REVISED 02050 WITNESS LIST

DEFENDANT TUCSON OFFICIALS WHO CONSPIRED TO VIOLATE PLAINTIFFS RIGHTS AND VIOLATE THE LAW

Witness

Contact

Testimony

1.
1 Mike Rankin

These Defendants conspired to

violate the law set forth in Gathright, and granted Exclusive Use
Permits to Pro Raza, Open Border conspirators who unlawfully sought to prevent Plaintiff
from speaking in Armory Park
on matters of public concern,
etc., knowing such permits violated the law and Plaintiffs
rights.

2.
2 Richard Miranda
3.
3 Lisa Judge
4.
4 Fred Gray
5.
5 Reenie Ochoa

TUCSON OFFICIALS WHO ADVISED DEFENDANT TUCSON

CITY OFFICIALS ON CONSPIRACY AND ISSUANCE OF UNCONSTITUTIONAL EXCLUSIVE USE PERMITS
Witness

Contact

Testimony

6 Judge Eugene Hays

These judges (1) provided advice and counsel to Tucson City

Defendants on how to violate
the law set forth in Gathright regarding excluding public speakers from public parks and (2) issued orders of prior restraint
later enforced by TPD officers.

7 Judge Thomas Berning

8 Judge Antonio Riojas

CIVILIAN CUSTOM AND PRACTICE WITNESSES

Witness

Contact

Testimony

Kathy McKee

Phone:

Ms. McKee has knowledge of

the custom and practice of
Tucson City Officials to employ
the Tucson Police Department to
harass, annoy, intimidate, retaliate against, or otherwise to terrify those who speak out in opposition to the Open Border policies of Tucson City Officials.
See Affidavit of Kathy
McKee enclosed on the terabyte drive.

623 582 4209

623 466 5657

10 Laura Leighton

520 881 4408

Custom and practice; Same as

McKee. See Affidavit of Kathy
McKee enclosed on the terabyte drive.

11 Manny Enriquez

520 892 6153

Custom and practice; Same as

McKee and Leighton.

12 Dr. Kevin Gilmar- 520 744 0703

tin

Dr. Gilmartin has knowledge of

the custom and practice of
Tucson City Officials, and Defendants Miranda and Rankin, to
(1) conspire to violate the law
and (2) engage in acts of first
amendment retaliation, and (3)
the Tucson City policy of cronyism. See Gilmartin Settlement, the Continuum of Compromise and other Gilmartin
Documents enclosed on the
terabyte drive.

13 Jack Harris

520 977 6727

Custom and practice; Same as

Gilmartin.

14 TPD Sgt. Easton

Custom and practice; Same as

Gilmartin, Harris.

DOCUMENT AUTHENTICATION

Witness
15 Jim Kay

Contact

Testimony

520 622 3095

Authentication of all Jim

Kay produced video listed
on terabyte drive and
posted on YouTube.

TPD OFFICERS WHO ENFORCED USE OF UNCONSTITUTIONAL EXCLUSIVE USE PERMITS IN ARMORY PARK

Witness

Contact

Testimony

16

TPD Kevin McCarthy

Defendants enforced unconstitutional exclusive use permit

on May 1, 2012

17

TPD Diana Lopez

18

TPD Paul Sayre

19

TPD Kathleen Robinson

Robinson enforced unconstitutional exclusive use permits in

2008 and 2009; also intimidated Plaintiffs landlady in
2006 resulting in Plaintiffs
eviction, loss of income and
six years of homelessness.

20

TPD Terry Rozema

These officers enforced unconstitutional exclusive use permit

on May 1, 2010, and an unconstitutional order of prior restraint issued by Judge Eugene
Hays, which had been stayed,
pending appeal, at time of enforcement.

21 TPD Stamatopoulos
22 TPD David Azuelo
23 TPD Johnson
24 TPD Woolridge

TPD OFFICERS WHO COMMITTED OFFENSES, TESTIFIED AT

PLAINTIFFS CRIMINAL PROCEEDINGS, AND ENGAGED IN
THE CUSTOM AND PRACTICE OF TPD TO GET CITIZENS
LIKE PLAINTIFF, GILMARTIN, AND HARRIS WHO CHALLENGE THE RECTITUDE OF OFFICIAL CONDUCT

Witness
25 TPD Friedman
26 TPD Dormand

Contact

Testimony
TR 9091490
These officers conspired and unlawfully seized Plaintiffs car in 2009,
as an act of first amendment retaliation and as an example of the custom and practice of TPD officers to
get citizens like Plaintiff, Gilmartin, and Harris who challenge the rectitude of official conduct.

27 TPD Flores

CR 8017672

28 TPD Kugler

These officers permitted Alan Ward

assault even though Plaintiff had a
12-1809 Injunction; then arrested
Plaintiff for engaging in self defense.
Another example of the custom and
practice of TPD officers to get
citizens like Plaintiff, Gilmartin, and
Harris who challenge the rectitude of
official conduct.

29 TPD Brad Traynor

CR 7030208

30 TPD Coleman

These Officers permitted pro-raza

demonstrators to assault Plaintiff at
rally; then arrested Plaintiff for issuing words of self- defense. Another
example of the custom and practice of TPD officers to get citizens like Plaintiff, Gilmartin, and

Harris who challenge the rectitude of

official conduct.

CONSPIRATORS / PERMIT HOLDERS WHO APPLIED TO EXPRESSLY EXCLUDE PLAINTIFF

Witness
31 Isabel Garcia

32
33
34
35
36
37

Contact

Testimony

5130 S.
Camino de
las Tierra,
Tucson Arizona
85746

Isabel Garcia instructed these

pro raza activists on (1) how
to disrupt Plaintiffs rallies, (2)
how to apply for exclusive use
permit to deny Plaintiff entry
into Armory Park, paid for permit application fees and insurPaul Teitelbaum
These are
ance at Armory Park May Day
permit ap- events from which Plaintiff was
Pancho Medina
plicants or expressly excluded, and proprosecution vided orange Pima County
John Miles
witnesses
snow fencing to encircle Arwhose con- mory Park, in furtherance of the
Wade Colwell
tact info
Tucson City Defendant conhas
been
spiracy to violate the law as per
Alexander Rodriquez
redacted
Gathright.
from recArturo Rodriquez
ords. Defendants
have contact info;
Plaintiff
does not.

MEDIA WITNESSES TO POLICE MISCONDUCT/ CONSTITUTIONAL VIOALTIONS IN ARMORY PARK

Witness
38 Bud Foster

Contact

Testimony

Tucson
News Now

Foster interviewed Plaintiff in Armory Park on May 1, 2012 and witnessed TPD misconduct on other
occasions.

520 744
1313
39 Loraine Rivera

Lorraine Ri- Rivera interviewed Plaintiff on May

vera (@lor- 1, 2006 and witnessed TPD misrainerivera) conduct, and direction of pro-raza
assault on Plaintiff, in Kennedy
twitter
Park on May 1, 2006.

40 Barbara Grijalva Tucson

News Now
520 744
1313
41 Lupita Murillo

KVOA
520 792
2270

Grijalva interviewed Plaintiff on

several occasions and viewed TPD
misconduct at Armory Park demonstrations.
Murillo witnessed Isabel Garcia
coaching witnesses at Plaintiff
criminal trial, interviewed Plaintiff
on several occasions and viewed
TPD misconduct at Armory Park
demonstrations.

Submitted: January 8, 2017

/s/ Roy Warden