Exhibit A to Eliasberg Declaration 255-4: MCJ-00856

Video shows two deputies punching a handcuffed person in the head after that person kicks backward into one of their legs. They continue to punch him in the head and body multiple times even after he has been taken to the ground. Head punches found within policy. Discipline imposed for taking him out of his cell instead of calling for a supervisor, but no discipline for head strikes. Sinclair declaration paragraphs 32 – 34 cover this incident.

Exhibit B to Eliasberg Declaration 255-4: MCJ-04485

The video starts after the use of force with the person no longer fighting but bleeding on the ground. Later medical exams reveal he has an orbital bone fracture. At issue in this video is the brutal use of WRAP, including placing a spit mask on him when he is profusely bleeding from the face. No discipline because there was no finding that the WRAP or spit mask use was problematic, and no finding that anyone put him in medical danger. Thomas declaration discusses the video at length in paragraphs 12 – 15.

Exhibit D to Eliasberg Declaration 255-4: MCJ-00590

The video is an example of improper force and dishonesty. A deputy clearly and intentionally puts his knee on the man’s neck at 1:15 and keeps it there until 1:39 (there is a problem with the time stamp on the video – the accompanying report admits that it was 46 seconds). In the deputy’s report, he states he “inadvertently” put his knee across the man’s neck and shoulders. There was no finding of dishonesty on review by supervisors.

Exhibit E to Eliasberg Declaration 255-4: MCJ-03103

This incident is an example of failure to use force prevention and dishonesty. A deputy talks with a person who needs soap. That person asks to speak to a supervisor. Instead, the deputy grabs him by both arms, turns him into a wall, and when the person tries to turn back around, the deputy starts punching him in the head. The witnesses to the incident, the detainee’s statement, and the video contradict the deputy’s report that the detainee was assaulting him. But the reviewing watch commander claims to be unable to evaluate the veracity of the deputy’s statement because the video is pixelated. No out of policy findings for head strikes or failure to use force prevention, and no discipline imposed.

Exhibit 3 to Thomas Declaration 262-1: IRC-01692

The video shows a rapid escalation of force to handle a person who is upset about people not being taken to the bathroom in the Inmate Reception Center front bench. (They are lying in urine.) The person is put into a WRAP with very significant force to the back of his head and neck, creating danger of asphyxiation. There is no finding that the WRAP was used in any way out of policy and therefore no discipline imposed.

Exhibit A to Sinclair Declaration 255-1: MCJ 922-02080

Two deputies slam a man’s head into a concrete wall after he exits his cell. Photos of the injuries to the head are also in Sinclair’s declaration at paragraph 23.