Warden Opposition To State's Motion To Preclude Evidence

Case 4:14-cv-02050-DCB Document 95 Filed 11/30/16 Page 1 of 13
Roy Warden, Publisher

Arizona Common Sense
6502 E. Golf Links Rd.
Tucson Arizona 85730
520 551-3496
roywarden@hotmail.com
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA
ROY WARDEN
Case No. 14-cv-02050
PLAINTIFF in pro-se
v
RESPONSE TO DEFENDANTS MOTION TO PRECLUDE WITNESSES

& EVIDENCE AND AFFIDAVIT OF
ROY WARDEN
ORAL ARGUMENT REQUESTED
RICHARD MIRANDA, MIKE

RANKIN, THE CITY OF TUCSON, et al.,
THE HON. DAVID CHARLES BURY
DEFENDANTS.
1
2
Comes Now the Plaintiff, Roy Warden, with his response to Defendants
Motion to Preclude Witnesses and Evidence.
3
4
I. PRELIMINARY STATEMENT
Counsel Baird Greene continues to bleat1 and cry foul while he lies to
the court2, engages in the custom and practice of Tucson City Defendants
to destroy documents,3 and continues to misstate the record, while at the same
time he delays the proceedings, denies Plaintiff the opportunity to present his
case to a jury, and provides this Court with yet another opportunity to ham-
string Plaintiffs case.
II. RESPONSE SUMMARY
For more than a decade Defendants harassed, prosecuted, impoverished
Plaintiff and otherwise ground him under the brutal jackboots of the local
10
pro-raza-open-border-cheap-illegal-labor state; literally, stripping him of
11
all his belongings, driving him into the streets4 and forcing him to sell his
12
plasma to survive5. [See Warden Deposition, (WD), Attachment 1]
13
Now counsel Greene asks Plaintiff to indicate which6 of the files and
14
documents that (he) intend(s) to introduce at trial,7 claims pro-se Plaintiff
Counsel complains: there is only one lawyer one this case with a paralegal he
shares with other attorneys in the office, both working many other cases than this
one. (MTP; 6:20-22)
Defendants never requested Plaintiff to agree to an extension of time to file dispositive motions.
See Exhibit One: the December 11, 2012 Attorney General Criminal Division
Border Crimes Enforcement Report on the theft of 250 million dollars in the Rio
Nuevo scandal.
Defendant Tucson City Officials impoverished Plaintiff in retaliation for his public criticism. (WD; 98:17-99:6, 102:20-104:9)
WD; 99:9-13; 21:23; 88:17-22
(MTP; 3:17-18)
Plaintiff, who is still searching for a trial attorney simply doesnt know which
documents his eventual attorney will elect to use at trial, therefore; in an excess
of caution Plaintiff has provided Defendants with all the evidence in Plaintiffs
possession. See paragraphs 3 and 4.
2
intends to surprise, and prejudice Defendants and demands that Plaintiff
pay for and provide Defendants with copies of documents which are now
under Defendants exclusive custody and control in what amounts to a de-
mand that Plaintiff pay a dry cleaning fee8 for cleaning his own blood off
Defendants uniforms.
III.
I, Roy Warden, Plaintiff in the above captioned action, do herein declare,
7
8
AFFIDAVIT OF ROY WARDEN
swear and affirm as follows:
1.
I am the Plaintiff in the above captioned case;
10
2.
On November 3, 2016 Defendants filed their Motion to Preclude
11
Witnesses and Evidence, (Doc.87)9, which shamefully distorts the
12
facts as to Plaintiffs extraordinary effort to abide by the Order of
13
this Court and by F.R.Civ.P Rule 26 regarding a partys duty to dis-
14
close;
3.
15
On or about February 26, 2016, at this cases inception, (in what
16
turns out to be a nave gesture of good faith) and not knowing what
17
documents his trial counsel might want to introduce at trial, this
18
pro-se Plaintiff elected to give Defendants counsel everything he
19
had in his possession as it might reasonably relate to any of the is-
20
sues set forth in the First Amended Complaint, even if such evidence
The Tucson City Court charges me an $18.00 fee merely for accessing each case
file; both TPD and the City Court charge a .50 per page copying fee. There may
be more than 1,000 pages of relevant documents now within the exclusive custody and control of Defendant Tucson City which Plaintiff does not presently
have access to.
On November 10, 2016 Defendants filed an Addendum to their Motion to Preclude, which takes back many of the allegations made in Doc. 87. (Doc. 90)
3
might embarrass Plaintiff or damage his cause10; (WD; 139:21-
141:80)]
4.
These disclosures, set forth in 17 clearly marked categories11, en-
compass more than ten years of political speech and conduct; more
than a terabyte of videos12, media stories, Plaintiffs public state-
ments, rallies, associated news stories etc., all of which motivated
Tucson City Defendants to engage in acts of First Amendment Re-
taliation (FAR), etc.; (WD; 142:1-15)

5.
Moreover; Plaintiff has informed Counsel Greene that all the docu-
10
ments Plaintiff needed to prove the commission of Defendants un-
11
lawful conduct (which officials did what acts) had came from
12
Defendants Initial and Supplemental Disclosures; (WD; 140:24-
13
141:2)
6.
14
Therefore; Plaintiffs disclosures relate almost exclusively to as to
15
what Plaintiff said or did to inspire Defendants to retaliate13 against
16
Plaintiff for his political speech; in other words Plaintiffs disclo-
17
sures will answer the question foremost in the juries mind; Why did
18
Tucson City Defendants violate the law and Plaintiffs rights in the
19
first place? (WD; 141:10-20; 142:1-15)

7.
20
Moreover; Plaintiff informed Counsel Green his internet search for

additional documents relevant to Tucson City Open Border Policy
21
10
Astonishingly; Plaintiff elected to fulfill the states disclosure obligations for

criminal prosecutions.
11
See exhibit six of Defendants MTP.
12
Many of these videos were created by Activist Russ Dove.
13
Plaintiff speaks out and Tucson City retaliates: this case is a mirror image and
repeat of Gilmartin and Harris v City of Tucson, 4:00-cv-00352-FRZ-CRP.
4
was ongoing, and that he would be happy to disclose additional doc-
uments14 as he found them because they strengthen my case. (WD;
155:25-156:4)
8.
Significantly; subsequent to the April 10, 2006 Riot in Armory Park
Assistant Chief of Police Kathleen Robinson came to Plaintiffs res-
idence and intimidated his landlady leading to Plaintiffs unlawful
eviction by Rathbun Realty, Inc. in early August 2006 and 8 years
of homelessness. (WD; 98:17-100:10)

9.
During Plaintiffs eight years of homelessness15 he was dispossessed
10
of many of his possessions, including video records16 and most of
11
the specific criminal case files and TPD reports that were generated
12
consequent to Plaintiffs 13 arrests.

10.
13
Please be advised: subsequent to the filing of this document Plain-
14
tiff intends to file a F.R.Civ.P. Rule 11 Motion regarding Counsel
15
Greenes motions and assertions made in bad faith.
16
Further Affiant Sayeth Not
17
November 30. 2016
18
A. DEFENDANTS MISREPRESENTATIONS AND LIES
19
11. In their Motion to Preclude (MTP) Defendants variously state:
/s/ Roy Warden
20
21
a)
Plaintiff has violated the November 1, 2016 deadline. (MTP;

1:21)
22
23
24
25
b)
As of right now it is still unclear unclear which cases and what

matters etc. that Plaintiff will pursue. And it is unclear because of
the abusive discovery practice of the Plaintiff himself. If he has
had these documents for years why is his (sic.) still keeping or
14
See Defendants outrageous misrepresentation in paragraph 12(b)
15
Homeless and poverty caused by Defendants in retaliation for Plaintiffs speech.
16
See Docs 127 & 128 in Case No. 4:11-cv-004-60 DCB

5
hiding them from counsel? Is his goal to surprise and prejudice

Defendants? (MTP 6:24-7:2, emphasis added)
1
2
3
4
5
6
7
8
9
10
11
12
12.
b)
(For Plaintiffs response see paragraphs 1-10 above.)

Plaintiff indicates hes going to violate the Courts order that discovery be completed November 1, 2016 by giving by sending material after the deadline. (MTP; 7:9-10)
13. (For Plaintiffs response see paragraphs 1-10 above.)

c)
The discovery deadline is past and Plaintiff has failed to disclose

documentation he has in his possession regarding twenty eight witnesses listed in the first two pages of this motion, including police
reports, court documents, statements, minute entries, etc.: (MTP;
6:3-5)
13
14. (For Plaintiffs response see paragraphs 1-10 above.)
14
B. PLAINTIFFS REVISED WITNESS LIST
15
15. Regarding Defendants Revised witness list, Defendants make this
16
17
18
19
20
(outrageous) misrepresentation:
Twenty three of those witnesses are new and there is no
accompanying documentation (including contact information) in his disclosure to identify most of them. (MTP;
4:-22)
21
16. Twenty one of those twenty three new witnesses are in fact De-
22
fendant Tucson City employeesTPD Officers, City Court Judges,
23
etc.whose contact information Plaintiff doesnt have but whose
24
contact information is certainly within Tucson City Defendants ex-
25
clusive custody and control.
26
27
28
29
30
C. THE DOCUMENTS AND WITNESS INFORMATION DEFENDANTS NOW SEEK REMAIN IN THE EXCLUSIVE CUSTODY AND CONTROL OF DEFENDANTS
31
ments Plaintiff has in his possession that Defendant Tucson City
32
created to effect 13 prosecutions in retaliation for Plaintiffs lawful
33
exposure of Open Border Policy.
17. Counsel Greene clearly seeks Plaintiffs disclosure of all the docu-
18. However; Plaintiff has disclosed everything he has, which Defend-
ants now concede, includes substantial documentation relating to
Plaintiffs 13 arrests. (Defendants Addendum to MTP; Doc. 90)
LEGAL STANDARD FOR DISCLOSURE
5
6
7
8
9
10
11
12
Parties to a lawsuit must make their initial disclosure based

on information (which is) reasonably available. Fed.R.
Civ.P. 26(a)(1)(E); Tamas v Family Video Movie Club, Inc.
304 F.R.D. 543, 546 (N.D. Ill. 2015); San Francisco
Baykeeper v. West Bay Sanitary Dist., 791 F. Supp.2d 718,
733 (N.D. Cal. 2011) (Reasonably available covers information known to a party, its agents and counsel, as well as
information available through reasonable investigation).
13
14
15
16
17
18
19
20
21
22
Failure to make initial disclosures as required by Rule 26

(a)(1) results in the exclusion of the undisclosed witness or
information, unless the party failing to make disclosure can
demonstrate that the failure was harmless or there was substantial justification. Quesenberry v. Volvo Group North
America. 267F.R.D. 475,478 (W.D. Va. 2010) ( no need to
show that bad faith was the cause of the nondisclosure); Russell v. Absolute Collection Services, Inc., 763 F.3d 385, 396
(4th Cir 2014) (court has broad discretion in determining
sanctions).
23
24
25
26
27
Any witnesses, depositions, or exhibits not properly disclosed under Rule 66(a)(3) will be excluded from use at trial
unless the failure was substantially justified or harmless.
Diaz-Garcia v. Surillo-Ruiz, 98 F.Supp.3d 396, 400 (D.
Puerto Rico 2015)
28
29
30
31
32
33
34
35
36
37
38
Two additional cases are pertinent regarding discovery

abuses: (1) Norman v. CP Rail Systems, No. 99 C 2823, 2000
WL 1700137 (N.D. Ill. Nov. 13, 2000) (noting that Rule
26(a)(1 ) is a fairness rule, not a technicality. The point is to
avoid having to slog through heaps of discovery material);
and (2) Robinson v. Champaign Unit 4 Sch. Dist, 412 Fed.
Appx. 873, 877 (7rh Cir. 2011) (noting that the advisory
committee notes to the 1993 enactment of the Rule 26(a) (1)
(A)(iii) disclosure requirements emphasize that the disclosure requirements should, in short, be applied with common
sense to help focus the attention on the discovery that is
7
1
2
needed, and not used to indulging gamesmanship with respect to the disclosure obligations.)
18. Since all of the evidence Defendants now seek remains in their
exclusive custody and controlat Tucson City Court and the
Tucson Police DepartmentPlaintiff cheerfully states: He
lifted the entire preceding 4 paragraphs of legal argument
directly from pages 7 and 8 of the MTP, because the citations
support Plaintiffs cause and not City Defendants.

SUMMARY
9
10
Plaintiff patiently submits: In (all) fairness he has provided Defendants
11
with all the documents which are reasonably available. Moreover; Plain-
12
tiff has provided this court with substantial justification17 for his alleged
13
failure to provide Defendants counsel with documents now under the exclu-
14
sive custody and control of Tucson City Defendants.

CONCLUSION
15
16
Defendants know that for eight years theyve operated in a friendly
17
court18 in which the assigned19 judge will move heaven and earth and, as
18
the Ninth Circuit has ruled, will violate basic law as to claim preclusion20 and
19
12(b)(6)21 to protect Tucson City Defendants and the Open Border, Pro
17
See the Affidavit of Roy Warden, set forth on pages 3-5, with particular emphasis on paragraphs 8 and 9.
18
This explains just why Judge Bury has been appointed to preside over Plaintiffs last five cases in spite of L.R.Civ.P. 3.7 which requires random, automated
judge assignment.
19
In defiance of L.R.Civ.P 3.7 which requires random automated judge selection

Judge Bury has been assigned to Plaintiffs last 5 court filings dating back to
2008. Plaintiff has his own personal judge.
20
0167
21
0283
8
Raza, Cheap Mexican Labor policies which have dominated Arizona22 state
policy for the past three decades.

PRAYER
To formulate a common sense resolution to this disclosure dispute Plain-
4
5
tiff now prays the court to:
Deny Defendants Motion to Preclude;
Require Defendants to instruct the Tucson Court Clerk to provide

Plaintiff immediate access to the Tucson City Court Records;
8
9
Require Defendants to permit Plaintiff to have 2 copies23 of every
10
document in each of the case files, including trial transcripts and re-
11
cordings of all hearings, which correspond to Plaintiffs various crim-
12
inal prosecutions.
13
Require Defendants to instruct to Tucson Court Clerk to waive the
14
Tucson City Court File Access fee (now $18.00 to inspect each and
15
every case file);

Require Defendants to instruct the Tucson Court Clerk to waive the
16
.50 cent per page copying fee;
17
18
Require Defendants to instruct the Clerk of Records for the Tucson
19
Police Department to (1) disclose and to provide Plaintiff without cost
20
all documents which relate to (2) Reports Plaintiff has made to TPD,
21
and (3) reports or dossiers TPD has created concerning Plaintiff.

Provide such other relief the Court deems reasonable.
22
Respectfully submitted November 30, 2016.

/s/ Roy Warden
22
A 2014 Harvard study identifies Arizona as the most corrupt state:

http://ktar.com/story/94909/study-arizona-most-corrupt-state-in-us/
23
1 copy for Plaintiff and 1 copy for Defendants

9
EXHIBIT ONE
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Case 4:14-cv-02050-DCB Document 95-1 Filed 11/30/16 Page 1 of 201
Page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
ROY WARDEN,
)
)
Plaintiff, IN PRO SE
)
)
v.
) NO. 4:14-CV-2050-TUC-DCB
)
RICHARD MIRANDA, individually )
and in his official capacity )
as Tucson City Manager; et al.)
)
Defendants.
)
VIDEOTAPED DEPOSITION OF ROY WARDEN

Tucson, Arizona
September 7, 2016
10:00 a.m.
COLLEEN KELLY, RPR

CR #50386 (AZ)
EATON, GREEN & WILLIAMS, INC.
549 North Sixth Avenue
Tucson, AZ 85705
(520)623-0593
800-759-9022
Page 2
1
APPEARANCES
2
FOR THE DEFENDANTS:
OFFICE OF THE TUCSON CITY ATTORNEY

BY: BAIRD GREENE, ESQ.
255 West Alameda Street, 7th Floor
Tucson, AZ 85701
Also present:
Mr. Bobby Soltero, videographer
10
11
12
13
14
15
16
17
BE IT REMEMBERED that the videotaped deposition
18
of ROY WARDEN was taken at the office of the Tucson City
19
Attorney, 255 West Alameda Street, 7th Floor, in the
20
City of Tucson, County of Pima, State of Arizona, before
21
Colleen Kelly, RPR, Certified Court Reporter #50386, in
22
and for the State of Arizona, on the 7th day of
23
September, 2016, commencing at the hour of 10:00 a.m. on
24
said day, on behalf of the Plaintiff, in a certain cause
25
now pending before the Pima County Superior Court.
520-623-0593
800-759-9022
Page 3
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DEPOSITION OF ROY WARDEN
INDEX
Examination by Mr. Greene
Page
5
EXHIBITS
No. 1 - Photograph
12
No. 2 - Photograph
28
No. 3 - Photograph
38
10
No. 4 - Photograph
39
11
No. 5 - Photograph
40
12
No. 6 - Photograph
43
13
No. 7 - Photograph
44
14
No. 8 - Photograph
44
15
No. 9 - Photograph
44
16
No. 10 - Photograph
58
17
No. 11 - Photograph
61
18
No. 12 - Photograph
62
19
No. 13 - Photograph
64
20
No. 14 - Photograph
65
21
No. 15 - Photograph
67
22
No. 16 - Photograph
70
23
No. 17 - Photograph
71
24
No. 18 - 4-27-06 Memorandum to Kathleen Robinson

19
from Mike Rankin & 2-4-16 Memorandum
to Chief Christoper Magnus from Mike Rankin
25
520-623-0593
800-759-9022
Page 4
1
(Exhibit Numbers 1 through 18 marked.)
THE VIDEOGRAPHER:
I'm Bobby Soltero with Green
Legal Video, 549 North 6th Avenue, Tucson, Arizona.
court reporter is Colleen Kelly, with Calabro (sic).
And this is the videotape deposition of Roy Warden, in
the matter of Roy Warden versus Richard Miranda,
individually and in his official capacity as City of
Tucson Manager.
10
Case number is 4:14-CV-2050-TUC-DCB.
The deposition is being held in the offices
11
of the Tucson City Attorney, 255 West Alameda, 7th
12
floor, on September 7th, 2016.
13
a.m.
14
15
The time now is 10:00
Will everyone please introduce yourselves

and the court reporter will swear in the witness.
16
THE WITNESS:
17
MR. GREENE:
18
The
My name is Roy Warden.

And I'm Baird Greene with the
Tucson City Attorney's Office.
19
20
ROY WARDEN,
21
having been first duly sworn to state the truth, the
22
whole truth, and nothing but the truth, testified as
23
follows:
24
////
25
////
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800-759-9022
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2
EXAMINATION
BY MR. GREENE:
Q.
Good morning, Mr. Warden.
A.
Good morning.
Q.
I know you know a lot about the law, but I
don't know if you've been deposed before.
A.
Once.
Q.
Once.
Okay.
I just want to mention something to you
10
about my questions real quick before I get into the
11
matter.
12
A.
Okay.
13
Q.
And that is that if for any reason you don't
14
understand one of my questions or it's confusing or
15
unclear, if you'd just let me know, and I'll attempt
16
to restate so it's understandable.
17
Does that work?
18
A.
Thank you.
19
Q.
Okay.
Let's get right into it then.
I want
20
to talk to you about the events of May the 1st of
21
2012.
22
A.
Okay.
23
Q.
Is the day listed in your Complaint?
24
A.
That's the date of the event; right?
25
Q.
Yes.
520-623-0593
800-759-9022
Page 6
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A.
Okay.
Q.
So tell me a little bit about your day, how
3
4
it started.
A.
Well, I knew I was going to a rally in
Armory Park.
to discuss issues regarding open borders or
immigration and workers' rights, which was the
announced the purpose of the rally.
many times before.
10
I had been to many such rallies before
I had been there
So I prepared myself and went down and
11
was there a little bit early in expectations of being
12
able to enter the park and just speak to folks I know
13
that are part of that movement.
14
15
16
Q.
Do you recall what time it was that you
arrived at Armory Park?

A.
Not at all.
Maybe around 10:00.
Maybe
17
earlier.
18
generally start around noon because they have a march
19
that comes up and goes in.
20
It could have been 9:30 or 10:00.
21
I don't know when they start.
I think they
So probably before 12:00.
I see some pictures there.
Certainly
22
when I encountered those folks I had just gotten
23
there about 10 minutes before I ran into those folks.
24
25
Q.
Okay.
Did you go alone or with somebody
else?
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800-759-9022
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A.
No, I went alone, but I had somebody that
showed up sometimes.
some of those still photos.
He's been part of many different demonstrations that
I've had and he takes films the best he can, takes
still photos, and basically tries to document what
goes on.
In fact, he's the one that took

His name is Jim Kay.
Q.
You met Mr. Kay there at the park?
A.
Yeah.
10
Q.
You mentioned when you got to the park that
11
you ran into those folks.
12
police officers?
And that would be the
13
A.
Yes.
14
Q.
Tell me about that.
15
A.
Well, I happened to have a long-term
What happened?
16
relationship of sorts with Paul Sayre, a fairly
17
friendly, genial fellow.
18
been promoted from the last rank that he had the
19
previous time I had seen him.
20
In fact, I think he had
So he was in a company of what turns out
21
to be -- was it Sergeant Lopez?
22
her rank is.
23
remember, I had never met her before.
24
a Captain McCarthy, and he was part of that.
25
520-623-0593
I'm not sure what
I had not been familiar -- as far as I

Then there was
I'm not sure if they were all three

800-759-9022
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1
together when I met them.
was just Paul Sayre and Lopez, and I think McCarthy
came over later.
at that point.
Q.
It occurs to me that it
But we had substantial interactions
Before we get into that, you said that you
had something like a long-term congenial relationship
with Paul Sayre?
8
9
A.
I've seen him as a result of many of my --
many of my rallies.
We've had very good
10
conversations.
11
public relations and also, as a police officer,
12
conducts himself very well.
13
I believe he's a very effective
We seem to have basically a relationship
14
where we speak candidly to each other back and forth.
15
And I presume everything I say to him would be, from
16
his standpoint, useful to the Tucson Police
17
Department, and I don't hold anything back.
18
talk back and forth.
19
So we
And I believe once upon a time I filed an
20
IAD investigation report against Assistant Chief
21
Kathleen Robinson for misconduct that occurred back
22
in 2006.
23
reviewed the information from me that I gave him,
24
gave TPD.
25
Q.
520-623-0593
And he was the intake officer on that and
Is it fair to say he's always been

800-759-9022
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1
respectful towards you?
A.
Yeah.
Q.
Have you -- previous to this event on May
1st, 2012, have you encountered Paul Sayre at Armory
Park on May 1st at some other year?
A.
I'm sure I have, but I would be very hazy on
that.
at least most of the events, and I can go back and
review it.
I've got basically film of all of the events,
And I assume he was there.
I think in
10
some of the after-action and other reports that you
11
gave me regarding previous years, I think he's
12
mentioned.
13
So if he was there, it wouldn't surprise
14
me.
15
But whatever he says, I'm sure he was there on
16
previous occasions.
17
18
If he wasn't there, it occurs to me that he was.
Q.
Have you ever had occasions where he was
disrespectful towards you?
19
A.
No, not at all.
20
Q.
Did you ever discuss your safety or public
21
22
safety in general?
A.
I've had many conversations with police
23
officers over the years, going back to 2006, and I've
24
always stressed with them I'm very concerned about
25
their safety.
520-623-0593
I want to make sure they are safe.

800-759-9022
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want to make sure everybody is safe, that there
shouldn't be any violence or any reason for violence.
And that goes back to 2006.
And there was some more specific things
were said in terms of police department officials,
various officials over the years have warned me that
people mean to kill me.
other side of this issue that my life may be in
danger and I may be subject to -- that they've heard
10
People are so angry on the
about threats, and so forth.
11
And I did have threats that I heard that
12
I reported back in 2006.
13
conversation there.
14
So there's been a lot of
In fact, there was once upon a time I was
15
communicating with Kathleen Robinson when she was
16
assistant chief, and I was asserting my right to
17
carry a firearm because I was concerned about public
18
safety and threats that had been made against me.
19
And I said, you know, I'm very concerned
20
about you guys.
21
of a roped-off perimeter, and I want to speak and be
22
safe, and you people are on the outside, looking out
23
at the crowd, and I don't want you to be afraid that
24
somehow you might get shot if, you know, gunfire
25
comes out.
520-623-0593
Here I am in the middle of a circle
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1
So I would be quite willing to meet with
your officers prior to the event and give them all
the ammo, you know, that I would have in the gun --
and we had e-mails back and forth on this -- so that
they could be assured that I was possessing nothing,
I had no lethal force capacity, but I wanted the
illusion that I was armed in order to protect myself.
8
9
Q.
Do you have any recollection that you spoke
about your personal safety with Paul Sayre at any
10
point?
11
A.
At what time?
12
Q.
At any point.
13
A.
Okay.
I don't believe there were any issues
14
that day.
15
wasn't any violence that day.
16
I wasn't concerned about any.
There
On previous occasions there had been and
17
I'm sure that came up.
18
reasons I filed an IAD report against Kathleen
19
Robinson for her basically constructing events that
20
might lead to violence in Kennedy Park in 2006.
21
was the subject of our conversation.
22
Q.
In fact, that was one of the
So when you -- you stated earlier that when
23
you arrived May 1st, 2012, at Armory Park, that
24
you -- was it you almost immediately came into
25
contact with the police officers, including Paul
520-623-0593
That
800-759-9022
Page 12
1
Sayre?
A.
I think I was there for 10 or 15 minutes.
And I probably was sitting, as I see in the picture,
as I recollect, when they came walking up.
there before they were.
what direction they came from.
appeared at the park well before the events had
started.
I was
And I can't remember from

But they basically
Because these people have a ritual by
10
which they march from South Tucson, they march in a
11
large group, and it's quite colorful and theatrical
12
and quite effective, and that hadn't even begun to
13
happen yet.
14
at the park itself.
15
16
17
Q.
So I believe there were very few people
Is the picture you're referring to this one
which is marked as Exhibit Number 1?

A.
Yes.
And this is actually across the street
18
from Armory Park.
19
Park.
20
nice looking building, classic building, like a
21
library or school or something, a museum or
22
something, just west of Armory Park.
23
be the northwest corner, I believe, of Armory Park,
24
if I'm looking at this correctly.
25
Q.
520-623-0593
This is on the west side of Armory
I don't know what that building is, a very
And that would
In that picture who do you see besides

800-759-9022
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1
yourself?
A.
Pardon?
Q.
In that picture who do you see besides
4
5
yourself?
A.
Well, I see Sergeant Sayre on the left-hand
side.
I only know her because I remember looking at this
picture carefully at home on my computer to see what
her name was.
I see, I guess she's a Lieutenant, Lopez.
And
I had forgotten what her name was.
10
And then it was later I ran into a card that they'd
11
given me, and I think it was Kevin McCarthy's card,
12
and I think he's standing behind Lieutenant Lopez.
13
Q.
Do you recall what conversation you had with
14
the police officers at this point before the rally
15
began?
16
A.
No, I don't, just generally.
I did inform
17
them of the Mike Rankin letter, which is the central
18
part of this case, that he wrote back in 2006, that
19
he said that it was not lawful for them to keep me
20
out of Armory Park.
21
We did talk about that.
And we had talked on previous occasions
22
about that.
23
letter because I usually bring the letter to me
24
whenever I come to the park, in case there's any
25
issues.
520-623-0593
And I believe I gave him a copy of the
800-759-9022
Page 14
1
In the letter it says quite clearly that
I have a right to enter the park and speak with
people there on matters of community concern.
believe I gave him a copy of that.
So I
But you have to understand, I've had
many -- 50 or 75 rallies, and they all blend into
each other.
not more remarkable than the other.
until this became a legal issue, there was no more
And at the time they're happening one is

So it's not --
10
reason to remember this encounter than there was on
11
any of the other occasions.
12
13
Q.
When you gave him a copy of the letter, do
you recall what his reaction was?
14
A.
He had seen it before.
15
Q.
Had you had -- prior to him -- excuse me.
16
17
Prior to you giving Paul Sayre the

letter --
18
A.
Yeah.
19
Q.
-- was there a conversation about what was
20
21
going to happen that day?

A.
I believe he told me that he was -- that
22
they were going to keep me out of the park.
23
declared his intentions right then and there that we
24
won't let you go into the park.
25
we'll just have to see.
520-623-0593
He
And I says, well,
800-759-9022
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1
Q.
Who are the "they" you're referring to?
A.
I think that was Paul Sayre.
He was
basically -- I didn't know -- I understand Kevin
McCarthy is a superior officer, but my communications
were with Paul Sayre, I guess because I'd known him
before.
Q.
What I meant with that is you said that Paul
Sayre said they were intending to keep you out of the
park.
10
A.
The police department.
11
Q.
The police?
12
A.
The police department would keep me out of
13
14
15
the park that day.

Q.
Did he ever mention the May 1st Coalition
when he was talking to you at this point?
16
A.
17
if he did.
18
Q.
19
20
He may or may not have.
I can't recollect
Were you informed at any point that they had
an exclusive use permit for the park for that year?

A.
Sure.
That was the basis of the Mike Rankin
21
letter, saying that even with that exclusive use
22
permit, you can't keep him out of the park.
23
very focussed on that issue.
24
25
Q.
I was
What I'm getting at is how did you know that
this May 1st Coalition had an exclusive use permit
520-623-0593
800-759-9022
Page 16
1
2
for Armory Park?

A.
I don't know that I knew that at that time.
I knew they were the same group that had done the
same thing before on numerous other occasions, and I
presumed it was the same group.
publicity before the -- before the event that was on
the internet, and I had looked at that.
I recollected that that moment was focusing on them
as an entity or not, I don't know.
10
They put out
And whether
I do know that there's a mistress that's
11
behind all of this who organizes these groups.
12
it was Isabel Garcia's groups or groups that work
13
with her.
14
specifics of whether we talked about May 1st, I can't
15
recollect.
16
Q.
So I presumed it was them.
And
But as to the
Had you been aware that the City of Tucson
17
had issued exclusive use permits on May 1st, 2006,
18
and every May 1st, up to 2012, to this group or a
19
similar group for the use of Armory Park?
20
A.
Absolutely.
And the fact they also did for
21
the April 10th, 2006 event, which I refer to as the
22
riot in Armory Park, when they had 15,000 people
23
there, and that was the first time we burned the
24
flag.
25
520-623-0593
And that was when -- it was that seminal

800-759-9022
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1
incident that resulted in Mike Rankin's letter saying
that you may not like it -- basically telling the
City Council they may not like it but Mr. Warden has
a right to come to the park and speak and do the
things he's doing.
Q.
Are you familiar with the difference in the
Tucson City Code in the park section between a permit
and an exclusive use permit?
A.
I can't focus on that right now.
It's
10
basically a legal analysis.
11
look at both.
12
through, there's a permit process they go through.
13
I'd have to sit down and
I know there's a process they go
And basically my understanding, as I
14
stated in this case, is what Mike Rankin said in his
15
letter in 2006 is absolutely the law as it's stated
16
in Gathright versus City of Portland.
17
case.
18
of the park, exclusive use permit or no.
19
Q.
I read the
And it was unlawful for anybody to keep me out
So the answer to my question would be no, at
20
this point you don't know the difference between
21
that?
22
A.
I'd have to sit and look at both documents
23
and make an analysis of it.
24
I've looked at either.
25
simply don't know the relevance of the question and I
520-623-0593
It's been a while since
So I don't know, I mean, I
800-759-9022
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1
2
don't understand how to answer it.

Q.
Okay.
When you handed the letter to Paul
Sayre, did he make a comment about that you would
nevertheless be excluded from the interior of Armory
Park?
A.
I don't know if he said so at that moment or
not, but certainly before I appeared at the entrance
of the park, at the other than fenced-off area, the
entrance itself that was left open, when I appeared
10
there before then, I wasn't surprised when he said,
11
no, you're not going to come in.
12
it, we went through the formalities of doing it, but
13
until then I wasn't -- I knew beforehand, he had
14
indicated that they were going to keep me out.
15
Q.
We took pictures of
Is it fair to say that what happened in
16
terms of you being excluded from Armory Park, as it
17
was fenced off, had not only happened on May 1st,
18
2012 but on every May 1st back to 2006?
19
A.
Yeah.
20
Q.
Okay.
21
A.
Okay?
In 2006 there was no fencing.
They came up with the fencing
22
subsequent to that.
23
confidential memo that you disclosed, that that was a
24
subterfuge.
25
Rankin scheme.
520-623-0593
And I understood that from the
I call it the confidential memo or the

How do we get around the law as per
800-759-9022
Page 19
1
Gathright and keep Warden out of the park, even
though the law of Gathright says he as right to come
in?
So it was a contrivance.
Q.
For the record, are you referring to what's
been marked as Exhibit 18, which is a memo dated
April 27, 2006?
A.
I'm not going to bother reading the whole
thing, but this looks very familiar.
Kathleen Robinson, yeah.
Mike Rankin to
It says a lot of things in
10
here.
11
because they use the same analysis in here that the
12
Ninth Circuit shut down in Gathright, the same quotes
13
and cases that the Ninth Circuit says this doesn't
14
hold water in these particular -- in this particular
15
case.
And I remember finding it extraordinary
16
I was rather amused that they had put
17
these citations in, I believe, as a means of
18
conveying a feeling of legitimacy or that the law
19
allowed for this, when clearly, according to
20
Gathright, and the Gathright analysis made by the
21
court, it was not.
22
23
24
25
Q.
When is the first time that you saw Exhibit
18, that memo?

A.
shocked.
520-623-0593
When you disclosed it, I believe.
I was
I said, wow, somebody made a mistake here,

800-759-9022
Page 20
1
you know.
was the kind of document I would never expect to see.
3
4
5
Q.
I was happy to get it.
And I thought it
So that would be sometime probably in May of
this year that you got that?

A.
Whenever your Initial Disclosures came out.
I remember sitting down with a couple of attorneys I
know, and they were shocked, too.
is a smoking gun.
get around what he wrote in 2006.
I said, geez, this
This is how they got -- tried to

This is a record
10
of how do we get around the law, and it's what
11
they've been doing all the way up to 2012 until they
12
stopped, stopped issuing those permits.
13
Q.
Aside from the conversations that you've
14
already described between yourself and Paul Sayre,
15
when you were with these police officers across the
16
street from Armory Park, did you have further
17
discussions with him at that time?
18
A.
19
they were.
20
friendly, relaxed relationship with Paul Sayre.
21
may have talked about basketball or football, or
22
something of that sort, just general chitchat
23
conversations.
24
25
It's a long time ago.
I don't remember what
Like I said, I've always had a very

We
What was clear was in spite of the

fact -- a couple of things, one, he had seen the
520-623-0593
800-759-9022
Page 21
1
letter before, was quite familiar with the contents
of the letter before, and, two, no, we're not going
to let you -- TPD is not going to let you enter the
park today.
5
6
Q.
He was very, very clear on that.
Anything else you can remember about the
conversations that were taking place at this time?
A.
No.
Q.
It appears that Paul Sayre is laughing and
Captain McCarthy is smiling in the background?
10
A.
Yeah.
11
Q.
What was the atmosphere of this encounter?
12
A.
Like I say, he's always been very genial and
13
pleasant.
14
with Kathleen Robinson based on her attitude and
15
based on previous things she had done back in 2006.
16
But other than the incident in 2010, my general
17
recollections were it's been fairly pleasant.
18
Usually it is I've had some contentions
You have to understand, this comes --
19
this comes after a lot of other demonstrations not in
20
Armory Park, not on the issue of exclusive use
21
permits, in which I've had sometimes friendly and
22
sometimes acrimonious interactions with Tucson police
23
officers.
24
very matter of fact, well, we don't care what the
25
letter says, you're just not going to go into the
520-623-0593
So this was very friendly at this point,
800-759-9022
Page 22
1
park.
was no -- you know, he's got the gun and the badge.
And I didn't see any need to get arrested trying to
force my way into the park.
that.
Q.
But there wasn't any argument about it.
There
I wasn't required to do
Did you have a discussion about you
delivering your message that day elsewhere, aside
from inside of Armory Park?
A.
You know, you kind of missed the whole point
10
of what the Armory Park event is.
11
been consistent with the left wing movement since the
12
beginning.
13
the public will get together and discuss the issues
14
regarding workers' rights and immigrants' rights.
15
And I'm very interested in those issues, not just in
16
terms of opposing some of them, for reasons which you
17
may not be aware of, but I'm very interested in
18
participating in community meetings.
19
And one, this has
It's announced as a public meeting, where
So I went there not necessarily to,
20
quote, protest and to oppose them, but to communicate
21
with them on that issue.
22
wanted to bring up, and I brought it up before, is
23
that Cesar Chavez himself did not approve of illegal
24
labor coming across the border because it competed
25
with his American farm workers union, which was made
520-623-0593
And one of the issues I
800-759-9022
Page 23
1
up of Filipino and Mexican people, people of Hispanic
background, American citizens, but nonetheless they
were of Hispanic background.
He didn't like having to compete with
strike breakers and other people that the contractors
would bring across the border to work to perform farm
labor at half the wages.
of his farm workers.
I met Chavez.
He couldn't raise the wages
I met him on a march in
10
Berkeley.
11
Berkeley, but I met him back in 2006, and you're not
12
following what he wanted.
13
these people outside of the leadership, they begin to
14
understand it, and they start to realize that maybe
15
we're on the wrong side of this issue, we're not
16
really humanitarians.
17
Q.
Actually, I was going to school in
And whenever you talk to
So you never had a conversation with any of
18
these police officers at this time about where it was
19
you might deliver your message?
20
A.
No.
That I was going to enter the park.
21
That's all.
22
And it wasn't a matter of using a loudspeaker.
23
I was going to go through the entrance.
A loudspeaker is only if I'm kept out of
24
the park, I don't have any other way of saying
25
anything or doing anything.
520-623-0593
But if I entered the
800-759-9022
Page 24
1
park, there was no reason -- unless the crowd was
very loud, there was no reason to use the loudspeaker
because I certainly didn't intend to speak over their
speakers.
Q.
What I'm getting at is when Paul Sayre told
you you were not going to be allowed inside the park,
after that did it follow that you were going to speak
somewhere else?
A.
No.
10
Q.
But you ended up speaking somewhere else
11
12
that day; correct?

A.
No.
I was outside of the park, and I
13
walked -- as the march came north on, what is that,
14
4th Street, whatever that is there, as the crowd came
15
north, I walked south and communicated through the
16
loudspeaker and said a lot of things, some of them
17
confrontational and some of them were you're
18
betraying the dream of Cesar Chavez, and you're
19
actually setting these poor migrants up for
20
exploitation where they are hired for diminished
21
wage, they are driving down the cost of labor, the
22
value of labor here in Tucson, putting many Hispanic
23
workers, American citizens, putting them out of work,
24
reducing their wages, making life very difficult.
25
520-623-0593
And I talk -- we have a great analysis or

800-759-9022
Page 25
1
have a lengthy analysis about how the legal system is
profiting from prosecuting and defending cases that
arise out of illegal immigration and all of the crime
it's done on these people on their way here.
Q.
Aside from telling you that you couldn't go
into Armory Park, did the police put any other
restrictions on you?
8
9
10
11
A.
Not that I remember.
Unlike 2010, when they
told me to leave within a thousand -- couldn't be

within a thousand feet of the park, no.
Q.
Was there a probation condition on you at
12
that time, or had there been a probation condition
13
that you couldn't be within a thousand feet of the
14
park for demonstration?
15
A.
This is really interesting.
The Tucson City
16
Court issued a series of totally unconstitutional
17
prior restraint upon my ability to organize and to
18
speak politically, including do not come within a
19
thousand feet of any political -- do not speak within
20
a thousand feet of any political demonstration.
21
Clearly, according to any analysis,
22
totally an act -- unconstitutional, unlawful act of
23
prior restraint.
24
25
Nonetheless, the court issued it.
What I did was I appealed it.
But since
it was a Tucson municipal court case, my right of
520-623-0593
800-759-9022
Page 26
1
appeal stopped in Superior Court, and I had to
proceed by special action from them.
filed my notice of appeal in City Court, they stayed
-- they stayed the order because it was under appeal.
And so when I
After Superior Court, when they denied
me, it was -- the stay continued all the way up until
-- until it was -- after it was heard by the Supreme
Court, and during that period of time, May 1st, after
this event happened, May 1st, 2010 happened.
10
there was no order in effect.
11
And
It had been stayed.
And so there was no order in effect, even
12
though that's what they told me, if I didn't leave,
13
they'd put me under arrest for violating the court
14
order.
15
the order has been stayed, you don't have any
16
authority.
17
Q.
And even though I told them, I said, look,
So it sounds like the police officer you
18
dealt with in 2010 was unaware of what was going on
19
in the upper courts?
20
A.
Unaware.
And that was very -- it was
21
acrimonious.
22
south of here, on the southern end of the park,
23
across the street, there were two officers there.
24
There was another officer on the north end of the
25
park that originally wouldn't let me come in.
520-623-0593
There were two people, and that was
And
800-759-9022
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1
they were very, very nasty.
I've got a lot of film of that.
I think
you've seen it.
disclosed it and it's been seen in the previous case.
Q.
Okay.
A lot of film of that.
And I've
But no other restrictions besides, on
this date in 2012, that you couldn't go inside the
park?
8
9
A.
No.
Just simply I believe it was on the
basis of the exclusive use, special use permit,
10
exclusive use.
11
permit and every time I do I'm thinking they have a
12
different term, a slightly different term they're
13
using.
14
Q.
I tend to call it exclusive use
And, by the way, all these -- well, this
15
picture I just showed you is something you disclosed
16
to me; correct?
17
A.
Pardon?
18
Q.
This picture you --
19
A.
I believe so.
This looks like a series of
20
pictures that Mr. Kay took.
21
you can see where he was from the standpoint of where
22
he took the picture.
23
laughing at, I don't know what they're laughing at, I
24
can't remember what it was.
25
Q.
520-623-0593
And I believe -- well,
What they're looking at and
Okay.
800-759-9022
Page 28
1
A.
If you offered me a million dollars, I
couldn't tell you what it was.
funny.
laughter.
occurring at the time.
6
7
Q.
But it was something
They were laughing and it wasn't unusual

It was consistent with whatever was
Showing you what's been marked as Exhibit
Number 2.
A.
Sure.
Q.
Do you recognize the contents of that?
10
A.
Yes.
Bud Foster.
And I'm explaining to him
11
about keeping me out of the park and the whole issue
12
of prior restraint and the issue of the letter and
13
the issue that Mike Rankin writes the opinion later
14
in 2006, which coincidentally clearly states the law
15
as it was then and as it still is, and they were
16
still using -- they reversed themselves and now were
17
keeping me out of the park, even though I wanted to
18
go in and speak.
19
that.
So we had a conversation about
20
And I have, you might say, a long-term
21
collegial or, you know, friendly relationship with
22
Bud Foster.
23
acrimonious with me.
24
been trying to talk about different things.
25
told me once, quite frankly, consistent with the case
520-623-0593
A lot of the reporters in town are very

He's been friendly and he's
And he
800-759-9022
Page 29
1
I had against Rathbun Realty, and on other cases, he
says, Roy, he says, no matter what you do, unless you
do something wrong, my employers will never do any
story that shows you in any favorable light.
can't show you in an unfavorable light, they simply
will not do a story.
If we
And he's told me on several occasions of
stories that he wanted to pursue and write and
interview me about, and he had gone to them, and they
10
said, no, we won't run any story that shows Roy
11
Warden in anything other than an unfavorable light.
12
Q.
Who does Bud Foster work for?
13
A.
I believe I'm thinking Channel 13.
14
I don't
know if that's KOLD or whatever they are.
15
Q.
How long have you been in Tucson?
16
A.
Oh, since '97, '96.
17
Q.
Have you known him as a reporter that whole
18
19
time?
A.
No, not at all.
Once I became -- other than
20
seeing him on TV, once I became involved in political
21
events, I think I saw him right after, or maybe it
22
was even during the riot in Armory Park.
23
actually, it was kind of odd because I had a series
24
of -- after the event itself, within the week I had a
25
series of interviews with reporters and we talked
520-623-0593
And
800-759-9022
Page 30
1
very candidly on the issues of illegal immigration
and my perspective that these people were being
exploited, that they were being exploited by Tucson
City government and by local contractors and by the
Mexican government and very, very, you know,
heartfelt and deep communication.
None of the substance of those
communications ever came to light in any news
reports.
It was all Roy Warden, the anti-Mexican
10
racist, Roy Warden, the racist.
11
they put on it.
12
on whatever it was I said, they simply never reported
13
it, even though they recorded it on film.
14
Q.
And if they couldn't put that spin
In your response you just referred to the
15
riot in Armory Park.
16
that happened April 6th of 2006?
17
A.
Are you referring to the events
April 10th, 2006.
18
too.
19
Day of Protest.
20
That was the spin
April 10th, 2006.
I'll mix up the dates,
It was called the National
It was part of a national protest all
21
around the country.
22
protests in many cities, in New York City and in
23
Phoenix, I believe, and in Los Angeles they had over
24
100,000 people in these large street demonstrations.
25
They were all demonstrating for immediate amnesty and
520-623-0593
There were dozens and dozens of
800-759-9022
Page 31
1
immediate, you know, continued open borders and all
of this stuff.
And nobody was dealing with the
underlying issue, that this was exploitation of the
Mexican people and horrific for the American workers,
many of whom were Hispanics, who had to compete with
lower wages, and all of the crime that was done upon
the illegals coming in as a consequence of the
industry, the rapes and the murders and the sex
10
trafficking, that all this was being ignored, that
11
this was not a day of celebration, this was a
12
horrible event.
13
And so they were all around the country
14
having these events.
15
National Day of Protest.
16
it all.
17
Legal Defender's Office, using infrastructure and
18
County equipment.
19
They had one here in Tucson,

And Isabel Garcia organized
She organized it all from her Pima County
In fact, the fence, the orange fence that
20
goes around the park there, my understanding is that
21
it comes from Pima County.
22
property for her own personal political activities,
23
which is clearly unlawful.
24
25
Q.
Use of government
She was doing that.
Why do you characterize what happened on
April 10th, 2006 as a riot?
520-623-0593
800-759-9022
Page 32
1
A.
That's the way that you conclude when you
read the police after-action report and what we
witnessed and what we filmed.
demonstrators jumping on the backs of police
officers, knocking them to the ground, kicking them
in their face, throwing ball bearings and hitting
police officers, and one officer had a cut cheek,
when you have this going on and the police have to
draw weapons, when they have to fire teargas balls
When you have
10
and teargas itself into people to try to get some
11
kind of crowd control, when people are throwing
12
frozen water bottles, which are like very hard
13
missiles -- and I was hit in the head myself and
14
nearly knocked out -- when they're throwing that, I
15
call it a riot.
16
17
18
Q.
That's what it was.
How long did you speak with Bud Foster that
morning?
A.
I don't know, five or 10 minutes.
It was
19
like whenever we talk, there's never a beginning and
20
an ending point, it's a continuation of a long series
21
of very friendly conversations we've had over the
22
years.
23
trying to get the story of what I'm up to that moment
24
or what's going on, it's more in the context of all
25
these other things as well.
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So it's not like he's -- as a reporter he's
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So I don't believe it was a very long
conversation.
saying, why are you upset, Roy?
they're breaking law again.
to break the law and they know that it's wrong and
they're doing it anyway.
complaining to Bud Foster about.
Q.
began?
10
A.
There was no need for it.
Okay.
No.
He was just
And I said, because
They're using the police
That's what I was
This happened before the march itself
I believe the march had already
11
occurred -- I could be wrong -- and they were in the
12
park and I had been denied entry.
13
entered the park, there was only -- this time there
14
was only like 120 of them.
15
fewer and fewer people show up to the marches.
16
I've been told by members of those groups it's
17
because when they hear about Cesar Chavez and what he
18
really stood for and when they find out what really
19
happens to the poor Mexicans who come in, how they're
20
exploited, many people drop out of the movement.
21
After the marchers
Every year they've had

And
And so the leadership of the movement,
22
there's a great disparity between the leadership of
23
the movement and the rank and file.
24
the rank and file hears this, they tend to drop away.
25
And by this point in 2012, they had gone from 15,000
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And so whenever
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active marchers in 2006, every year had been
basically cut in half.
figures from police reports and from news media.
seemed like every year you could cut it in half.
5
6
Q.
I tried to extrapolate
It
What did you understand the message of the
leadership of this group to be then?
A.
You have to understand, it's all in context
with larger messages that have been put out over the
years through Isabel Garcia and Arizona Border Rights
10
Foundation, which is her foundation, Derechos
11
Humanos, which has no legal status but acts as an
12
activist group, and the May 1st Coalition for Worker
13
and Immigrant Rights.
14
together and one reinforces the other, and so -- I'm
15
sorry, I lost the train of thought of your question.
16
17
18
All of their publicity merges
Q.
What do you believe that their basic message
A.
It's basically a very false message and it's
is?
19
basically one that comes out of basic -- basic
20
communist theory back in the '60's which I studied.
21
It was very clear that the communists in America,
22
often referred to by communists themselves, like
23
Stalin, as useful idiots and dupes and fellow
24
travelers because of their lack of knowledge of the
25
issues, that they were dividing America on the basis
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of race and ethnicity, creating racial -- trying to
create racial strife and class warfare.
That was one of their reasons for
supporting the Civil Rights Movement, even though, in
my opinion, the Civil Rights Movement was a very
grand time in American history, and I call it the
second American revolution, and a very happy time,
the communists were supporting that, but they weren't
supporting it basically because they wanted people to
10
have rights, they wanted to create racial division
11
and racial strife.
12
And so that continued on with the
13
Pro-Raza movements and the Chicanos Por La Causa and
14
the Pro-Raza statements of, you know, we're going to
15
kick the Gringo back to Plymouth Rock and we're going
16
to kill them and we're going to do all of these
17
things.
18
And it's a nonsensical message because
19
they look at the so-called Gringo as white people
20
who've exploited the indigenous poor and they ignore
21
the fact that that also includes Spanish
22
Conquistadores from Southern Europe who invaded South
23
and Central America and absolutely brutalized the
24
indigenous people in Central and South America and in
25
Mexico and up here in the Americas.
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It ignores all
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of that.
And it ignores the fact that the
practical consequence of open border policy is one of
misery and exploitation for the workers themselves,
along with all the other issues that are most popular
in the media in terms of the crime that's committed
by people involved in that, so...
8
9
10
Q.
When you use the term "Pro-Raza", do you
take that to mean pro Mexican or pro Hispanic race?

A.
No.
I take it to mean it in the political
11
sense of Viva La Raza:
12
everything; for outside the race, nothing.
13
consider that to be a hideous and horribly divisive
14
and totally unAmerican sentiment.
15
expressed sentiment of what I call the Raza movement.
For those of the race

I
And that is the
16
Q.
Which race do you take that to be?
17
A.
Oh, somehow making the assumption that being
18
Hispanic is a race.
19
it's a totally inaccurate statement and a very bad
20
statement.
21
Q.
To me it's a very racist and
To me it's as bad as white supremacy.
Did you -- when you were speaking with
22
Mr. Foster at this point that's shown in Exhibit 2,
23
did you discuss any of that?
24
25
A.
time.
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We have over the years.
We may have at that
I understand Mr. Foster has basically a dual

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personality and I have sympathy for him.
wrote an article critical of him and have later
apologized to him, felt very badly about it.
has a great interest as a classic reporter in these
issues.
I once
And he
When I was a kid, reporters seemed to be
very enthusiastic about ferreting out crime and
corruption and writing about these issues and
bringing it to public view, and that has changed in
10
modern journalism where they no longer do it.
11
declare two different sides and they report a story
12
here, a story there, and they don't get involved in
13
the controversy.
14
They
He's always seemed to be very interested
15
in these issues but he also has to make his living.
16
And he goes to his office -- goes to his boss and
17
says because I want to do a story about Roy Warden, I
18
want to do a story about the fact that he's not a
19
racist and he's in support of the Mexican poor that
20
he stands up with.
21
Emiliano Zapata and the Mexican
22
revolution speaks about these things, and yet they
23
portray him as a racist.
24
not going to do that kind of a story.
25
going to let our people hear that side of Roy Warden.
520-623-0593
And they said, no, we're
We're never
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1
2
3
So he's conflicted.
He's got a living to
make and a family to feed and he's got a job to do.

Q.
Do you have any recollection of speaking to
him on that day regarding what your countermessage
was to the message of the May 1st Coalition?
A.
I have no idea of the specifics.
Q.
Moving on to Exhibit Number 3, another
photograph supplied by you, and I guess taken by
Mr. Kay?
10
A.
Yeah.
11
Q.
What does that show for us?
12
A.
That's funny.
That's the actual entrance
13
walk-in.
14
Armory Park, the organizers had a bunch of people
15
there, and they were all dressed up in these outfits
16
here, so that, as I understood later in how they
17
deployed themselves, so that if I was to do anything,
18
which was not my intention to do it anyway, to burn a
19
flag or anything of that sort, nobody would see it
20
and therefore be traumatized by visually seeing it.
21
This is before the marchers ever got to
So it was a way of blocking out whatever
22
message they perceived I wanted to convey.
23
thought it was silly beyond belief.
24
Running around like ghosts in white sheets.
25
look like KKK people.
520-623-0593
And I
Ridiculous.
They
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1
2
Q.
Showing you Exhibit Number 4.
Is that a
similar photograph?
A.
Yeah.
That's from across the street where
that museum is, or whatever that official building
is.
to Armory Park, and that has been -- I don't know if
it was in 2006 but ever since then that has been the
official entrance, I believe, into Armory Park and
that's where I've been blocked.
That's the southern -- southern western entrance
10
Actually, one of the years before 2007 I
11
think I was blocked on the northern side.
12
pictures that show that.
13
always the southern entrance of the park.
14
15
Q.
I've got
But ever since then it was
So 3 and 4 show the orange fencing that's
placed around the park temporarily?
16
A.
Yeah.
17
Q.
And they also show you at or near the
18
19
The County fencing?
Yeah.
entrance?
A.
Yeah.
I believe that's snow fencing, to
20
prevent snow drifts.
21
identify it as coming from Pima County, having a lot
22
of roads up in the mountains they need to keep clear
23
of snow drifts.
24
25
Q.
That's why I was able to
And then again both 3 and 4 depict before
the actual march began?
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1
A.
I believe before, yeah, it would seem before
the march was ever -- actually, as to 4, I can't tell
you.
people in the park, but they're not near the
bandstand.
they gather to speak and use the facilities of the
bandstand, so it occurs to me that the marchers had
not gotten there yet.
I can see that there seems to be a lot of
And the bandstand is where -- is where
I could be wrong.
I don't know what relevance it has but it
10
occurs to me, as I look at this, I would say the
11
marchers had not yet arrived in Armory Park, nor had
12
they in photo 3.
13
Q.
Showing you number 5.
14
15
What does that show?

A.
Well, it's funny, because it's been a while
16
since I have really looked at this picture.
17
accept it, based on the fact of the way I'm dressed,
18
it's the same -- the same day, the same event.
19
appears to be the southwestern, across the street
20
corner, where some of their people are there, but I
21
don't really understand -- they mingled and moved
22
around.
23
I would
This
It could be -- I don't think it's part of
24
Armory Park.
25
background.
520-623-0593
I don't see the orange fencing in the

So I really can't -- it's a little
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confusing and I can't tell you what it is.
they were milling around across the street.
3
4
Q.
here.
Let me indicate with my finger.
Obviously
Right over
Do you see orange fencing there --
A.
Oh.
Q.
-- toward the top extreme side?
A.
Oh, yeah, then that would have to be.
Maybe
that -- yeah.
not focusing -- I should be able to focus on what
Again, when I'm looking at this, I'm
10
this building is here and know this by looking at it.
11
I'm not that comfortable with it.
12
Armory Park if that is in fact orange fencing there.
Evidently it was
13
Q.
Okay.
14
A.
And I don't -- and really I don't know --
15
oh, I'm sorry.
16
going -- that could be the northern -- the southern
17
entrance into the park there by one -- I call them
18
angels for some reason because they look like they
19
have wings, this lady on the left here.
20
might have been a banner that the marchers carried
21
that came up the street to enter the park.
22
This could be the south, as you're
And that
That occurs to me that's the southwestern
23
corner and the south part of that, going south of
24
Armory Park.
25
I can't really place these buildings here.
520-623-0593
That would make sense to me.
Although
I'm not
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familiar with what they are and I'm a little confused
by the picture.
3
4
Q.
Do you -- there's a banner we can see, part
of which says "Peace".
A.
Yeah.
Q.
Do you see that?
A.
Yeah.
Q.
Do you recall whether or not that was either
at the very beginning of the parade or close to the
10
beginning?
11
A.
Not at all.
12
Q.
What are you depicted as doing in number 5?
13
A.
I'm walking back from across the street
14
there.
15
my megaphone on my shoulder.
16
if I had been -- I don't think I'd been -- it was
17
probably after being rejected from entrance or maybe
18
that was before the marchers even got there.
Not at all.
I have a bottle of water in my hand.
19
I have
I guess, I don't know
Again, I can't orient this in terms of
20
time and place.
21
pictures.
22
occurred to me I was having my animated conversation
23
with Bud Foster after they kicked me out of the park.
24
I could be wrong on that but it occurs to me that's
25
when we were doing it.
520-623-0593
I don't see Bud Foster in the
And as I looked at these pictures here, it
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2
Q.
Let me show you what's been marked as number
6, Exhibit Number 6.
A.
Yeah.
Q.
A.
Resistance - Tucson May 1st Coalition.
I was always curious because of the
nature of the signs seemed to be disconnected from
what was actually going on.
resisting?
10
11
12
13
Q.
What were they
Resisting what?
So is this picture of the march or the
parade?
A.
I think this is a small portion of the
parade.
14
Q.
Okay.
15
A.
And the parades used to go on for hours.
16
They had so many people, it took forever.
17
people and drums, and, like I say, quite theatrical,
18
and kind of surprising because the Indians they
19
portrayed were always Aztecs.
20
Indians, they appeared to be Aztec-oriented.
21
Dancing
These weren't American
And, of course, the American Indians
22
hated the Aztecs and hated the Mexicans and hated the
23
Spanish because as bad as we were to them, they were
24
equally bad, if not worse.
25
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And so the fact that they tried to make

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an assumption here that there's a connection between
the American indigenous and the Mexican indigenous,
the connection is one of hostility and violence and
anger, no cooperation.
message, which I guess appears to uneducated
left-wingers that don't really understand the
history, but it doesn't make any sense.
8
9
10
Q.
So it's always a mixed
Let me draw your to attention to Exhibits 7,
8 and 9, and ask you what are in them.

A.
7 is, I believe -- I don't know that -- I
11
don't think I've asserted yet my right to go into the
12
park.
13
and I'm -- and I don't know if this is before or
14
after, but I'm communicating and telling them lots of
15
things.
16
a video of it because Kay didn't bring his camera, so
17
I don't really know.
18
It's as they are marching up towards the park,
And I don't have a tape recording of this or
I'm probably telling them about Zapata
19
and Zapata's dream for Mexico and that they needed to
20
have a revolution in Mexico to get Mexico away from
21
the upper class that continues to exploit and send
22
people out, that this is part of Mexican economic
23
policy to send poor people out of Mexico, where they
24
have no economic value to the Mexican society.
25
when they come up here and they work and they send
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And
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money back, they contribute more money than they make
from the sale of oil.
So it is a very cynical exploitation of
poor people, sending them out of the country so they
can grub for a living up here and send money back.
I'm telling them things of that nature.
you're telling through a bullhorn, you don't get
anywhere.
group of people and you're starting to explain these
And when
But if you're sitting one-on-one in a
10
things, they listen because you're just a regular
11
person, you're not the enemy, you're just a regular
12
person talking to them.
13
They're concerned about these issues,
14
too.
15
very hideous aspect of it and leadership of their
16
groups want revolution and don't want anything to be
17
peaceful and happy for Mexican people or American
18
people, for that matter.
They don't realize that they're involved in a
19
That's number 7.
This is the same thing.
Occupy Tucson.
20
I'm familiar with that movement and I had a lot of
21
contact with them when they were going on.
22
Number 8.
23
That's
I had a lot of communication with them.

Again, misguided people not understanding
24
the underlying issues, which I share concern for the
25
underlying issues but they were going about it the
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wrong way.
Number 9.
I'm not sure who the cameraman
is but it looks like a professional camera.
always media of some sort there; sometimes more,
sometimes less.
media camera.
this point I'd been kept out of the park or not.
8
9
10
11
Q.
There's
That obviously is a professional
I don't know if -- I don't know if by
The message that you were delivering in 7, 8
and 9, is that a message you've been delivering for a

number of years?
A.
The message of you as marchers, you as
12
participants have been betrayed by your leadership?
13
Yes, very consistent, and never reported by the
14
press.
15
Bud Foster was very impressed with it
16
from the standpoint, well, I never knew that, Roy.
17
And we've always had conversations about that.
18
writings have been -- it was actually the end of 2006
19
when we started out -- when I started out, this
20
so-called protective border movement had gone on for
21
several years before I became involved, I took it at
22
face value.
23
is the argument now and it's an absurd argument, that
24
a bunch of Mexican people are coming into America to
25
take America over and take away our jobs, that that's
520-623-0593
My
And the face-value argument, which still
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their intent.
And it was by the end of 2006 I started
to say, no, these people are actually being invited
in.
policy, where the officials and the business people
are aiding and abetting their entry and encouraging
their entry so they can exploit them politically and
economically, that they are actually victims as well;
in fact, the greatest victims in this whole
10
There's a policy.
I called it open border
horrendous enterprise of open borders.
11
That's been a very consistent message,
12
which when I speak with people one on one, like I
13
have done at the federal court on demonstrations
14
against Operation Streamline, and I did again just
15
recently down at a Lavoy Finicum rally with some
16
left-wing people, we share a great amount of sympathy
17
with each other on those viewpoints.
18
poor people getting exploited by the rich people, and
19
that this is a further example of that.
20
21
22
Q.
It's always the
Do you use the term open border -- or did
you use the term open border policy May 1st, 2012?
A.
I'd believe I did.
If somebody has a
23
recording of the entire event and I didn't use it,
24
I'd be highly surprised.
25
theme, and that is there's a policy, there's a
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It's been a consistent
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governmental policy which benefits the politicians
and the upper class people and the rich who want more
and more poor people to fight over jobs to keep the
wages -- it's like the Grapes of Wrath, if you read
Steinbeck's Grapes of Wrath, it's the same policy of
bringing in excess labor to the point that you
diminish the value of labor because you've got 10
workers for every job.
I said, it's exploitive, it's horrendous.
10
It's creating misery for all kinds of people.
11
you people are tacitly participating in it and
12
encouraging it, is what you're doing by your
13
marching.
14
Q.
And
To me this location in 7, 8 and 9 appears to
15
be across the street and to the south of Armory Park.
16
Is that accurate?
17
A.
I don't -- actually, I think it's on the
18
same side as Armory Park.
19
the street.
20
but it's on the -- this is the north, south, this is
21
coming up from the south, it's the western side of
22
Armory Park, if you continue down to the south, it's
23
that part of the street.
24
museum or that, you know, I talked about that nice
25
building, it's not -- it's not that side of the
520-623-0593
I believe it's not across
It's across the street from Armory Park,
But it's not where that
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1
2
3
4
street.
Q.
Okay.
It's on the same side as -- of the
street as Armory Park is on?

A.
Yeah.
See, the real problem is when you're
speaking through a microphone and you're kept out as
someone, don't listen to him and those people are
putting up the white barriers and stuff -- in fact,
they used this sign -- now that I'm looking at this
10
long sign here, they use that to shield me from the
11
marchers, then you are an enemy.
12
to you.
13
just basically an agitator that's against what
14
they're doing.
15
16
17
Q.
People won't listen
They don't care what you're saying.
You're
Who used a sign to shield you from the
marchers?
A.
These people right here.
I recollect how
18
they did it.
19
park originally.
20
the sign and they would walk parallel to me, trying
21
to keep the sign between me and the people marching,
22
so the people marching would not have a view of me.
23
24
25
Q.
They -- I think they had been up at the

They came down and they positioned
They have some sort of message on that sign;
is that correct?
A.
520-623-0593
Yeah.
It could be the same one we saw in
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1
the previous picture.
guess I could try to read it backwards.
that picture was there, I would basically guess it
would be the same -- same sign.
5
6
Q.
I don't know what it is.
Whatever
And that would be a message that was
opposite to what you were saying?
A.
group.
Q.
Okay.
10
A.
It was basically that.
11
Q.
I gotcha.
12
A.
One of those general messages.
No, it was a message supportive of their
You see, the
13
messages sound great until you separate them from the
14
reality of what's happening, then you realize it's
15
all smoke and mirrors and propaganda and not to
16
anybody's interest except the leadership of these
17
groups.
18
19
20
Q.
bullhorn outside of Armory Park?

A.
21
22
23
24
25
Did you speak to any persons without the
I'm sure I did.

And I'm going to have to have a bathroom
break real soon.

Q.
Okay.
Let me finish this up and then we'll
do that.
A.
520-623-0593
I'm sure I did.

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1
2
3
Q.
Did you speak to these two individuals
holding the sign without the bullhorn?

A.
I don't believe I did.
I believe it was
basically their attitude was one of like those people
with the -- it seems that there's college kids there
and they have a very focused, I call them political
operative.
left-wing ideological purpose, and they're not there
-- they're not there for communication.
They seem to have a very focused
They're
10
there to basically organize and run the groups and
11
they're not part of the league of common people.
12
They're part of the organizers.
13
14
Q.
Did you try to talk to any of the marchers
without the megaphone?
15
A.
No way to.
16
Q.
You couldn't walk out in the street and talk
17
18
There was no way to.
to them?
A.
They're making a lot of noise as they're
19
marching up and chanting and talking and so forth.
20
There was no way to communicate to them on that
21
basis.
22
Q.
23
24
25
So you didn't make any attempts outside of
the park?
A.
I may have.
I don't recollect that I did.
It was counterproductive.
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You see, once you're in
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the park and everybody's in the group and you're
standing there, you have -- the way the dynamics of
it is there's a whole bunch of people, there's people
speaking, there's lulls of activity in between,
there's people commenting upon what the speakers are
saying and interacting.
dynamic.
the event.
occur.
10
Q.
11
12
It's a much different
You're not marching to an event; you're at

And that's when real communication can
When the event finished, did you attempt to
speak to anyone outside the park?

A.
I think I left before that.
Basically,
13
they're keeping me out, there's nothing I can do.
14
don't believe I waited until the finish of the event.
15
Again, I've been excluded from the event.
16
clear.
17
That was
And so again, I can't speak to these people.

Like I said, it was oddly enough I got to
18
speak with people during the Lavoy Finicum rally.
19
And we have all of this on film and the Arizona Star
20
film.
And they came over and I invited them to
21
speak.
I said, I want you to speak through the
22
loudspeaker and I want you to explain your viewpoints
23
on the rancher issues and the Indian issues.
24
25
And they were very eloquent and very

passionate and I was very grateful for that.
520-623-0593
In
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fact, I said many times I'm happy that this
communication with people who have historically been
on the opposite side of an issue.
that the American Indians were exploited and cruelly
treated and they have a claim to this land, too, just
like the ranchers were claiming that the federal
government's claiming it.
8
9
And I understand
Because we all have a claim to the land,

but between us, we, the people, there's a lot of
10
sympathy between us.
11
And they talked to me personally, and yeah, we've
12
seen you down here, Roy, and we've seen you before,
13
we know who you are and we agree with that.
14
know, and then when I talk about -- when they talk
15
about Operation Streamline, that it's horrendous,
16
they agree with that.
17
You
And that was an attempt at that time to
18
start that process.
19
until after that.
20
And they acknowledged that.
Q.
And I was never able to start it
How long -- that you're pictured in 7, 8 and
21
9 there, how long were you delivering your message to
22
the marchers?
23
A.
I don't believe that I was effectively
24
delivering any message.
25
wasn't my intention I'm delivering a message.
520-623-0593
There was no -- it certainly
If I'm
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1
talking to them through this loudspeaker, they're not
hearing because we're not in a position where they're
going to listen.
together and you're talking informally.
people listen.
loudspeaker, which is what I was reduced to doing,
there's no communication at all.
8
9
10
Q.
You listen when people are gathered

That's when
When you're shouting through a
How long were you using the loudspeaker to
convey what you wanted to convey?

A.
I wasn't able to convey what I wanted to
11
convey.
12
the dream of Cesar Chavez.
That's not a communi --
13
it's a statement of fact.
It's not a communication.
14
I wasn't communicating anything of what I wanted to
15
communicate to these people as a group and
16
individually.
You understand?
Other than you're betraying
17
Q.
How long were you doing that?
18
A.
Half an hour, maybe, 20 minutes.
19
recollect.
20
Q.
Okay.
21
A.
Could have been less, it could have been
22
23
24
I can't
I really don't know.
more.
Q.
Let me ask you just a couple more questions
and we'll take a bathroom break.
25
520-623-0593
Earlier you stated you thought you talked

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1
to Bud Foster after the rally was over.
2
3
Do you recall that?

A.
I believe so.
And I could be in error on
that.
dispute him.
animation, I remember being somewhat animated when
I'm talking to him.
do this?
it says, and here's what they're doing.
10
If he has a different recollection, I wouldn't

It occurs to me, just based on my
I said, hey, Bud, how can they
You read the Rankin letter, you know what

How can they
do it?
11
And he's laughing and saying, well, you
12
never know what these people do.
13
supposed to protect the law.
14
we elect and appoint to protect the law, which
15
protects all of our rights, and they are
16
intentionally violating the law.
17
this, Bud?
18
paycheck to earn and people to feed at home, so I go
19
as far as I can go and that's it.
20
Q.
I said, they're
They are the officials
Why are they doing
Just he'd smile, you know, I've got a
So it sounds to me, from your recollection,
21
you may have actually been there after the rally was
22
over?
23
A.
I don't think so, no.
My recollection is
24
these people are generally there for two hours.
25
know I was not there for that time, that period of
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time.
believe I communicated with anybody after the rally.
I wasn't nearly there that long and I don't
Basically I'm kept out of the rally.
Again,
it's an antagonistic relationship between me and
these people on the basis of they've enforced this
permit.
They've expressly put my name down on the
permit.
Keep Roy Warden out.
he has to say.
the rest of the leadership.
10
Don't listen to what
This is coming from Isabel Garcia and
And so the people that follow don't know
11
until I do have a time to talk to them informally,
12
like I've done down at the federal building at
13
Operation Streamline rallies that they've had, and
14
they've got a little table set up and we have very
15
informal chats and they say, you know, we get -- a
16
lot of us get your e-mails, Roy, and we agree with
17
what you have to say.
18
So that's real communication.
And that's what I wanted that day.
19
That's what I didn't have that day nor any day before
20
that.
21
22
23
Q.
Because you weren't allowed inside Armory
Park?
A.
Because I'm not allowed in because I
24
basically have been identified as the enemy that we
25
have to keep out because he's dangerous and even the
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1
2
3
4
police have to be here to keep him out, yeah.

Q.
But the basis of your lawsuit is you should
have been allowed to be inside Armory Park?

A.
I should have -- they should not have issued
that permit, they should have not kept me out.
knew what the law was expressly stated.
They
And I've got to tell you, in some of my
cases over in Tucson municipal court, Judge Berning
and other judges were quite, quite surprised when
10
they saw that letter.
They just said:
Really?
11
And they, you know, tried to get their
12
minds around the significance of the City attorney
13
correctly stating the law one day and then within six
14
months he's actively doing exactly the opposite to
15
placate Isabel Garcia and other members of her group
16
that felt that the police department had betrayed
17
their movement.
18
She said so in the media, said so on TV.
19
We lost trust in the Tucson Police Department.
20
betrayed us.
21
by keeping the enemy out.
22
Now we're trying to reestablish trust
MR. GREENE:
Don't listen to them.
All right.
Why don't we go
23
ahead -- it's about just shy of 11:00.
24
go ahead and take a break.
25
THE VIDEOGRAPHER:
520-623-0593
They
Why don't we
Going off the record at
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1
10:58.
(Recess taken from 10:58 to 11:06 a.m.)
THE VIDEOGRAPHER:
4
5
6
We're back on the record.
This is medium number two and the time is 11:06.

Q.
(By Mr. Greene)
Mr. Warden, I'd like to
show you what's been marked as Exhibit Number 10.
A.
Uh-huh.
Q.
Do you recognize the contents of that photo?
A.
Yeah.
And again it's probably one I haven't
10
looked at for a while.
11
orientation, south of Armory Park, immediately south
12
of Armory Park, crossing the street towards the
13
entrance to Armory Park.
14
It seems to be the same
I don't know whether that was when I was
15
making my move to enter and I was denied.
16
have pictures of that.
17
three or four looking at them directly, Sayre and
18
Lopez and the other fellow, McCarthy, at the
19
entrance, when they're denying me entrance.
20
see them in the background.
21
are.
22
entrance or after.
23
You do
I sent you pictures of that,
I don't
I don't know where they
I don't know if this is before I've been denied
Q.
I have no idea.
Based on your recollection today, did you
24
use the bullhorn before seeking entrance into the
25
park?
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1
A.
May have but I don't think so.
I may have
on the basis that -- that Sayre says we're not going
to let you in.
made up, I'm not going to be able to enter the park
and talk to these folks like normal people talk to
each other.
So at that point I knew the mind was
And so I may have already been reduced to
speaking through the bullhorn, knowing that that's
the only chance I was going to get of any
10
communication whatsoever.
11
them about Cesar Chavez.
12
guy's hand once back in 1966 on the Delano grape
13
strike march, which I went on, when they recruited
14
people out of UC Berkeley.
15
and followed his career.
16
him.
I said, I may as well tell

Oddly enough, I shook the
I actually met the guy
Very highly impressed with
17
And it's absurd when these people hold up
18
posters of him as if he is a leader of their movement
19
or he would agree with their movement, when he was
20
passionately against labor coming up from Mexico,
21
passionately against illegal immigrants competing for
22
jobs with the farm workers.
23
In fact, he went to jail for that in Yuma
24
for trying to -- they broke his strike.
25
in illegal labor and broke a strike that he had and
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They brought
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he and his strikers went back out there and they got
involved in rock throwing and screaming and yelling.
He was put in jail for 30 days.
collateral -- an issue of collateral estoppel that
came out of that that reflected in some way to my
criminal cases in City Court.
whole case because it had an interesting legal issue
and it was good for me.
And there was
So I reviewed the
And I said, hey, you know, I've known
10
about Cesar Chavez for all these years.
11
totally against this.
12
straight in the face and say you're doing the wrong
13
thing for Mexican people and for Americans, you're
14
doing the wrong thing.
15
people understand it because they're not educated.
16
Q.
He would be
If he was here he'd look them
But you can't make these
Does that picture 10 show a number of police
17
officers and then you apparently crossing the street
18
towards Armory Park?
19
A.
Yeah.
20
Q.
Is it possible that you --
21
A.
Towards the corner of where I had my
22
confrontation or communication with Bud Foster, I
23
believe it was on that side of the street.
24
was less people around at the time.
25
that's towards the entrance.
520-623-0593
And there
But I believe
It would be natural
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that we would all be near that entrance because
that's where the action was and that's where they
kept me out of the park.
Q.
Showing you Exhibit 11.
A.
Okay.
Q.
A.
Well, it shows -- and again it gives a very
good showing of where they're holding up that sign to
keep me -- that sign was there before the marchers
10
got there, and as they deployed themselves and moved,
11
it was clear their prearranged plan was to deploy
12
that sign in such a way that the marchers wouldn't
13
see and therefore wouldn't comprehend anything I'd
14
have to say.
15
I know they deliberately went through that.
16
realized how silly that is.
17
That's what that occurs to me.
Because
And I
And these were -- I guess these weren't
18
marchers, these were people that had organized the
19
event.
20
And rather than having communication and debate, they
21
don't want any outside information.
22
any questions as to the motives of their leadership.
23
They don't want any of that.
24
to be too stupid and think that they're standing up
25
for humanitarian reasons, when they're not.
520-623-0593
These were some of the political leadership.
They don't want
They want the marchers
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1
2
Q.
Are you speaking through your bullhorn in
that picture?
A.
I think so.
Q.
Does that appear to be your microphone in
your left hand?
A.
Yes, it appears to be a microphone.
And I
don't generally use the microphone, but it occurs
that's what I'm doing there.
9
10
Q.
12.
11
12
Does it show something similar?

A.
Yeah.
And again the same purpose of the
13
sign was to keep me from having any communication
14
with the crowd that might be receptive.
15
leadership, of course, these people holding it,
16
they're never going to be receptive.
17
hardcore left-wingers and devotees of Isabel Garcia.
18
They call actively for the overthrow of the American
19
government.
The
They're
20
Q.
Are you also using your bullhorn there?
21
A.
Yes, I am.
22
anybody.
23
communicate.
24
25
But I'm not communicating with
I'm venting my frustrations that I can't
And I believe that's Sayre to my

right-hand side, and Lopez, it could be, kind of
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looks like them.
them and all that.
be Lopez.
Q.
But the picture seems to shorten

But that could be Sayre and could
As you sit here today, do you have any
recollection of speaking to Diana Lopez at the scene
at all at Armory Park?
A.
Frankly, I don't.
I'm not saying I did or
didn't, I just simply -- I'm only kind of focusing on
Paul because, like I said, he's such a friendly guy,
10
and I know in the ways that we've been friendly in
11
previous communications, I know he's looking for
12
information that's relevant to the police department
13
and on issues of prosecuting me, but he's so friendly
14
about it, we get along real good, so I'm focusing on
15
just maybe communicating with him.
16
17
18
Q.
Do you have any recollection of speaking
with Captain McCarthy, Kevin McCarthy?

A.
Frankly, my recollections of him was that
19
there was a third person there, and later when I
20
analyzed the photographs on my computer and zoomed
21
in, I could see his name, McCarthy.
22
third person was there.
23
was a captain.
24
or other, I learned what his status was.
25
520-623-0593
And so I knew a
I think later I learned he
Through some discovery or something
And as I researched it further, I found

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out he had been kicked out of the police department
for lying about serving with valor in combat in Iraq
or Afghanistan, and he hadn't.
great witness he's going to make.
5
6
Q.
And I said what a
To the best of your knowledge, you never had
a conversation with him that day?
A.
I don't recollect that I did.
Q.
All right.
A.
Except he was part of the triumvirate that
10
were physically going to prevent me or arrest me for
11
trying to enter the park.
12
people standing between me and the park.
13
Q.
Showing you what's been marked as Number 13.
14
15
He was one of the three
Do you recognize the contents of that

exhibit?
16
A.
Well, that's me in the background behind,
17
with a water bottle, looking kind of silly.
18
believe that's Lopez on my left-hand side.
19
that's Sayre on my right-hand side, it would occur to
20
me.
21
I
I believe
It could be that we were speaking on that
22
side of the street, and I said, well, I'm going to
23
enter now and so they says, well, we'll put ourselves
24
in position to stop you from entering.
25
been that.
520-623-0593
It could have
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Q.
Okay.
A.
I don't know whether it does or not, but
something occurs to me that if that is -- I obviously
accept the picture as being valid, and it would occur
to me maybe that's what happened then.
Q.
It appears that you are saying something.
Would you agree with me on that?
A.
Probably, yeah.
Q.
Do you have any recollection what you might
10
have been saying at that point?
11
A.
No idea.
Like I say, I only have any
12
recollection of any of this simply by looking at the
13
pictures.
14
asked me that once, I says, you don't understand,
15
when you've had dozens of these marches, if you don't
16
look at pictures, you don't remember anything.
17
don't remember anything other than I knew on that day
18
I had been kept out of the park.
19
I don't have any independent -- somebody
Q.
21
A.
Yeah.
22
Q.
Do you recognize that?
23
A.
Yeah.
20
24
25
14.
That's just before the denial of
entry into the park, I believe.

Q.
520-623-0593
Tell me about what's going on in that

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1
2
picture.
A.
Well, it seems like Sayre and Lopez are
talking with the march organizers, who were supposed
to, if they had somebody come into the park that they
didn't want to come into the park, they were going to
exclude them.
I don't know who that guy is, but I know
he was named as an unnamed defendant or unknown
identity, a John Doe or -- I don't know how I
10
referred to him.
11
going through the ritual of them asking him do you
12
want him to come in and they said no.
13
Unidentified protestor.
And so I don't know.
I think
They're having a
14
conference, police are there, they're having a
15
conference with this guy.
16
told me maybe an hour earlier, without this guy even
17
being there, we're going to keep you out of the park.
18
That's all.
19
20
21
Q.
And the police had already
And the "this guy" you're referring to, is
he a tall man with a ball cap and orange vest?

A.
Yeah.
And he's just basically -- yeah, and
22
I have him on film in the 2010 event, or maybe it was
23
2009, when Kathleen Robinson kept me out of the park,
24
and I remember him being basically not very
25
intelligent in terms of what he said.
520-623-0593
And I'm asking

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1
him, why do you want to keep me out of the park?
speak -- I'd want to speak with you.
want to speak with me on these issues?
Mike Rankin says, you know, we don't have to let you
into the park.
Why don't you
Q.
Let me show you --
A.
I said, well, here's a letter.
says you got to let me in.
different now.
11
Q.
Well, because
Giving me this whole song and dance.
10
I'd
Mike Rankin
Well, he says something
So the law doesn't mean anything.
Let me show you what's been marked as
Exhibit Number 15 and see if you recognize that.
12
A.
Yeah.
13
Q.
So what does that show us in 15?
14
A.
It shows Lopez and Sayre together.
This is the masthead of my website.
I don't
15
see McCarthy, but I think he's there in other photos
16
of that, because I think we have three or four of
17
that time.
18
dark -- one eye dark and other light glasses and the
19
orange vest, he's the guy we're looking at the back
20
here.
The guy on the left-hand side with the
21
Q.
In 14?
22
A.
Yeah.
23
Q.
Okay.
24
A.
There's a cameraman behind him.
25
And then
there's this guy here, he's Teadle -- I think later I
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figured out, and it was just recently, I never knew
how to put names to these people, but it occurs to me
this is Teadlebaum.
internet, member of the Communist party, which is no
big deal these days.
to whatever party he wants.
He's a self-avowed, on the
And that's fine, he can belong
But he's very happy that the police are
keeping out somebody that wants to speak on these
First Amendment issues.
And I remember talking to --
10
talking at people like that.
11
you're so much against the police interfering with
12
the right of protest when you're trying to protest,
13
but when you want to keep somebody else out, you're
14
all supportive of the police doing this.
I says, it's so funny,
15
You people just believe in the use of the
16
law and the police to protect your personal political
17
objectives but if somebody has a different point of
18
view, you don't want to hear that and you're happy to
19
have the police shut them up.
20
when the government changes and they do that to you?
21
You're going to be complaining of police misconduct.
What's going to happen
22
Q.
Are you on your bullhorn there in 15?
23
A.
I could be.
It certainly appears that I am.
24
I don't remember the exact moment except I was very
25
-- I remember being frustrated at this guy's grin and
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the great hypocrisy that the law protects only those
who speak the viewpoint that we agree with, you see.
And that's what I've always thought
greatly hypocritical about these left-wing people.
They're so happy to use the police to stop your right
of speech if you disagree with them, but if you agree
with them, it will be front page news, letters six
inches high, the police are violating the right of
free speech in Armory Park.
If the roles were
10
reversed here, there would have been headlines:
11
Police State.
12
Q.
What are you saying at that moment in 15?
13
A.
I have no idea.
Really.
I may have been
14
expressing my frustrations.
15
their standpoint.
16
frustrations because I'm very frustrated at the
17
hypocrisy of that, very frustrated when I talk to
18
police officers like Sayre, and they read a letter
19
that says the law says one thing and then they do
20
exactly the opposite, based on instructions they get.
21
It seems relaxed from
I believe I was expressing
And the law is not that fragile.
The law
22
means what it says.
23
something different because you don't like the guy's
24
political viewpoint.
25
doing that, and that seems to vex me tremendously,
520-623-0593
It doesn't mean you can do
You can't do that.
But they're
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and it might vex people like Bud Foster but he won't
really admit it to me.
these people at all.
4
5
Q.
8
9
16.
6
7
But it doesn't seem to vex
Do you recognize what that's a picture

of?
A.
Yeah, it's a close-up -- it's basically -- I
know it's the same encounter, either before or after,
10
different perspective of it.
11
McCarthy's name.
12
That's when I saw
And he's in the picture.
And again I believe that's Teadlebaum
13
there.
14
wasn't aware of that name at the events here.
15
when I filed the lawsuit, the name -- I had seen the
16
name before on previous permits and stuff but I
17
didn't associate it with him.
18
the internet.
19
I only came up with that name recently.
And
Ran his name through
And, frankly, his picture looks different
20
than he is here, but it's the same guy.
21
from California and he's a California organizer.
22
He's a member of the Communist party.
23
all about these very radical overthrow America
24
doctrines that they follow.
25
Q.
520-623-0593
And he comes
And they're
Do you know whether you're using your

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2
bullhorn in that picture, 16?

A.
I have no idea.
I'm just noticing that my
stomach is a lot fatter than it should be, other than
that.
5
6
Q.
Drawing your attention to number 17, another
photograph that you supplied me.
A.
Yeah.
Q.
What's going on in that picture?
A.
I know exactly what's going on.
Sometime
10
before or just after, it occurs that it's just after,
11
they are writing down identification information on
12
business cards, one of which apparently I still have,
13
and I may have disclosed, and others -- it seems like
14
all three, or at least two of the three, Sayre and
15
Lopez, are writing down information.
16
one card at home and I think I have disclosed a
17
picture of it.
18
they're doing.
19
20
21
22
23
I think I have
But that's what it occurs to me that
Because I wanted documentation of who you

are and what you've done.
Q.
What are you shown doing in that picture,
Mr. Warden?
A.
That's not a gun in my hand.
24
looks like right now.
25
pointing it at them.
520-623-0593
That's what it
It looks like I have a gun

It's not.
I didn't have any
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weapon on me that day.
weapon.
Didn't have any -- any
I'm apparently holding my microphone in
my hand.
shoulder.
tucked into something.
information and then I'm watching them as they write
it down, writing down their personal identifiers.
I have the loudspeaker over my left

I have a bottle of water there that's
And I'm asking them
And as I look at it now, if somebody said
10
this is Warden just before he shot those three
11
officers, I'd say, yeah, the picture sure seems to
12
show it.
13
appears to show that to me, but --
Doesn't it?
Well, I am just saying it
14
Q.
It looks like a microphone to me.
15
A.
Huh?
16
Q.
Looks like a microphone to me.
17
A.
Looks to me like a gun, like the back end of
18
a gun with the hammer down, although Glocks don't
19
have a hammer in the back.
20
21
22
Q.
How long were you at this event on May 1st,
2012?
A.
From the first time -- from the time I first
23
encountered Sayre and the other officers in the first
24
picture 'til I left?
25
Q.
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Yes, sir.
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1
A.
It could have been as short of a half an
hour, it could be longer than that, to an hour.
wasn't greatly longer than an hour, as far as I
recollect.
documentation showing that it was longer, I wouldn't
disagree with it.
It
But if somebody was there with the
I simply don't know.
Q.
Okay.
A.
But this is near the end of the event, when
I know I've officially been rejected from Armory
10
Park, even though they told me an hour earlier they
11
were going to keep me out.
12
now I've got the -- I need some identifying
13
information.
14
It's just happened and
And I remember losing all that stuff and
15
didn't have it before I filed the suit, didn't have
16
access to it, so I didn't have the names of these
17
people.
18
situation at that point.
19
files.
20
on it.
I was actually living in a homeless

Didn't have access to my
So that occurs to me now as I'm looking back
21
Really, in my mind, I have to probably at
22
some point sort back and go back through every step
23
of the way.
24
obviously, I think, just after I'm rejected from the
25
park, officially told I'm not -- you know, for the
520-623-0593
And I don't know if this is --
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second time actually not we're going to keep you out,
we're keeping you out.
Q.
Okay.
A.
Can I have some more water?
Q.
Absolutely.
A.
Thank you.
Q.
What kind of reaction did you get from
individuals at the event when you were using your
bullhorn?
10
A.
When you say individuals at the events, what
11
I would separate, there are -- first of all, there
12
are people there that support protect the borders.
13
And they show up in some of the film that I've -- I
14
think I've disclosed all the film that I have.
15
show up in some of the pictures.
16
thinking of videos of other events, but there were
17
people there that want to protect the borders.
18
They
Or maybe I'm
Most of the people, of course, are open
19
borders people.
20
and are willing to discuss the issue because they're
21
concerned about the welfare of the Mexican poor, just
22
like I am, so we can talk about the issues.
23
Some of those people have open minds
Other people are event organizers and
24
they don't care at all.
25
they spent constructing these stupid things just so
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You realize how much time
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1
people wouldn't see?
Q.
And you're referring to the angels --
A.
The so-called angels.
Q.
-- in 14?
A.
Yeah.
And then the way they carry signs and
don't let anybody see.
listen to him.
Don't do anything with him.
organizers want.
10
11
12
Don't listen to him.
He's an outsider.
Don't
Don't see him.
That's what the event
Q.
And that's what you're referring to here in
A.
That's what they're doing there, yeah.
11?
So
13
this is -- and I'm saying, what's wrong with these
14
people that are so afraid of talking?
15
afraid of talking?
16
Why are they
It used to be back in 2006 the logo was
17
prayer and dialogue on immigration, in a folded
18
ribbon, a bow.
19
been any dialogue, never been any rational talking on
20
the issues and what the solutions are.
21
more passionately concerned with what happens to poor
22
people than these people could every dream of being,
23
in a practical way, and have applied many aspects of
24
my life to that.
25
They don't want dialogue.
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Prayer and dialogue.
There's never
Because I'm
So there's never been any dialogue.
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Q.
Those people in 11 that have this banner,
when they were walking in front of you, how close
were they to you?
4
5
A.
I would only be able to extrapolate it from
the picture itself.
Q.
Okay.
A.
They seemed intent, as much as they could,
to put themselves between me and the marchers so that
I would not be able to communicate with the marchers
10
there, and certainly by keeping me out of the park,
11
so I wouldn't be able to communicate with them there.
12
13
Q.
Did you make any efforts to go around them
or avoid them?
14
A.
No.
15
Q.
Did you just --
16
A.
You mean to dodge and move and to do all of
17
18
19
20
this kind of stuff?

Q.
So that you could have better access to the
marchers.
A.
I wasn't going to get into physical
21
conflicts with these people where they have to
22
reposition themselves, and so forth.
23
any violence.
24
speak with these people.
25
vociferously as I could, and that was it.
520-623-0593
I didn't want
It was clear they didn't want me to

I did the best I could, as
There was
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1
2
3
4
nothing more to be done.

Q.
When you were using the bullhorn, did you
stay in one place or did you move?

A.
No, I moved.
You can see here I'm walking,
moving back north towards the park.
are across the street and down the sidewalk, next to
that fence here, and I'm half a block to the south.
At one point we
Q.
Showing 9 --
A.
And these people are still there.
10
Yeah, you
see?
11
Q.
Is that number 9?
12
A.
Yeah.
13
Q.
Okay.
14
A.
And these people are there.
So they came to
15
position themselves between me and the crowd.
16
were not part of the march, otherwise the banner
17
would be pointing out, so people watching the march
18
could see what they were about.
19
keeping me from having any communication with the
20
marchers.
21
22
23
Q.
They
They were about
Was that one of the reasons you had the
bullhorn, so that you could project your voice?

A.
I carry the bullhorn wherever I go when I go
24
to these events.
25
people to speak, just so if you have something to
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And many times I offer it to other
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say, I'm quite willing to have you say it.
said at all of my rallies, I don't care what side of
the issue of open borders or immigration you're on,
if you have something rational to say about it, for
or against, you're welcome to use the loudspeaker and
communicate to us what your opinions are, so we can
have dialogue on this issue.
8
9
10
11
Q.
And I've
Was one of the reasons you had a bullhorn
there so that you could reach people that were far

away from you?
A.
I'm just trying to tell you, I've always
12
carried them to my rallies to use them.
13
in 2006 and I've had one ever since.
14
better sound system now.
15
people that are somewhat of a distance from you,
16
yeah, certainly.
17
18
Q.
I've got a much
It's to communicate with
On May 1st, 2012, did you see -- well, let
me ask you this:
19
20
We used them
Do you know what Richard Miranda looks

like?
21
A.
Yes.
22
Q.
Mike Rankin?
23
A.
Yeah.
24
Q.
Lisa Judge?
25
A.
No.
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Q.
Fred Gray?
A.
No.
Q.
Reenie Ochoa?
A.
No.
Q.
Did you see either Mr. Miranda or Mr. Rankin
6
7
at that May 1st, 2012 rally?

A.
I didn't see any of them there, nor did I
see Isabel Garcia, nor had I seen her for several
years.
10
Q.
Okay.
11
A.
But I'd read things published on the
12
internet that she had written, knew of that, and, of
13
course, I had read the permits going back to 2006.
14
You see, by this point here I have those
15
operative documents from 2006 that I disclosed to
16
you, and got back from you, showing what happened,
17
the permit process, who's involved in the permit
18
process.
19
Rene -- Reenie Ochoa's name and Mike Rankin's name,
20
and I knew about Miranda before, but I became
21
familiar with all these people as a consequence of
22
that.
23
That's when I first became familiar with
But I don't think I ever laid eyes on
24
them at any of these events.
25
Tucson City Council meetings, got a pretty good view
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Although I did at the
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1
of Miranda on numerous occasions and Mike Rankin on
numerous occasions.
Q.
In your Complaint you mention cronyism.
A.
Uh-huh.
Q.
And open border policy, for that matter.
And I think you've explained to me what open border
policy is.
8
9
What is cronyism?
A.
Well, let's put it this way.
Are you
10
familiar -- really familiar the facts of the
11
Gilmartin case?
12
Q.
You explain to me, if you would, what --
13
A.
Well, when a guy like Miranda does what he
14
did that the jury heard and the jury comes back, and
15
says this so vile, we're going to charge the City of
16
Tucson -- that we're going to charge the City of
17
Tucson $900,000, and we're going to charge Miranda,
18
Ochoa and Smith, they're going to pony up two million
19
between the three of them, punitive damages, we're
20
going to do that because we're so disgusted at the
21
way you treated Gilmartin, and three weeks later,
22
after paying 1.8 million dollars of that judgment,
23
they hire Miranda at an increase in pay, promote him
24
to Assistant City Manager, that's cronyism.
25
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You take care of your own.

You take care

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1
of your buddies.
with jobs.
service for you.
4
5
6
Q.
You pay off your political debts
You make money for people who've done a

That's what cronyism is.
Do -- any other examples involving the City
of Tucson that you have of cronyism?

A.
Rio Nuevo.
The fact that Mike Rankin helped
disguise a theft of 250 -- I put down 200 million
dollars in one of my articles.
million dollars.
Apparently it was 250
This money was stolen from Rio
10
Nuevo.
11
the documents that were missing.
And Mike Rankin helped steal the documents,
12
When you read the FBI reports, it says we
13
found no evidence of criminal conduct that we connect
14
to any individual.
15
investigation.
16
documents had been lost.
17
stolen.
That was the purpose of our
They said memories were confused and

So the evidence had been
18
And here you have 250 million dollars out
19
of how much they got that went into accounts and went
20
out of accounts and they say we can't find it.
21
isn't a pile of money on a table like this that
22
anybody could come by and take some for his pocket
23
and therefore you can't account for where it went.
24
Money goes into a bank account, checks are written,
25
it comes out.
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This
It's very easy.

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Q.
Are you saying that you're the person who
brought Rio Nuevo and the Gilmartin matter to the
attention of the Tucson City Council?
A.
Of course not.
I brought the issue of the
fact that what was written was a coverup.
all about these issues.
political deal.
attention that you think you're fooling everybody
else and the media doesn't care about these things
They knew
That's part of their
No, I didn't -- I bring it to the
10
because they sympathize with you politically on open
11
border policy, but you people are engaged in an
12
ongoing criminal conspiracy and criminal misconduct.
13
Q.
Did you have evidence yourself that
14
Mr. Miranda was hired on as the City Manager in
15
return for doing something because of the Gilmartin
16
case?
17
A.
Did you read the Gilmartin settlement
18
papers?
19
disclosed to you and you're going to be asked to
20
authenticate them.
Or you will soon because they're going to be
21
The point is that it's impossible, ask
22
any employee, any government employee, if you cost
23
the government 1.8 million dollars paid of nearly a 3
24
million dollar verdict, you get promoted?
25
make any sense.
520-623-0593
It doesn't
You don't get promoted over that.
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1
You get fired over that.
put in jail over that.
You get investigated and
Q.
So where's the cronyism in that?
A.
They hired him because he's a good old boy
buddy.
Tucson city, I don't know.
Roy Warden up.
lofty position, but God knows the dirt that goes on
behind the scenes, the dirt in the underlying
10
Gilmartin case and before that that was done.
11
no idea.
12
standing on the outside.
What he did to generate the goodwill of

Maybe it was try to shut
I don't hold myself in such high or
I have
You can just infer a lot of things from
13
When you see a duck moving through the
14
water, he's very calm and placid, but his feet are
15
going like crazy, and he's moving 20 miles an hour
16
through the water, you know something's going on.
17
Q.
In terms of Mike Rankin and cronyism and Rio
18
Nuevo, did you have evidence somehow that he
19
benefitted from what happened there?
20
A.
Sure.
21
Q.
What's that?
22
A.
He keeps his job.
He gets whatever other
23
considerations he gets.
24
Tucson City officials are amongst the most highly
25
paid City officials in all of Arizona.
520-623-0593
He gets his retirement.
The
And even
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1
though the City is commensurate with size of
Albuquerque, their pay is much, much higher.
piggy bank.
unemployed because they can't find work because
there's too many lawyers in the market?
Q.
It's a gold mine.
It's a
How many lawyers are
What is it, Mr. Warden, you have evidence of
that Mike Rankin did in terms of Rio Nuevo that
allowed him to keep his job?
A.
He covered -- helped cover it.
Where do you
10
think the documents went?
11
Tucson City Attorney and the Tucson Convention
12
Center, they had equal -- they each had keys and
13
these documents -- why can't you find documents in
14
the files of these events going back to 2006?
15
They're not in files anymore?
16
Who has possession?
Why?
How does a document get lost and then the
17
computer that generated it, how does it get lost?
18
gets deleted.
19
can't find these things because they no longer exist.
20
I don't think you stole them.
21
them.
22
common, everyday documents that should be in the
23
files.
24
unless somebody deleted them, and yet there's no
25
record of these documents.
520-623-0593
Somebody has to delete it.
It
And you
You're not hiding
They're not giving them to you.
These are
And the computer files should be there,
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1
2
3
4
Q.
So how do you know Mike Rankin helped cover
up Rio Nuevo's loss of money?

A.
As opposed to the offices of Tucson City
Attorney?
Q.
As opposed to anybody, sir.
A.
I'm drawing the obvious inference.
the Tucson City's office.
his procedures.
writing the opinion letter in 2006 and then
He runs
They are very happy with
How they could be happy with him
10
contriving this as a conspiracy and a contrivance to
11
violate the law and still keep his employment, I
12
don't know.
13
But the City Council is as a corrupt as
14
the rest of them.
15
The people that they hire are instruments of that.
16
17
Mike Rankin is the instrument.
But how can you reconcile those two

documents?
18
How does he explain that?

If I'm looking at an employee, how can
19
you write the first letter that you wrote, the
20
opinion letter saying Gathright is correct, and then
21
contrive a scheme to violate Gathright?
22
put us in the middle of a multimillion dollar
23
lawsuit?
24
I'd be angry about that.
25
Q.
520-623-0593
And now you
What the fuck's going on here, Mr. Rankin?

Nobody is.
In the conspiracy Count, Count III, you

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1
indicated that Defendants Miranda, Rankin, Judge,
Gray, Ochoa and others formulated a plan to deny your
exercise of First Amendment rights on May 1st, 2012.
What's the basis for that?
A.
Again, I'd have to go back and read the
Complaint again.
They approved, they were cc'd on this permit process,
they wrote these documents, they granted these
approvals, even though they knew as far back as 2006
It's been sometime since I had.
10
when Miranda and Gray, and I believe Ochoa, got
11
copies of that first letter, the April 12th, 2006
12
letter that Miranda wrote, memo that Miranda -- I'm
13
sorry, Rankin wrote, they knew Gathright said that.
14
In spite of that, year after year they continued on
15
granting the permits all the way through 2012, and
16
then -- and you've got interrogatories coming asking
17
that -- then they stopped because these people
18
stopped marching to Armory Park.
19
Q.
Then they stopped what?
20
A.
They stopped issuing the exclusive use
21
permits because they realized they were in so much
22
trouble over it now, they had to at some point stop
23
it.
24
engaged in unlawful procedures.
25
They're acknowledging the fact that they were
Q.
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Do you have evidence of that?

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1
2
3
4
A.
I've asked you for it in the interrogatories
that are coming.

Q.
You'll be getting it.
I want to make sure I'm understanding what
you're saying.
Are you saying that there was some
realization at some point that the exclusive use
permit process was illegal, so that's why they
stopped issuing them?
A.
I'm saying what they were doing specific to
10
the May 1st Coalition for Worker and Immigrant Rights
11
and keeping Roy Warden specifically out of the park,
12
that the same process that they did in 2006, which he
13
says in -- Rankin says in his 2006, April 10th
14
letter, that you can't keep him out of the park, you
15
have your permit but you still can't keep him out of
16
the park, they did anyway.
17
until 2012.
18
And they did that up
Then by great mystery in 2013, the
19
left-wing people didn't march to Armory Park, they
20
marched someplace else in South Tucson.
21
march to the heart of Tucson where they were up in
22
front and center.
23
followers and they no longer marched to Armory Park.
24
And the only thing I could deduce from that is they
25
were no longer granted exclusive use permits to do
520-623-0593
They didn't
They no longer had 15,000
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so.
Q.
event?
A.
Unless they changed the location of the
I'm going to find out.
I've sent -- like I
said, you're going to be getting interrogatories
within the next two days.
Q.
Okay.
A.
Was there a final permit process where they
9
10
applied for one and didn't get one?
And I'm asking
that question.
11
Q.
Did you go to the 2013 rally?
12
A.
Like I said, I think that they didn't
13
have -- my recollections are very unclear on this.
14
don't seem to have any film of it, as far as I
15
understand.
16
didn't have it at Armory Park, I didn't go to it.
17
I don't know that they had one.
If they
And by 2013 I'm getting some help from
18
the VA.
19
living in horrendous circumstances with people that
20
were deplorable people of very low character,
21
alcoholics and drug addicts and so forth.
22
of survival I have to interact with these people.
23
And in 2013 I think I'm in that process of getting
24
out of one and getting into veteran's housing.
25
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I had been homeless up until that point,
As a means
And so I don't have any records showing

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that I -- the funny thing is if somebody brought me
pictures and said this is where you were in 2013, it
could be.
Armory Park.
events.
I don't think there was any event in

I don't think I went to any more
And that all happened at a time, like I
said, when I'm getting out of being homeless and
living with bad people into a decent way to live.
Q.
I asked you in terms of one of the
10
conspiracy subparts where you said Defendants
11
Miranda, Rankin, Judge, Gray, Ochoa and others whose
12
identities are unknown, they formulated a plan to
13
deny Plaintiff to exercise his First Amendment rights
14
on May 1st, 2012, and I understood your answer to be
15
that evidence you had is they approved the permit
16
process.
17
A.
Well, that was part of it.
Then when I got
18
this sensational document here, confidential memo, I
19
see the names associated with this, cc'd Liz Miller,
20
Richard Miranda, Fred Gray, back as far as 2006.
21
This is how we get around Mike Rankin's letter of
22
April 12.
23
Q.
And that's Exhibit 18?
24
A.
Yeah.
25
And when I wrote the Complaint, I did
not have access to the initial disclosures.
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Q.
In terms of your -- the next subpart of that
conspiracy, you said that Sayre and other
individuals, subpart B, when they met with members of
Defendant Tucson May 1st Coalition for Worker and
Immigration Rights, they formulated a plan to deny
entry into Armory Park May 1st, 2012.
7
8
What's your evidence on that?

A.
Again, coming from your disclosures, and
they go all the way back to 2006, I've got documents
10
going -- or, actually, I found a document from 2010,
11
as part of the permit process for Armory Park, the
12
custom was they would apply for the permit, that
13
permit would be cc'd by Ochoa and sent up through
14
Gray, or however they did it, up to Rankin.
15
would write the letter authorizing and cc it to all
16
of the important public officials that needed to sign
17
off on it and notified them, sent it back down.
Rankin
18
And once that happened, they set up a
19
series of meetings, a community meeting, I forget
20
what they called it, where all of the event
21
organizers and members of the police department and
22
people who signed in on the sign-in sheet, which is
23
very definitive for 2012, they all signed in on that
24
sign-in sheet, and the purpose of that was to sit
25
down and talk about how are we going to handle this
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public event.
we going to keep Roy Warden out of the park because
he was the express subject matter of the permit
application and the permit granting.
And the center part of that is how are
So they sat down and talked about it.
After that, in the police department, there were two
meetings.
There was a general briefing and a command
briefing.
The command briefing, apparently the
commanders went to that.
The general meeting was the
10
one the general officers went to.
11
explicit instructions on how to handle all the issues
12
in Armory Park, including how to deal with Roy Warden
13
and how to deal -- I would presume how to deal with
14
the fact he's going to show you a letter saying one
15
thing but we're going to do something else.
16
And they received
All of those are acts by which these
17
people participated in a conspiracy to keep me out of
18
the park.
19
20
Q.
Okay.
You weren't present at that
discussion, I take it?
21
A.
Huh-uh.
22
Q.
Do you have any witness statements from
23
that?
24
A.
Not yet.
25
Q.
How do you know, as you sit here, that you
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2
were discussed?
A.
Funny thing is when they get an exclusive
use for Armory Park, the specific reason is to keep
one individual out, coincidently, Roy Warden,
coincidently the one guy that's telling the rank and
file you're being betrayed by your leadership, you're
exploiting these Mexican people, you're not helping
them, you're not humanitarians, you're creating a
great deal of misery upon them, is what you're doing.
10
I'm the express target of the exclusive use permit to
11
keep me out.
12
That's why the police are deployed in the
13
numbers they are, is to keep Warden out and to stop
14
anything from happening if he does anything, like if
15
he burns the Mexican flag and people get upset about
16
it, we're going to have deal with that.
17
All of the violence they had to deal with
18
in Armory Park in 2006, consequent to my
19
communicating in a lawful manner constitutes a
20
protective matter, they turned into a riot as set
21
forth in the after-action report.
22
Q.
And you're referring to April 6th, 2006 --
23
A.
April 10th.
24
Q.
I'm so sorry.
25
A.
Yeah.
520-623-0593
The April 10th, 2006.
And I didn't go to the May 1st event.
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You may not be aware of the circumstances and they're
not really relevant to this because Kathleen
Robinson's not a part of this case.
after the April 10th event.
and this was part of what happened to me, she comes
out to where I'm living, she's talking to my
landlady, she comes out with other people on several
occasions in a police car, two police cars.
She comes to me
She says, Mr. Warden --
My landlady gets all upset about the fact
10
that the police keep coming out to the house.
11
she tells me these people mean to kill you,
12
Mr. Warden, they're very, very dangerous, and we want
13
to protect your right to speak, we want to protect
14
your right to burn the flag, but you have to
15
understand, these people are very dangerous.
And
16
And she promised me, she said, if you
17
please don't go to the May 1st demonstration that
18
they're going to have -- this was after April 10th,
19
they're going to have another big one May 1st -- if
20
you don't go to that, if you promise not to go to
21
that this week, we will provide you with police
22
protection at your events after that and we will
23
protect public safety and your right to speak.
24
gives me this guarantee.
25
520-623-0593
So I didn't go.
She
And just prior to the
800-759-9022
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1
May -- May 1st event she's on TV talking with the
Pro-Raza groups and they're all laughing and smiling.
She says, yeah, I talked with those other people that
were involved with the flag burning.
going to come.
They're not
We did you -- you know, we did you solid,
basically.
them.
Have fun.
They're not going to come.
We talked to
They're not going to come and bother you.
10
Like that.
It wasn't that at all.
She's telling me
11
we'll protect -- very concerned about apparently my
12
public safety and my safety in the public, we're
13
going to protect you.
14
we basically coerced him into not coming, so you
15
won't have to worry about him this time.
16
then they have the May 12th event -- May 1st event
17
which I didn't go to.
18
19
Q.
But she goes to them and says
2006 event, was there any violence?

A.
On May Day?
21
Q.
Yes, of 2006.
22
A.
May 1st, 2006 I wasn't there.
24
25
And
To the best of your knowledge, that May 1st,
20
23
See?
So I don't
know.
Q.
Do you have any information that there was
violence?
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800-759-9022
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1
A.
No, I don't.
I presume that there probably
wasn't because if you're not willing to stand up and
oppose their viewpoint lawfully -- here's what I
don't know about.
after-action report, you'll see that independent of
me -- this is in the police report 2006, April
10th -- that on the march up there were people
standing with signs opposing open borders and they
were being hit by sticks and signs and frozen water
10
bottles, violence that was occurring independent of
11
Roy Warden.
12
building -- huh?
If you go back and read the
That they went down to the federal
13
Q.
May 1st or --
14
A.
No, this was the April 6th -- April 9th --
15
April 10th, 2006 after-action report.
16
violence happened before Roy Warden ever showed up in
17
the park.
18
19
20
Q.
All kinds of
Did you attend every May 1st rally at Armory
Park from the years 2007 through 2012?

A.
I didn't in 2007 for a very specific reason.
21
Some jerk judge named Eugene Hayes signed an unlawful
22
order of prior restraint forbidding me from going to
23
Armory Park to speak on the 7th -- on May Day -- May
24
1st of that year.
25
520-623-0593
There was a court order.
And I don't know if you've studied orders

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1
of prior restraints.
Totally unlawful.
Totally unconstitutional.
And so I didn't go.
But after that I said next time they give
me one of these I'm going to shove it right up where
the sun doesn't shine because I have a right to
ignore an unconstitutional order of prior restraint,
not prior restraint of conduct, but prior restraint
of speech.
A big difference between public speech
10
writing and speaking and conduct like marching and
11
picketing.
12
prior restraint based on public safety issues and
13
other things.
14
walking down the streets of Birmingham, Alabama, like
15
Martin Luther King did, the police had a right to
16
instigate that, simply because you need time to
17
organize and facilitate the march and not interfere
18
with the public access too much.
19
Those can be constrained by orders of
And march -- permit marches for
Very reasonable.
But that does not include speech.
Pure
20
speech writing and speaking you cannot have an act of
21
prior restraint.
22
ignore it with impunity.
23
24
25
Q.
And if you issue one, you may
So as I understand it then, you didn't go
May 1st, 2006 or May 1st, 2007, but you did -A.
520-623-0593
Yeah.
2008 we started again.
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Q.
2009 --
A.
Yeah.
Q.
2010 --
A.
Got film of all of it every time.
Q.
-- 2011, 2012 --
6
7
8
THE COURT REPORTER:
Please don't all talk at the same time.

Q.
(By Mr. Greene)
9
10
11
Hold on a second.
Let me finish my question.
So you went 2008, May 1st, 2008, 2009,

2010, 2011, 2012; correct?
A.
I believe so.
I may have missed something
12
in there.
13
think that I did.
14
film.
15
amount.
16
and other people made it.
17
reports.
I certainly intended to and tried to.
I haven't gone through all of the
Frankly, as you saw, it's an overwhelming
18
I didn't make a lot of it.
Russ Dove did,
And there were news
There may have been one of those dates
19
missing.
20
every year because I want to communicate with people.
21
And every year -- my impressions now are every year
22
my right to enter was violated.
23
24
25
Q.
If there is, you know, my intent was to go
Was there any violence at any of those
Mayday rallies, May 1st, 2008 through 2012?

A.
520-623-0593
I don't know that I witnessed any.

I was
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1
only there for a portion of the time because I'm --
I'm excluded.
particular, that was the SB 1070 rally, and there
were a lot of people down there for that and there
was a propensity for violence and a lot of anger.
And so I don't know what happened after I left.
And after I'm excluded, and in 2010 in
I do know, independent of Roy Warden,
these people are incredibly violent to anybody that
opposes their viewpoint, even little old ladies
10
sitting in lawn chairs, as described in the
11
after-action report of 2006.
12
Q.
Let's shift gears then to damages.
Let's
13
talk about you a little bit.
14
to consider damages, they may want to know a little
15
bit about you.
16
17
You're asking the jury
Back on May 1st, 2012, were you employed?

A.
No.
I was nearing -- although I didn't know
18
it at the time, nearing the end of seven years of
19
homelessness that came consequent to the police
20
showing up at my house where I lived after the first,
21
what I call the riot in Armory Park, and intimidating
22
my landlady.
23
handled her real estate, and together they cooked up
24
a scheme to me -- even though I just signed a new
25
lease, they cooked up a scheme to have me evicted
520-623-0593
And she went to Rathbun Realty, who
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1
from the property.
And I fell into homelessness as a result
of that, and what business I had went down the tubes
and what employment I had went down the tubes, and I
ended up homeless and living in incredibly miserable
circumstances from 2006 on, August of 2006 on.
7
8
9
Q.
In 2012 what was your source of -- what were
your sources of income?

A.
You want to look at some scars here?
10
Selling plasma.
11
I didn't have any Social Security.
12
then at that point.
13
And I could use that to gain somewhat of toehold into
14
one particular household where I had my computer.
15
needed my -- I perceived I had the need for a
16
full-time computer hooked up to the internet, so I
17
could communicate with people who had basically
18
followed my adventures, and so forth.
19
them had helped me in the past, sent me money in the
20
past.
21
That's all I had.
Selling plasma.
I had food stamps
Selling plasma and food stamps.
And some of
So I was willing -- I had to compromise
22
myself to maintain that.
23
then was plasma sales and food stamps.
24
Q.
25
that time?
520-623-0593
My only source of income
Were you eligible for Social Security at
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1
A.
I was told by social workers -- I had been
down to a number of social service agencies through
the City of Tucson and Pima County, and unfortunately
I believe deliberately, but it's not really an issue
that I can do anything with, I was given
misinformation, because I was eligible for veterans
benefits, being a veteran of the Viet Nam era, not a
combat veteran but a military -- I volunteered back
in 1966, that time frame there, and I was eligible
10
for benefits.
11
They told me expressly we searched and
12
you're not eligible for benefits.
13
ignorance of the fact that there were benefits to be
14
had.
15
because my economic means are very modest but I
16
didn't know that.
And that would have resolved all of my issues
17
Q.
18
like that?
19
A.
20
So I was in
Do you receive any trust funds or anything
No.
Trust funds?
You mean income from
family trust funds?
21
Q.
Yes.
22
A.
No.
23
Q.
Any other income from other individuals?
24
A.
No.
25
I did get some political donations.
Within three days of the news going out after the
520-623-0593
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1
first rally, the riot in Armory Park, within three
days -- and nobody had my address, people really had
to scrounge to get it -- I end up with over $3,000 in
donations, cash donations and small checks and stuff
like that.
And I said maybe I'm on to something
here.
I can sustain myself in part by political donations
and by doing political work.
Maybe now that I end up homeless later, maybe
From that point on I
10
described myself in all my legal papers as an unpaid
11
political activist working on behalf of the people of
12
Pima County.
13
So I employed myself as a political
14
activist and I investigated all the issues I could
15
relating to open borders, the cronyism, to Rio Nuevo,
16
all of these issues we've talked about, and I began
17
very thorough investigations.
18
One of the first ones actually was with
19
the garbage department when they combined the water
20
and the garbage department and they would use cutting
21
-- if you didn't pay the new garbage fee, which
22
hadn't been assessed before, they'd cut your water
23
off.
Very contentious issues.
24
And I researched the law on that and
25
worked on behalf of a litigant who had a lawsuit
520-623-0593
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1
against the City of Tucson.
all of that, the City of Tucson had to back down and
withdraw the connection between the two departments
and separate them.
to coordinate and then multimillion dollar to
separate.
And as a consequence of
Multimillion dollar collaboration
And I exposed the fact that it was based
on a faulty reading of the underlying case law.
were totally wrong and they had to -- they had to
They
10
disconnect the departments and stop using the threat
11
of cutting off your water if you fail to pay the new
12
garbage pickup.
13
they were receiving reduced revenues from all of the
14
economic activity consequent to open borders.
15
Q.
That's when they started realizing
Did you tell me, Mr. Warden, that you had
16
either lost a job or lost a source of income as a
17
result of some of the events of 2006?
18
A.
Yeah.
19
Q.
What job or income was that?
20
A.
Okay.
It was a very unique situation.
21
had a background -- I don't know if I had the license
22
then, I believe I did.
23
background.
24
to be a legal document preparer by the State of
25
Arizona.
520-623-0593
I have a background, a legal
I had applied for and received a license
I was involved in selling -- involved in

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1
soliciting the sales of revocable living trusts and
became an insurance agent, worked for a company up in
Phoenix named Asset Preservation Specialists.
was all prior to 2006.
This
As a consequence of what happened at that
point, I started my own business called Avoid Probate
Now, and invested most of my ready cash in about two
years of advertising to mail out little cards
soliciting people in very targeted neighborhoods like
10
Saddlebrooke, down in Green Valley and all the active
11
adult retirement communities, because they were the
12
primary people interested in revocable living trusts
13
and asset protection.
14
advertising, and I had a very genial relationship
15
with my landlady, who happened to live right behind
16
me, and her mother had Alzheimer's Disease, and I got
17
along very well with her.
18
I had taken out a bunch of
And my landlady was employed as a nurse,
19
very, very good employment, and she couldn't find
20
anybody for a reasonable wage that could take care of
21
her mother while she was working.
22
So she employed me for $10 an hour to look in on her
23
mother while I did my computer work, while I did my
24
advertising for asset -- for Avoid Probate Now and
25
all of my other things.
520-623-0593
So I said I would.
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1
All of that came to a shrieking end as
soon as the police kept coming out to the house and
it was all over the news that Roy Warden was a racist
and he burned the Mexican flag, and my criminal
prosecutions in Tucson criminal court.
nothing to do with me as a result of that.
She wanted
I went through an eviction, was thrown
out into the street.
seized.
All my possessions were
10
It wasn't until 2012 that I managed to
11
get Rathbun Realty in court on breach of contract,
12
breach of promissory estoppel, other issues, got a
13
jury to give me $112,000, gave me a verdict of that.
14
They turned around and said, screw you, we'll give
15
you $30,000 cash.
How about that?
16
I said, screw you back to them and started
17
divulging information about their use of illegal labor
18
for landscaping and refurbishing their 800 properties
19
that they managed.
20
that, using illegal labor for refurbishings and for
21
landscaping and so forth.
22
My landlady was also involved in
And all of those things happened and so
23
that's what happened.
24
money, as you read in the newspapers and saw on TV.
I didn't -- I ended up with no
25
520-623-0593
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1
As a consequence of those writings I had,
they were contacted by the Department of Real Estate.
know this because later I had a meeting with several
people involved with the Department of Real Estate.
met down at the state building downtown, across the
street from wherever we are, across from the federal
building.
they investigated Rathbun Realty, they found out that
they embezzled 1.8 million dollars from the client trust
We
And they said on the basis of my writings
10
funds that they were holding, and shut them down.
11
then they filed bankruptcy and now they're still
12
involved in the bankruptcy process.
13
And
My judgment has been expunged as a result of
14
the bankruptcy.
15
on a RICO violation once the bankruptcy is over.
16
filed before the bankruptcy started but was stayed as a
17
result of the bankruptcy by the legal procedure.
18
will hope to get some of their personal assets, should
19
they have any, once their bankruptcy is over.
20
I have a civil action that I will file

It was
And I
All of that happened consequence of the
21
police coming out, Mr. Warden, you're doing the wrong
22
thing, Kathleen Robinson talking to my landlady, we got
23
to get rid of this guy.
24
Warden.
25
Q.
520-623-0593
A lot of hostility towards Roy
And all those contacts with Kathleen

800-759-9022
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1
Robinson and your prosecutions happened prior to May
1st, 2012?
A.
Oh, yeah.
Q.
Have you ever worked for an employer?
A.
Sure.
Q.
Tell me about before doing legal document
7
8
9
10
work preparation what other work you did.

A.
Why don't I do this -- first of all, it's
not all that much but I'll start at the very

beginning.
11
It's relevant to the issues of this case.

Back in 19 -- generally referred to as
12
the '60's, '67, '68, '69, beginning in that time
13
frame, I worked as an investigator for a team of
14
constitutional and drug and music attorneys in San
15
Francisco.
16
so-called hippy rock and roll -- sex, drugs and rock
17
and roll movement in Haight-Ashbury, San Francisco,
18
Berkeley in the 1960s, involved with some very heavy
19
political cases, civil rights cases, cases dealing
20
with the Black Panthers.
21
Was absolutely at the center of the
My father was an attorney who represented
22
poor black people in Oakland, California, which is
23
one of the reasons I hate this tag of racism that's
24
been put on me.
25
because of that I had political currency with the
520-623-0593
He represented those people and
800-759-9022
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1
Black Panther party and they let me go to some of
their meetings and let me hang out.
buddies and so forth.
We were buddy-
This later came to use for the criminal
attorneys I worked for from the standpoint that the
DEA, before it was the DEA, it was the Bureau of
Narcotics and Dangerous Drugs, some of their agents
were setting up the so-called hippies for murder.
They were trying them as career criminals under --
10
I'm trying to think of the name of the statute.
11
was the first organized crime -- organized strike
12
force against organized crime and racketeering.
13
It
And they were developing a series of laws
14
to go after the mafia back East and they tried these
15
laws out first for constitutionality against the
16
so-called hippy major league drug dealers of San
17
Francisco area in that time.
18
And I'm working for the attorneys as an
19
unlicensed investigator, which was a real reason for
20
being unlicensed.
21
that they had interviewing clients, getting cases to
22
them, talking to the people, working with people,
23
showing them how the legal system worked.
24
background started there.
25
520-623-0593
Worked for them working on cases
My
Was actually going to go back to UC

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1
Berkeley to study criminology later, was studying
criminology, was going to get a degree in that.
I had a friend who was unlicensed at that
time but he later got a license to be a private
investigator in California and I worked with him on a
number of significant drug investigations, including
malfeasance of drug agents who murdered hippies,
murdered what they called drug dealers.
These are just kids growing a little bit
10
of pot, selling a little bit of weed, turned them
11
into major league dealers so they could bust them.
12
Half the time they'd steal their money, steal their
13
products, sell the products.
14
investigating all of that.
15
I was involved in
Later it led to work on the Patty Hearst
16
case.
17
the top litigators in San Francisco history.
18
also coincidently the Progressive party candidate for
19
President in 1952.
20
had two kids, Kayo Hallinan and Patrick Hallinan.
21
Worked with a guy named Morley Shapiro who worked
22
with all of those -- the younger Hallinans on these
23
drug cases and civil rights cases and music cases.
24
25
I worked with Vincent Hallinan, who was one of

He was
Very, very interesting guy.
He
Worked with an attorney named Brian

Rohan.
520-623-0593
I don't know if you ever read the Electric

800-759-9022
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1
Kool-Aid Acid Test.
a Thomas Wolfe book that documents that era --
3
4
5
Q.
Brian Rohan is mentioned in it,
How long did you do the private
investigation work?
A.
1968 through 1971.
And then for reasons,
whatever reasons, I end up overseas in North Africa
and spent two years there.
after my friend and partner Michael Murphy was
murdered.
Came back, came back just
Phil Ryan was his attorney.
Prominent San
10
Francisco drug attorney.
11
drug enforcement agents because we had developed a
12
significant amount of evidence before I left of drug
13
agent involvement in murders and rip-off of drugs.
14
Thought he was murdered by
Drugs were being sold to the Hells Angels
15
who had an office in a residence, the leader of the
16
Hells Angels, Sonny Barger, had a house in Oakland,
17
California, which was later bought by a friend of
18
mine.
19
connection there.
20
21
Q.
So I had an inside connection to that whole
What kind of other work besides the
investigating did you do?
22
A.
That was it.
23
Q.
Okay.
24
A.
I mean, everybody in those days, it was sex,
25
drugs and rock and roll.
520-623-0593
That was it.
So employment
800-759-9022
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1
coming out of that.
promotions, promoted rock and roll shows, made money,
lost money, as everybody that did that did, except
Bill Graham, who was successful at it.
types of little hippy enterprises, mostly
investigation work.
I was involved in rock and roll
Lots of those
Q.
You said you came to Tucson in 1997 or '87?
A.
'97.
Q.
'97.
10
A.
When I came here?
11
Q.
Yes.
12
A.
Okay.
What kind of work did you do in 1997?
When I came here -- sounds a little
13
more grandiose than it was -- I had a fledgling
14
import business from Mexico.
15
I'd known for generations, it seems, Swiss guy,
16
operated out of Mexico, Mexican wife, very happy,
17
wonderful family guy, had a factory making a product
18
called Music Spheres.
A friend of mine whom
19
And these were round objects that had a
20
chime mechanism inside when you shook them and they
21
would have sterling silver design work on the outside
22
of various designs.
23
having the whole world in your hand type of thing.
24
Necklaces.
25
designs, all kinds of metaphysical designs, again cut
520-623-0593
Obviously it lent itself to
They would have Shaman designs, Indian
800-759-9022
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1
out of the sterling silver and placed on the outside
of these.
I had that business and I came to Arizona
with that business.
relocated here was to help raise my daughter, who had
been living back East with her mother, and also to
run that business and go to the Tucson Gem & Mineral
Show, which is one of the shows where I showed my
product -- product line.
10
And one of two reasons I
Went to gift shows up in Phoenix, went to
11
gift shows around the country, in New York for the
12
corporate market, and in Chicago.
13
And so I moved to Tucson, I think it was
14
either '96 or '97, but in that time frame.
15
the first year I was here the Cats won the NCAA
16
basketball tournament.
17
something that was going to happen every year, but,
18
of course, it didn't.
19
when I moved here.
20
21
22
Q.
I think
So I thought that was just
I remember that as basically
What kind of -- how long did that business
go for?
A.
A couple of years.
And then not because of
23
my ineptitude, because of my lack of realization that
24
it was a niche market, it was a temporary market, it
25
was a fad product, it had gone in and out of fashion
520-623-0593
800-759-9022
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1
before, and a lot of people were very successful with
it.
product hadn't been on the market for a while, which
is why I got back into it, based on the initial sales
and so forth, it just basically there wasn't a
market.
less money was coming from sales.
And then because of administrative reasons the
More and more money went into cost of sales,
I had that -- carried that all the way
through until I was still -- until I moved over to
10
Glenn Street, my address on Glenn Street, which was
11
where I resided -- was residing at the time that
12
these events first started, 2006, from which I was
13
rejected on a lease renewal.
14
15
16
17
Q.
When that business stopped, did you get any
further employment at that time?

A.
I had savings and I lived on that, and I had
help from my family.
18
And I'd like some more water, if I could.
19
MR. GREENE:
20
Absolutely.
Actually, at this point it is 10 after
21
12:00.
22
break so you guys don't die of hunger?
23
you think we would --
24
THE WITNESS:
25
Is it customary for us to take a little lunch
forever.
520-623-0593
I don't care.
How long do
I can go
I know these guys need a break.

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1
MR. GREENE:
THE VIDEOGRAPHER:
MR. GREENE:
the record.
6
7
12
It's 10 after 12:00.

Off the record -- going
off the record at 12:10.

(Recess taken from 12:10 p.m. to 1:00 p.m.)
11
Yeah, okay, why don't we go off
THE VIDEOGRAPHER:
10
Should we go off record
first?
4
5
What's the best for our --
THE VIDEOGRAPHER:
We're back on the record,
media number three, and the time is 1:00 p.m.

Q.
(By Mr. Greene)
Mr. Warden, continuing on
with questions about damages.
13
You had listed in your Complaint that you
14
suffered emotional distress by the loss of your
15
rights and reputation.
16
those -- the emotional distress was?
17
A.
Can you describe what
Let's -- and this maybe makes it easier for
18
you procedurally or not, I don't know.
19
anything specific that came out of 2012, I had
20
already been reduced by Tucson City policy towards me
21
to homelessness, to despair, to living in horrible
22
circumstances.
23
was.
24
25
As to
I could go no further down than I
And whenever I -- for example, I'm in the

homeless shelter once upon a time, talking to the
520-623-0593
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1
counselor there, she says, what kind of work do you
do?
license in legal document preparer.
and trusts, I have all the software, quite skilled at
it.
paralegal work, I can do a lot of things, research,
things of that nature.
I says, well, I used to have a degree -- a

I've done wills
And I said, so I can do legal work, I can do
So she searches and she comes back -- and
I says, but I don't think anybody is going to hire me
10
because I've got a bad rap in town.
11
around about me because of all my political
12
activities.
13
wasting any time trying to get a job, she says, I
14
researched it -- I don't know what she did, maybe
15
nothing, maybe something -- she says you'll never get
16
a job in this town.
17
Bad news going
She came back and she said don't bother
I was told that also by -- heard that
18
indirectly from Tom Zlaket, Supreme Court Chief
19
Justice, Retired, in a case I worked on which he was
20
representing a client that I had brought to him.
21
he told her, you'll never get any justice in this
22
town as long as you have any association with Roy
23
Warden.
24
He's against the system.
He's against the good old
25
boys, the establishment.
He's not going to get
520-623-0593
No work.
Bad reputation.
And
He's a racist.
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1
nothing.
Did any more of that happen after 2012?
Same thing.
was before I walked into the park and when I was
denied entry.
time period.
I mean, there's no way to measure what I
Nothing measurably happened in that
Q.
Nothing majorly, you mean?
A.
No measurable diminution on the basis of one
rejection from the park.
10
Q.
Okay.
11
A.
Part of the overall practice of doing it
12
13
14
15
again and again.

Q.
You had mentioned earlier frustration.
Is
that part of what you were feeling?

A.
Certainly.
Anger, frustration.
They're
16
doing it again -- it just drives me crazy.
17
think maybe I am crazy because most of the people I
18
talk to don't seem to care.
19
crazy when public officials who know the law
20
intentionally break the law.
21
But I
I says, it drives me
And people say, well, it's just City
22
Hall, that's just the way it is.
23
like the Jack Nicholson movie.
24
about it because they just accept it as being normal.
25
So nobody's angry.
520-623-0593
It's Chinatown,
And they're not angry
But it frustrates me.
Makes my
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1
2
3
4
stomach turn.
Q.
Did you -- have you received any medical
care as a result of what happened May 1st, 2012?

A.
I was being treated for depression well
before these events happened.
improve me, made things a lot more difficult when I
became homeless.
8
9
It certainly did not
Did anything specifically happen after

Armory Park, May 1st, 2012?
No.
Just a continuation
10
of the same thing.
11
renewal of my frustration based on what happened that
12
year.
13
Q.
Certainly frustration is a -- a
You mentioned loss of your reputation.
14
Anything you want to add besides what you've already
15
said?
16
17
A.
I can't say anything more than that.
wouldn't know anything relative to say to that.
18
I certainly suffered, as I found out,
19
because of the unlawful eviction I had because I had
20
been evicted in terms of applying from a place.
21
I'll tell you, the eviction was -- it was an unlawful
22
detainer on the basis of not paying rent, but the
23
underlying real issue was breach of contract.
24
had signed a lease.
25
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And
And I
And the judge knew it and I pled the case

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that way.
process, I've paid my rent.
simply declined to accept it because they didn't want
to -- they wanted me out.
Rathbun wanted me out.
and out.
I said, you can't use this abbreviated

At that point they
Dugan wanted me out.
They wanted me in the street
And so after that I ran into when I
applied, got a little bit of money together, worked
with people, maybe I can get a place.
10
Warden.
Oh, not you,
You've been evicted.
11
Q.
And that eviction was in 2006?
12
A.
Yeah, I think in August.
13
Q.
You mentioned that you had some lost income
14
as a result of having to defend yourself in three
15
criminal prosecutions?
16
A.
Sure.
17
Q.
Can you describe that for us?
18
A.
Those happened all immediately subsequent to
19
the April 10th, 2006.
20
July or maybe -- for some reason I want to say 4th of
21
July but I think it was June, another demonstration,
22
one prior to that in Kennedy Park.
23
of all that stuff, I had been advertising, and on for
24
the next couple years, like I said, I paid for two
25
years of advertising for my business, and yet when
520-623-0593
There was a June -- or 4th of
As a consequence
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1
I'd knock on the door after that, they'd say, oh,
you're the guy we read about in the paper.
I ran your name through the internet and found out
you've got a criminal record for misdemeanor crimes
connected to your political stuff.
to hire you.
7
8
Q.
We're not going
You're not going to do any work for us.
What do you think -- let me strike that.
Let me try this.
9
10
He says,
Are you currently employed?

A.
No.
Oh, well, let me back up.
I'm not
11
employed for pay.
12
as what I told you, unpaid political activist and
13
investigator, but also I have a fledgling -- it's not
14
registered yet as a nonprofit -- an organization
15
called Vets Feeding Vets, which is designed to help
16
employ homeless veterans and get them jobs and get
17
them money producing using aquaponics and hydroponics
18
to produce high-end food and sell that to the VA for
19
food and for other ways of distribution.
20
actively involved in that and have been very, very
21
busy with that for the last two years, associated
22
along with the rest of this stuff.
23
24
25
Q.
I'm self-employed in my capacity,
I'm
You're not claiming any property damages;
correct?
A.
520-623-0593
As a result of 2012?
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1
Q.
Yes, sir.
A.
No.
But as a result of 2006, it's well
documented in the Rathbun case tons of stuff I lost.
I know it's too far removed from the events, but lost
hundreds of thousands of dollars of art and personal
property.
7
8
9
Q.
Did you tell me that you have a claim in
bankruptcy court for them?

A.
Rathbun Realty has a claim.
And once they
10
went into bankruptcy court, we were offered, along
11
with everybody else, to buy in and accept whatever
12
settlement.
13
I did not.
And, of course, the debt against the
14
corporation was discharged.
15
subsequent to winning the case in Superior Court,
16
researched it, and when they engaged in forming a new
17
corporation to hide the assets and protect it from
18
the liability of my judgment in the old case, they
19
changed the name of Rathbun Realty, Incorporated to
20
Rathbun Property Investments, or something of that
21
sort, but they committed a RICO offense by forming a
22
new corporation for an unlawful purpose, as
23
testified -- not testified but declared under oath by
24
the property manager herself, Catherine King, I think
25
was her name -- Cassidy King, because she was accused
520-623-0593
But we had researched it
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1
of the theft of the 1.8 million dollars.
to avoid that they committed a RICO thing.
So in order
When the bankruptcy is over theoretically
I have -- and I will file it, if they have any assets
left that I can find, I'm entitled to damages as a
consequence of what they did.
7
8
9
Q.
Have you incurred any Plaintiff -- excuse
me -- attorney's fees up to this point?

A.
I certainly used up a lot of goodwill for
10
the helps that I've got.
11
money, probably no more than $1,000 over the years,
12
for various things.
13
One payment of $500, I know in particular.
14
not -- it depends on if this goes to trial, I intend
15
to have a trial attorney.
16
an hourly basis where he's paid, which I'll borrow
17
money or use money that I have or money that I can
18
get, or it will be based on a contingency fee.
19
don't know how all that will strike out in the end.
20
I've paid nominal sums of
I don't keep records of that.

But I'm
Of course, that may be on
There's certainly attorney fees
21
associated with criminal -- with civil rights
22
violations under 1984.
23
inducement.
24
-- and this goes back to 2006, they are afraid to
25
represent me because of official retaliation.
520-623-0593
So that's an added
But, frankly, the attorneys I talked to
I had
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1
a whole lot of attorneys that, you know, if you were
a child molester or some kind of pervert and you were
arrested for those crimes, public defender couldn't
defend you for whatever reasons they couldn't and
they have to appoint counsel, every lawyer in town
would step up to the plate to represent you.
Many of them told me privately when they
were assigned to my cases, we can't represent you,
Roy, because the system wants you and we can't afford
10
not to get future court appointments, so we decline
11
representing you.
12
municipal court in front of Judge Berning and in
13
front of Judge Hayes, it's very well documented,
14
statements made by attorneys, we have a conflict of
15
interest, is what they like to call it.
And this is a matter of motions in
16
And the conflict was they thought if they
17
won the case -- if we lose the case, we're home free,
18
but if we win your case, we're screwed because we
19
won't get further appointments.
20
So I don't know that I'll be able to
21
succeed in getting somebody to represent me at trial.
22
I may have to do it myself.
23
24
25
Q.
Good luck with that.
Have you incurred any attorney's fees
related to this case, the May 1st, 2012 matter?

A.
520-623-0593
Yeah, yeah.
When I tell you I paid
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1
$1,200 -- I'm sorry, $500, I laid $500 on somebody's
table.
Q.
In direct relationship to this case?
A.
Yeah.
Q.
And so did that payment happen after May
1st, 2012?
A.
Oh, certainly.
It happened within the last
six months.
Again, I am desperately looking for a
10
trial attorney but nobody has committed yet.
11
succeed in beating the summary judgment, which I'm
12
not concerned about legally, and maybe winning my own
13
summary judgment motion on the facts, maybe things
14
will change, but until that happens -- I had an
15
attorney up in Phoenix, civil rights attorney, was
16
very interested in the case, until it came down to I
17
couldn't lay a bunch of money on his table and he
18
couldn't represent the case.
19
tell you.
20
21
22
Q.
If I
So I don't know what to
What kind of legal costs have you incurred
in relation to this case so far?

A.
And isn't it silly that I can't remember.
23
In pro se I think I would be in forma pauperis of my
24
status of that.
25
520-623-0593
I bounced back and forth.
What happened in this case is when I

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1
filed it, I had just had received money from the VA
and money from Social Security that I was entitled
to.
filing fees.
statute more carefully that based on my income and my
assets I was still entitled to in forma pauperis
status.
And so I went ahead and thought I had to pay the
8
9
Didn't understand by reading the
I may go and reapply to the court now for

the same purpose regarding fees for this and
10
appellate fees when I have to appeal, as we know we
11
will have to do before we even go to trial.
12
Q.
So you've got some filing fees in this case?
13
A.
Yeah, certainly.
14
Q.
Anything else?
15
A.
No.
There were no service fees.
16
be other incidentals.
17
minor amount of money.
18
There may
Whatever it was, it was a
I'm very poor at keeping records or being
19
anal about those things.
20
pay me this because I went and paid that.
21
keep receipts for mailings and things of that sort.
22
Q.
Saying, well, you've got to

I don't
Aside from everything that we have talked
23
about so far, is there any other damages that you
24
have suffered?
25
A.
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I will answer that you take Gilmartin's

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1
statements to the court, multiply it by 10.
on several occasions he couldn't sleep.
occasions I think about these things, and every time
I think about them, a great amount of anger rises up
inside and I simply have to put my mind on something
else, pray, put my mind on something else.
He said
On many
I think this fact of going through this
today, as a consequence of knowing this was coming
up, I've done some work and so forth in reviewing
10
some of the matters in terms of my disclosures, and
11
again it's like an oil, it raises up in your stomach,
12
and you want to throw it up and it's horrible and you
13
can't sleep.
14
with that.
15
I have trouble sleeping.
So I deal
Have I been treated specifically for that
16
since then?
17
medications for that and I'm being treated by
18
medications I get from the VA and have learned to
19
live with it.
20
Q.
No.
It's part of my depression.
I take
From what you said earlier, you would be in
21
a different position now with the May 1st, 2012
22
incident than you were before because you had kind of
23
reached bottom, for lack of a better term?
24
25
A.
it.
520-623-0593
No.
I don't know quite how you're putting
I was in an extremely bad situation then in

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2012, no more so after the rejection, other than the
frustration and that, than before.
position now because in 2013 I started to get
veterans -- help from the VA.
immeasurably as a consequence of that.
hadn't been in that pit to begin with, I wouldn't
have needed the help from the VA and Social Security.
8
9
10
Q.
But I'm in better
So my life improved
But if I
Any other damages that I haven't mentioned
to you?
A.
Not that I think of.
11
I understood that issue in the case,
12
which is why I was so interested in the Gilmartin
13
case and his absence of damages.
14
so in his closing argument.
15
argument.
16
Wonderful closing
You should read it.
Wonderful.
He says, I don't know what to ask you
17
for.
18
because he saw private clients.
19
they did to him.
20
stole.
21
He made -- lost some money, he made more money

But it's nasty what
They lied and they cheated and they
We don't want public officials doing that.

And it wasn't "they".
22
specifically.
23
He's a bad man.
24
25
And his lawyer said
It was Miranda
My defendant Miranda in this case.
Do you want to talk about the Patty

Hearst case?
520-623-0593
It may not even be familiar to you.

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You're a younger guy.
it.
3
4
5
Q.
guy.
A lot of people don't remember
Thank you for that.
Maybe I am an older
But I'll pass on that for right now.
A.
Interesting case.
Not like what you read.
And Hallinan would have walked her free.
would have done a day.
8
9
Q.
She never
So when -- we know you weren't at the 2007
and 2006 May 1st events at Armory Park.
But on the
10
other ones that you participated in, did you address
11
marchers or the crowd or police or anyone during
12
those demonstrations with your message?
13
A.
The exclusion from the park always precluded
14
the thing I wanted the most, which was actually
15
stated in a Tucson Weekly article written in 2006.
16
At that point they still were printing
17
things I said rationally to the experiences that we
18
all were involved in.
19
because of the great anger this issue of open borders
20
has created and this great anger towards illegal
21
people in country.
22
events will spin out of control.
23
dialogue with the leadership of these groups so we
24
can prevent it.
25
520-623-0593
And I said I'm very concerned
I'm greatly concerned that these

I seek to have
I said, I'm afraid something may happen

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1
to myself.
people I don't like as a reason for violence.
don't want that to happen.
talk.
And if it does, I'll be used as a -- by

And I
So let's sit down and
That was accurately reported but never
became -- I always wanted to sit down and talk with
them, perhaps to have a debate with the media
present, because it would be so easy to demolish the
whole idea of a humanitarian effort to let these
10
people come in.
11
they were being solicited to come in.
12
being exploited magnificently by the leadership of
13
these groups and by the legal system and by the
14
contractors.
15
what happened to them was horrendous.
16
Q.
Because they weren't just coming in,

And they were
These people were cannon fodder.
And
The message that you delivered through the
17
bullhorn in 2012, were the messages in 2011, 2010,
18
2009 and 2008 similar, different?
19
A.
2010 was somewhat different because of
20
SB 1070 and H.R.2281, which was the Raza studies
21
program, were issues that were on the table.
22
things were talked about there.
23
So
But, you see, I'm not going to plead the
24
facts of 2010 in this case, you're not going to bring
25
it to the jury.
520-623-0593
It's not an issue.
It's a separate
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1
case on its own, which I believe will come from the
Ninth Circuit and we'll come back in here again on
another case.
Q.
I'm reading somewhere the judge's orders to
indicate that you may be allowed to admit evidence
from those different events.
asking some questions about that.
A.
Okay.
Q.
So tell me 2010.
10
A.
I'll make it simple.
So that's why I'm
Morgan versus National
11
Railroad.
12
somewhat similar in reoccurrence, even though they
13
fall outside of the statute of limitations, you may
14
plead them to support your Monell claim, the custom
15
and the practice of the City.
16
Q.
If you have a series of events that are
And I'm sorry to interrupt you.
But I'm not
17
asking you about the law, I'm asking you about the
18
message that you delivered on 2010.
19
20
21
What was it that you said to the

marchers?
A.
I can't remember.
I mean, I have to go back
22
and review all the film which I haven't looked at.
23
There was nothing substantially different other
24
than --
25
Q.
520-623-0593
Okay.
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1
A.
-- at that date we were dealing with the
SB 1070 issue.
But it was always let's talk this over because your
people are misguided.
doing but they're not thinking about the humanitarian
interest of the legal people.
Q.
So we had additional communication.
Leadership knows what they're
I think I read in your Complaint, maybe in
paragraph 18, what your basic political stance was
about open borders and cronyism and things of that
10
nature.
11
12
13
I take it that's a theme that you have

followed for many years, at least since 2006?
A.
Since the end of 2006.
There were many --
14
there were several contentious demonstrations, and
15
one in particular that I was reviewed, brought back
16
to mind in front of the cathedral on the issues of --
17
and I've got a great history and interest in
18
corruption in the Catholic Church, based upon my own
19
experiences and based upon my family's knowledge of
20
what Father Serra did to the indigenous Indian
21
population in San Luis Obispo County, which I have a
22
profound background in.
23
And I said a lot of anger was expressed
24
then.
25
really looking at how the system was dealing with me
520-623-0593
And it wasn't until after that that I got to
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1
and dealing with this whole issue, I says, well,
they're benefitting from this.
unwritten policy because the government officials on
the County and the City bases, they're not disturbed
by it, they're helping to encourage it.
There must be an
And then I got to thinking about how the
contractors are making all this money by hiring
cheaper labor and how they were making all this money
and this would result in campaign contributions, I
10
understood how the politics would evolve out of that.
11
And so it was only probably to the end of
12
2006 that it's like I woke up in the middle of the
13
night and I said, Jesus Christ, they want it to
14
happen.
15
Open border policy.
16
it really meant.
These people are involved with the process.
17
And I got to thinking about what
And I remember sitting down there, it
18
took me two hours to construct a simple phrase or a
19
statement.
20
entice and invite and to otherwise encourage the
21
illegal entry of impoverished Mexican citizens for
22
economic and political exploitation.
23
And so I came up with to aid and abet,
And that became a focal point then.
24
I could really see what was going on, why it was
25
happening and who was benefitting.
520-623-0593
Then
That's the first

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thing in a criminal investigation:
the crime?
Who benefits from
There's a whole lot of straight people, a
whole lot of establishment people benefitting from
this.
Then I realized what the real reason was.
Q.
Lots of money to be made off of illegals.
So your open borders message is something, I
take it, you delivered at Armory Park every year
since 2007?
10
A.
Tried to.
Always wanted to.
But that's,
11
like I say, when you can't talk to people, when you
12
communicate through a bullhorn, it's simply reduced
13
to Cesar Chavez did not oppose this.
14
understand that.
15
down there in front of library square, we had many
16
high school kids that would come.
17
They can
I had -- you had demonstrations
And the interesting part was -- and this
18
would drive it crazy because there's a left-wing
19
operative that -- who's a writer for the Tucson
20
Weekly and her husband works as a legal defender or a
21
public defender, and she looks at me with great
22
hatred because these kids would come up, some of them
23
were Indian kids or Hispanics, and they would want to
24
talk, and they would speak through the microphone or
25
through the speaker, and they would say, hey, maybe
520-623-0593
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1
what he's saying is right, maybe we are being
exploited, maybe there's more to this than just poor
people coming here wanting to work, maybe they are
being exploited, we should listen.
And I would look at the hatred on her
face.
Didn't want anybody to speak or to understand the
dynamics of what was going on.
support from the high school kids.
She was really (indicating) hated that.
So I got a lot of
Not all of them.
10
Some of them are very violent, but some of them are
11
very thoughtful.
12
Q.
When Paul Sayre told you either once or
13
twice that you weren't going to be allowed to go
14
inside Armory Park, can you describe to me the manner
15
in which he did that?
16
A.
Very matter-of-factly.
It happened probably
17
in the context of that first picture we saw here of
18
everybody smiling and friendly, he says, well, you
19
know, Roy, we're not going to let you come in today.
20
And that's when I handed him the letter, and I says,
21
well, look at this.
22
And we had talked about it before, very
23
matter-of-factly.
24
He says, I've been told to keep you out.
25
but look what the letter -- this is what the law
520-623-0593
Very, very -- and he understood.
And I says,
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says.
law is.
I'm going to keep you out because I was told to.
You're an intelligent man.
You can read what
He says, well, we've got an ordinance and
Q.
Did you say we've got an ordinance?
A.
I think he said -- referred something about
the City had ordinances, you know, I'm authorized
because I've been told to and this ordinance says we
can do this and that.
that's all nonsense in his response to your motion to
10
11
Of course, the judge said
dismiss.
Q.
So that ordinance we're talking about,
12
there's actually a couple of ordinances in the
13
park's --
14
A.
Sure.
15
Q.
-- in the park's --
16
A.
I was so happy for Judge Bury to tell me
17
about the second one.
18
in my inexperience.
19
20
21
Q.
I had neglected to put that in
Actually, two and one.
Who are you seeking punitive damages
against?
A.
Miranda, Gray, Ochoa and Rankin.
They all
22
knew it was wrong, they all knew it was against the
23
law, they did it anyway and continued to do it.
24
25
I don't have any particular animosity

towards Sayre and Lopez and McCarthy.
520-623-0593
They're told
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to do something, if they want to keep their job, they
do it.
police officers whom we have on film that were
absolute assholes, very arrogant and pushy.
damages against them for the way they were going
about their business.
7
8
9
10
Q.
I would have -- in my 2010 case there will be
Punitive
You filed a lawsuit in regard to that,
though; correct?
A.
That's the 2010 case which is up at the
Ninth Circuit.
11
You know why they dismissed it?
They
12
said rather than didn't give enough information about
13
the claim, gave too much information.
14
Q.
So going back to this case, though, you're
15
not seeking punitive damages against Sayre, Lopez and
16
McCarthy?
17
A.
No.
18
Q.
You didn't mention Lisa Judge, where she fit
19
into this.
20
A.
Oh, she fits -- she was the signatory on
21
those letters as well.
22
Judge is based on finding her name as one of the cc
23
recipients of those letters.
24
known in the very beginning Gathright, and I assume
25
maybe at some point she bothered, being an attorney,
520-623-0593
That's my only knowledge of
And she had to have
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1
to read the case, she would understand completely we
can't do this, this is wrong.
signed off on it anyway.
Q.
She went ahead and
What is, in your opinion, their motive in
signing off on that, I guess on the -- wait a minute.
Let me strike that.
7
8
9
10
You believe they signed off on a memo

approving the exclusive use permit?
A.
I believe when they did it, they knew the
law did not permit them to issue that permit.
11
Q.
Okay.
12
A.
Directly.
13
Q.
And what do you ascribe the motive to each
14
15
I don't know how else to put it.
one of those five individuals as being?

A.
Probably the same people that signed the
16
order that put the Jews in the concentration camp.
17
Because that was all as a result of an order.
18
knew it was wrong.
19
wanted to survive, they wanted to keep their jobs.
20
Simple.
21
They
They did it anyway because they
They don't care about the law.

We hired -- see, we, the taxpayers, hire
22
those people.
23
City doesn't have any money, except what they take
24
from -- they represent the people.
25
supposed to protect the people.
520-623-0593
You may think the City hires them.
The law is
The people that we
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1
employ in City government or elect to City government
can't break the law to get what they want.
They knew they were breaking law, they did it anyway
to keep their salaries and to keep everything going.
And it's the same thing as Rio Nuevo.
They did.
And I know attorneys have to represent
their clients.
school.
think it's because I am any better person than
And that's why I dropped out of law
I can't do things like that.
10
anybody else.
11
with hypocrisy.
12
been a lot easier.
13
14
Q.
I wish I could.
I can't deal
My life would have
Tell me something, I need to know -- I will
go back to that.
15
16
It just rubs me wrong.
And I don't
Tell me about Mr. Jim Kay.
Where would I
find him?
17
A.
In a way, a hard guy to find, but will make
18
it for him.
19
is.
20
repossessed and his trailer repossessed and now he's
21
living in an apartment.
22
actually, if you'd like, I can get him to contact
23
you, and then you can go from there with him.
Even I don't even know where his address
He's been relocated.
24
Q.
That's fine.
25
A.
I'll do that.
520-623-0593
He had his house
I can get you his phone --
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2
3
Q.
Or, I mean, if you want, you can send me his
phone number and I'll call him.

A.
He's very reluctant.
Frankly, he doesn't
answer his phone.
to pick up.
He hears who it is.
If it's somebody he
wants to talk to, he'll pick up.
If it's somebody he
wants to ignore, and he's involved in his own legal
controversies, he will simply ignore it, and that
will be the extent of your contact with Jim Kay.
10
He waits for the answering machine
But I will talk to him and say, look, you
11
need to authenticate those pictures and what you
12
witnessed, so he's going to want to ask you questions
13
on that.
14
that's what he's going to have to do, but he will
15
have to do that.
And I don't think it's occurred to him that
16
Q.
Will you give me his number?
17
A.
Pardon?
18
Q.
Will you give me his number?
19
A.
No, I won't.
Because, like I said, there's
20
no point to it.
21
way, either he contacts you or I will give you the
22
number.
23
And I will -- I will put it this
I will make sure that you have contact
24
with him because he's a prescient witness and he
25
created those documents and he will be able to
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acknowledge the authenticity of those documents, and
in order to do that, he has to make himself available
to you.
That's on me.
Q.
weeks?
A.
So I will make sure all of that happens.
Can I ask you to do that in the next two
Oh, I'll do it right away.
I'll tell him
tonight, get this ready because I've got a case
that's moving forward and this is part of your --
10
he's already done that in another case I have that
11
came out of the Lavoy Finicum rally, which he took
12
film, he's already authenticated film over in
13
Superior Court.
14
be a process in this case to do the same thing.
15
Q.
So he's aware that there's going to
You sent me an e-mail May 7th, 2016.
I had
16
asked you to elaborate on your first disclosure, and
17
your response was, Mr. Greene, attached is my
18
compliance with your request to be supplemented by
19
information gathered from your future disclosures.
20
And you end it before you signed, RW, frankly, my
21
entire case is made on the basis COT, City of Tucson,
22
disclosures.
23
24
25
Is that an accurate statement?

A.
It is in terms of the documents that were
produced, Miranda's letter, Rankin's original letter,
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the police reports.
conspiracy comes out of City documents.
comes out of that, can directly be inferred.
confidential memo, all of those things, I don't have
-- other than the film, off the top of my head, I
don't have any independent inside information that I
would disclose, not that I don't have it, but that I
would be willing to disclose.
The whole case and the

All of it
The
You see, I have a background -- I have a
10
responsibility as a journalist.
11
talk to me because I'm an internet blogger, and they
12
reveal confidences to me, with the understanding I
13
will not disclose who they are or use what they tell
14
me in any way that could lead back to them.
I've got people that
15
So there may be a lot of things I know
16
about that frankly I'm not going to be able to use
17
because I won't reveal who these people are without
18
their permission.
19
20
21
Q.
So you would not be testifying to things
that you haven't disclosed to me?

A.
I can't think of why I would.
I'll tell
22
you, in the very beginning, that's why I sent you
23
everything.
24
side everything?
25
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What kind of an idiot sends the other
I hadn't seen most of that stuff for

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years.
ever had to say or do on this subject matter.
of it may be good, some of it may be bad, but
whatever it is, it's what happened, it's what history
shows happened.
But I knew this is everything that Roy Warden
Some
And I don't have the time to review
these.
News reports.
give them everything.
I mean, it's a half a terabyte of data.
10
No.
I don't have the time to go -- I'll
In fact, because I don't know until I sit
11
down with my trial attorney and we look at the
12
specific documents what is relevant to how he wants
13
to present the case and what isn't.
14
go through that, I know I'll have to do that at the
15
pretrial meeting when we're laying our evidence on
16
the table to introduce at trial.
17
will be a selected amount of material that will be
18
set forth.
19
going to be.
20
21
22
23
24
25
Q.
So rather than
At that point there
Until then, I don't know what that's
Am I going to find liability for all of my
clients, the Defendants, in my disclosure to you?

A.
I'm sorry.
I don't really understand the
question.
Q.
Am I going to find liability on the behalf
of the Defendants in what I have given to you, as
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1
2
opposed to what you have given to me?

A.
Oh, certainly.
Those are the letters that
were cc'd, copied.
point.
Gilmartin.
Gilmartin settlement agreement and a couple of other
documents.
next couple of days.
Mike Rankin's letter is the focal
Miranda, everything.
Well, and including the
You see, you haven't received the
They're being disclosed to you in the
Q.
Okay.
10
A.
And you'll see those.
And within all of
11
that you'll see what I have right now.
12
there's many ways of reading the judge's order as to
13
December 1st being the cutoff date for the completion
14
of discovery.
15
disclose to you all of the documents and information
16
I intend to use or might use.
17
And I presume
I presume by then I will have had to
And I'm not holding anything back in
18
secret surprise.
19
problem will be what can I get admitted at trial?
20
What's relevant and how do I go through all that?
21
Q.
I've got no reason to do that.
So I'm just trying to understand this.
My
So
22
the Gilmartin case you're going to give me, plus the
23
April 12th memo from Mike Rankin, plus what I have
24
disclosed is going to reveal the liability of the
25
Defendants?
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1
A.
It's going to -- it's going -- it's going to
reveal what is in essence a criminal conspiracy to
violate my rights.
Q.
So that would be a yes to my question?
A.
That's a yes, certainly.
I guess it comes down to motive.
Why
did -- if they engage in acts of First Amendment
retaliation, retaliating against Warden for what?
Well, what Warden says.
10
What Warden writes about
what they're doing.
11
So, you see, a lot of it comes out of
12
that, inferences you can draw from that.
13
Warden say that so angered them?
14
some of it.
15
all the stuff I've given you.
16
Q.
What did
Well, you've seen
And all of it certainly is included in
What, in your opinion, is the policy,
17
custom -- policy or custom that establishes municipal
18
liability in this case?
19
A.
The unwritten custom and practice of the
20
Tucson City government, officials involved in the
21
government to favor certain political groups,
22
Pro-Raza, open border groups on the basis of cheap
23
labor comes from that, and to apply the law in a --
24
I'm being very awkward with this -- discriminatory
25
fashion and violate the law on the basis of
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1
somebody's political beliefs, that the law says they
can't do it, but they find ways to get around it,
such as the confidential memo.
around enforcing the law.
law.
This is how we get
We don't care about the
The custom and the practice is to wink,
wink, nod, nod and get around it.
practice is to protect Tucson City officials and use
public money, which is against the Arizona statutes,
The custom and the
10
to pay punitive damages, as they did -- that's
11
exactly what they did in the Gilmartin case.
12
paid a good chunk of the punitive damages.
13
called it something else.
14
fees and yah dah yah, a lot of other things.
15
essence they paid $900,000 more than the judgment
16
allowed them to pay.
17
$900,000.
18
Q.
They
They called it attorney
What Arizona statutes were you referring to
that prohibit the paying of public moneys for
20
indemnifying employees?
A.
But in
They only were on the hook for
19
21
They
I think you -- not indemnifying, the
22
punitive damage aspect.
23
in one of your pleadings to me.
24
didn't know that there might be a statute involved.
25
I did know that the purpose of punitive damages is to
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I think you referred to it

And before that I
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hold the individual liable.
doesn't do any good if the City pays for the punitive
damages of an individual because he's not going to be
deterred from future misconduct.
him anything.
6
7
8
9
And that's why it
It's not costing
Do you understand that?

Q.
It's very clear.
Do you think that there's an Arizona statute
or law that prohibits that practice?

A.
I'm saying I only picked that up, I think,
10
on something which I thought you had said in one of
11
your answers and I haven't gone back to find it.
12
Q.
Okay.
13
A.
And you said something about that he's
14
saying we're in violation of such and such whatever.
15
And so that alerted me to that.
16
general from reading punitive damages cases against
17
government entities that the entities themselves are
18
not liable, the individuals are liable, personally
19
liable.
20
But I knew in
And they can't be indemnified by the City.

And Mike Rankin writes this letter back
21
then -- it's in the materials I sent you -- where he
22
says -- it's actually in a news article -- we
23
indemnify all City officials.
24
25
Yeah, well, that sounds fine, except you

can't pay their punitive damages, you can't indemnify
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1
them against that, and that's what you did in
Gilmartin.
show.
Q.
That's what the settlement agreement will
And I'm trying to follow your logic.
You're
saying that the City can't pay that because otherwise
what's the deterrent effect of punitive damages?
A.
To use public money -- the purpose of
punitive damages is to deter public -- misconduct of
the government by public officials.
And if you make
10
the public pay for their own damages, the public
11
officials that misconduct themselves no longer have
12
any inducement to not break the law.
13
just make the public pay for it.
14
They say we'll
Miranda got off scot-free, as did Smith
15
and Ochoa.
16
Q.
Two million dollars of punitive damages.
Back to the practice and custom of the City
17
of Tucson that you talked about earlier.
18
you believe that -- or how long are you going to be
19
able to prove that that's been going on?
20
A.
How long do
I will tell you this, and it's a document
21
that's been disclosed to you and now it's been
22
specifically referenced to you in a section of that
23
document provided in my most recent -- coming through
24
disclosure, interrogatory and admissions.
25
was back in 2004, the Mayor of Tucson, Walkup, and
520-623-0593
And that
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Rankin and Miranda cc'd, and Barbara La Wall received
a letter from Kathy McKee, who was the author of the
original Prop 200 which limited the use of welfare
money to assist illegal aliens and required certain
background checks on licenses and things like that.
It was the initial step to control people who were
here unlawfully in 2004.
8
9
And you heard about -- they had a

demonstration.
And at that demonstration people
10
showed up, committed incredible acts of violence
11
against them.
12
The police department came to her and
13
said we're very sorry this is happening, ma'am,
14
because we were told not to interfere, to let it
15
happen.
16
continue.
And the police department let the violence

She documented it in a letter.
17
At one point some 87-year-old lady, she
18
reaches up and pulls the mask off of a guy that was
19
masked in front of her, screaming and yelling,
20
cursing obscenities at her.
21
assault.
22
pays a $1,200 fine.
23
She was arrested for
She was charged in municipal court.
She
Custom and the practice.
And Kathy McKee writes in her
24
Declaration, I was afraid to go back to Tucson after
25
that.
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Don't demonstrate against those people down

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there, they'll get you.
Q.
I read --
A.
In sum and substance.
Q.
I'm sorry to interrupt you.
I read in your Complaint, your Affidavit,
and then I also read that letter and your disclosure.
Anything else in terms of the length of that custom
and practice?
A.
10
thing.
11
all the ways in which that applies other than what
12
I've alleged in the Complaint.
Custom and practice is kind of a complicated

I haven't -- frankly haven't thought about
13
Q.
Okay.
14
A.
There will be more -- more instances of
15
that.
16
the Rankin confidential memo.
17
layperson sitting on the Council, this looks like we
18
have incredible legal justification for continuing on
19
with this policy.
Well, I think implications could be made with

In fact, you see, to a
Look at all these citations.
20
And they're the exact cases the Ninth
21
Circuit said close but no cigar, because they are
22
parade permits which are different than park permits.
23
Totally different animal.
24
And so the City attorney that put that
25
together, the little paralegal or hotshot, whoever
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thought he was being clever, is layering on all these
layers of legal justification which were absolutely
not applicable.
Q.
Bullshit.
Tell me about what police officers, aside
from Officer Sayre and Diana Lopez and Captain
McCarthy, were doing on May 1st, 2012 out at Armory
Park.
8
9
A.
I've named named Defendants on the basis of
what they specifically did.
There were other
10
officers may have supported them.
11
in my proposed Third Amended Complaint, officers who
12
attended the public meeting -- not public meeting,
13
but the organizing meeting with Tucson City and
14
County officials in how they were going to organize
15
Armory Park after the permit was granted, there were
16
a number of officers and people that participated in
17
that, but the judge would not let me amend the
18
Complaint to add those people in with a nonsensical
19
ridiculous argument of statute of limitations.
20
There's no point of discovery -- the offense had been
21
alleged, had been alleged for a number of years.
22
There's no point of discovery to find new people
23
involved in the same event that you're alleging if
24
they're going to say, well, it happened so long ago,
25
you can't bring them in.
520-623-0593
As you've learned
It's a stupid argument.
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Q.
My question is lot more simple than that.
A.
Okay.
Q.
I guess, what did you see -- besides those
three officers, what did you see the other Tucson
police officers doing that day out at Armory Park?
6
7
A.
Nothing other than there was whole lot of
them.
Q.
Okay.
A.
Nothing.
10
Q.
We saw a lot of them in pictures 1 through
A.
I was actually surprised.
11
12
17.
If you had told
13
me how many were there, I would have said three
14
before we had this meeting.
15
pictures and we've talked about it.
16
were a whole lot more there.
17
18
19
Q.
Okay.
Now I've seen a bunch of

Evidently there
Did you have any interaction with any
of those police officers?

A.
I may have.
There's a number of officers I
20
have a friendly relationship with on the basis that
21
we've met before at other demonstrations.
22
frankly, there's a number of police officers who, off
23
the record, have given me a great deal of
24
information, including the original reason on why the
25
Gilmartin case is so important.
520-623-0593
And, quite
I would not have
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fastened on to that based on my own research, but it
was police officers telling me, you don't understand,
Roy, this is what these people do, and we're afraid
to talk about it because we'll get fired like
Gilmartin did, and all those horrible things that
happened.
7
8
Q.
Aside from talking to those officers, did
you have any other interactions with them?
A.
Not that I remember.
10
says we did, we did.
11
noteworthy to me.
But if one of them
It certainly wasn't anything
12
Q.
Okay.
13
A.
There wasn't any acrimony.
There wasn't any
14
threats made or blows struck or insults traded or
15
anything of that sort that I can recall.
16
Q.
Okay.
17
A.
If one of them says Roy Warden might have
18
called me an asshole, maybe I did.
19
it.
20
Q.
I don't remember
The Gilmartin lawsuit, I guess, you know, I
21
don't have all of it.
22
from it, so...
23
this.
24
link between that lawsuit and City of Tucson open
25
border policy that you allege, are you?
520-623-0593
I have some small documents
But let me ask you -- let me ask you
That lawsuit, you're not alleging there's a
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A.
No.
I'm saying that's part of the custom
and the practice.
Gilmartin's case, it was simply testifying on behalf
of police officers who subpoenaed him to trial in
federal court against Tucson City officials,
including Miranda, apparently, they will retaliate
against you.
did it to Gilmartin.
9
10
When somebody speaks out -- in
They will use the law to get you.
They
First Amendment retaliation and

conspiracy.
Those were two of my claims.
11
Q.
Right.
12
A.
The same series of events, although mine are
13
14
much more dramatic.

Q.
So as I recall some of the facts in
15
Gilmartin, Dr. Gilmartin was to testify in US
16
District Court in a position adverse to Chief Smith?
17
A.
Could be, yeah.
18
Q.
And on the basis of that he ordered --
19
A.
They said don't talk.
20
21
You're not a friend
of Tucson City if you talk about those things.

Q.
Did you understand from the trial that Chief
22
Smith, Doug Smith, then instructed Miranda and Jesse
23
Ochoa to not award the contract to --
24
25
A.
Oh, yeah.
Take these retaliatory steps,
including Miranda falsified documents, falsified the
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test results.
you who specifically, other than Smith.
didn't -- I think they were of equal rank.
Rankin -- and Miranda was put in charge of that
contract renewal.
Q.
He was given orders.
And I can't tell

Ochoa
And
And, I'm sorry, I don't know a lot about the
case and I don't want to talk too much more about it.
But do you recall what it is that Gilmartin said that
then Chief Smith took such offense to?
10
A.
No.
What I understood from reading the case
11
-- and again I'm skimming through it to pick up
12
things that would appear to me to be significant in
13
terms of my own tale of woe at the time, so if I read
14
it now, I might read it differently.
15
It seemed that three officers, including
16
a captain and a lieutenant and a sergeant, had a beef
17
against Tucson Police Department, and I presume Doug
18
Smith was the recipient of that beef ultimately, and
19
they had come to Gilmartin for counseling.
20
that's how he originally, in his capacity as a
21
counselor for the City of Tucson, working with police
22
officers, first responders, that he was given this
23
information.
24
25
And
And then they later said will you testify

for us in court and laid a subpoena on him.
520-623-0593
And so I
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talked to Gilmartin about this.
feel any -- he would have testified anyway, subpoena
or not, just because it was the right thing to do.
He said he didn't
They had uncovered some misconduct
regarding police funding or the use of cars, or
police equipment, some interdepartmental thing with
the use of public property on a personal basis.
8
9
And so he testified on their behalf in

terms of what he thought was retaliation, and he was
10
told not to do so before he did, and then they said
11
we'll get you for doing it.
12
Q.
Mr. Warden, since I haven't gotten all those
13
materials yet, will you consent to me deposing you at
14
a later date regarding that case in the event that it
15
comes up?
16
A.
Be happy.
And I'll tell you, I have very
17
little -- you're going to be getting the settlement
18
agreement.
19
agreement, it's very funny, it's not part of the--
20
it's not a public document, never was.
21
confidential, the settlement.
22
You see, I had to pull teeth.
Settlement
It was a
And I had to threaten the City Council,
23
you either give it to me or I'll sue you under Title
24
39, and you'll give it to me one way or -- well, it's
25
confidential.
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I said, I don't care what your issues

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are, you spent public money, I'm going to get those
documents.
Q.
And I got right in their face about it.
Regarding the Rio Nuevo matter that we
talked about, you haven't disclosed any documents to
me about that.
documentation?
Are you intending on disclosing other
A.
Okay.
Q.
Excuse me.
I take that back.
You did
disclose to me a memorandum from Mr. Michael Jette
10
over at the Arizona Attorney General's Office.
11
other than that, I haven't received anything.
12
13
But
Am I going to be getting anything more?

A.
I don't know that there is anything more.
14
In fact, I probably -- I have to think about how I
15
came into contact with that.
16
research recently, within the last couple of months,
17
the whole Rio Nuevo issue on this basis.
18
this issue to their attention on numerous occasions
19
in a very confrontational way.
20
and cheaters and you stole money.
21
Nuevo money.
22
Yeah, I went back to
I brought
You people are liars

You stole the Rio
So I decide at some point a couple of
23
months ago to research it further on the internet.
24
did so, and that's when I came up with newspaper
25
articles and with the FBI report itself, which said
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in sum and substance we can't find the documents
because they no longer exist.
And I said, well, that's the same problem
I'm having with you.
documents that should be there no longer exist
because they would lead to the chain of
responsibility, who's responsible for taking the
money.
Documents no longer -- common
So I said this is very similar.
And I had been talking about that in
10
front of the City Council many times, or at least one
11
time prior to this exclusion from Armory Park.
12
part of my allegation of retaliation, you speak
13
against the people on these issues, they will break
14
the law to stop your right of speech, retaliate
15
against you in the way that -- in a different way but
16
in the same way they did against Gilmartin.
17
Custom and practice.
18
They will break the law.
19
they're above the law.
20
consequences.
21
damages.
22
Q.
So as
They will get you.
They don't care because
They don't have to pay the
Miranda didn't have to pay punitive
So I take it from that you're not sure
23
whether or not I'm going to get any other disclosure
24
on Rio Nuevo?
25
A.
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I'm not holding anything back.

I mean, if I
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find more stuff, I'm more than happy to give it to
you.
not holding anything back for any reasons.
I can get, I'll give you.
All it does is strengthen my case.
Q.
I mean, I'm
Whatever
So again, if there's something new that
comes out of that or another issue, do I have your
consent to depose you again on those additional
issues?
A.
I don't know that I have to give consent.
10
You're going to do what you're going to do.
11
take a look at the rules.
12
Q.
Well, that's why I ask you.
I'll
Because usually
13
the federal rules say you've got to work on it first
14
before you go to the judge.
15
A.
Okay.
Let me put it this way.
In
16
principle -- and I've been this way from the very
17
beginning -- you see, I know these crazy political
18
people, they have all this incredible software,
19
encryption software, everything is secret messages.
20
I got nothing secret.
21
together that list of attorneys and cops, and
22
everything I do, before I do it, I send it out.
23
Everybody knows.
24
other than the identity of people who helped me.
25
got nothing I hold back.
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That's why I put
I got nothing I'm hiding back,

I
I want to give it to you.
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I got nothing I want to hold back regarding if it's
going to enhance my issues in these cases.
Showing more responsibility for theft of
money in Rio Nuevo, it just deepens your clients'
enthusiasm and reason for retaliating against me for
speaking out against it.
7
8
9
Q.
Tell me about the April 10th, 2006 event
which you have called a riot a number of times.

A.
Uh-huh.
Have you seen the police film on
10
that?
11
police helicopters, loudspeakers, cops swinging
12
batons, people shooting pepper balls into people, cop
13
with his gun, cops being knocked to the ground and
14
people jumping on their backs kicking?
15
a riot.
16
Q.
With a fog of teargas hanging over the park,
Okay.
Yeah, that's
Have you read, I think it was then
17
Lieutenant Timpf's memorandum after-action about what
18
happened?
19
A.
Yes, of course.
And I've got more
20
communications about Timpf which I'll be happy to
21
talk to you about.
22
Q.
Did you find his report to be accurate?
23
A.
Yes and no.
Yes, in that he accurately
24
described what happened.
25
describe the why of one of the things.
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He didn't completely
You see, he
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says we're looking at this, and it was clear that
there was going to be public acrimony, and so we
moved in to provide -- created this perimeter to back
up the peacekeepers, we moved in to maintain public
order.
That's a load of horseshit.
I went to
him.
We're not going to have any room to do our flag
burning.
I said, look, these people are pushing in.
We're not going to be able to speak because
10
these people occupy the space.
11
right to do this.
12
I says, we have a
He says, Mr. Warden, you wanted to be
13
here.
14
Park.
15
Let's see how long you can stay in Armory
And I pointed to my fanny pack.
And
16
you'll see in the pictures, hanging from there was a
17
concealed weapon permit.
18
hanging there.
You can see something
19
I said, Mr. Timpf -- he was a sergeant
20
then, or maybe a Lieutenant, he's a captain now, I
21
think.
22
said, here's the deal, you'll protect us or we'll
23
protect ourselves.
24
down, break the perimeter, kick us to the ground,
25
kick us in the face, if they try to drive us out of
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I said, Timpf -- looked at his name tag -- I
If these people try to knock us
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the park by violence, we have a right to stand our
ground.
into their faces.
people in the ground today.
Earp did at the O.K. Corral look like a Sunday school
picnic.
board explaining why you didn't protect public safety
when the need arose.
We will withdraw firearms and discharge them

I said, I'll put more than 30
We'll make what Wyatt
And then you'll be standing before your
He was willing to have these people beat
10
us up and throw us out of the park, like they did to
11
Kathy McKee.
12
13
14
Q.
So what happened after you made your
statements to Timpf?
A.
He looked -- he -- fury.
His face turned
15
red in fury.
16
within three minutes 40 officers appeared, came
17
marching in, and they entered the circle, expanded
18
the peacekeepers out, backed up the peacekeepers,
19
expanded it out, created room, and began ejecting
20
people that were there that shouldn't be there, like
21
newspaper reporters.
22
And then he was on his cellphone.
And
I told Rathbun -- I don't know if she's
23
connected to the Rathbun Realty.
24
name.
25
inside the circle.
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I forget her first
I said -- she says, we have a right to be

I says, no, you don't.
I says,
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you're not the news.
This is our circle, this is our day, this is our
event.
purpose for it is to prevent us from burning the
flag.
of public safety.
get out of here.
8
9
We are political protestors.
You can't stand in here because your only
If we want to burn a flag, we can't, because

So you're in here to stop us.
She wouldn't.
There was some shoving
between me and one of the other reporters.
That was
10
the subject of a criminal arrest after the rally.
11
They arrested me for that, pushing and shoving.
12
You
I says, get out of here because we're
13
going to set this on fire and you're going to burn
14
up.
15
police ejected them.
Get out of here.
16
So they were ejected.
They were very cooperative.
The
They
17
understood our right at that point to do what we were
18
going to do, and they weren't going to let anybody
19
create a public danger to interfere with us.
20
that was only because I said, if you don't do it,
21
we'll do it at the point of a gun.
22
23
Q.
But
Do you have any other disagreements with
lieutenant -- I don't know his rank -- Timpf's --
24
A.
Timpf, yeah.
25
Q.
Do you have any other disagreements with his
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after-action report, I guess it was, besides what you
have said?
A.
No.
I think they accurately described -- of
course, I learned much from that.
about them throwing frozen water bottles at the
marchers as they marched north.
them assaulting the old ladies that were sitting in
lawn chairs.
down at the federal building.
I didn't know
I didn't know about
I didn't know about what they had done
10
All that was -- I didn't know about them
11
kick -- I didn't see anybody kick a cop in the face.
12
I didn't see -- I saw batons being swung, I think.
13
saw the air of -- the cloud of teargas.
14
screams and yells and sirens and all that crap.
15
didn't see any of that stuff.
16
I heard
I
So when I read the report and I said
17
these people were remarkably lawless.
18
Isabel Garcia goes between -- before the City Council
19
and she complains, well, we got a bad report.
20
after-action was a bad report.
21
described what those people did on that day.
And then
The
I think it accurately
22
I don't have -- I don't have any factual
23
complaints about anything, as far as I can recollect
24
now, that I've read in police reports.
25
Q.
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Okay.
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A.
They're remarkably revealing.
Q.
You mentioned in one of your disclosures an
expert witness to testify about the 28-foot rule.
4
5
What's the 28-foot rule?

A.
Okay.
I had an expert, firearms training,
works with the police department.
expert on firearms.
tell the officers, it's either 28 or 21 feet.
sticks in my brain, but it seems like an awfully big
10
He's a well-known
He says, at the academy they

28
distance.
11
He says, if you as an officer allow a
12
potential assailant to get within this distance, 28
13
feet of you, he's effectively neutralized any power
14
you may have from your firearm.
15
quicker than you can draw your arm -- your firearm
16
and fire.
17
you to the ground, they can take that weapon away
18
from you and shove it where the sun don't shine or
19
shoot you.
20
Q.
21
22
He can rush you
He can knock you to the -- crowd can knock
What does that rule that you've just
articulated have to do with May 1st, 2012?

A.
Nothing.
Other than the fact, if people are
23
going to be violent against you, you need to have
24
perimeter, you need to have a protected space.
25
asserted my rights to do all of those things before.
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I had
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I did not assert them on that date because it was not
my intention to be the center of attention, speaking
out in a conflicting way with their points, it was to
talk with them reasonably, passionately but
reasonably, as citizens with the same concerns about
poverty and about poor people being exploited.
7
8
Q.
When did you personally learn about this
rule?
A.
Back in 2006.
10
Q.
Did you learn it from the individual that
11
12
you disclosed as an expert?

A.
I learned it, yeah.
Disclosed then?
13
haven't disclosed anybody now as an expert for the
14
20 -- if there's confusion on that, I'll clear it up.
15
Q.
Okay.
16
A.
I have not asserted any issue on the 21-foot
Go ahead.
17
rule.
18
up in the context of all of this, and frankly I
19
can't, at the moment, put my finger on it.
20
I don't know how -- in fact, I know it's come
But I don't assert any of that.
Other
21
than the fact I was taught that that's why we had --
22
we started creating perimeters and roped-off areas,
23
saying don't cross this.
24
saying we will protect that, we will allow Warden to
25
put that up to keep a space between him.
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And the police started
Because if
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you're wearing a fire -- if you're asserting your
Second Amendment right and your First Amendment
right, and you say you will be willing to stand your
ground, that means they both may come together.
I don't think any of that has anything to do with
this case, as far as I can understand.
7
8
Q.
But
So you're not intending on calling a witness
for that purpose?
A.
No, no.
10
Q.
Tell me about your practice in the past to
11
12
put up the rope barriers.

A.
Why did you do that?
I did this because, first of all, I could
13
see in retrospect that the so-called peacekeepers at
14
the original rally, they were a very intelligent part
15
of that whole movement.
16
people.
17
things are.
18
and says this is what we're going to do.
They were very bright
I don't know how coordinated all of these
19
I don't know if somebody sits at the top
But they were very smart in realizing
20
this was a contentious issue.
21
people to be involved in any violence.
22
asserting these people have a right to say what
23
they're going to say. We don't want there to be any
24
violence.
25
these people.
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They didn't want their

And they kept
And we also don't want you to look at

So we're going to join hands and
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circle them.
In fact, in one of the films it shows a
lady with a loud -- she says, ignore the ignorant.
Don't listen to what they have to say.
nothing to say.
They've got
And so they surrounded us, joined hands,
and were somewhat of a barrier, until people kept
pushing in anyway, including the media, who wouldn't
respect it.
10
That's when we called for the police to
protect the barrier.
11
So I thought they did a very -- it was a
12
very good thing.
13
public speakers, mayors or personalities,
14
celebrities, that their private security oftentime
15
creates a perimeter, a physical barrier, roped-off
16
barrier, in which you can stay on the outside but you
17
cannot enter.
18
we're assuming you mean a threat of some sort and
19
we'll take you down.
20
And I realized whenever you see
If you take one step on the inside,
So I started using a perimeter, and
21
said -- and it was also symbolic protest.
22
like this is how you protect the border, you put a
23
border up and you say don't cross this line or you're
24
subject to what we're going to do to you.
25
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It's just
And with me it was a matter of public

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safety.
if you think you're going to rush in here and knock
me down and beat me up, you're sadly mistaken.
said that over and over again in very dramatic terms,
so it was very easily understood by the marchers.
I don't want there to be any violence, but
And I
Whether they understood the legal
implications behind it and appreciated that or not,
whether they understood stand your ground, which
frankly they are entitled to invoke as well, it's
10
just simply we don't want any violence here.
11
the line you do not cross.
12
This is
You cross into here and I'm going to
13
consider it to be a deadly threat because my life has
14
been threatened.
15
force and this is my dividing line.
16
and I'll put you in the ground.
17
18
19
Q.
I've been threatened with deadly

You come in here
How many times did you employ at that rope
barrier?
A.
I didn't employ it in 2012 because I was not
20
asserting a piece of land that I wanted to speak out
21
against in terms of crowd.
22
Tucson Weekly public forum down in library square, I
23
employed it.
24
25
Every time we did the
And that was a dozen times or more.
I employed it a dozen times or so in

front of the Mexican Consulate for the same purpose,
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same reason, to keep a barrier between those that
were against us and those that might support us, in
order to avoid any violence, anything whatsoever of
that sort.
I'm 69 years old now.
If somebody pushes
me to the ground, I might die, might have a stroke.
Who knows?
if I was 23 years old and in perfect shape, if I was
a police officer, they can't employ deadly force
I don't have to put up with -- you see,
10
under the same circumstances I can, because they have
11
a different level of training and they work in
12
concert with each other.
13
public, my limitations are based on what a reasonable
14
person would do at that particular age and physical
15
ability and health and all of that.
16
Q.
But as a member of the
So it sounds to me like 12 plus 12 is 24.
17
So greater than 20 times, a fair statement, that you
18
used the rope barrier?
19
A.
It would depend on how many rallies I've
20
had.
21
be under 30, it could be more than 60.
And again, I've totally lost track.
22
It could
Like I said, I just recently had one down
23
in front of the federal building.
24
a barrier there, but we spoke.
25
occurred.
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We did not employ
And violence
I was assaulted by a skinhead, by a Nazi,

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a supporter of the Nazi cause, for saying what I had
to say about Lavoy Finicum.
had a barrier to keep him out.
Q.
And I wish I would have
When you were prosecuted in the past -- I
brought this up earlier.
the past -- I will withdraw the question.
you've answered it.
THE VIDEOGRAPHER
MR. GREENE:
When you were prosecuted in

I think
10 minutes, Mr. Greene.
I'm sorry?
10
THE VIDEOGRAPHER:
11
MR. GREENE:
10 minutes.
10 minutes?
All right.
12
think I'm almost done, everyone will be happy to
13
know.
14
Q.
(By Mr. Greene)
In terms of the 2008, 2009,
15
2010, 2011 and 2012 May 1st rallies that you
16
attended, when you spoke outside of Armory Park, what
17
kind of reactions did you get from marchers, from
18
police, from pro your side, et cetera?
19
A.
I can answer part of that very easily.
And
20
it's a new wrinkle on all of what we talked about.
21
The pro Protect the Border people, I will say my
22
observations here in Tucson, street people, people
23
involved in these things, invariably, I won't say all
24
of them, but many of them are racists.
25
people I despise as much as I despise anybody.
520-623-0593
They are
Nazi
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1
thoughts.
I've had Nazis approach me and wanted to
incorporate me into their movements, and I've told
them to bugger off.
things said about me was said by a skinhead on the
internet.
I even -- one of the nicest
He said, Roy Warden, we went down and
tried to tell him all about the Jews that were
ripping off the country and how they were all
10
involved with the beaners and all of that.
11
Warden said, get away from me.
12
don't want to speak to you anymore.
13
Warden may stand up to protect the border, but he's
14
no WN.
Meaning white Nazi.
15
And Roy
Don't come back.
And he says, Roy
He's not one of us.
I was very happy to read that.
Most of
16
these people, they don't understand the larger
17
dimensions.
18
employers get.
19
we see crime as a consequence to this.
20
They don't see the benefit that the

They don't see any of that.
They see
In fact, I'll say, oddly enough, Trump,
21
in his initial representations in the way that he
22
characterizes, especially the comments he made about
23
the Mexican judge, is very similar.
24
25
Very narrow-minded people.

understand larger dimensions.
520-623-0593
Don't
May be delving into
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1
latent racial bias.
I hate racism.
I hate any of that.
I've
got a background with Hispanic people and with Mexico
and my family.
comes from the left-wing Pro-Raza.
thing.
Q.
I hate all of that.
Even when it
It's the same
It's ugly.
Did you receive any hostile reactions over
the years from the Pro-Raza people or the MECha
people
10
A.
Did I receive any what?
11
Q.
Hostile reactions, name calling, things of
12
that nature.
13
A.
Starting from Armory Park?
14
Q.
Yes.
15
A.
Starting from 2006?
16
Q.
Yes.
17
A.
Quite often, but not at the Armory Park
18
events that -- you know, the permit events, simply
19
because -- I can't really tell you why.
20
to get in.
21
I'm trying
They're focused on other things.

When I -- most of the violence to me came
22
in 2006 and came at the Tucson Weekly public forums
23
and in front of the Mexican Consulate because here I
24
am establishing territory and now they're coming up
25
to inquire and they get angry.
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So whenever I established, you might say,
a beachhead or a perimeter, I'm subject to the
violent conduct.
Q.
Okay.
A.
But at Armory Park, when I'm not
establishing a line and where they keep me out,
there's never been anything.
interactions have been with the followers, not with
the leadership.
10
Like I say, most of my
Never been any real problem.
Which makes me realize that if we all sit
11
down and talk, there are great resolutions to these
12
issues and we can dispense with the illusion of
13
humanitarianism or any of that benefit.
14
helping the poor.
15
incredible exploitation and horror, you know.
16
We're
No, you're setting them up for
MR. GREENE:
Awful.
Those are all the questions I
17
have at this time, subject to further disclosure and
18
whatnot.
19
THE WITNESS:
20
MR. GREENE:
21
So with that I guess we'll go
ahead and conclude.
22
23
Okay.
THE VIDEOGRAPHER:
videotape deposition.
That concludes the
The time is 2:11.
24
25
520-623-0593
(The deposition was concluded at 2:11 p.m.)

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4
____________________________
ROY WARDEN
5
6
7
8
9
10
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STATE OF ARIZONA)
) ss:
COUNTY OF PIMA )
BE IT KNOWN the foregoing deposition was taken by me;
COLLEEN KELLY, RPR, Certified Reporter in the State of
Arizona; that ROY WARDEN, before testifying was duly
sworn by me according to law; that the proceedings were
taken down by me and reduced to writing under my
direction; that the preparation, production and
distribution comply with law and code; that the
10
transcript is a full, true and accurate record, all done
11
to the best of my skill and ability.
12
IT IS FURTHER CERTIFIED the ethical obligations set
13
forth in ACJA 7-206 (J)(1)(g)(1) and (2) are in
14
compliance; that I am not a relative or attorney of
15
either party or otherwise interested in the events of
16
this action.
17
( ) Deposition review and signature was waived.
18
(X) Pursuant to request, notification was provided
19
that the deposition is available for review
20
and signature.
21
WITNESS my hand this 27th day of September, 2016.
22
23
_______________________
COLLEEN KELLY, CR, RPR
CR #50386 (AZ)
_____________________________
NO. R1040
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a.m 1:17 2:23 4:13
58:2
abbreviated 117:1
abet 130:19
abetting 47:6
ability 25:17
167:15 173:11
able 6:12 39:20
41:9 53:18 54:10
59:4 76:4,9,11
121:20 137:25
139:16 145:19
158:9
absence 125:13
absolute 134:4
absolutely 16:20
17:15 35:23 74:5
106:15 112:19
148:2
absurd 46:23 59:17
academy 162:7
accept 40:17 65:4
115:24 117:3
119:11
access 73:16,18
76:18 89:25 96:18
account 81:23,24
accounts 81:19,20
accurate 48:16
138:23 157:22
173:10
accurately 127:5
157:23 161:3,20
accused 119:25
Acid 109:1
ACJA 173:13
acknowledge 138:1
acknowledged
53:10
acknowledging
86:23
acrimonious 21:22
26:21 28:23
acrimony 150:13
158:2
act 25:22,22 96:20
action 26:2 61:2
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105:14 173:16
active 34:1 103:10
actively 57:14
62:18 118:20
activist 34:12
101:11,14 118:12
activities 31:22
114:12
activity 52:4
102:14
acts 34:11 91:16
142:7 146:10
actual 38:12 39:25
add 116:14 148:18
added 120:22
addicts 88:21
additional 129:2
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funds 100:17,19,20
105:10
funny 28:3 38:12
40:15 68:10 89:1
92:2 153:19
further 20:16
47:19 63:25
112:15 113:22
121:19 154:23
171:17 173:12
fury 159:14,15
future 121:10
138:19 144:4
G
g 173:13
gain 99:13
garbage 101:19,20
101:21 102:12
Garcia 31:15 34:9
56:8 57:15 62:17
79:8 161:18
Garcia's 16:12
gather 40:6
gathered 54:3
138:19
Gathright 17:16
19:1,2,12,20,20
85:20,21 86:13
134:24
gears 98:12
geez 20:7
Gem 111:7
general 9:21 20:22
21:16 50:12 91:7
91:9,10 144:16
General's 154:10
generally 6:18
13:16 55:24 62:7
106:11
generate 83:5
generated 84:17
generations 110:15
genial 7:17 21:12
103:14
getting 15:24 24:5
47:18 87:2 88:5
88:17,23,24 89:7
107:21 121:21
153:17 154:12
ghosts 38:24
gift 111:10,11
Gilmartin 80:11,21
82:2,15,17 83:10
125:12 141:5,6,22
143:11 145:2
149:25 150:5,20
151:8,15,15 152:8
152:19 153:1
155:16
Gilmartin's 123:25
151:3
give 11:2 96:3
104:13,14 134:12
137:16,18,21
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140:9 141:22
153:23,24 156:1,4
156:9,25
given 13:11 100:5
140:25 141:1
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152:1,22
gives 61:7 93:24
giving 14:16 67:5
84:21
glasses 67:18
Glenn 112:10,10
Glocks 72:18
go 6:24 9:8 14:24
17:11,12 21:25
23:21 25:5 27:6
28:18 43:15 44:11
55:18,19 57:22,24
73:22 76:12 77:23
77:23 86:5 88:11
88:16 90:9 92:25
93:17,20,20,25
94:17 95:4 96:2
96:23 97:19 107:1
107:14,25 111:7
111:21 112:24
113:2,4,22 123:8
123:11 128:21
132:13 136:14,23
140:8,14 141:20
146:24 156:14
163:15 171:20
God 83:8
goes 6:19 7:7 10:3
31:20 37:16,16
81:24 83:8 94:13
120:14,24 161:18
going 6:4 9:23
14:20,22 18:11,14
19:7 21:2,3,25
23:10,20,21 24:6
24:7 26:18 32:8
32:24 35:14,15,16
37:24,25 41:16,23
43:8 45:21,25
50:21 54:3 57:25
59:2,4,9 62:16
64:4,10,22 65:25
520-623-0593
66:5,11,17 68:19
68:21 71:8,9
73:11 74:1 76:20
79:13 80:15,16,17
80:18,20 82:18,19
83:15,16 84:14
85:23 88:4,5
90:10,25 91:2,14
91:15 92:16 93:18
93:19 94:5,7,8,13
95:22 96:4 100:25
107:25 108:2
111:17 113:6
114:9,10,25 118:5
118:6 124:7
127:23,24 130:24
132:8,13,19 133:3
134:5,14 136:4
137:12,14 138:13
139:16 140:19,20
140:24 141:22,24
142:1,1,1 144:3
145:18,19 148:14
148:24 153:17
154:1,12 155:23
156:10,10 157:2
158:2,8,9 160:13
160:13,18,18
162:23 164:18,23
164:25 165:24
166:2,12
gold 84:3
good 5:3,4 8:9 60:8
61:8 63:14 79:25
83:4 103:19
114:24 121:22
140:3 143:12
144:2 165:12
goodwill 83:5
120:9
gotcha 50:11
gotten 6:22 40:8
153:12
government 30:4,5
31:21 62:19 68:20
82:22,23 130:3
136:1,1 142:20,21
144:17 145:9
government's 53:7
governmental 48:1
Graham 110:4
grand 35:6
grandiose 110:13
granted 86:8 87:25
148:15
granting 86:15
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Grapes 48:4,5
grateful 52:25
Gray 79:1 86:2,10
89:11,20 90:14
133:21
great 24:25 33:22
37:4 47:16 50:13
64:4 69:1 87:18
92:9 124:4 126:19
126:20 129:17
131:21 149:23
171:11
greater 167:17
greatest 47:9
greatly 69:4 73:3
126:21
Green 1:23 4:3
103:10 173:23
Greene 2:4 3:4
4:17,17 5:2 57:22
58:5 97:8 112:19
113:1,4,11 138:17
168:8,9,11,14
171:16,20
grin 68:25
Gringo 35:15,19
ground 32:5
157:13 158:24
159:2,4 162:17
164:4 166:8,16
167:6
group 12:11 16:3,5
16:18,19 34:6,12
45:9 50:8 52:1
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groups 16:11,12,12
33:16 45:16 50:17
51:10 94:2 126:23
127:13 142:21,22
growing 108:9
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guarantee 93:24
guess 13:6 15:5
38:8 42:15 44:5
50:2,3 61:17
135:5 142:6 149:3
150:20 161:1
171:20
gun 11:3 20:8 22:2
71:23,24 72:17,18
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gunfire 10:24
guy 59:14 63:9 66:7
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67:19,25 70:20
80:13 92:5 105:23
108:19,21 110:15
110:17 118:2
126:1,4 136:17
146:18
guy's 59:12 68:25
69:23
guys 10:20 112:22
112:25
158:16,18
happen 12:13
14:20 68:19
111:17 115:2
116:8 122:5
126:25 127:3
130:14 146:15
happened 7:14,15
18:15,17 26:9,9
30:16 31:24 33:8
65:5 73:11 79:16
83:19 89:6 90:18
93:5 95:16 98:6
103:5,15 104:22
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106:1 115:5 116:3
116:5,11 117:18
122:7,25 127:15
132:16 140:4,5
148:24 150:6
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happening 14:7
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happens 33:19
75:21 122:14
138:3
H
happy 20:1 35:7
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45:17 53:1 68:7
Haight-Ashbury
68:18 69:5 85:7,8
106:17
110:16 133:16
half 23:7 34:2,4
153:16 156:1
54:18 73:1 77:7
157:20 168:12
108:12 140:7
169:15
Hall 115:22
hard 32:12 136:17
Hallinan 108:16,20 hardcore 62:17
108:20 126:6
hate 106:23 170:2,2
Hallinans 108:22
170:4
hammer 72:18,19
hated 43:22,22,22
hand 42:14 59:12
132:6
62:5 71:23 72:4
hatred 131:22
110:23 173:21
132:5
handed 18:2
Hayes 95:21
132:20
121:13
handle 90:25 91:11 hazy 9:6
handled 98:23
he'll 137:6
hands 164:25 165:6 head 32:13 139:5
hang 107:2
headlines 69:10
hanging 157:10
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health 167:15
hear 33:17 37:25
68:18
heard 10:9,11 26:7
80:14 114:17
146:8 161:13
hearing 54:2
hears 33:24 137:5
Hearst 108:15
125:25
heart 87:21
heartfelt 30:6
heavy 106:18
held 4:10
helicopters 157:11
Hells 109:14,16
help 88:17 111:5
112:17 118:15
125:4,7
helped 81:6,10 84:9
85:1 99:19 156:24
helping 92:7 130:5
171:14
helps 120:10
hey 55:7 60:9
131:25
hide 119:17
hideous 36:13
45:15
hiding 84:20
156:23
high 69:8 83:7
131:16 132:9
high-end 118:18
higher 84:2
highly 47:24 59:15
83:24
hippies 107:8 108:7
hippy 106:16
107:16 110:5
hire 80:23 85:15
114:9 118:6
135:21
hired 24:20 82:14
83:4 135:21
hires 135:22
hiring 130:7
Hispanic 23:1,3
520-623-0593
24:22 36:9,18
170:3
Hispanics 31:6
131:23
historically 53:2
history 35:6 44:7
108:17 129:17
140:4
hit 32:13 95:9
hitting 32:6
hold 8:17 19:14
59:17 83:7 97:6
144:1 156:25
157:1
holding 51:2 61:8
62:15 72:3 105:10
141:17 155:25
156:3
home 13:8 55:18
71:16 121:17
homeless 73:17
88:18 89:7 99:5
101:7 113:25
116:7 118:16
homelessness 98:19
99:2 113:21
hook 143:16
hooked 99:16
hope 105:18
horrendous 47:10
48:9 53:15 88:19
127:15
horrible 31:12
113:21 124:12
150:5
horribly 36:13
horrific 31:5
horror 171:15
horseshit 158:6
hostile 170:7,11
hostility 44:3
105:23
hotshot 147:25
hour 2:23 54:18
66:16 73:2,2,3,10
83:15 103:22
hourly 120:16
hours 43:15 55:24
130:18
house 93:10 98:20
104:2 109:16
136:19
household 99:14
housing 88:24
huh 72:15 95:12
Huh-uh 91:21
humanitarian
61:25 127:9 129:5
humanitarianism
171:13
humanitarians
23:16 92:8
Humanos 34:11
hundreds 119:5
hunger 112:22
husband 131:20
hydroponics
118:17
hypocrisy 69:1,17
136:11
hypocritical 69:4
I
IAD 8:20 11:18
idea 38:6 58:22
65:11 69:13 71:2
83:11 127:9
identification
71:11
identified 56:24
identifiers 72:8
identify 39:21
identifying 73:12
identities 89:12
identity 66:9
156:24
ideological 51:8
idiot 139:23
idiots 34:23
ignorance 100:13
ignorant 165:3
ignore 35:20 96:6
96:22 137:7,8
165:3
ignored 31:10
ignores 35:25 36:2
III 85:25
illegal 22:23 25:3

30:1 59:21,25
87:7 104:17,20
126:20 130:21
146:4
illegals 31:8 131:5
illusion 11:7
171:12
immeasurably
125:5
immediate 30:25
31:1
immediately 11:24
58:11 117:18
Immigrant 34:13
87:10
immigrants 59:21
immigrants' 22:14
immigration 6:7
25:3 30:1 75:17
78:3 90:5
implications
147:15 166:7
import 110:14
important 90:16
149:25
impossible 82:21
impoverished
130:21
impressed 46:15
59:15
impressions 97:21
improve 116:6
improved 125:4
impunity 96:22
inaccurate 36:19
inches 69:8
incident 17:1 21:16
124:22
incidentals 123:16
include 96:19
included 142:14
includes 35:21
including 11:25
25:18 91:12 108:6
141:4 149:24
151:6,25 152:15
165:8
income 99:8,22
100:19,23 102:16
102:19 117:13
123:5
incorporate 169:3
Incorporated
119:19
increase 80:23
incredible 146:10
147:18 156:18
171:15
incredibly 98:8
99:5
incurred 120:7
121:23 122:20
indemnified 144:19
indemnify 144:23
144:25
indemnifying
143:20,21
independent 65:13
95:5,10 98:7
139:6
INDEX 3:3
Indian 52:23
110:24 129:20
131:23
Indians 43:18,20
43:21 53:4
indicate 41:3 128:5
indicated 18:14
86:1
indicating 132:6
indigenous 35:20
35:24 44:2,2
129:20
indirectly 114:18
individual 81:14
92:4 144:1,3
163:10
individually 1:7
4:8 54:16
individuals 51:1
74:8,10 90:3
100:23 135:14
144:18
inducement 120:23
145:12
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industry 31:9
ineptitude 111:23
inexperience
133:18
infer 83:11
inference 85:6
inferences 142:12
inferred 139:3
inform 13:16
informal 56:15
informally 54:4
56:11
information 8:23
61:21 63:12 71:11
71:15 72:7 73:13
94:24 104:17
134:12,13 138:19
139:6 141:15
149:24 152:23
informed 15:18
infrastructure
31:17
initial 20:5 89:25
112:4 146:6
169:21
inquire 170:25
inside 22:8 24:6
27:6 56:21 57:3
109:18 110:20
124:5 132:14
139:6 159:25
165:17
instances 147:14
instigate 96:16
instructed 151:22
instructions 69:20
91:11
instrument 85:14
instruments 85:15
insults 150:14
insurance 103:2
intake 8:22
intelligent 66:25
133:1 164:14
intend 24:3 120:14
141:16
intended 97:12
intending 15:8
520-623-0593
154:5 164:7
intent 47:1 76:7
97:19
intention 38:18
53:25 163:2
intentionally 55:16
115:20
intentions 14:23
interact 88:22
interacting 52:6
interaction 149:17
interactions 8:3
21:22 150:8 171:8
interdepartmental
153:6
interest 37:4 50:16
121:15 129:6,17
interested 22:15,17
37:14 103:12
122:16 125:12
173:15
interesting 25:15
60:7 108:19 126:5
131:17
interfere 96:17
146:14 160:19
interfering 68:11
interior 18:4
internet 16:7 68:4
70:18 79:12 99:16
118:3 139:11
154:23 169:6
interrogatories
86:16 87:1 88:5
interrogatory
145:24
interrupt 128:16
147:4
interview 29:9
interviewing
107:21
interviews 29:25
intimidating 98:21
introduce 4:14
140:16
invaded 35:22
invariably 168:23
invested 103:7
investigated 83:1
101:14 105:8
investigating
108:14 109:21
investigation 8:20
81:15 109:4 110:6
131:1
investigations
101:17 108:6
investigator 106:13
107:19 108:5
118:13
Investments
119:20
invite 130:20
invited 47:3 52:20
invoke 166:9
involved 29:20
36:7 37:12 45:14
46:21 60:2 79:17
94:4 102:25,25
104:19 105:4,12
106:18 108:13
110:1 118:20
126:18 130:14
137:7 142:20
143:24 148:23
164:21 168:23
169:10
involvement
109:13
involving 81:4
Iraq 64:2
Isabel 16:12 31:15
34:9 56:8 57:15
62:17 79:8 161:18
issue 10:8 14:9
15:23 21:20 22:21
23:15 28:11,12,13
31:4 53:3 60:4,7
74:20 78:3,7 82:4
96:21 100:4
116:23 125:11
126:19 127:25
129:2 130:1
135:10 154:17,18
156:6 163:16
164:20
issued 16:17 25:16

25:23 57:4
issues 6:6 11:13
13:25 22:13,15,21
30:1 34:25 36:5
37:5,8,15 45:13
45:24,25 52:23,23
63:13 67:3 68:9
74:22 75:20 82:6
91:11 96:12
100:14 101:14,16
101:23 104:12
106:10 127:21
129:16 153:25
155:13 156:8
157:2 171:12
issuing 20:12 86:20
87:8
judges 57:9
judgment 80:22
105:13 119:18
122:11,13 143:15
July 117:20,21
jumping 32:4
157:14
June 117:19,21
jury 80:14,14 98:13
104:13 127:25
justice 114:19,21
justification 147:18
148:2
K
Kathleen 3:24 8:21
10:15 11:18 19:9
21:14 66:23 93:2
105:22,25
J
Kathy 146:2,23
159:11
J 173:13
Kay 7:3,8 27:20
Jack 115:23
38:9 44:16 136:15
jail 59:23 60:3 83:2
137:9
jerk 95:21
Kayo 108:20
Jesse 151:22
keep 13:19 14:22
Jesus 130:13
15:8,12,22 17:17
Jette 154:9
18:14 19:1 39:22
Jews 135:16 169:8
48:3 49:21 56:7
Jim 7:3 136:15
56:25 57:1 61:9
137:9
62:13 66:17 67:1
job 38:2 48:8 83:22
68:13 73:11 74:1
84:8 102:16,19
84:8 85:11 87:14
114:13,16 134:1
87:15 91:2,17
jobs 46:25 48:3
92:3,11,13 93:10
59:22 81:2 118:16
120:12 123:21
135:19
132:24 133:3
John 66:9
134:1 135:19
join 164:25
136:4,4 163:25
joined 165:6
167:1 168:3 171:6
journalism 37:10
keeping 28:11,17
journalist 139:10
52:13 57:21 68:8
judge 57:8 78:24
74:2 76:10 77:19
86:1 89:11 95:21
87:11 123:18
116:25 121:12,13
keeps 83:22
133:8,16 134:18
Kelly 1:22 2:21 4:5
134:22 148:17
173:4,23
156:14 169:23
Kennedy 11:20
judge's 128:4
117:22
141:12
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kept 23:23 46:7
6:12,17 10:19,24
49:6 56:3 57:5
11:3 12:19 13:7
61:3 65:18 66:23
15:3,24 16:2,9,10
104:2 164:21
17:11,20,24,25
165:7
18:6 20:1,7 22:2,9
Kevin 13:11 15:3
27:23 28:21 29:14
63:17
30:5 31:1 32:18
keys 84:12
33:5 35:14 39:6
kick 35:15 158:24
40:9 41:10,14
158:25 161:11,11
42:15 44:10,13,17
kicked 42:23 64:1
46:6,6 48:24 50:1
kicking 32:5
53:13,14 54:19
157:14
55:8,12,17,25
kid 37:6
56:10,15 57:11
kids 51:5 108:9,20
58:14,20,21 60:9
131:16,22,23
61:15 63:10,11
132:9
65:2 66:7,7,9,13
kill 10:7 35:16
67:4 70:9,25 71:9
93:11
73:6,9,23,25
kind 20:2 22:9
78:19 83:6,16
29:23 32:11 37:24
85:1,12 88:15
43:18 62:25 63:8
91:25 94:6,23
64:17 74:7 76:17
95:4,25 97:19,25
109:20 110:9
98:6,7,14,17
111:20 114:1
100:16 102:21
121:2 122:20
105:3 108:25
124:22 139:23
112:25 113:18
147:9 168:17
114:14 115:19
kinds 48:10 95:15
116:17 119:4
110:25
120:13,19 121:1
King 96:15 119:24
121:20 122:18
119:25
123:10 124:24
KKK 38:25
125:16 126:8
knew 6:4 16:2,3
132:19 133:6
18:13 46:16 57:6
134:11 135:12
59:3 63:21 65:17
136:6,13,18
68:1 79:12,20
139:15 140:10,14
82:5 86:9,13
140:18 143:24,25
116:25 133:22,22
150:20 152:6
135:9,18 136:3
154:13 156:9,17
140:1 144:15
159:22 160:23
knock 118:1
161:4,6,8,10
158:23 162:16,16
163:17,17 164:16
166:2
164:17 168:13
knocked 32:14
170:18 171:15
157:13
knowing 59:8
knocking 32:5
124:8
know 5:5,5,6,15
knowledge 34:24
520-623-0593
64:5 94:18 129:19

128:17 132:25
134:21
133:2,23 135:10
known 15:5 29:17
135:20,24 136:2,3
60:9 110:15
136:7 142:23,25
134:24 173:3
143:1,4,5 144:8
knows 83:8 129:4
145:12 151:7
156:23 167:7
155:14,18,19
KOLD 29:14
173:6,9
Kool-Aid 109:1
lawful 13:19 92:19
lawfully 95:3
L
lawless 161:17
La 35:13 36:11
lawn 98:10 161:8
146:1
laws 107:13,15
labor 22:24 23:7
lawsuit 57:2 70:15
24:21,22 48:6,7
85:23 101:25
59:20,25 104:17
134:7 150:20,23
104:20 130:8
150:24
142:23
lawyer 121:5
lack 34:24 111:23
125:13
124:23
lawyers 84:3,5
ladies 98:9 161:7
lay 122:17
lady 41:19 146:17
layering 148:1
165:3
layers 148:2
laid 79:23 122:1
laying 140:15
152:25
layperson 147:17
land 53:5,8 166:20 lead 11:20 139:14
landlady 93:7,9
155:6
98:22 103:15,18
leader 59:18
104:19 105:22
109:15
landscaping 104:18 leadership 23:13
104:21
33:21,22 34:6
large 12:11 30:24
45:15 46:12 50:16
larger 34:8 169:16
56:9 61:19,22
169:25
62:15 92:6 126:23
latent 170:1
127:12 129:4
laughing 21:8
171:9
27:23,23 28:3
league 51:11
55:11 94:2
107:16 108:11
laughter 28:4
learn 163:7,10
Lavoy 47:15 52:18 learned 63:22,24
138:11 168:2
124:18 148:10
law 5:5 17:15 18:25
161:4 163:12
19:2,18 20:10
lease 98:25 112:13
28:14 33:4,5
116:24
55:13,14,16 57:6 leave 25:9 26:12
57:13 67:9 68:16 led 108:15
69:1,19,21,21
left 18:9 22:11
85:11 101:24
41:19 52:12 62:5
102:8 115:19,20
72:4,24 98:6
109:12 120:5
left-hand 13:5
64:18 67:17
left-wing 47:16
51:8 69:4 87:19
131:18 170:5
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Warden Opposition To State's Motion To Preclude Evidence

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Warden Opposition To State's Motion To Preclude Evidence

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Case 4:14-cv-02050-DCB Document 95 Filed 11/30/16 Page 1 of 13

Roy Warden, Publisher

IN THE UNITED STATES DISTRICT COURT

Case No. 14-cv-02050

RESPONSE TO DEFENDANTS MOTION TO PRECLUDE WITNESSES

RICHARD MIRANDA, MIKE

THE HON. DAVID CHARLES BURY

Case 4:14-cv-02050-DCB Document 95 Filed 11/30/16 Page 2 of 13

string Plaintiffs case.

II. RESPONSE SUMMARY

For more than a decade Defendants harassed, prosecuted, impoverished

pro-raza-open-border-cheap-illegal-labor state; literally, stripping him of

plasma to survive5. [See Warden Deposition, (WD), Attachment 1]

documents that (he) intend(s) to introduce at trial,7 claims pro-se Plaintiff

WD; 99:9-13; 21:23; 88:17-22

Case 4:14-cv-02050-DCB Document 95 Filed 11/30/16 Page 3 of 13

intends to surprise, and prejudice Defendants and demands that Plaintiff

under Defendants exclusive custody and control in what amounts to a de-

I, Roy Warden, Plaintiff in the above captioned action, do herein declare,

AFFIDAVIT OF ROY WARDEN

swear and affirm as follows:

I am the Plaintiff in the above captioned case;

On November 3, 2016 Defendants filed their Motion to Preclude

Witnesses and Evidence, (Doc.87)9, which shamefully distorts the

facts as to Plaintiffs extraordinary effort to abide by the Order of

this Court and by F.R.Civ.P Rule 26 regarding a partys duty to dis-

On or about February 26, 2016, at this cases inception, (in what

documents his trial counsel might want to introduce at trial, this

pro-se Plaintiff elected to give Defendants counsel everything he

had in his possession as it might reasonably relate to any of the is-

Case 4:14-cv-02050-DCB Document 95 Filed 11/30/16 Page 4 of 13

might embarrass Plaintiff or damage his cause10; (WD; 139:21-

These disclosures, set forth in 17 clearly marked categories11, en-

than a terabyte of videos12, media stories, Plaintiffs public state-

ments, rallies, associated news stories etc., all of which motivated

Tucson City Defendants to engage in acts of First Amendment Re-

taliation (FAR), etc.; (WD; 142:1-15)

ments Plaintiff needed to prove the commission of Defendants un-

Defendants Initial and Supplemental Disclosures; (WD; 140:24-

Therefore; Plaintiffs disclosures relate almost exclusively to as to

what Plaintiff said or did to inspire Defendants to retaliate13 against

Plaintiff for his political speech; in other words Plaintiffs disclo-

first place? (WD; 141:10-20; 142:1-15)

Moreover; Plaintiff informed Counsel Green his internet search for

Astonishingly; Plaintiff elected to fulfill the states disclosure obligations for

See exhibit six of Defendants MTP.

Many of these videos were created by Activist Russ Dove.

Case 4:14-cv-02050-DCB Document 95 Filed 11/30/16 Page 5 of 13

was ongoing, and that he would be happy to disclose additional doc-

uments14 as he found them because they strengthen my case. (WD;

Significantly; subsequent to the April 10, 2006 Riot in Armory Park

Assistant Chief of Police Kathleen Robinson came to Plaintiffs res-

idence and intimidated his landlady leading to Plaintiffs unlawful

eviction by Rathbun Realty, Inc. in early August 2006 and 8 years

of homelessness. (WD; 98:17-100:10)

During Plaintiffs eight years of homelessness15 he was dispossessed

of many of his possessions, including video records16 and most of

consequent to Plaintiffs 13 arrests.

Please be advised: subsequent to the filing of this document Plain-

tiff intends to file a F.R.Civ.P. Rule 11 Motion regarding Counsel

Greenes motions and assertions made in bad faith.

Further Affiant Sayeth Not

November 30. 2016