Justice Department Witness List

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 1 of 24
1 Steven H. Rosenbaum (NY Bar #1901958)

2 Judy Preston (MD Bar)
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R. Tamar Hagler (CA Bar #189441)

Christy E. Lopez (DC Bar #473612)
Eric W. Treene (NY Bar #2568343)
Sean R. Keveney (TX Bar #24033862)
Jessica Clarke (NY Bar #4694972)
Matthew J. Donnelly (IL Bar #6281308)
Emily M. Savner (NY Bar #5214358)
Sharon I. Brett (NY Bar #5090279)
United States Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530
Phone:
(202) 305-4013
Facsimile: (202) 514-1116
E-mail: sean.r.keveney@usdoj.gov
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Attorneys for the United States

IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF ARIZONA
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United States of America,
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Plaintiff;
No. 3:12cv8123-HRH
v.
UNITED STATES TRIAL
WITNESS LIST AND
DESIGNATION OF
DEPOSITION TESTIMONY
Town of Colorado City, Arizona, et al.,
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Defendants.
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Pursuant to the Courts order of July 24, 2015, ECF No. 626, the United States
submits the following list of witnesses it intends to call at trial.
1. Isaac Wyler
Mr. Wyler is a fact witness. He is a former member of the FLDS Church, a long-
26 time resident of the Colorado City/Hildale community, and works for the United Effort
27 Plan Trust (UEP Trust). He is expected to testify regarding claims and facts alleged in
28 the United States Complaint in this case, as well as the matters discussed in his
1 deposition and trial testimony in Cooke v. Town of Colorado City, 3:10-cv-08105 (D.
2 Ariz.). In particular, his testimony will include: his excommunication from the FLDS
3 Church; tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS
4 Church; instructions and directives from FLDS leaders; consequences of losing
5 membership in the FLDS Church; the treatment of non-FLDS members living in the
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community by Defendants city officials, FLDS Church Security, the CCMO, and other
community members; the FLDS opposition to Bruce Wisan and his administration of
the UEP Trust; the CCMOs failure to enforce UEP Trust Occupancy Agreements;
FLDS leaders control over the Cities; the CCMOs failure to respond to vandalism of
UEP Trust property; Defendants interference with the administration of the UEP Trust;
the CCMOs refusal to investigate or arrest FLDS individuals for trespass; his
prosecution by the Cities for allegedly trespassing on UEP Trust property while working
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for the UEP Trust at that time; his knowledge of Ron and Jinjer Cookes inability to
secure a water connection from the Cities; his knowledge of other homes and buildings
on UEP Trust property that received water connections; his knowledge of building
permits received for homes and businesses on UEP Trust property; and his knowledge of
homes, buildings, utilities, businesses, and individuals on UEP Trust property.
2. Richard Holm
Mr. Holm is a fact witness. He is a former member of the FLDS Church and a
19 long-time resident of the Colorado City/Hildale community. He is expected to testify

20 regarding claims and facts alleged in the Complaint, as well as the matters discussed in
21 his deposition and trial testimony in Cooke. In particular, his testimony will include: his
22 excommunication from the FLDS Church; tenets of the FLDS religion; how Warren
23 Jeffs became the leader of the FLDS Church; instructions and directives from FLDS
24 leaders; consequences of losing membership in the FLDS Church; the treatment of non25 FLDS members living in the community by Defendants city officials, FLDS Church
26 Security, the CCMO, and other community members; his experiences as a Hildale City
27 councilmember and the control the FLDS Church had over the City; the CCMOs
28 handling of a trespass complaint at a property for which Mr. Holm had a UEP Trust
1 Occupancy Agreement; and his arrest by the CCMO for criminal trespass at a
2 commercial property to which he had title and the County Attorneys subsequent
3 decision to decline to prosecute that charge.
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3. Robert Foster
Mr. Foster is a fact witness. He is a FBI agent who helped search for and
apprehend Warren Jeffs. Agent Foster is expected to testify regarding claims and facts
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alleged in the Complaint, as well as the matters discussed in his testimony in Cooke. In
particular, his testimony will include the law enforcement search for fugitive Warren
Jeffs; the CCMO and other Defendant employees resistance to capturing Warren Jeffs;
and foundational testimony to admit letters and other documents from that search,
including documents seized from Seth Jeffss vehicle and documents and items seized at
the time of Warren Jeffss arrest.
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4. Charlene Jeffs
Ms. Jeffs is a fact witness. She is a former member of the FLDS Church and the
ex-wife of FLDS Bishop Lyle Jeffs. Ms. Jeffs is expected to testify regarding claims
and facts alleged in the Complaint, as well as the matters discussed in her deposition. In
particular, her testimony will include: tenets of the FLDS religion; instructions and
17 directives from FLDS leaders; consequences of losing membership in the FLDS Church
18 and the United Order; the CCMOs involvement in her child custody dispute and legal
19 proceedings involving Lyle Jeffs; FLDS Church directives regarding the selection of
20 CCMO officers; CCMO officers consecrating money for fugitive Warren Jeffs; CCMO
21 reporting law enforcement information to Lyle Jeffs; Lyle Jeffss phone calls requesting
22 license plate checks of vehicles; membership of CCMO officers and Defendants city
23 officials in the FLDS Church, United Order, and FLDS Church Security; former Town
24 Council member Vergel Steeds role in facilitating the separation of non-United Order
25 members from their United Order family members; ECO Alliances relationship to the
26 FLDS Church; then Town Council Member Kimball Barlows role in administering the
27 Bishops Storehouse; Isaac and Nephi Jeffss role as messengers between imprisoned
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1 Warren Jeffs and Bishop Lyle Jeffs; and Warren Jeffss role in directing the Church
2 from prison.
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5. Dowayne Barlow
Mr. Barlow is a fact witness. He is a former member of the FLDS Church and a
5 former aide to FLDS Bishop Lyle Jeffs. Mr. Barlow is expected to testify regarding
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claims and facts alleged in the Complaint, as well as the matters discussed in his
deposition. In particular, his testimony will include: his departure from the FLDS
Church; tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS
Church; instructions and directives from FLDS leaders; consequences of losing
membership in the FLDS Church and United Order; the treatment of non-FLDS
members living in the community by Defendants city officials, FLDS Church Security,
the CCMO, and other community members; his knowledge and experience with FLDS
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Church Security; the surveillance conducted by FLDS Church Security of non-FLDS;

the coordination between the CCMO and FLDS Church Security, including by sharing
surveillance equipment and information in law enforcement databases; harassment of
non-FLDS members by FLDS Church Security; participation by Defendants city
officials in FLDS Church Security; FLDS directives to separate family members,
17 including the families of Defendants city officials and CCMO officers; membership of
18 CCMO officers and Defendants city officials in the FLDS Church; the operation of the
19 Bishops Storehouse and illegal activity conducted out of the Storehouse; and
20 Defendants city officials and CCMO officers consecrating money for fugitive Warren
21 Jeffs.
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6. John Nicholas Hanna

Mr. Hanna is a fact witness. He is a Texas Ranger with the Texas Department of
24 Public safety who was involved in the criminal investigations and conviction of Warren
25 Jeffs. Ranger Hanna is expected to testify regarding claims and facts alleged in the
26 Complaint, as well as the matters discussed in his testimony in Cooke. In particular, his
27 testimony will include the criminal investigation regarding Warren Jeffs, the conviction,
28 and Warren Jeffss communications and activities during his incarceration in Texas; the
1 CCMO and other Defendant employees resistance to helping with the criminal
2 investigations of Warren Jeffs; and foundational and explanatory testimony to admit
3 FLDS priesthood records and other documents uncovered during the criminal
4 investigation of Warren Jeffs, including documents seized from the YFZ Ranch.
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7. Jennifer Smith
Ms. Smith is a fact witness. She is a mail room employee in prisons run by the
Texas Department of Criminal Justice. In particular, Ms. Smith will be asked to
authenticate documents sent to or from Warren Jeffs during his incarceration. Ms. Smith
will also testify about the amount of mail Warren Jeffs receives and how he selects the
mail he reads.
8. Rosemarie Urbanski
Ms. Urbanski is an expert witness for the United States. She is a forensic
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scientist and owner of The Drake Group. She has expertise in handwriting identification
and analysis. Her additional qualifications are attached. Ms. Urbanski is expected to
testify consistent with the expert opinions provided in her reports and deposition in this
case. In particular, her testimony will cover the authentication of documents signed by
Joseph Allred, George Barlow, and Vance Barlow.
9. Willie R. Jessop
Mr. Jessop is a fact witness. He is a former member of the FLDS Church, the
19 former Legal Coordinator for Church affairs, and the former head of Church Security.
20 Mr. Jessop is expected to testify regarding claims and facts alleged in the Complaint, as
21 well as the matters discussed in his deposition. In particular, his testimony will include:
22 his decision to leave the FLDS Church; tenets of the FLDS religion; how Warren Jeffs
23 became the leader of the FLDS Church; instructions and directives from FLDS leaders;
24 consequences of losing membership in the FLDS Church; the treatment of non-FLDS
25 members living in the community by Defendants city officials, FLDS Church security,
26 the CCMO, and other community members; his knowledge and experience with FLDS
27 Church Security; the surveillance conducted by FLDS Church Security of non-FLDS;
28 the coordination between the CCMO and FLDS Church Security, including training
1 FLDS Security and the sharing of surveillance equipment and information in law
2 enforcement databases; harassment of non-FLDS members by FLDS Church Security;
3 participation by Defendants city officials in FLDS Church Security; FLDS directives to
4 separate family members, including the families of Defendants city officials and
5 CCMO officers; interactions with Defendants city officials and FLDS leaders at R&W;
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the identification of signatures of Defendants city officials; the arrest of Harvey

Dockstader; Defendants city officials and FLDS leaders conspiring or agreeing to use a
water shortage as a pretext for discrimination; FLDS and CCMO involvement in the
burglary of R&W Construction, Inc. in 2011; FLDS and CCMO involvement in an
alleged burglary at ECO Alliance and an alleged home invasion at a home on Johnson
Ave.; and FLDS and CCMO involvement in the theft of two vehicles and their contents
from Mr. Jessops home.
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10. Gary Wilbanks

Mr. Wilbanks is a fact witness. He is an agent with the Texas Office of Inspector
General. His testimony will include: the authenticity of audio recordings of Warren
Jeffs taken at the Powledge Unit of the Texas Department of Criminal Justice; the timing
and frequency of various individuals visits with Warren Jeffs while Warren Jeffs has
17 been imprisoned at the Powledge Unit, including Isaac and Nephi Jeffs; Texas
18 Department of Criminal Justice policy concerning visitation with prisoners, including
19 dress code and jewelry; information concerning visitors of Warren Jeffs recording
20 conversations with him via wrist watch recorders; and Warren Jeffs violation of prison
21 rules regarding communications.
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11. Isaac Jeffs

The United States will offer Mr. Jeffs deposition testimony in lieu of live
24 testimony at trial. The United States designates the follow deposition testimony by page
25 and line numbers:
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16:23-16:25
21:17-22:14
32:2-33:1
19:14-20:13
27:18-28:1
33:13-36:8
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38:2-38:7
58:10-58:14
87:23-88:12
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61:5-69:9
88:14-91:11
47:12-48:13
70:7-71:9
93:5-93:21
48:20-48:25
74:10-76:5
94:11-99:15
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79:12-83:17
99:25-102:9
51:22-52:1
83:19-85:6
53:15-54:2
85:24-86:4
12. Guy Timpson

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Mr. Timpson is a fact witness. He is former member of the FLDS Church, a

former member of the Utility Board, a former member of FLDS Church Security, and
the former president of Pure Ph8, a water bottling company in Hildale. He is expected
to testify regarding his knowledge of claims and facts alleged in the Complaint, and
matters discussed in his depositions in this case and in Cooke and his trial testimony in
13 Cooke. In particular, his testimony will include: FLDS leaders control of the Cities,
14 TCWA, TCWW, Inc., and the CCMO; FLDSs treatment of non-FLDS; his knowledge
15 and experience with FLDS Church Security; the surveillance conducted by FLDS
16 Church Security of non-FLDS; the coordination between the CCMO and FLDS Church
17 Security, including by sharing surveillance equipment and information in law
19 participation by Defendants city officials in FLDS Church Security; his knowledge of
20 Pure Ph8 and its water connection; his knowledge of the Cities discriminatory water
21 policy and the Cities enforcement of that policy; the Cities providing a new water
22 connection to Twin City Improvement Association; his experiences on the Utility Board;
23 consequences of losing membership in the FLDS Church and United Order; his
24 termination from the Utility Board after he was no longer a member of the FLDS
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Church; and the Cities opposition to the administration of the UEP Trust.
13. Thomas Jeffs
Mr. Jeffs is a fact witness. He is a former member of the FLDS Church and the
son of FLDS Bishop Lyle Jeffs. Mr. Jeffs is expected to testify regarding claims and
1 facts alleged in the Complaint, as well as the matters discussed in his deposition. In
2 particular, his testimony will include: his excommunication from the FLDS Church;
3 tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS Church;
4 instructions and directives from FLDS leaders; consequences of losing membership in
5 the FLDS Church; the treatment of non-FLDS members living in the community by
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Defendants city officials, FLDS Church Security, the CCMO, and other community
members; his knowledge and experience with FLDS Church Security; the surveillance
conducted by FLDS Church Security of non-FLDS; the coordination between the
CCMO and FLDS Church Security, including by sharing surveillance equipment and
information in law enforcement databases; harassment of non-FLDS members by FLDS
Church Security; participation by Defendants city officials in FLDS Church Security;
FLDS directives to separate family members, including the families of Defendants city
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officials and CCMO officers; membership of CCMO officers and Defendants city
officials in the FLDS Church and United Order; the operation of the Bishops
Storehouse and illegal activity conducted out of the Storehouse; and Defendants city
officials and CCMO support for fugitive Warren Jeffs.
14. Lyle Mann
Mr. Mann is a fact witness. Mr. Mann is the Director of Arizona Peace Officer
18 Standards and Training Board. Mr. Mann is expected to testify regarding which CCMO
19 officers have been decertified since 2003, and the factual findings and reasons for each
20 decertification.
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15. Vincen Barlow

Mr. Barlow is a fact witness. His is a former member of the FLDS Church and
23 the former City Manager for Hildale. Mr. Barlow is expected to testify regarding claims
24 and facts alleged in the Complaint, as well as the matters discussed in his depositions
25 and Cooke testimony. In particular, his testimony will include: tenets of the FLDS
26 religion; how Warren Jeffs became the leader of the FLDS Church; instructions and
27 directives from FLDS leaders regarding city business and picking officials of the Cities;
28 Defendants city officials sharing information with FLDS leaders; intermingling of
1 Church and Hildale records; consequences of losing membership in the FLDS Church
2 and United Order; treatment of non-FLDS members by Defendants city employees;
3 authentication of documents produced or created by Hildale and TCWA; knowledge of
4 and experience with Church Security, including coordination and training with the
5 CCMO, participation by Defendants city officials, video surveillance and harassment
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of non-FLDS members; the Bishops Storehouse and illegal activity conducted out of
the Storehouse; FLDS directives to cities to oppose efforts of UEP Trust Special
Fiduciary Wisan; the Cities water policy and water rights.
16. Jethro Barlow
Mr. Barlow is a fact witness. He is a former member of the FLDS Church and an
employee of the UEP Trust. He is expected to testify regarding his knowledge of claims
and facts alleged in the Complaint, and matters discussed in his depositions and trial
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testimony in Cooke. In particular, his testimony will include: his excommunication from
the FLDS Church; consequences of losing membership in the FLDS Church; the
treatment of non-FLDS members living in the community by Defendants city officials,
FLDS Church Security, the CCMO, and other community members; the Cities
interference with non-FLDS members use and enjoyment of UEP Trust property; the
17 CCMOs refusal to enforce UEP Trust Occupancy Agreements; his prosecution by the
18 Cities for allegedly trespassing on UEP Trust property even though he was serving as a
19 representative for the UEP Trust; Ron and Jinjer Cookes attempts to obtain housing
20 from the UEP Trust; Ron and Jinjer Cookes attempts to obtain utility service from the
21 Cities; UEP Trusts attempts to work with the Cities regarding water rights and the
22 subdivision; the Cities changed building permit requirements; Twin City Water Works
23 transfer of public money to the FLDS Church; his attempts to serve on Hildales City
24 Council; his knowledge of homes and buildings on UEP Trust property that received
25 water connections; his knowledge of building permits received for homes and businesses
26 on UEP Trust property; and his knowledge of homes, buildings, utilities, businesses, and
27 individuals on UEP Trust property.
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17. Jerold N. Williams

Mr. Williams is a fact witness. He is a former member of the FLDS Church and a
3 former FLDS elder. Mr. Williams is expected to testify regarding claims and facts
4 alleged in the Complaint, as well as the matters discussed in his deposition. In
5 particular, his testimony will include: his excommunication from the FLDS Church;
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tenets of the FLDS religion; how Warren Jeffs became the leader of the FLDS Church;
instructions and directives from FLDS leaders; consequences of losing membership in
the FLDS Church and United Order; the treatment of non-FLDS members living in the
community by Defendants city officials; the authentication of Church records; the
marriage of his underage daughter to the Mayor of Colorado City; the CCMOs decision
to arrest him for criminal trespass at a property that he built and for which he had a UEP
Trust Occupancy Agreement; the emotional distress, embarrassment, and humiliation he
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suffered as a result of the CCMOs conduct; the role of the Cities, their employees, and
the FLDS Church in constructing a compound for Warren Jeffs and the Bishops
Storehouse, including the Cities decision to permit a water connection at that
compound.
18. Timothy Rohbock
Mr. Rohbock is a fact witness. Mr. Rohbock is a former member of the FLDS
18 and former member of FLDS Church Security. He is expected to testify regarding his
19 knowledge of claims and facts alleged in the Complaint. In particular, his testimony will
20 include: tenets of the FLDS Church; directives from Warren Jeffs; the consequences of
21 losing membership in the FLDS Church and United Order; his knowledge and
22 experience with FLDS Church Security; the surveillance conducted by FLDS Church
23 Security of non-FLDS members; the coordination between the CCMO and FLDS
24 Church Security, including by sharing surveillance equipment and information in law
26 participation by Defendants city officials in FLDS Church Security; the CCMOs
27 actions and the FLDS Churchs involvement in the arrest of Jerold N. Williams for
28 trespassing.
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19. Elizabeth Wayman

Ms. Wayman is a fact witness. Ms. Wayman is a resident of the Twin Cities and
3 a former FLDS member. She is expected to testify regarding her knowledge of claims
4 and facts alleged in the Complaint. In particular, her testimony will include: the tenets
5 of the FLDS religion and structure of FLDS leadership; FLDS leaders control of the
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Cities and the CCMO; her departure from the Church; the consequences of losing
membership in the FLDS Church and United Order; knowledge of the Bishops
Storehouse and illegal activity conducted out of the Storehouse; CCMOs treatment of
her once she left the Church; the arrest of her husband, Jerold N. Williams, for
trespassing; and the emotional distress, embarrassment, and humiliation she experienced
as a result of that incident.
20. Helaman Barlow
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Mr. Barlow is a fact witness. He is a former member of the FLDS Church and a
former Chief of the CCMO. Mr. Barlow is expected to testify regarding claims and facts
alleged in the Complaint and the matters discussed in his depositions in this case, as well
as the matters discussed in his depositions and trial testimony in Cooke. In particular,
his testimony will include: his excommunication from the FLDS Church; tenets of the
17 FLDS religion; how Warren Jeffs became the leader of the FLDS Church; instructions
18 and directives from FLDS leaders; consequences of losing membership in the FLDS
19 Church; authentication of documents produced or created by Defendants city officials
20 and the CCMO; the treatment of non-FLDS members living in the community by
21 Defendants city officials and the CCMO; the coordination between the CCMO and
22 FLDS Church Security, including training FLDS Security and the sharing of
23 surveillance equipment and information in law enforcement databases; membership of
24 CCMO officers and Defendants city officials in the FLDS Church and United Order;
25 CCMO efforts to interfere with outside law enforcement; the operation of the Bishops
26 Storehouse and illegal activity conducted out of the Storehouse; the CCMO handling of
27 alleged trespassing at various properties; the CCMOs knowledge of underage
28 marriages; FLDS Churchs influence over the operations of the CCMO.
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21. Joseph DeLopez

Mr. DeLopez is an expert witness for the United States. He is a consultant
3 regarding police practices and services and a former Chief of the Village of Winnetka,
4 Illinois, Police Department and former high-ranking Chicago Police Department officer.
5 He has expertise in police policies, procedures, practices, and administration. His
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additional qualifications are attached. Chief DeLopez is expected to testify consistent

with the expert opinions provided in his report and in his deposition. In particular, his
testimony will include expert opinions on the CCMOs: administration; policies and
procedures; practices; training; accountability systems/practices; investigations; police
reports; coordination with the FLDS Church; and religiously biased policing.
22. Steven Bateman
Mr. Bateman is a fact witness. Mr. Bateman is a former FLDS member. He is
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expected to testify regarding his knowledge of claims and facts alleged in the Complaint,
and matters discussed in his deposition in this case and in Cooke. Mr. Bateman testified
in the Cooke trial by deposition. In particular, his testimony will include: his departure
from the Church; the treatment of non-FLDS members living in the community by
Defendants city officials, FLDS Church Security, the CCMO, and other community
17 members; the consequences of losing membership in the FLDS Church; the CCMOs
18 search of his vehicle without probable cause; his interactions with CCMO during a
19 subsequent traffic stop.
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23. Randy Servis

Mr. Servis is a fact witness. He is employed by the Arizona Department of
22 Agriculture and investigated the CCMOs euthanization of non-FLDS member Lydia

23 Cookes horse in 2011. He is expected to testify regarding matters discussed in his
24 deposition. In particular, his testimony will include: his investigation of the horse
25 euthanization and his findings; and his review of CCMO records produced to him during
26 the course of his investigation.
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24. Samuel Brower

Mr. Brower is a fact witness. He is a private investigator. Mr. Brower is
3 expected to testify regarding claims and facts alleged in the Complaint, as well as the
4 matters discussed in his deposition. In particular, his testimony will include: the
5 CCMOs discriminatory treatment of non-FLDS members; the CCMOs efforts to
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obstruct the service of process on FLDS members; the Cities assistance to the FLDS
Church in its surveillance of non-FLDS members; and the coordination of FLDS Church
Security personnel and the CCMO.
25. Jesseca Jessop
Ms. Jessop is a fact witness. She is a resident of the Colorado City/Hildale
community and has never been a member of the FLDS Church. She is expected to
testify regarding claims and facts alleged in the Complaint, as well as the matters
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discussed in her deposition. In particular, her testimony will include: the CCMOs
failure to take action to enforce a valid UEP Trust Occupancy Agreement; harassment
(including acts of vandalism and property damage) by members of the community and
the CCMOs response to and/or investigation of these incidents; employees or officials
Defendants threats, intimidation and interference with the Jessops use and enjoyment
17 of the property for which they received a UEP Trust Occupancy Agreement; treatment
18 as a non-FLDS person residing on UEP Trust land; various interactions with FLDS
19 Church Security, including incidents of monitoring and video surveillance and a hit-and20 run involving her son, Randy West, as well as the CCMOs involvement in and response
21 to these incidents; and the emotional distress, embarrassment, and humiliation she
22 suffered as a result of the CCMOs actions regarding her home.
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26. Christopher Jessop

Mr. Jessop is a fact witness. He is a former member of the FLDS Church and a
25 resident of the Colorado City/Hildale community. He is expected to testify regarding

26 claims and facts alleged in the United States Complaint in this case. In particular, his
27 testimony will include: his departure from the FLDS Church; the treatment of non-FLDS
28 members living in the community by Defendants city officials, FLDS Church Security,
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1 the CCMO, and other community members; consequences of losing membership in the
2 FLDS Church; his experiences growing up in the Colorado City/Hildale area; the
3 CCMOs failure to take action to enforce a valid UEP Trust Occupancy Agreement;
4 harassment (including acts of vandalism and property damage) by members of the
5 community and the CCMOs response to and/or investigation of these incidents;
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employees or officials Defendants threats, intimidation and interference with the

Jessops use and enjoyment of the property for which they received a UEP Trust
Occupancy Agreement; treatment as a non-FLDS person residing on UEP Trust land;
various interactions with Church Security, including incidents of monitoring and video
surveillance and a hit-and-run involving his son, Randy West, as well as the CCMOs
involvement in and response to these incidents; and the emotional distress,
embarrassment, and humiliation he suffered as a result of the CCMOs actions regarding
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his home.
27. Darrell Cashin
Mr. Cashin is a fact witness. He is a Deputy with the Washington County
Sheriffs Office (WCSO). He is expected to testify regarding claims and facts alleged
in the United States Complaint and will testify consistent with his deposition testimony.
17 In particular, Deputy Cashins testimony will include the CCMOs lack of cooperation
18 with and lack of support of the WCSO; the CCMOs coordination with FLDS Church
19 Security; the CCMOs actions during UEP Trust Occupancy Agreement disputes; the
20 Holm School incident; and the Willie R. Jessop stolen generator incident.
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28. Lyle Jeffs

Mr. Jeffs is a fact witness. Mr. Jeffs is the Bishop of the FLDS Church and
23 brother of Warren Jeffs. He is expected to testify regarding the matters discussed in his
24 deposition in this case. In particular, his testimony will cover: his communications with
25 Warren Jeffs; his role in the FLDS Church; Warren Jeffs control over FLDS Church
26 members, including Defendants city officials, from 2004 through the present;
27 Defendants city officials communication with Warren Jeffs while he was a federal
28 fugitive; FLDS Church instructions regarding non-members and membership in the
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1 United Order; Warren Jeffs dictations and edicts; the Cities opposition to the UEP
2 Trust and its subdivision efforts; the Bishops Storehouse and illegal conduct conducted
3 out of the Storehouse; directions he has given to the CCMO and Defendants city
4 officials regarding government business; the incident at Eco Alliance involving Willie
5 Jessop and theft of Mr. Jessops property; the role of FLDS Church Security and its
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coordination with the CCMO and Defendants city officials; the CCMO enforcing
FLDS Church edicts or directives; the CCMOs protection of FLDS Church leaders; the
FLDS membership status of Defendants employees; and interactions with Defendants
city officials, and their counsel, at R&W. In lieu of live testimony, the United States
may present Mr. Jeffs deposition testimony at trial. As such, the United States
designates the follow deposition testimony by page and line numbers:
19:22-19:24
31:4-31:7
61:5-73:19
20:8-20:10
31:13-31:20
73:25-74:15
21:5-21:6
32:10-33:16
74:21-91:6
21:10-21:20
35:3-45:1
92:6-94:24
22:5-22:16
45:21-47:15
95:3-101:6
23:3-23:10
48:14-52:22
101:19-101:23
17
23:13-23:15
53:7-58:7
18
29:1-29:5
58:11-60:23
12
13
14
15
16
19
20
29. Zachary Renstrom

Mr. Renstrom is an expert witness for the United States. He is a Washington
21 County Commissioner and a licensed professional engineer. He has expertise in

22 municipal water systems. Prior to serving as a County Commissioner, he was the
23 President of Bush & Gudgell, Inc. His additional qualifications are attached. Mr.
24 Renstrom evaluated the Colorado City/Hildale water system for the UEP Trust and as an
25 expert witness in Cooke. Mr. Renstrom is expected to testify consistent with the expert
26 opinions provided in his reports for the UEP Trust, Cooke, and the United States, his
27 depositions in this case and in Cooke, and his trial testimony in Cooke. In particular, his
28 testimony will include his expert opinions on: the water supply and distribution system
15
1 in the Colorado City/Hildale area; the availability of water for new culinary water
2 connections; the incident that occurred with the water system in July 2007; the Cities
3 failure to investigate or develop additional sources of water; the additional sources of
4 water reasonably available to the Cities; the effect on the water system of additional
5 water connections to Ron and Jinjer Cooke, Patrick Barlow, and John Cook; Twin City
6
7
8
9
10
11
Improvement Association and other entitys receipt of water; whether there were
additional ways for the Cities to conserve water other than instituting a moratorium; the
Cities impact fee study; and the opinions of Defendants expert witnesses.
30. Ronald Cooke
Mr. Cooke is a fact witness. He is a former member of the FLDS Church and a
resident of the Colorado City/Hildale community. He is expected to testify regarding
claims and facts alleged in the United States Complaint in this case, as well as the
12
13
14
15
16
matters discussed in his deposition and trial testimony in Cooke. His testimony will
include: his experiences growing up in the Colorado City/Hildale area; his departure
from the FLDS Church; the treatment of non-FLDS members living in the community
by Defendants city officials, FLDS Church Security, the CCMO, and other community
members; consequences of losing membership in the FLDS Church; his accident,
17 disability and disability-related housing needs; his familys application for and selection
18 of a property on UEP Trust land; his familys efforts to obtain utilities for the that
19 property through Defendants; denial of water and obstruction and delays regarding other
20 utilities and municipal services, including a building permit, for that property by
21 Defendants; Defendants threats, intimidation and interference with the Cookes use and
22 enjoyment of the property for which they obtained a UEP Trust Occupancy Agreement;
23 treatment as a non-FLDS member residing on UEP Trust land; and the fair housing
24 complaint the Cookes filed with the Arizona Attorney General and the subsequent
25 lawsuit.
26
27
31. Jinjer Cooke

Ms. Cooke is a fact witness. She is a resident of the Colorado City/Hildale
28 community and has never been a member of the FLDS Church. She is expected to
16
1 testify regarding claims and facts alleged in the United States Complaint in this case, as
2 well as the matters discussed in her deposition and trial testimony in Cooke. In
3 particular, her testimony will include: Ronald Cookes accident, disability, and
4 disability-related housing needs; her familys application for and selection of a property
5 on UEP Trust land; her familys efforts to obtain utilities for the that property through
6
7
8
9
10
11
Defendants; denial of water and obstruction and delays regarding other utilities and
municipal services, including a building permit, for that property by Defendants;
Defendants threats, intimidation and interference with the Cookes use and enjoyment
of the property for which they obtained a UEP Trust Occupancy Agreement; treatment
as a non-FLDS person residing on UEP Trust land; interactions with the CCMO
involving the Stubbs farm; and the fair housing complaint the Cookes filed with the
Arizona Attorney General and the subsequent lawsuit.
12
13
14
15
16
32. John Cook

Mr. Cook is a fact witness. He is a former member of the Colorado City/Hildale
community and has never been a member of the FLDS Church. He is expected to testify
regarding claims and facts alleged in the United States Complaint in this case and the
matters discussed in his deposition, as well as the matters discussed in his deposition and
17 trial testimony in Cooke. In particular, his testimony will include: his efforts to procure
18 water services in Colorado City; the Defendants actions to prevent him from living in
19 the Twin Cities; and the emotional distress, embarrassment, and humiliation he suffered
20 as a result of the above-described conduct by Defendants.
21
22
33. Joseph Allred

Mr. Allred is a fact witness. He is the Mayor of Colorado City. He is expected to
23 testify regarding his knowledge of claims and facts alleged in the Complaint, and
24 matters discussed in his depositions in this case and in Cooke and his trial testimony in
25 Cooke. In particular, his testimony will include: FLDS leaders control of the cities,
26 TCWW, Inc., TCWA, and the CCMO; treatment of non-FLDS members; his knowledge
27 and experience with FLDS Church Security; Defendants efforts to discriminate against
28 Ron and Jinjer Cooke; membership in the United Order; Defendants use of an alleged
17
1 water shortage as a pretext for discrimination; his marriage to an underage girl; and his
2 efforts, while serving as a city official, to embezzle money from TCWW, Inc. for the
3 benefit of the FLDS Church.
4
34. Patrick Barlow
Mr. Barlow is a fact witness. Mr. Barlow is a former member of the FLDS
Church and a former member of FLDS Church Security. He is expected to testify
7
8
9
10
11
regarding his knowledge of claims and facts alleged in the Complaint, and matters
discussed in his deposition and trial testimony in Cooke. In particular, his testimony will
include: tenets of the FLDS Church; directives from FLDS leaders; the consequences of
losing membership in the FLDS Church and the United Order; his knowledge and
experience with FLDS Church Security; the surveillance conducted by FLDS Church
Security of non-FLDS members; coordination between the CCMO and FLDS Church
12
13
14
15
16
Security, including by sharing surveillance equipment and information in law

enforcement databases; harassment of non-FLDS members by FLDS Church Security;
participation by Defendants city officials in FLDS Church Security; the water
connection provided to Espresso Creek; his failure to obtain a water connection from the
Cities at his home on Arizona Avenue; and the emotional distress, embarrassment, and
17 humiliation he suffered as a result of not receiving water to his home.

18
19
35. Claude Seth Cooke

Mr. Cooke is a fact witness. He is Ronald Cookes brother, a general contractor,
20 a former member of the UEP Trust Housing Board, a former FLDS member, and a
21 successful party in Jeffs v. Stubbs. He is expected to testify regarding claims and facts
22 alleged in the United States Complaint in this case, as well as the matters discussed in
23 his deposition and trial testimony in Cooke. In particular, his testimony will include: his
24 departure from the FLDS Church; the treatment of non-FLDS members living in the
25 community by Defendants city officials, FLDS Church Security, the CCMO, and other
26 community members; consequences of losing membership in the FLDS Church; FLDS
27 efforts to remove him and others from UEP Trust land and related litigation; the UEP
28 Trust under Wisans administration; Defendants changed policies regarding building
18
1 permits, water connections, and subdivision after Wisans appointment as UEP Trust
2 Special Fiduciary, and the UEP Trusts inability to complete unfinished homes on UEP
3 Trust land; Ronald Cookes disability and disability-related housing needs; the Cookes
4 application for and selection of a property on UEP Trust land; the Cookes applications
5 and efforts to obtain utilities and a building permit for the subject property through
6
7
8
9
10
11
Defendants, their agents, employees or officials; the CCMOs enforcement of church

law against him and others, including intimidation and interference with the Cookes use
and enjoyment of the property for which they had obtained a UEP Trust Occupancy
Agreement and his arrest by the CCMO; and his interactions with the CCMO and arrests
at the Cottonwood Zoo in October 2015.
36. Taylor Nelson
Mr. Nelson is a fact witness. He is a Sergeant with the Mohave County Sheriffs
12
13
14
15
16
Office (MCSO). He is expected to testify regarding claims and facts alleged in the
United States Complaint in this case and the matters discussed in his deposition. In
particular, his testimony will include: the CCMOs arrest of Patrick Pipkin and Andrew
Chatwin, on two occasions in October 2015, for allegedly trespassing on commercial
property that Mr. Pipkin and Mr. Chatwin had permission to access; the CCMOs refusal
17 to cooperate with outside law enforcement; CCMO Chief Jerry Dargers assault on Mr.
18 Pipkin; the CCMOs handling of an incident involving Sabrina Tetzner, including that
19 CCMO officers stood by and provided insufficient police services regarding the
20 enforcement of Ms. Tetzners child custody orders.
21
22
37. Patrick Pipkin

Mr. Pipkin is a fact witness. He is expected to testify regarding claims and facts
23 alleged in the United States Complaint in this case. He is a non-FLDS member whose
24 testimony will include: the CCMOs arrest of him and Andrew Chatwin, on two
25 occasions, for allegedly trespassing on commercial property that he and Mr. Chatwin
26 had permission to access; the CCMOs refusal to cooperate with outside law
27 enforcement; and CCMO Chief Jerry Dargers assault on him.
28
19
1
2
38. Andrew Chatwin

Mr. Chatwin is a fact witness. He is a former FLDS member and has worked for
3 the UEP Trust. He is expected to testify regarding claims and facts alleged in the United
4 States Complaint in this case, as well as the matters discussed in his deposition
5 testimony in Cooke. In particular, his testimony will include: his knowledge of homes
6
7
8
9
10
11
and buildings on UEP Trust property that received water connections; treatment as a
non-FLDS person residing on UEP Trust land; Defendants interference with non-FLDS
individuals use and enjoyment of UEP Trust housing; and his interactions with the
CCMO and the arrests of him and Patrick Pipkin at the Cottonwood Zoo.
39. Lorin Holm
Mr. Holm is a fact witness. He is a former FLDS member. He is expected to
testify regarding claims and facts alleged in the United States Complaint, as well as the
12
13
14
15
16
17
18
matters discussed in his deposition. In particular, his testimony will include:

consequences of losing FLDS membership; CCMOs reports to FLDS leaders;
membership of CCMO officers and Defendants city officials in FLDS Church Security;
CCMO officers becoming FLDS Church Security members after being decertified; and
the CCMOs traffic stop of him after FLDS Church Security was following him.
40. Ron Rohbock
Mr. Rohbock is a fact witness. He is a former member of the FLDS Church and a
19 former FLDS elder. Mr. Rohbock is expected to testify regarding claims and facts
20 alleged in the Complaint, as well as the matters discussed in his deposition. In
21 particular, his testimony will include: tenets of the FLDS religion; how Warren Jeffs
22 became the leader of the FLDS Church; instructions and directives from Warren Jeffs;
23 consequences of losing membership in the FLDS Church; the treatment of non-FLDS
24 members living in the community by Defendants city officials; the CCMOs failure to
25 investigate underage marriages; the CCMOs actions regarding enforcement of his UEP
26 Trust Occupancy Agreement and harassment at his home; and the emotional distress,
27 embarrassment, and humiliation he suffered as a result of the CCMOs actions regarding
28 his home.
20
41. Mark LoManto

Mr. LoManto is an expert witness. He is a CPA with expertise in auditing,
3 accounting, and tax issues. His expertise is in the area of accounting services related to
4 government and government contracts. His additional qualifications are attached. His
5 testimony is relevant to the existence and, more particularly, the scope of a conspiracy
6
7
8
9
10
11
among City officials, FLDS leaders, and employees of TCWW to cede control over their
operations to the FLDS Church and to divert funds improperly to the FLDS Church. He
is expected to testify regarding Colorado City Mayor Joseph Allreds efforts to advance
FLDS Church interests by improperly diverting TCWW funds to a series of activities
unrelated to the business operations of TCWW. He is also expected to testify that the
value of the TCWW funds diverted to other than TCWW business operations totaled
$1,729,987.29.
12
42. R. Brian Jessop
13
14
15
Mr. Jessop is a Hildale City Council member. The United States may present Mr.
Jessops deposition testimony at trial. As such, the United States designates the follow
deposition testimony by page and line numbers:
16
6:14-7:18
9:8-9:10
25:20-27:16
17
18
19
20
21
22
23
24
25
26
27
The United States recognizes that this Court previously issued an order regarding Mr.
LoMantos testimony. See Order, Hildale Defendants Motion in Limine; Proposed
Testimony of LoManto at 2 (Mar. 17, 2015), ECF No. 606. However, [i]t is well settled
law that rulings on motions in limine are provisional. Such rulings are not binding on the
trial judge [who] may always change his mind during the course of a trial. BNS Ry. Co.
v. Quad City Testing Laboratory, 7-CV-170, 2010 WL 4337827, at *1 (D. Mont. Oct. 26,
2010) (quoting Ohler v.United States, 529 U.S. 753, 758 n.3 (2000)). This Courts earlier
order was based in part on the Courts finding that the United States has not
demonstrated . . . any connection between [the] alleged diversion of [TCWW] funds and
an alleged water shortage. Id. at 2. The United States intends to prove that connection at
trial. The United States further intends to prove that Mayor Joseph Allreds diverting
funds was in furtherance of a conspiracy with the FLDs Church. Proof of these facts will
make Mr. LoMantos testimony relevant.
28
21
29:8-29:24
33:20-34:16
38:6-40:2
41:14-44:17
47:5-49:2
49:12-50:18
54:19-57:3
60:1-62:8
64:3-65:12
70:14-70:19
76:19-88:23
88:24-89:20
90:6-92:4
92:5-94:9
94:10-94:23
96:5-97:22
99:15-101:2
103:20-104:22
7
8
9
10
11
111:5-112:22
43. Jack Harris
Mr. Harris is a rebuttal expert witness for the United States. He is the former
Chief of the Phoenix Police Department, the former Public Safety Manager for the City
of Phoenix, and is an expert in police policies, practices, procedures, and administration.
His additional qualifications are attached. He is expected to testify consistent with the
12
13
14
15
16
expert opinions provided in his report and in his deposition in this case. He reviewed the
expert report and opinions offered by the Defendants police-procedures expert, Greg
Meyer, and is prepared to rebut those opinions. He is prepared to testify, among other
things, that Greg Meyer: did not address appropriately all the police misconduct issues
involved in this case; did not address the extent to which CCMO policies and training
17 failed to address recurring policing issues associated with UEP Trust property; did not
18 consider adequately that the CCMO waited until 2007 to include non-discrimination
19 language in its policy manual; did not consider adequately the extent to which CCMO
20 officers omitted data from their reports; did not consider the extent to which CCMO
21 officers engaged in, ignored, or failed adequately to investigate illegal acts; did not
22 adequately consider evidence that the CCMO was taking direction from FLDS leaders or
23 sharing law enforcement resources with the FLDS Church; did not consider evidence
24 that the CCMO fails to cooperate with outside law enforcement; and did not adequately
25 consider the CCMOs seizure of property without due process.
26
27
44. Kenneth Spiers

Mr. Spiers is a rebuttal expert witness for the United States. He is the Vice
28 President of Bowen Collins & Associates, Inc., and he is a licensed professional
22
1 engineer. He has expertise in municipal water systems. His additional qualifications are
2 attached. Mr. Spiers evaluated the report produced by Agua Southwest, LLC on
3 Defendants behalf. He is expected to testify consistent with the expert opinions
4 provided in his report and his deposition in this case. His testimony will include that:
5 the Cities failed to act reasonably when they limited new water connections; the Cities
6
7
8
failed to timely improve and update their water system; and it is not sensible or
economically feasible for the UEP Trust to construct, operate, and maintain a separate
parallel water system.
9
10
11
The United States will also call records custodians, as necessary, to admit
documents produced during discovery, including custodians from the Mohave County
Sheriffs Office, the Washington County Sheriffs Office, South Central
12
Communications, American West Bank, and the State Bank of Southern Utah.
13
14
Respectfully submitted this 2nd day of November, 2015,
15
R. TAMAR HAGLER
CHRISTY E. LOPEZ
Deputy Chiefs
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17
18
ERIC W. TREENE
Special Counsel
19
/s/ Jessica Clarke

SEAN R. KEVENEY
JESSICA CLARKE
MATTHEW J. DONNELLY
EMILY M. SAVNER
SHARON I. BRETT
United States Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, NW
Washington, DC 20530
Phone: (202) 305-4013
Facsimile: (202) 514-1116
E-mail: jessica.crockett@usdoj.gov
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CERTIFICATE OF SERVICE
I certify that on November 2, 2015, I caused a copy of the foregoing to be sent by
the Courts ECF system to the following:
Jeffrey C. Matura
Asha Sebastian
Melissa Jane England
Graif Barrett & Matura, P.C.
1850 North Central Avenue, Suite 500
Phoenix, Arizona 85004
Attorneys for Defendant Town of Colorado City
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8
9
10
R. Blake Hamilton
Ashley M. Gregson
111 East Broadway, Suite 900
Salt Lake City, Utah 84111
Attorneys for Defendants City of Hildale and Twin City Water Authority
11
/s/ Jessica Clarke

JESSICA CLARKE
Attorney for the United States
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Case 3:12-cv-08123-HRH Document 758-1 Filed 11/02/15 Page 1 of 18
RESUME AND AMPLIFICATION
OF
JOSEPH A. DeLOPEZ
ASSIGNMENT BACKGROUND
31 JANUARY 2011MARCH 2013
Vice Chancellor, Safety and Security, City Colleges of

Chicago
25 MARCH 2002JANUARY 2011
Chief of Police, Village of Winnetka
1 FEBRUARY 200016 FEBRUARY 2002
Deputy Superintendent, Chicago Police Department
30 JULY 199831 JANUARY 2000
Deputy Chief, Patrol Administration
26 MAY 199529 JULY 1998
Commander, 23rd District
13 JULY 199225 MAY 1995
Commander, Training Division
20 MAY 198912 JULY 1992
Commander, 10th District
26 JANUARY 198819 MAY 1989
Deputy Chief, Patrol Division, Area 4
12 JULY 198525 JANUARY 1988
Commander, 14th District
16 AUGUST 198411 JULY 1985
Youth Division, Commanding Officer, Area 5 Youth
12 JULY 198415 AUGUST 1984
20th District, Acting Watch Commander
16 MAY 198411 JULY 1984
13th District, Acting Watch Commander & Field Lieutenant
3 MAY 198415 MAY 1984
Promoted to the rank of Lieutenant, attended Pre-service

Lieutenants Training School
28 MAY 19812 MAY 1984
Youth Division, Watch Commander and Field Supervisor,

Area 4 Youth Section
2 APRIL 198127 MAY 1981
18th District, Patrol Supervisor
26 JUNE 19801 APRIL 1981
Traffic Division, Watch Commander, Public Vehicle and

Major Accident Investigations Section
16 JUNE 198026 JUNE 1980
Training Division Awaiting permanent assignment
13 SEPT 1979Traffic
14 JUNE 1980
Northwestern University Traffic Institute, 9 month Police

Administration Training Program
OCTOBER 197813 SEPT 1979
Detailed to Training Division. Assisted in the coordination of

Cardiovascular Health Program for Police Department
JUNE 1977OCTOBER 1978
13th District, District Supervisor
MAY 1977JUNE 1977
Promoted to rank of Sergeant, attended Pre-service

Sergeants School
OCTOBER 1973MAY 1977
Special Operations Group, Tactical Section North
NOVEMBER 1971OCTOBER 1973
14th District, Patrol Officer
14 JUNE 1971NOVEMBER 1971
Basic Recruit Training
14 JUNE 1971
Appointment Date to Chicago Police Department
(For Additional Information See Amplified Resume)
EDUCATION
Lewis University, Criminal/Social Justice

Masters Degree Program
Degree:
M.S. Criminal Justice
1988 - 1992
Police Executive Research Forum

Senior Management Institute for Police
June 1991 July 1991
Degree:
Certificate, Executive
Strategies Management
Northwestern University Traffic Institute

Degree:
Certificate, Traffic Police
Administration Training Program
Activities:
Class Social Co-Chairman
1979 - 1980
University of Illinois at Chicago Circle

Degree:
B.S. in Management
Honors:
Dean's List
Activities:
University swimming and water
Polo teams, intramural
wrestling
1965 - 1969
1961 - 1965
DePaul Academy
Graduated from Pre-Engineering College
Prep Program in upper 5% of class
Other Training
and
Certification:
Numerous Chicago Police Department

Professional Certificate Extension
Courses
Blood Pressure Technician Training
and Certificate, Chicago Heart Assoc.
Cardiopulmonary Resuscitation
Instructor Training and Certificate
Police Instructor Training Course
Certificate
Illinois State Police Academy,
Dimensional Management Training
and
Law Enforcement Officers Training

School-Media Relations Course
One Minute Managers Seminar
Promotional Assessor Training

Chicago Police Department
Cook County Department of
Personnel
Illinois State Police
Metro Dade Police Department
International Association of
Chiefs of Police
PERSONAL
Born:
19 May 1947, Chicago, Illinois
Physical:
Height: 5/10", Weight 165
Health:
Excellent
Married, 14 June 1969 (5 Children)
Marital Status:
Own Home
Residence:
Hobbies:
Racquetball, swimming, running
Adjunct Professor of Criminal

Justice, University of Illinois at
Chicago,- 1994
Additional Work
Experience:
Illinois Police Association

Affiliations:
Present and
Past
Illinois Association of Chiefs of Police

International Association of Chiefs of
Police
University of Illinois Alumni Association
Senior Management Institute for Police
Alumni Association
Latin American Police Association

St. Jude Police League
Northwestern University Traffic Institute
Alumni Association
Hispanic Institute of Law Enforcement
Hispanic American Police Command Officer's
Association
Former Advisory Board Member, General Woods

Boys Club
Civic:
Past Program Chairman Immaculate Conception

Parent's Club
Awards:
Chicago Crime Commission Public Service

Aware
Chicago Park District Recognition Award
Certificate of Appreciation, Logan Square
Lions
Board of Education Award of Appreciation

American G.I.Forum Award
Little Village Chamber of Commerce
Outstanding Performance Award
Pilsen Neighbors Community Council Public

Service Leadership Award
12th Ward Public Service Award
U.S. Postal Service Award of Appreciation
Concerned
Award
Citizens OfLittle Village Service
La Mexicana Radio Citizen of the Week
La Tribuna de Chicago Newspaper Citizen of

the Week
Chicago Police Department Youth Division

Role Model Recognition Award
2 Chicago Police Department Unit Meritorious

Awards
2 Chicago Police Department Commendations

Chicago Police Department Fitness Award
Chicago Police Department Appearance Award
Numerous Chicago Police Department Honorable
Mention Awards
AMPLIFIED RESUME
AMPLIFIED
RESUME
JOSEPH A. DeLOPEZ
31 January 2011-March 2013

Vice Chancellor, Safety and Security
City Colleges of Chicago
Hired by City Colleges of Chicago to coordinate the
centralization and re-organization of the Office of Safety and
Security. The City Colleges of Chicago system is comprised of
eight primary locations and six satellite locations serving a
student population of approximately 120,000 and a faculty and
staff population of approximately 6000. The Office of Safety
and Security provides all of the public safety needs of the
City College system through the employment of a combination of
500 off-duty and retired members of the Chicago Police
Department, the Illinois State Police Department and the Cook
County Sheriffs Department. The annual operating budget for
the Office of Safety and Security is $11.5 Million.
25 March 2002 January 2011

Chief of Police, Village of Winnetka
AS Chief of Police for the Village of Winnetka, served a
community of 12,500 residents. The Village of Winnetka is
located 14 miles from downtown Chicago along the shores of Lake
Michigan. The Winnetka Police Department had a complement of
36 personnel and a total budget of $6.3 Million. The
Department was nationally accredited by the Commission on
Accreditation for Law Enforcement Agencies (CALEA). During my
tenure as Chief in Winnetka, I re-organized the Police
Department, enhanced training of personnel through a
collaborative effort with Oakton Community College and the
Northeastern Illinois Public Safety Training Academy (NIPSTA),
where I served in the roles of President, Vice-President and as
an Officer of the NIPSTA Foundation.
AMPLIFIED
RESUME
JOSEPH A. DeLOPEZ
1 February 2000 - 16 February 2002

Bureau of Technical Services
Assigned as Deputy Superintendent, Bureau of Technical

Services. This position coordinates one of the five
Bureaus that comprise the Police Department. The
Bureau consists of the Communications Division, the
Electronics and Motor Maintenance Division, Evidence
and Recovered Property Section, and the General
Support Division.
Duties included coordinating police communications

issues and needs with the Chicago Office of Emergency
Communications, which includes the Alternate Response
Program. Respondent was also responsible for
overseeing the maintenance and replacement of the
Department's vehicle and Marine Unit fleets, and
establishing and implementing policy for management of
the Central Detention Section, Evidence and Recovered
Property Section, Equipment and Supply Section and the
Reproduction and Graphic Arts Section.
Respondent also coordinated the Chicago Police

Department's Capital Development and Improvement
Programs, overseeing construction of and repairs to
Department facilities. Responsibilities also required
overseeing a personnel and non-personnel budget of
over 60 Million dollars.
30 July 1998 - 31 January 2000

Patrol Division Administration
Assigned as Deputy Chief of Patrol Administration.

Responsibilities included the coordination of all
administrative functions for this 10,000 member
Division. This position entailed serving as a member
of the Department's labor contract negotiation team,
member of Chicago's Community Policing Management
Team, member of the Information Systems Development
Group, and numerous other departmental and intergovernmental planning and oversight groups.
AMPLIFIED RESUME
JOSEPH A. DeLOPEZ
26 May 1995 - 29 July 1998
23rd District:
Assigned to the 23rd District, Town Hall, as the

District Commander. Responsibilities included
overseeing the implementation ofan innovative
com unity policing initiative, known as Chicago's
Alternative Policing Strategy (C.A.P.S.). In
addition, direction and leadership of
approximately 300 sworn and civilian personnel,
adherence to and implementation of labor contract
provisions, and allocation of resources to ensure
that crime conditions and quality of life issues
were addressed were primary responsibilities.
Through use of joint community-police problem

solving meetings, problems were identified and
prioritized and strategies planned. Addressing
and solving problems included liaison with other
city agencies, chambers of commerce, churches and
community groups as well as individual community
members.
13 July 1992 - 25 May 1995
Training Division:
Assigned as Commander of Training Division.

Responsibilities included managing and directing the
implementation and performance of the programs of the
Chicago Police Department's Training Division.
The Commander also represents the Superintendent of

Police when sitting on the Illinois Law Enforcement
Training and Standards Board located in Springfield,
Illinois. Duties also entailed serving as Secretary
of the Chicago Police Department's Academic Selection
Board.
AMPLIFIED RESUME
JOSEPH A. DeLOPEZ
The undersigned conferred with management and

supervisory personnel to determine training needs;
implemented and monitored new training programs;
managed and directed research into new training
methods and techniques; supervised the development
of training policies and procedures and monitored
their implementation; oversaw and implemented
assessment of any training or educational needs and
subsequent programs.
As Commander of the Training Division, the selection,

training and supervision of a staff of approximately
120 persons, and the preparation and control of the
Training Division budget was a primary responsibility.
20 May 1989 - 12 July 1992

10th District:
Assigned to the lOth District, Marquette, as the

ensuring the provision of quality police services to
the community in conformance with the policies and
procedures of the Chicago Police Department. The
reporting subject was responsible for the guidance and
direction of over 300 sworn and civilian personnel in
an effort to maximize the efficiency and effectiveness
of delivery of police services to a multi-racial and
multi-ethnic population of approximately 140,000
persons.
The undersigned utilized Mission-Oriented Directed

Patrol, Selective Enforcement Techniques, and
Strategic Foot Patrol in order to deal with crime
conditions and improve the quality of life for
community residents.
Guidance and training of subordinates by Watch

Commanders, Field Lieutenants, and Sector Sergeants
was assured, as well as effective training and
evaluation of Probationary Police Officers by Patrol
Specialists.
AMPLIFIED RESUME
JOSEPH A. DeLOPEZ
The reporting subject established a liaison with other

city agencies, Chambers of Commerce, Churches, and
Community Groups in an effort to minimize or eliminate
the adverse impact of the multitude of social,
economic, and crime problems affecting the Lawndale,
Little Village, and the Pilsen Communities which
comprise the Marquette District.
During the time assigned as District Commander, the

undersigned received over 50 letters of Commendation,
8 Awards of Appreciation, and The Pilsen Neighbors
Community Council Public Service Leadership Award.
26 January 1988 19 May 1989

Patrol Division:
Assigned as Deputy Chief of Patrol, Area 4. Area 4

was comprised of the lOth, 11th, 12th, and 13th
Districts and covered approximately one-sixth of the
geographic area of the City of Chicago.
Responsibilities included overseeing the activities of
four District Commanders to ensure the effective and
efficient delivery of police services to the
community. The writer was responsible for the
guidance and direction of approximately 1,400
personnel, and implemented innovative approaches to
deal with crime and quality of life issues.
12 July 1985 - 26 January 1988

14th District:
Assigned to the 14th District, Shakespeare, as the

ensuring the provision of quality police services to
the community in conformance with the policies and
procedures of the Chicago Police Department. The
reporting subject was responsible for the guidance and
direction of 266 sworn police personnel and two
civilian employees in an effort to maximize the
efficiency and effectiveness of delivery of police
services to a multi-racial and multi-ethnic population
AMPLIFIED RESUME
JOSEPH A. DeLOPEZ
of approximately 155,000 persons. The undersigned

assured the implementation of mission-oriented
directed patrol, Supervisory guidance and
responsibility for subordinates by Watch Commanders,
Field Lieutenants, and Sector Sergeants, and a
continuous analysis of the effectiveness of the
enforcement efforts
The reporting subject also worked close

with other
City Agency heads as well as leaders of
community-based organizations and service agencies to
seek solutions to, or prevent, the many social,
economic, and crime problems affecting the Shakespeare
Community.
During the tenure as District Commander of the 14th

District, the undersigned received over 60 letters of
commendation, five awards of appreciation, and the
Chicago Crime Commission Public Service Award.
16 August 1984 - 12 July 1985

Youth Division:
Assigned to the Youth Division, Area 5 Youth Section,

as the Commanding Officer. Duties consisted of
decision making, guidance, and implementation at the
Area level of policies and procedures adopted by the
Chicago Police Department and the Commander of the
Youth Division. The reporting subject was responsible
for the coordination of the efforts of seven
Sergeants, 40 Youth Officers, and 11 School Patrol
Officers so that the greatest possible utilization of
personnel and equipment was directed toward the basic
police functions of aggressive and preventive patrol
and prompt and efficient response to calls from other
units for youth services.
The reporting subject also participated actively and

positively with community groups and agencies in programs
designed for the prevention of juvenile delinquency and
related youth problems. To this end, the reporting subject
has been a member of the Mayor's Task Force on Youth Crime
AMPLIFIED RESUME
JOSEPH A. DeLOPEZ
through the Area 9 Youth Advisory Council, a member of

the Board of Education District 4 Gang Committee, a
member of the Mayor's Police Community Relations
Committee for the Fourteenth District, and regularly
met with the Board of Education Superintendents and
Principals and with representatives of community based
youth agencies.
During the time as Commanding Officer of Area 5 Youth,

the undersigned received numerous letters of
commendation, a Recognition Award from the Chicago
Park District, a Service Award from School District 4,
and a Certificate of Appreciation from the North
Central Management Association for serving as an
Evaluation Team Member.
12 July 1984 - 16 August 1984

20th District:
Duties consisted of decision making and coordination

of efforts of a complement of officers assigned to
patrol and clerical functions.
16 May 1984 - 12 July 1984

13th District:
Duties consisted of field supervision and decision

making with regard to the patrol functions of six
Sergeants and 30 Police Officers. During the time
assigned, reporting subject also commanded one-half of
the Spanish Company assigned to security at the
Humboldt Park Puerto Rican Week Festival.
3 May 1984 - 16 May 1984:
Pre-service Lieutenant's Training.
AMPLIFIED RESUME
JOSEPH A. DeLOPEZ
28 May 1981 - 3 May

Youth Division:
1984
Assigned to the Youth Division, Area 4 Youth Section,

in the capacity of Watch Commander and Field
Supervisor. Duties consisted of decision making,
supervision and guidance of Youth Officers involved in
a broad spectrum of juvenile related situations. Area
of responsibility was approximately one-sixth of the
City of Chicago, encompassing four police districts.
The reporting member was responsible for the proper
investigation, classification and coordination of
missing persons, child abuse, family related and
juvenile related case investigations. Member worked
directly with the Youth Area Commander to assure that
unit goals were met and that manpower was allocated
efficiently and effectively.
Additionally, the reporting subject was a member of

the City of Chicago Department of Personnel Police
Officer Screening and Assessment Team.
Duties consisted of conducting a one-day Assessment

Center to observe and evaluate applicants for the
position of Police Officer. This reporting subject
has served both as an Assessment Team Member, and as
Assessment Team Leader. The opportunity also arose to
serve on the Assessment center panel for the Cook
County Civil Service Commission during May, 1983.
2 April
1981 18th
1981 - 28 May
District:
Temporary assignment. Duties consisted of field

supervision of uniformed patrol officers and decision
making as a first-line supervisor. Reporting member
was routinely utilized in the capacity of Acting
Lieutenant.
AMPLIFIED RESUME
JOSEPH A. DeLOPEZ
26 June 1980 - 2 April 1981

Traffic Division:
Assigned to the Traffic Division upon completion of

nine month course of study in P o l i c e A dministration at
the Northwestern University T raffic Institute.
Duties
in the Traffic Division included assignments as Watch
Commander, first in the Public Vehicle Section, and
then in the Major Accident Investigation Section.
This member was exposed to various aspects of
investigation, and coordinated manpower efforts in
order to achieve desired results in a cost-effective
manner. Member assumed progressively more
responsibility for administrative activities.
13 September 1979 - June 1980

Northwestern University Traffic Institute:
Assigned to Traffic Police Administration Training

Program at Northwestern University Traffic Institute.
While at the Institute, the nine-month course of study
exposed subject to advanced managerial techniques and
practices which included graduate level course
material.
October 1978 - September 1979

Training Division:
While detailed to the Training Division, this member

was assigned to progressively intense and responsible
functions in the area of in-service training.
Initially, reporting member was assigned the duty of
assisting in coordination of Cardiovascular Health
Program. Subsequently, this supervisor took on the
added responsibility of Cardiopulmonary Resuscitation
Team Supervisor, Use of Force Instructor, and assisted
in the revision of Civil Disorder Training for Special
Operations Group and District Tactical Units.
AMPLIFIED RESUME
JOSEPH A. DeLOPEZ
While involved in training, member received

commendations from the Chicago Heart Association for
contributions and efforts at reduction of heart
disease and related disabilities, and a Chicago Police
Department Commendation for c ardiopulmonary resuscitation
t raining efforts.
June 1977 - October 1978

13th District:
Upon completion of pre-service Sergeant's training,

member was assigned to the 13th District. Duties
consisted of field supervision and decision making.
Upon demonstration of abilities, member was routinely
utilized in the capacity of Acting Field Lieutenant.
May 1977 - June 1977:
Pre-service Sergeant's Training.
October 1973 - May 1977

Special Operations Group, Tactical Section North:
Duties involved selective enforcement of specifically

identified crime problems, sometimes requiring covert
techniques. Member was required to demonstrate
ability to assume responsibility and work with minimal
amount of supervision. Accumulated numerous Honorable
Mention Awards and citizens letters of commendation,
and earned the Unit Meritorious Citation.
November 1971 - October 1973

14th District:
Worked as patrol officer, enforcing laws and

ordinances, providing needed public safety and
community services. Received several Honorable
mention Awards for effort in crime reduction, and was
eventually assigned to attend Chicago Police
Department Spanish Language School.
AMPLIFIED RESUME
JOSEPH A. DeLOPEZ
June 1971 - November 1971

Basic Recruit Training:
While assigned to Recruit Training, earned distinction of

maintaining the distinction of Class Commander throughout
the training period.
Curriculum Vitae
Zachary D. Renstrom, PE., Esq.
October 29, 2015
Personal Contact Information
Zachary D. Renstrom,
205 E Tabernacle Suite 4
St. George Utah, 84770
435-673-2337 Office
435-673-3161 Fax
Academic Background
1997 Weber State University, Ogden, Utah
Associates in General Studies
1999 University of Utah, Salt Lake City, Utah
BS- Civil Engineer
2002 Washburn University, Topeka, Kansas
Juris Doctor
Professional Licenses/ Affiliations
Utah Professional Engineer
Utah professional structural engineer
Arizona Professional Engineer
Utah State Bar
Nevada State Bar
United State Patent and Trademark
375326-2202
375326-2202
49162
9726
8236
50395
Professional Affiliations
ASCE American Society of Civil Engineers
APWA American Public Works Associations (Past President of Southern Utah Branch)
ACEC American Council of Engineering Companies
ITE
Institute of Transportation Engineers
Utah State Bar
Nevada State Bar
United States Patent Bar
Curriculum Vitae
Professional Experience
2015 - Current Washington County
2015 - Current Washington Water Conservancy District
2004 2015
Bush and Gudgell Inc. St. George, Utah
2002 2004
Lincoln, Gustafson & Cercos, Las Vegas, Nevada
2002
U.S District Court of Topeka, Kansas
2000
Weber County, Ogden Utah
1998 1999
Bountiful City, Bountiful Utah
Commissioner
Board Member
Engineer/ In-house Council
Attorney
Legal Externship
Engineering
Engineering
Pay Rate
I am compensated at an hourly rate of $165.00. Deposition or trial I am compensated at
an hourly rate of $265.00. All costs are billed at cost. All out of town travel will be billed
at a minimum of eight hours per day.
Project Experience
Commercial
Sportsmans Warehouse
Utah State Liquor Store
Utah State DMV
Quality Business Building
Utah State Tax Commission
Checker Auto
Stone Brook Town Square
Pine Valley Resort
Olive Garden
Fort Peirce Industrial Park
Grease Monkey
B&G Gateway
Washington County Library
Washington County Sheriffs Building
Snow Field Excavation Pit
Red Rock Commons
Dicks Sporting Goods
Taco Bell
PM Storage Sheds
George Washington Academy Charter School
Airport Technology Park
Bullfrog -Lake Powell National Park
Hunter Communication building
Curriculum Vitae
Residential
Tonaquint Terrace Subdivision
Tonaquint Valley Subdivision
Tonaquint Heights Subdivision
Franklin Place Subdivision
Royal Pines Subdivision
Frienze Subdivision
Hidden Valley Subdivision
Shoal Creek Subdivision
Eseclara Subdivision
Highlands Subdivision
Red Rock Park Subdivision
Comanche Cliffs Subdivision
Foremaster Ridge Subdivision
Kayanta Subdivision
The Trails Subdivision
Westbend Subdivision
Last sun Subdivision
Rio De Sion Subdivision
Heritage Estates Subdivision
Sunstone Master Plan Community
Bella Vista Subdivision
Artesia Terrace Subdivision
Bella Terrazza Subdivision
Cotton Mannor Subdivision
High Chapprral Subdivision
Silver Falls Subdivision
Silver Falls Subdivision
LaVerkin Wash Subdivision
Los Colinas Subdivision
Palisades Subdivision
SteepleChase Subdivision
Stucki Farms Subdivision
Boulder Cove Subdivision
Whisper Ridge Subdivision
Crimson Cove Subdivision
Red Cliffs Park Subdivision
Curriculum Vitae
Municipal/ Governmental improvement projects

Indian Hills Drive
Little Valley Road Ways
3000 E Road Way design
St. George Airport Feasibility Analysis
Half Way Wash Flood Design
1350 S Road Way design
Dixie Downs Road Drainage
English Oaks Wash
Red Hawk Outfall Sewer Line
Hilldale City Infrastructure Feasibility Study
Colorado City Infrastructure Feasibility Study
Little Valley Road Ways
Delta High School, Utah
Millard High School, Utah
Telegraph Rd, Washington, Utah
400 N Road, Bountiful City, Utah
Washington Fields Rd, Washington, Utah
Brookside, Utah -Water System
Pine Valley, Utah -Water System
Bountiful City, Utah -Water System
Enterprise, Utah -Water System
Dalton Wash, (Virgin City, Utah) - Water System Feasibility Analysis
3000 E Roadway improvement, St. George, Utah
1450 S Roadway improvement, St. George, Utah
Mountain Meadow Memorial, Washington County, Utah
Expert Witness
United Effort Plan Trust
Sky vs. Houston
Santa Clara City vs. Stucki Lane
Rogers vs. Lions Gate development
Sunset & Westridge, vs. El Pollo Loco,
LD, LC vs. Rincon Del Sol
LC, LC vs. Colman
Ronald Cooke, et al. v. Town of Colorado City, et al.
Eaglebrook Corporation et al. vs. Ledges Land LLC, et al.
Sienna Hills at Sienna Hills v. Sienna Heights LLC. et al.
Curriculum Vitae

Appendix II
Page 1
MARK LOMANTO - CURRICULUM VITAE
Mark F. LoManto
Telephone:
Office (215) 579-8555
EMPLOYMENT HISTORY
ML Weekes & Company, PC
Principal
Jan. 2000 - Present
Ernst & Young LLP

Government Contract Services/Sr. Mgr.
Sep.1994 - Jan. 2000
GE Aerospace Group (acquired by Martin Marietta in 1994)

Astrospace Div./ Mgr, Program Finance
Sept. 1992 - Aug. 1994
Astrospace Div./ Mgr, Contract Practices
Jun. 1990 - Aug. 1992
Govt Electronics Systems Div./ Mgr, Govt Accounting
Jun. 1988 - May 1990
Harris/RF Communications
Senior Analyst
Mar.1986 - May 1987
Defense Contract Audit Agency

Senior Auditor
Dec. 1981 Mar. 86
US Dept of Labor/Office of Inspector General

Auditor
Jul. 1979 Dec. 81
EDUCATION
B.B.A., Accounting
Niagara University
May 1979

Appendix II
Page 2
PROFESSIONAL CERTIFICATES & ASSOCIATIONS

Professional Certifications & Licenses
Certified Public Accountant licensed in the Commonwealth of Pennsylvania
Professional Association Memberships
American Institute of Certified Public Accountants (AICPA)
Pennsylvania Institute of Certified Public Accountants (PICPA)
American Bar Association (ABA)
National Contract Management Association (NCMA)

Appendix II
Page 3
MARK F. LOMANTO
Addendum
EMPLOYMENT HISTORY
ML Weekes & Company, PC
I am presently a Principal (and co-founder) of the accounting firm of ML Weekes &
Company, which is headquartered in Stamford, Connecticut. The firm provides
auditing, accounting, tax and advisory services to various clients who have contracts or
grants with federal, state, and local government agencies. The firms client base spans
various industries including Aerospace & Defense, Healthcare, and the Public Sector.
My services include auditing, accounting and tax services predominately related to the
government industry. My advisory services include the development and review of
indirect rates, analysis of billing, estimating, and project accounting systems, proposal
preparation, interpretation of public laws and procurement regulations, and assistance
in the resolution of disputes, including those requiring litigation.
Ernst & Young LLP

My most recent position was a Senior Manager in Ernst & Young LLP's Government
Contract Services practice. In this capacity I provided a variety of services to
contractors doing business with the Government. While at Ernst & Young, I assisted
clients on numerous federal contract matters, including the preparation, review and
settlement of contract claims and equitable adjustments; cost or pricing data analysis;
litigation support; and determining compliance with Government procurement
regulations and Cost Accounting Standards (CAS). I have also supported clients in the
development of indirect expense rates, as well as indirect cost submissions.
I have served numerous clients, including those specializing in large vehicle and
aircraft manufacturing, complex electronic systems, as well as pharmaceutical
companies, healthcare insurers and not-for-profit organizations.

Appendix II
Page 4
MARK F. LOMANTO
Addendum
EMPLOYMENT HISTORY - continued
GE Aerospace Group (acquired by Martin Marietta in 1994)

As Manager, Program Finance (government program finance lead) for GE Aerospaces
Astrospace Division in East Windsor, NJ (a large manufacturing facility producing
satellites for the government), I maintained financial reporting responsibility for a
number of major government projects which included customer reports such as
Contract Funds Status Reports (CFSR), Cost Performance Reports (CPR),
Cost/Schedule Control Systems Criteria (C/SCSC); as well as all internal financial
reporting applicable to the projects.
As the Manager, Contract Practices (government compliance lead) for GE Aerospaces
Astrospace Division in East Windsor, NJ (a large manufacturing facility producing
satellites for the government), I was responsible for all divisional government
compliance matters including: primary interface with DCAA and DACO, final indirect
rate preparation and certification, problem analysis and resolution, interpretation of
public laws and procurement regulations, and ethics training. I also chaired the
Divisions Government Compliance Committee, which was formed to ensure that all
know and potential compliance issues were being addressed.
As the Manager, Government Accounting for GE Aerospaces Government Electronics
System Division in Syracuse, NY (a large manufacturing facility producing radar and
sonar systems for the government), I reported directly to the Manager, Contract
Practices (government compliance lead) and assisted in many government compliance
matters including: primary interface with DCAA and DACO, final indirect rate
preparation and certification, problem analysis and resolution, interpretation of public
laws and procurement regulations, and ethics training.
Harris/RF Communications
As a senior financial analyst for Harris Corporation/RF Communications in Rochester,
NY (a midsize manufacturing facility producing radio and communication equipment
for the government), I was responsible for all Government compliance related issues,
include the preparation and response to any audit issues related to the Companys
pricing proposals, indirect rate submissions and other DCAA cost and systems reviews.

Appendix II
Page 5
MARK F. LOMANTO
Addendum
EMPLOYMENT HISTORY - continued
Defense Contract Audit Agency

As a DCAA senior auditor at IBMs Federal Systems Division in Owego, NY (a large
manufacturing facility producing electronics for the government), my oversight
responsibilities included audits related to contract proposals, indirect rate submissions,
cost estimating systems and various systems and control reviews.
US Dept of Labor/Office of Inspector General

As an IG auditor in the USDOLs Chicago Regional Office, my oversight responsibilities
primary focused on financial and compliance audits related to state and local government
agencies and non-for-profit organization receiving funds under the Comprehensive
Employment and Training Administration (CETA) program.

Appendix II
Page 6
MARK F. LOMANTO
PRIOR EXPERT WITNESS TESTIMONY AND LITIGATION

SUPPORT ENGAGEMENTS
United States of America ex rel, Robinson, et al. v. Northrop Corporation, US District Court,
Northern District of Illinois*
Martin Dresser v. DRC and Albert Rand, US District Court, District of Massachusetts
United States of America ex rel. Educational Career Development Inc. v. Central Florida
Regional Workforce Development Board, Inc. and Workforce Central Florida Inc., US
District Court, Middle District of Florida
US ex rel, Yannacopoulos v. General Dynamics and Lockheed Martin Corporation, US District
Court, Northern District of Illinois
Metro Machine Corp., GAO File No. B-297879
CACI Inc. v. Robert Donovan and Multimax Corporation, Arlington County (VA) Circuit
Court*
United States of America v. Robert P. Knowles, US District Court, District of Connecticut
United States of America ex rel. Becker v. Tools & Metals, Inc., US District Court, Northern
District of Texas
United States of America v. Nicholas Baroni and Keith Baroni, US District Court, District of
Maryland
Richard J. Ford and FedSys, Inc. v. Jerry W. Torres and Torres Advanced Enterprise Solutions,
LLC, US District Court, Eastern District of Virginia*
United States of America v. Michael Walker, US District Court, District of Eastern
Pennsylvania*
United States of America ex rel. Melan Davis and Brad Davis v. Erik Prince, Blackwater
Security Consulting, LLC, et al. US District Court for the Eastern District of Virginia
* Includes testimony.
JACK HARRIS
CURRICULUM VITAE
KENNETH L. SPIERS, P.E.

VICE PRESIDENT
BOWEN COLLINS & ASSOCIATES, INC.
EDUCATION
B.S., Civil Engineering, Brigham Young University, 1976
PROJECT EXPERIENCE
Municipal Water Supply
Arsenic Removal Study Washington County Water Conservancy District (St. George, Utah)
General Services Virgin Valley Water District (Mesquite, Nevada)
General Services Moapa Valley Water District (Overton, Nevada)
Jordan Aqueduct Terminal Reservoir 33 MG Expansion Central Utah Water Conservancy District
(Utah)
Huntington Water Treatment Plant Upgrade Energy West, Inc. (Utah)
7800 South Water Transmission Pipeline City of West Jordan (Utah)
Butte and Deer Mountain Booster Pumping Stations Jordanelle Special Service District (Utah)
Water Treatment Plant No. 3 Upgrade Weber Basin Water Conservancy District (Utah)
Water System Master Plan City of Ogden (Utah)
10 MG Reservoir Metropolitan Water District of Salt Lake City (Utah)
Water System Master Plan Bona Vista Water Improvement District (Utah)
Water System Feasibility Studies Jordanelle Special Service District (Utah)
Water System Master Plan City of North Logan (Utah)
City Water Supply Pipeline City of Preston (Idaho)
Water Rate Study City of Logan (Utah)
Water System Improvement Project City of Mendon (Utah)
Water System Improvements Project City of Pleasant Grove (Utah)
Municipal Wastewater Collection and Treatment
Jordan Basin Wastewater Reclamation Facility South Valley Sewer District
Timpanogos Water Reclamation Facility 2009 Expansion Timpanogos Special Service District
South Jordan Pump Station and Force Main South Valley Sewer District
West Regional Interceptor Sewer and Pump Station City of Logan
Pleasant Grove/Cedar Hills Interceptor Sewer Timpanogos Special Service District
Midas Pond Road Interceptor Sewer South Valley Sewer District
12300 South Interceptor Sewer South Valley Sewer District
City-Wide Sewer System, Trunkline and Pump Station City of Providence
City-Wide Sewer System and Trunkline City of North Logan
City-Wide Sewer System and Treatment Facility City of Franklin
2001 Sewer Project City of Monticello
400 South Sewer Lift Station City of Preston
Sewer Rate Study South Valley Sewer District
Storm Drainage and Flood Control
Storm Drain Master Plan, City of Hurricane
Great Salt Lake Diking Feasibility Study, Utah Division of Water Resources
Fiddlers Canyon Detention Basin, Cedar City Corporation
Dry Canyon Flood Control Project, Cedar City Corporation
Stephens Canyon Flood Control Project, Cedar City Corporation
1100 West Storm Drain Improvements, City of Woods Cross
Holmes Creek Detention Basin and Channel Improvements, City of Kaysville
Hydropower
Betasso Hydroelectric Project, City of Boulder
Preston Hydroelectric Project, City of Preston
Ralston Hydroelectric Feasibility Study, City of Arvada
First Dam Hydroelectric Feasibility Study, City of Logan
Roads and Bridges
400 East Street Improvements, City of North Logan
Center Street Improvements, City of Providence
Rudd Creek Flood Restoration, City of Farmington
800 North/UPRR Bridge, City of Clearfield
Other Projects
Little Cottonwood Water Treatment Plant HVAC Rehabilitation, MWDSLS
Maintenance Building, MWDSLS
PROFESSIONAL REGISTRATION
Professional Engineer - Utah
PROFESSIONAL ORGANIZATIONS
American Water Works Association
Water Environment Federation
American Council of Engineering Companies

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Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 1 of 24

1 Steven H. Rosenbaum (NY Bar #1901958)

R. Tamar Hagler (CA Bar #189441)

Attorneys for the United States

United States of America,

Town of Colorado City, Arizona, et al.,

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 2 of 24

19 long-time resident of the Colorado City/Hildale community. He is expected to testify

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 3 of 24

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 4 of 24

Church Security; the surveillance conducted by FLDS Church Security of non-FLDS;

6. John Nicholas Hanna

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 5 of 24

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 6 of 24

the identification of signatures of Defendants city officials; the arrest of Harvey

10. Gary Wilbanks

11. Isaac Jeffs

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 7 of 24

12. Guy Timpson

Mr. Timpson is a fact witness. He is former member of the FLDS Church, a

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 8 of 24

15. Vincen Barlow

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 9 of 24

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 10 of 24

17. Jerold N. Williams

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 11 of 24

19. Elizabeth Wayman

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 12 of 24

21. Joseph DeLopez

additional qualifications are attached. Chief DeLopez is expected to testify consistent

23. Randy Servis

22 Agriculture and investigated the CCMOs euthanization of non-FLDS member Lydia

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 13 of 24

24. Samuel Brower

26. Christopher Jessop

25 resident of the Colorado City/Hildale community. He is expected to testify regarding

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 14 of 24

employees or officials Defendants threats, intimidation and interference with the

28. Lyle Jeffs

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 15 of 24

29. Zachary Renstrom

21 County Commissioner and a licensed professional engineer. He has expertise in

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 16 of 24

31. Jinjer Cooke

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 17 of 24

32. John Cook

33. Joseph Allred

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 18 of 24

34. Patrick Barlow

Church and a former member of FLDS Church Security. He is expected to testify

Security, including by sharing surveillance equipment and information in law

17 humiliation he suffered as a result of not receiving water to his home.

35. Claude Seth Cooke

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 19 of 24

Defendants, their agents, employees or officials; the CCMOs enforcement of church

37. Patrick Pipkin

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 20 of 24

38. Andrew Chatwin

matters discussed in his deposition. In particular, his testimony will include:

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 21 of 24

41. Mark LoManto

42. R. Brian Jessop

Case 3:12-cv-08123-HRH Document 758 Filed 11/02/15 Page 22 of 24