On February 21, 2019 a
Party Statement
was filed
involving a dispute between
Mildred L. Oliver,
Oliver, Mildred L.,
and
City Of Oakland,
Oakland Police Department,
for Civil Unlimited (Civil Rights/Discrimination)
in the District Court of Alameda County.
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I DANA
21038097 |
BARBARA J. PARKER, City Attorney — SBN 069722 AL FILE YD
MARIA BEE, Chief Assistant City Attorney - SBN 167716 EDA ¢ rOUNTY
DAVID A. PEREDA, Special Counsel — SBN 237982
MICHAEL QUIRK, Deputy City Attorney ~ SBN 283351 DEC 27
One Fra . Ogawa Plaza, 6t oor
Oakland, California 94612 ERK O HE SUP
Telephone: (510) 238-6520 Fax: (510) 238-6500
Email: DPereda@oaklandcityattorney.org
33244/2874525
Attorneys for Defendant,
CITY OF OAKLAND
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF ALAMEDA
10
MILDRED L. OLIVER, Case No. RG19007799
11
Plaintiff,
12
v. DECLARATION OF OAKLAND
13 POLICE DEPARTMENT’S
CITY OF OAKLAND, OAKLAND CUSTODIAN OF RECORDS
14
POLICE DEPARTMENT, AND DOES 1- | KAROLINA ZACHOSZCZ
25, INCLUSIVE
15
16
Defendants.
17
18
19 I, Karolina Zachoszcz, declare as follows:
20 1. I am employed as an officer with the Oakland Police Department. I
21 serve as a Records Custodian in the Internal Affairs Division. I am familiar with
22 the Oakland Police Department’s policies and procedures regarding Internal Affairs
23 files. Ihave personal knowledge of the contents of this declaration, and ifcalled
24 upon to testify, I could and would competently testify to the matters stated herein.
25 2. I understand that on July 16, 2019, Plaintiff in the above-captioned
26 lawsuit served Request for Production of Documents to Defendant City of Oakland,
27 Set One (“Pre-Trial Discovery”).
28
-{-
DECLARATION OF OAKLAND POLICE DEPARTMENT’S CUSTODIAN OF RECORDS
KAROLINA ZACHOSZCZ
3. I also understand that the materials and information requested within
the Pre-Trial Discovery relate to Oakland Police Department Internal Affairs
investigation files.
4. The following Internal Affairs file relates to allegations of sexual
misconduct involving multiple police officers: 15-0771.
5. The confidential and private information contained in this file includes
statements made by other officers during the course of the investigation conducted
by Internal Affairs. The statements made by other officers were provided with an
expectation that the statements would be kept confidential. The files also contain
10 Internal Affairs Division’s investigation and review of officers, staff, and personnel
il files. The documents may also contain private information pertaining to third
12 parties.
13 6. The Oakland Police Department generated or maintained these
14 documents and has maintained their confidentiality.
15 7. It is important that the confidential and private information in these
16 documents be kept confidential to protect the privacy interests and safety of
17 Oakland Police Department officers and staff, as well as that of third parties.
18 I declare under penalty of perjury under the laws of the State of California
19 that the foregoing is true and correct, and ifcalled as a witness I could competently
20 testify thereto.
21 Executed on December _!9__; 2019 at Oakland, California.
22
23
FD
oy
24 OFFICER KAROLINA ZACHOSZCZ
25
26
27
28
-2-
DECLARATION OF OAKLAND POLICE DEPARTMENT’S CUSTODIAN OF RECORDS
KAROLINA ZACHOSZCZ
CLERK’S CERTIFICATE OF SERVICE BY MAIL
CCP 1013a(3)
CASE NAME: Oliver vs City of Oakland
ACTION NO.: RG19007799
I certifythat, I am not a party to the within action. Iserved the foregoing Declaration by
depositing a true copy thereof in the United States mail in Oakland, California in a sealed
envelope with postage fully prepaid thereon addressed to:
Scott Law Firm City of Oakland
Attn: Scott, John Houston Attn: Pereda, David
1388 Sutter Street One Frank H. Ogawa Plaza, 6" FI.
Suite 715 Oakland, CA 94612
San Francisco, CA 94109
Pamela Y. Price, Esq.
P.O. Box 5843
Oakland, CA 94605
I declare under penalty of perjury that the following is true and correct.
Executed on December 27, 2019 at Oakland, California
Chad Finke, ;
Executive Officer/Clerk
by Pamela Greene
Deputy Clerk
Document Filed Date
December 27, 2019
Case Filing Date
February 21, 2019
Category
Civil Unlimited (Civil Rights/Discrimination)
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I DANA 21038097 | BARBARA J. PARKER, City Attorney — SBN 069722 AL FILE YD MARIA BEE, Chief Assistant City Attorney - SBN 167716 EDA ¢ rOUNTY DAVID A. PEREDA, Special Counsel — SBN 237982 MICHAEL QUIRK, Deputy City Attorney ~ SBN 283351 DEC 27 One Fra . Ogawa Plaza, 6t oor Oakland, California 94612 ERK O HE SUP Telephone: (510) 238-6520 Fax: (510) 238-6500 Email: DPereda@oaklandcityattorney.org 33244/2874525 Attorneys for Defendant, CITY OF OAKLAND SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA 10 MILDRED L. OLIVER, Case No. RG19007799 11 Plaintiff, 12 v. DECLARATION OF OAKLAND 13 POLICE DEPARTMENT’S CITY OF OAKLAND, OAKLAND CUSTODIAN OF RECORDS 14 POLICE DEPARTMENT, AND DOES 1- | KAROLINA ZACHOSZCZ 25, INCLUSIVE 15 16 Defendants. 17 18 19 I, Karolina Zachoszcz, declare as follows: 20 1. I am employed as an officer with the Oakland Police Department. I 21 serve as a Records Custodian in the Internal Affairs Division. I am familiar with 22 the Oakland Police Department’s policies and procedures regarding Internal Affairs 23 files. Ihave personal knowledge of the contents of this declaration, and ifcalled 24 upon to testify, I could and would competently testify to the matters stated herein. 25 2. I understand that on July 16, 2019, Plaintiff in the above-captioned 26 lawsuit served Request for Production of Documents to Defendant City of Oakland, 27 Set One (“Pre-Trial Discovery”). 28 -{- DECLARATION OF OAKLAND POLICE DEPARTMENT’S CUSTODIAN OF RECORDS KAROLINA ZACHOSZCZ 3. I also understand that the materials and information requested within the Pre-Trial Discovery relate to Oakland Police Department Internal Affairs investigation files. 4. The following Internal Affairs file relates to allegations of sexual misconduct involving multiple police officers: 15-0771. 5. The confidential and private information contained in this file includes statements made by other officers during the course of the investigation conducted by Internal Affairs. The statements made by other officers were provided with an expectation that the statements would be kept confidential. The files also contain 10 Internal Affairs Division’s investigation and review of officers, staff, and personnel il files. The documents may also contain private information pertaining to third 12 parties. 13 6. The Oakland Police Department generated or maintained these 14 documents and has maintained their confidentiality. 15 7. It is important that the confidential and private information in these 16 documents be kept confidential to protect the privacy interests and safety of 17 Oakland Police Department officers and staff, as well as that of third parties. 18 I declare under penalty of perjury under the laws of the State of California 19 that the foregoing is true and correct, and ifcalled as a witness I could competently 20 testify thereto. 21 Executed on December _!9__; 2019 at Oakland, California. 22 23 FD oy 24 OFFICER KAROLINA ZACHOSZCZ 25 26 27 28 -2- DECLARATION OF OAKLAND POLICE DEPARTMENT’S CUSTODIAN OF RECORDS KAROLINA ZACHOSZCZ CLERK’S CERTIFICATE OF SERVICE BY MAIL CCP 1013a(3) CASE NAME: Oliver vs City of Oakland ACTION NO.: RG19007799 I certifythat, I am not a party to the within action. Iserved the foregoing Declaration by depositing a true copy thereof in the United States mail in Oakland, California in a sealed envelope with postage fully prepaid thereon addressed to: Scott Law Firm City of Oakland Attn: Scott, John Houston Attn: Pereda, David 1388 Sutter Street One Frank H. Ogawa Plaza, 6" FI. Suite 715 Oakland, CA 94612 San Francisco, CA 94109 Pamela Y. Price, Esq. P.O. Box 5843 Oakland, CA 94605 I declare under penalty of perjury that the following is true and correct. Executed on December 27, 2019 at Oakland, California Chad Finke, ; Executive Officer/Clerk by Pamela Greene Deputy Clerk