPLAINANT INFORMATION
1. Your full name (print) (dentifies y-ouas the Complainant)

Yout residenceaddtess(Street,City, State and Zip Code)

Your businessaddress(Stteet,City, State and Zip Code)

County

h o n# e 3 1 .{-S rq - qqG4 B u si n ep ss
COMPLAINANT DECLARATION

phone # Residence

I DECLARE I HAVE A COMPLAINT AGAINST: whom you afebringingthe allegation: 2. Full Nameof personagainst
(Check Cr''r"; Information Elected Official Appointed Official Candidate * City Employee Fill in Appropriate Office Held Board or Commission/ Title Office Souqht Tide/Department

CHIEF DAVID O. BRO\XA]/ DALLAS POLICE DEPARTMENT

(Street,City, State andZip Code) address Business 1400South Lamar Dallas.TX75215

OFTHECIry SECRETARY OFFICE

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PART C .- DESCRIPTION

OF COMPLAINT

Provide a statement of the facts upon which your complaint is based. Descdbe the events in the order in which they occurred. Keep datesof events in sequence. Include fulI names, addressesand phone numbers of all individuals involved, including any witnessesPresent when allegedviolations took place. Be factual;the information you provide in this statement must be basedon facts and not on personalconfecture.Try to answerthe questions"who", "what", "whefe", and "when", Attach extra sheetsif more spaceis needed.

Backgtound: On Octob et 74,Z}l3,Joyce Jacksoncalled the Dallas Police Departrnent becauseshe feared that het son, Bobby Gerald Bennett, who suffets from schizophreniaand bipolar disorder, would hutt himself. Dallas Police dispatchedOfficets Cardan Spencerand to the call. Within minutes of arriving, Officer Spencershot Bobby Christopher'$Tatson Bennett fout times in the stomach. Officet Christopher Watson wrote in his report that Mr. Bennett moved "in a threatening manner", and "lunged" at the officers with a knife, causing them to fear fot their lives. Mr. Bennett was chargedwith AggravatedAssault'udth a deadly weapon on a public servant,a felony, basedon the official report ftom Officer Watson. capturedthe confrontation on a home MauriceBfown, a neighbor ofJoyceJackson, surveillancecarnera. Mr. Brown's video evidenceshowed that Mr. Bennett never lunged at the officers, and that he didn't threaten them in any conceivablemanner. Mr. Bennett stood up when officers arrived, did not move, and kept his hands at his side when Officer Spencer beganrepeatedlyfiring his serviceweaPon. video before handing it ovet to the Maurice Brown showed Dallas Police the surveillance media. Police Chief David O. Brown made an official decision to Pursue chargesagainst the shooting victim even after seeingthe video evidence,because"Officer \Tatson's statementreally overrode what the video sho'wed". Chief David O. Brown went on to state, until we have other evidenceto prove "\Weput a lot of credibijity on officer's statements otherwise". Officer Watson was suspendedshordy thereafter fot making false statements in the report. Officer Spencerwas terminated from the Dallas Police, and the casehas been referred to a gtand jury. Officer l7atson's testimonyand Complaint: MauriceBrown's video contradicted undeimined the criminal chargeagainstBobby Gerald Bennett, In response,Chief David s, "Any Dallas officet O. Brown implemented the "72 Hour Review "policy, which state ot witnessedthe gunfire fired arJ/eaPon rvhsthff the officer involved in a police shooting - will now have the right to remain silentfor 72 hours...And even befote they give a statementabout the shooting, the officers can watch any availablevideo before they give a statement." The"T2Hour Review" policy developedand implementedby DallasPolice Chief David to protect officers from being caughtin a lie, and creates designed O. Brown is specifically a mandatefor officer-involvedshooting"cover-ups"in the City of Dallas. The policy rvill createa culrure of corruprion, giving dishonestofficers the ability to fix nattatives in CE OF THE Clry SECRETARY OFFf Page2 of 4 TEXAS DALLAS, 04-03-07

a tePort, ensuring that they do not conffadict availablevideo evidence. The "/ZHour Review" policy provides for an environment where deceit and collabotation between those dkecdy involved in officer involved shootings,will no longer be the exception, but the
flofTn.

T\e "72 Hour Review" Policy will createan environment where the public w.ill no longer trust officer-involved shootings reports, and elevates public perception of officers as receiving specialtreatment It decteases any semblanceof transparencyin the period betweenwhen the shooting happens,and when a report is filed. The public inierest of the tesidentsof the City of Dallas does not support the "72 Hour Review" policy, and demands exacdythe opposite. fn accotdance with this Code, I hereby request an evidentiary headng tegatding this complaint, whereby the facts may become know to the "ll public. PART D .- CODE VIOI.ATIONS List the sections and pangraphs of the Code of Ethics' provisions you believehave been violated: I. F'thics Code SEC.12A-3(a): IMPROPERECONOMIC BENEFIT,

Economic Intetests Affected. To avoid the appearance and risk of impropiettJ,a city official or employeeshall not tahe any official action that he or she knows is likely to affect particulady the economic interest of: (1) the official ot employee

Fthics Code SEC. 12A-3(a)Violation #t: The official decisionto implement the "-12Hout Review" policy is in direct responseto video evidencereleased after the shootingof Bobby Gerald Bennett on October 14,2073. The implementationof the "72 Hour Reviev/' policy violates this code of conduct by making unworkable the SpecialInvestigationsUnit FBI Notification Policy, which was designedto allow for neutral third party oversight of officer involved shootings. The elimination of neutral third party oversight is intended to protect Dallas Pofice Officers and Chief David O. Brown from public scrutiny, civil liability, and criminal charges. Chief David O. Brown's economic interest is affected through potential termination or demotion. Chief David O. Brown has an economic interest in maintaining his position within the Dallas Police Department. The economic interest is in the form of a yeaily salary, expenseaccounts,stipends,bonuses,and other fringe benefitsassociated with the position. "SIU FBI Notification Policy:Anytime an officer involved shooting occurs in which a ciazenis injured or killed, the Special

OFFICE OF THE Clry SECRETARY

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InvestigationsUnit (SILf will email the Dallas Division of the FederalBureau of Investigations,Civil Rights Unit, the shooting sunmafy, no later than the first
tt

Ethics Code SEC. 12A-3(a)Violation #2: The official decisionto implement the"72 Hour Review" poli.y is in direct responseto video evidencereleasedafter the shootingof Bobby GeraldBennett on October 74,2073. The implementation of the "72Hout Review" policy violates this code of conduct by allowing for the resultingin a loss of liberty to another (18U.S.C' intentionalfabricationof evidence $S241, 242). Criminal chargesagainsta shooting victim that arebasedon an officer's falsetestimony, of testimony that is contradicted by video evidence,is likely to affect Chief David O. Btown's economic interest, thtough Potential terminarion or demotion. Chief David O. Btown has an economic intetest in maintaining his position within the Dallas Police Depanment by avoiding public scrutiny, civil liability, and criminal charges. The economic intetest is in the fotm of aye ty with and othet ftinge benefitsassociated bonuses, accounts,stipends, salary,expense the position.

Ethics Code SEC. 12A-3(a)Violation #3: The implementationof the "72Hout Review" policy violates this code of conduct through an implicit effort to avoid future contradicting fepofts between swofn testimony submitted by a Dallas Police Officer and availablevideo evidence,as part of an officer involved shooting investigation. Criminal chargesagainsta shooting vic.Umthat ate based on an officer's false testimony, or testimony that is contradicted by video evidence,is likely to affect Chief David O. Brown's economicinterest,thtough potential termination or demotion. Chicf David O. Brown has an economicinterestin maintaininghis position within the Dallas Police Department by avoiding public scrutiny, civil Iiability, and criminal charges. The economic interest is in the form of a yeady with and other fringe benefitsassociated bonuses, stipends, accounts, salary,expense the position.

CE OF THE Clry SECRETARY OFFf

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Ethics Code SEC. 12A-3(a)Violation #4: The implementationof the "1ZHour Review" policy violates this code of conduct through an implicit effoft to avoid a federalinvestigation of officer involved shootings that have occurred in the City of Dallas. Any federal investigation into a pattem and practice of unconstitutional use of deadly ot excessiveforce againstthe residentsof Dallas, TX is likely to affect Chief David O. Brown's economic interest through potential termination or demotion. Chief David O. Brown has an economic interest in maintaining his position within the Dallas Police Depattment by avoiding public scrutiny, civil fiability, and criminal charges. The economic interest is in the fotm of a yeafy with accounts,stipends,bonuses,and othet fringe benefits associated salary,expense the position.

II.

Ethics code sEC. 12A-4(a): UNFAIR ADVANCEMENT INTERESTS,

OF PRTVATE

Genetal Rule. A city official or employeemay not use his or her

official position to unfaidy advanceor impede personalinterestsby granting ot securing,ot by attempting to grant or secure,fot anyPerson (including himself or herself any form of specialconsideration,treatment, exemption, of advantage beyond that which is lawfully availableto every other person or orgarizatjon-

Ethics Code SEC. 12A-4(a)Violation #1: The official decisionto implement the "72 Hgur Review" policy violates this code of conduct through an implicit effort to unfaidy advanceChief of Potce David Brown's personalinterests. Chief David O' implementation Rrovrn unfaidy usedhis position as a depattmentditector to secure of the "72Hour Review" policy to avoid continued political and internal Pfessufe from the Dallas Police Association,who has lobbied for the implementation of this yearsprior. The implementationof the "72Hout Review" policy policy for several a form of specialtteatment'and is his petsonalinterestand constitutes advances not lawfully availableto every other police officer, or orgarizaicrn within the City of Dallas.

OF THE Clry SECRETARY OFFICE

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Ethics Code SEC. 12A-4(a) Violation #2: The official decisionto implementthe "'/2 Hout Review" policy violates this code of conduct through an implicit effort to unfaidy advancespecialconsiderationfor the employeesof the Dallas Police Departrnent. The implementation of the "72Howr Review" potcy constirutesa form of specialtreatment, and is not lawfully availableto any other public employee, private citizen, or orgarizatton within the City of Dallas

III.

Ethics Code SEC. 12A-18: PARTICIPATION

IN ETHICS VIOLATIONS,

No person shall intentionally or knowingly induce, attemPt to induce, conspire with, aid, of assist,or attmpt to aid or assistanother Pefson to engagein conduct violative of this chapter. Ethics Code SEC. 12A-18Violations #lthtough #4: The official decision to

implement the "72 Hour Review" policy violates this code of conduct through an implicit effort by Chief of Police David Brown to intentionally or knowingly aid, assist,or induce high ranking police officets within the SpecialInvestigations Unit, Internal Affairs Division, Public Integrity Unit, and Crimes Against PersonsUnit to violate SFC. 12A-3(a): IMPROPER ECONOMIC BENEFIT, and SEC-.1244(a): UNFAIR ADVANCEMENT OF PRIVATE of the Ciw of Dallas Code of Ethics.

PART E ..

SOURCES OF EVIDENCE

Identifr sources of evidence, if any, that you believe should be considered by the Ethics Advisory Commission. Submit all information that you have; attach photocopies of any pertinent PaPers or documentation to support your allegation. The following files are attachedas sourcesof evidence:

A.

Dallas Police Shoot Bobby Getald Bennett and Lie About It: ^. http://www.wfm.comf news/local/dallas/surveillance-footage-disputesdallas-police-affidavit-officer-involved-shooting--mentally-ill-228252551.htm|

/news/opinions/wp /2014l01 /22 /do-cooling-off-perioclshttp: / /wwrv.vrashingtonpost.com -shootings-more-accuratcly' lice-involved help-cops-rememher-po

OF THE CITYSECRETARY OFFICE

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http://hloSs.dallasohserver.com/unfai?ark12013/12lright

to remain silent is new.php

h ttF: / /blogs. dallasoh server. com /unfairf'ark /20 13 / 10 / catdan sencer officer who shot.fhp

htrp: / /www.wfaa.crrm /news /lc'cal /dallas /sut'veillance-frr<''tage-disputes-dallas-p<rliceaffi davit-offi cer-involved-sh ooting--men tally-ill-228252551 .html

httF: / /www.dallasfolice.netlnews /201 3 /l-recemher/:l 3^oBrowl.pdf 16ao ^0 A 0 t0Messageo6^0ftom0/o^0ChieP' ^0David7o20().0

httf': / /www.theguardian.com/wodd/2013 ill-man

/oct /24 /dallas-Folice-fire-officer-shot-mentally-

http:/ /www.theblaze.com/stodes

/2013/10/18/cops-say-they-shot-mentally-ill-man-

4-times-aftet-he-came-at-them-with-a-knife-disturbing-suweillance-story-tells-a-

different-story/

I CERTIFY TI{AT I HA\IE READ THIS COMPI-AINT, I FUHY UNDERSTAND ITS CONTENTS, AI\TD I DECIARE UNDER PENALTY OF PERJURY UNDER THE I.AWS OF THE STATE OF TEXAS THAT THE IJOREGOING STATEMENTS AND PHOTOCOPIES OF ATTACI+ED DOCUMENTS ARE TRUE AND CORRECT. I UNDERSTAND THAT A COPY OF THIS COMPLAINT WILL BE SENT TO THE CHAIR OF THE ETHICS ADVISORY COMMISSION AND TO THE INDTYIDUAL CHARGED IN THIS COMPLAINT. ALL PAPERSAND COMMUNICATIONS REI-ATING TO A

COMPI.AINT MUST BE TREATED AS CONFIDENTIAL TO THE EXTENT ALLOWED BYU.W.

OFFICE OF THE CIry SECRETARY

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DALLAS, TEXAS 04-03-07

persondly of FeWuat\',200!L, day authority,on the 25 Before me the whose known to me to be the Person appeared, that he/she has personal knowledge stated swom duly being and hereio, ir subscribed n.".
of the facts hereinabove and that such facts are tnre and correct.

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Texas county,

My CommissionexPites:

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Special Note: Section 3.2 of the Ethics Advisory Commission Rules of Procedure states amended complaint may only be filed within seven days after the city secretary's ffi;^n receipt of the origind comPlaint" Should you have any questions conceming this form, please contact the City Secretary's office, at Ql4) 671-8970during regularbusinesshours (8:15am 5:15pm)' Upon completion of ALL sections of the complaint form, pleasehand delivet or send by certified mail with any attachmentsto: Office of the City Secretary CITY HALL 1500 Matilla Avenue - Suite 5DS Dallas, TX 75201

OF THE CITYSECRETARY OFFICE

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