SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA CIVIL DIVISION

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EST A TE OF ROBERT E. WONE, By Katherine E. Wone

Plaintiff,

2008 ca 8315

Judge Michael L. Rankin Calendar 7

v.

JOSEPH R. PRICE, et al.,

Defendants.

DECLARATION OF DANIEL HICKSON

I, Daniel Hickson, being first duly sworn, depose and say that:

1. I am the Commander of the Criminal Investigations Division for the Metropolitan

Police Department (MPD).

2. As the Commander, I oversee all investigations and personnel within the division.

3. I am authorized to assert the Law Enforcement Privilege on behalfofMPD.

4. It is my understanding that subpoenas have been issued in the above-referenced

case by counsel of Joseph R. Price for the following:

a. Deposition of Detective William Xanten on April 18, 2011, at 10:00 a.m.;

b. Deposition of Detective Daniel Whalen on April 20,2011, at 10:00 a.m.;

c. Deposition of Milton Norris on April 18, 2011, at 1 :00 p.m.; and

d. Deposition of Sergeant Daniel Wagner on April 20,2011, at 1 :00 p.m.

5. I have reviewed the investigative files regarding the murder of Robert Wone, to determine the nature and types of documents contained therein.

6. The investigation regarding the murder of Robert Wone remains open (pending Grand Jury proceedings).

7. The investigative files contain, among other things:

a. PD 251 Incident-Based Event Reports

b. PD 252 Supplement Reports, which contain a list of the names, addresses, telephone numbers, and hours of availability of witnesses and brief accounts of their statements.

c. W ACIIS Reports which contain:

1. The names, addresses, places of employment, or hangouts of the suspects, if known, along with their criminal history.

11. The names, addresses, telephone numbers, and any information provided when the area was canvassed.

111. Whether there was a pattern or modus operandi (MO) for the crimes and a description of the pattern or MO.

IV. The activities and developments in the cases since the last reports.

v. A list of evidence, contraband, fruits or instruments involved in the crime, including the current condition and location of the evidence. It is also reported in the PD 251 whether the suspect may have the

"fruits of the crime" or evidence.

VI. The recommendations of the investigative officers and their

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supervisors (suspend or investigate further).

VII. The names of the investigating officers and their supervisors.

c. PO 119 Complainant/Witness Statements, which contain:

1. The names of the witnesses,

11. The dates of the birth of the witnesses,

111. The gender of the witnesses,

IV. The home addresses of the witnesses,

v. The home and business telephone numbers of the witnesses,

VI. The occupations and business addresses of the witnesses,

Vll. The statements of the witnesses,

Vlll. The times and locations of the statements, and

IX. The names of the officers taking the statements.

d. DVD discs of video taped statements taken from witnesses and/or

suspects.

e. PO 120 Death Reports,

f Crime scene photographs

g. Photographs of the decedents

h. Evidence Reports, which contain:

1. Descriptions of the crimes scenes;

11. Lists ofthe physical evidence retrieved at the scenes;

Ill. Descriptions of the evidence recovered at the scene, including where the evidence was recovered;

IV. Whether photographs were taken of the crime scenes and by

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whom,

v. Whether diagrams of the crime scenes were prepared and by whom;

VI. Descriptions of the evidence taken from the decedents and by whom; and

Vll. The property book numbers for the evidence recovered and the current location of the evidence.

1. Supplementary Evidence Reports, which contain:

1. Lists of the physical evidence recovered at the autopsies;

11. Descriptions of the evidence recovered at the autopsies, including where the evidence was recovered;

IV. Whether photographs were taken of the decedents and by whom,

v. Whether fingerprints and footprints of the decedents were taken and by whom;

VI. Descriptions of the evidence taken from the decedents and by whom; and

Vll. The property book numbers for the evidence recovered and the current location of the evidence.

J. WACHS Investigative Supplement Reports, containing the notes of the

investigators.

k. Autopsy Reports

l. Family Contact Logs

ill. Case Status Review Investigative Supervisor Checklists

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n. Handwritten notes of the investigators

8. I have seen and considered the contents of the investigative files regarding the murder of Robert Wone and have formed the view that these investigative files ought not be produced, with the exception ofthe PO 251 s contained therein.

9. Excluding the documents provided to counsel during the criminal trial

(obstruction of justice, destruction of evidence), I am asserting the Law Enforcement Privilege on behalf ofMPD for the subject investigative files.

10. The investigative files should be deemed privileged to prevent disclosure oflaw

enforcement techniques and procedures, to preserve the confidentiality of sources, to protect witness and law enforcement personnel, to safeguard the privacy of individuals involved in the investigations, to prevent interference with the investigations and the successful prosecution of the crimes.

I declare, pursuant to 28 U.S.C. § 1746, under penalty of perjury that the foregoing is true and correct.

Executed: April 14, 2010

Daniel Hickson

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