deputy x7, wcso - deposition transcript (federal) - redacted

Frank Michael Taddonio, March 13, 2014Paul Murphy v. Whatcom County

3206 Wetmore, Suite 12, Everett, WA 98201BMA Court Reporters 425-252-7277

UNITED STATES OF DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON AT SEATTLE

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PAUL MURPHY, together with his ) marital community, ) Plaintiffs, ) ) vs. ) NO. 2:13-CV-00727 ) WHATCOM COUNTY, WASHINGTON, a ) government entity; WHATCOM COUNTY ) SHERIFF'S DEPARTMENT; WILLIAM J. ) ELFO, together with his marital ) community, ) Defendants. ) ---------------------------------------------------------------

DEPOSITION UPON ORAL EXAMINATION OF FRANK MICHAEL TADDONIO

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1:15PM - 1:50PM March 13, 2014 Whatcom County Courthouse 311 Grand Avenue Bellingham, Washington 98225

Reported by Kristen M. Uhlig Certified Court Reporter, CCR, CSR Washington CCR #1934

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1 A P P E A R A N C E S

2

3 FOR THE PLAINTIFFS:Robert Butler & Emily Beschen

4 Law Offices of Robert Butler103 East Holly Street Suite 512

5 Bellingham, Washington 98225360.734.3448

6

7 FOR THE DEFENDANTS WHATCOM COUNTY & SHERIFF'S DEPARTMENT & ELFODale Kamerrer

8 Law Lyman Daniel Kamerrer Bogdanovich2674 RW Johnson Blvd SW

9 Tumwater, Washington 98512360.754.3480

10

11 FOR WHATCOM COUNTY:Elizabeth Gallery

12 Whatcom County Prosecutor's Office311 Grand Avenue

13 Bellingham, Washington 98225

14ALSO PRESENT:

15 William ElfoTara Adrian-Stavik

16

17 I N D E X

18 EXAMINATION: PAGE

19 BY MS. BESCHEN...............................................3

20 BY MR. KAMERRER.............................................18

21

22 EXHIBIT DESCRIPTION PAGE

23 No Exhibits Marked

24

25

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1 FRANK MICHAEL TADDONIO,

2 having been first duly sworn, was called as a witness herein and

3 was examined and testified as follows:

4

5 DIRECT EXAMINATION

6

7 BY MS. BESCHEN:

8 Q Okay. Can you please state and spell your full name for the

9 record?

10 A It's Frank Michael Taddonio. T-A-D-D-O-N-I-O, but I go by

11 Mike.

12 Q Okay. Mr. Taddonio, have you ever reported retaliation in the

13 workplace?

14 A Retaliation? No.

15 Q Where are you currently employed?

16 A The Whatcom County Sheriff's Office.

17 Q How long have you been with the Whatcom County Sheriff's

18 Office?

19 A Approximately 10-and-a-half years.

20 Q What's your current position?

21 A I'm in training as a K9 deputy.

22 Q Do the K9 deputies receive higher pay than other deputies?

23 A We receive a premium. We do.

24 Q What is the premium?

25 A Three percent.

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1 Q And when did you -- is the K9 deputy a special assignment?

2 A It is.

3 Q When did that special assignment start for you?

4 A I believe that it would be the beginning of November.

5 Q Of 2013?

6 A Correct.

7 Q Prior to November of 2013, did you have any special

8 assignments?

9 A I did.

10 Q What was your special assignment?

11 A I was a deputy with the criminal interdiction team.

12 Q What years did you hold that special assignment for?

13 A It was about almost four years, so I would say 2008 -- 2009 to

14 last October.

15 Q Prior to that, did you hold any special assignments?

16 A I did not.

17 Q Okay. Who did you support in the 2011 election for sheriff?

18 A Sheriff Elfo.

19 Q Did you participate in any campaign activities or fundraising

20 events or anything like that?

21 A I did not.

22 Q Okay. Have you ever reported concerns about credibility of any

23 co-workers or superiors at Whatcom County Sheriff's Office?

24 A I guess that I have problems with the verbiage. I did report

25 an incident that I took concern of with a supervisor.

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1 Q And who was that supervisor?

2 A Sergeant Mede.

3 Q What did you report about Sergeant Mede?

4 A It was spoken about a traffic stop that, on face value, was

5 questionable.

6 Q Did Sergeant Mede write a police report for the traffic stop?

7 A He did.

8 Q Did you review that police report?

9 A I eventually did.

10 Q Okay. When was that traffic stop roughly?

11 A I honestly couldn't --

12 Q Do you know the year?

13 A It's was last year, so 2012, I would like to say.

14 Q Okay. How long after the stop did you have an opportunity to

15 review Sergeant Mede's report?

16 A From the time of the stop to the point that I actually pulled

17 the report was -- maybe six to eight months.

18 Q Okay. What caused you to pull the report?

19 A It was brought up during another interview that I was having

20 with Inspector Cooley and in kind of discussing the issue that

21 I saw on face value, being -- not knowing what exactly was

22 written up and how it was written up. I was then later pulled

23 in by admin, I believe that it was Chadwick and Rossmiller. It

24 was spoken of again. And then at that point, just because I

25 didn't know all of the full details, I went and pulled the

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1 report.

2 Q When you reviewed that report, did you see anything in that

3 report that you believed to be untruthful?

4 A I had an issue with omission from that report.

5 Q What was omitted from that report that you were concerned

6 about?

7 A The basics of the report said that it was a traffic stop.

8 Whereas, I had information from prior to that traffic stop that

9 I thought was possibly prudent to the investigation.

10 Q What was that information?

11 A That he had been observing the vehicle before it departed the

12 gas station. That he had contacted me in regards to that

13 vehicle and its occupants. And I was actually on my way to

14 conduct a, kind of a social contact, consensual encounter with

15 that vehicle. And then he stopped the vehicle and per his

16 report, that's where it started.

17 Q Do you know if there was ever any internal investigation into

18 Sergeant Mede for that situation that you were just referring

19 to?

20 A I believe that it was reviewed through an administrative

21 investigation. Or as part of an administrative investigation,

22 it was looked at.

23 Q Are you aware of what the resolution of that administrative

24 investigation was or the outcome?

25 A I read the letter of resolution and I don't know that there was

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1 anything that came of it.

2 Q Okay. In the traffic stop that you were just referring to,

3 what was the name of the person that was stopped?

4 A This is the same issue that I had during the initial. I don't

5 remember her. The passenger was Mason Saunders, who I was

6 familiar with mainly through his brother, so that's how I was

7 able to pre-call it. (Phonetic)

8 Q Okay. Do you know if Mason Saunders was prosecuted?

9 A I don't believe that anyone was prosecuted through that case.

10 Q Okay. Do you know if the information that you reported about

11 that stop with Sergeant Mede was ever reported to the

12 prosecuting attorney's office?

13 A I believe that I was told that it was discussed with the

14 prosecutor's office.

15 Q Were you ever told which prosecutor specifically it was

16 discussed with?

17 A I believe that it was McEachran and that then involved Mede

18 writing a follow-up to complete the report.

19 Q Were drugs found in the car when it was stopped?

20 A I believe so, but I can't remember what. I believe that there

21 was a search warrant that was supplied.

22 Q So was that, like, a beginning stage of a case that turned into

23 a bigger case?

24 A I don't follow.

25 Q Does that make sense?

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1 A Hm...

2 Q Well, it sounds like the person was stopped and some drugs were

3 found, but they were not prosecuted to your knowledge?

4 A I believe that the vehicle was stopped. They took the vehicle

5 to get a search warrant for it, and later got the search

6 warrant. I don't know if any action was taken once the drugs

7 were found because I don't believe that it was anything

8 significant.

9 Q Okay. Did you ever have any run-ins with Mason Saunders after

10 that stop?

11 A I have not.

12 Q Do you know if Sergeant Mede did?

13 A I do not.

14 Q You mentioned that a moment ago that that was brought up in a

15 meeting for another administrative investigation. Did I get

16 that correct?

17 A No. It was brought up during an internal.

18 Q During an internal. Okay. Do you know what that internal

19 investigation involved?

20 A Oh, I do.

21 Q Okay. Can you tell me about that?

22 A It was related to a pursuit that I had -- which involved

23 myself, Deputy Freeman and Sergeant Moyes were the, I guess,

24 main participants -- which ended in a collision.

25 Q And what caused that to turn into an internal investigation?

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1 A I don't --

2 Q I mean, if there was just an accident, is that something that

3 typically results in an investigation?

4 A There was a maneuver used so it wasn't a pursuit where the

5 suspect then wrecked out. It was that a sergeant pulled in

6 front, causing the collision. So I believe that it was his

7 actions that were raised in question and which took it to an

8 internal, I believe.

9 Q Okay. Do you have any other knowledge of statements that

10 either were false statements or statements by omission that

11 Mede has made?

12 A Through what I have heard, yes.

13 Q What other statements are you aware of?

14 A There was an incident with, I believe, that it was Calvin

15 Clement. This was, I guess, the rough range of it was maybe

16 eight years ago. I don't know the specifics of it as far as

17 date. But it's of similar situation, not reported. (Phonetic)

18 Q Where it was a pretextual stop; is that correct?

19 A There was a question to be pretextual, yes.

20 Q Do you know who the prosecutor on that case was?

21 A I believe it was Mr. Hulbert.

22 Q And do you know how that -- did that result in any sort of

23 internal or administrative investigation?

24 A That, I don't know.

25 Q Okay. Any other statements that you're aware of, either made

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1 directly to you or that you've heard from others that were

2 either false statements or an omission to the degree of being

3 false made by Sergeant Mede?

4 A In my contacts with Mede, there's been one other significant

5 one in which I was spoken to by a sergeant and the lieutenant

6 in regards to essentially procedural call out, as I was able to

7 be called out through my interdiction team. I was spoken to by

8 a sergeant and lieutenant, both advised that Mede had filed a

9 -- made a complaint about that situation. And then in taking

10 that to Sergeant Mede in an attempt to discuss it, he just said

11 that it never occurred and didn't know what I was talking

12 about. So from my perspective, that was an issue.

13 Q What was it that he said never occurred?

14 A That he spoke to any lieutenant or the sergeant about the call

15 out procedure, what was done. Both had actually named him by

16 name in saying that this is what he said. So I just went to

17 him with the complaint to kind of figure out what was going on

18 and he denied saying anything or talking to anybody about it.

19 Q Okay. Do you know who Sergeant Mede supported in the election

20 for sheriff?

21 A I believe that it was Elfo.

22 Q How do you know that?

23 A I believe that there was an ad on YouTube or something to that

24 effect.

25 Q Are there any other deputies or sergeants or anybody in the

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1 Whatcom County Sheriff's Office that you're aware of that did

2 an advertisement for Sheriff Elfo during the election?

3 A I believe that Sergeant Larson was also in that same video.

4 Q Anybody else?

5 A Not that I can recall.

6 Q Has Sergeant Larson ever made any statements that you knew to

7 be false?

8 A Not that I can think of.

9 Q Do you have any question into Sergeant Larson's credibility?

10 And I can expand on that question.

11 A From -- I have fairly limited personal work experience with

12 her.

13 Q Okay.

14 A The only thing that I would be able to, again, reference that

15 to is from co-workers that would raise concern to me.

16 Q Okay. How many other co-workers have raised concern to you

17 about Sergeant Larson's credibility?

18 A Like a rough number?

19 Q Yup.

20 A More than five.

21 Q Do you know if there has ever been an internal investigation or

22 administrative investigation into Sergeant Larson's conduct?

23 A I do not know.

24 Q Okay. Do you have any knowledge about false statements made by

25 Parks?

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1 A I do not.

2 Q Okay. Do you believe Deputy Harris to be a credible deputy?

3 A I do.

4 Q What about Deputy Roff?

5 A I do.

6 Q Are there any other deputies that you have any concern as to

7 their credibility?

8 A I do not.

9 Q Prior to today, have you ever met and spoken with Liz Gallery

10 about this case?

11 A I did.

12 Q How long ago was that?

13 A Last week. I don't recall what day.

14 Q Did she provide you with any information during that meeting?

15 A That was a general discussion. I don't know if there was any

16 specifics, just because there was an unknown on why I was there

17 -- or here.

18 Q Okay. Did she ask you any questions?

19 A Yeah. We spoke for a little while and just kind of back and

20 forth to try to determine.

21 Q What were the topics that you spoke about?

22 A I think the Mede incident was the significant one. I believe

23 it was mentioned about the election information. The previous

24 internal which I was involved in. I believe the Clement

25 situation was spoken of in part with the Mede situation, just

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1 because of the correlating facts.

2 We did speak of the specifics with Murphy, you know,

3 just as far as what I knew in regards to, are there any

4 computer issues or what I had heard. That's all that's coming

5 to me right now.

6 Q Okay. With regards to the election information, what

7 specifically did you discuss about the election information?

8 A I believe that she just kind of mentioned that I could be asked

9 who I supported and where I stood there.

10 Q Okay. With regards to information about Murphy, what did you

11 tell her that you knew about Murphy?

12 A As far the particular details of the internal, I am not aware

13 of -- I realized I did read some of his stuff on his website or

14 the Whatcom Uncovered website.

15 Q Mm-hm.

16 A So some -- was difficult to discern what I had been told and

17 what I had read. But it was all pretty limited as far as, you

18 know, what I knew in regards to that.

19 Q Okay. Did you receive any training on what Brady information

20 is?

21 A It's been discussed.

22 Q In what -- where has it been discussed? Where have you heard

23 that term before?

24 A I believe that it was, you know, briefly discussed during the

25 Academy, but otherwise I think that my true learning of it was

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1 just being at the prosecutor's.

2 Q Okay. Well, from being at the prosecutor's? Is that what you

3 said?

4 A Just speaking to prosecutors. There was a couple of

5 prosecutors that I just -- just speak with.

6 Q Okay. Which prosecutors have you spoken with about Brady?

7 A I believe that's Carrie Hawthorne, who is no longer here.

8 She's down in Oregon. Jim Hulbert. (Phonetic)

9 Q What did Jim Hulbert tell you about Brady?

10 A Just in the -- I don't know that I got an explanation of what

11 the full Brady is. But just the context of once you are

12 Brady'ed, then you are labeled and that has to come out during

13 every trial and kind of hampers your ability to be in law

14 enforcement, because now you've been found to be non-credible.

15 Q All right. Was that conversation with regards to any

16 particular deputy?

17 A I believe that came up during a conversation about Kevin Mede.

18 Q Okay. Did prosecutor Hulbert say that Mede -- that there was

19 Brady information with regards to Mede?

20 A It was discussed.

21 Q Okay. Have you ever had any conversations with Elfo about

22 Brady information?

23 A I don't know that we ever spoke and referenced Brady.

24 Q Okay. How about any other -- any supervisor in the Whatcom

25 County Sheriff's Department?

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1 A I spoke to him -- and, again, this is kind of trying to piece

2 together the different conversations that I had with Chadwick

3 and Rossmiller.

4 Q Mm-hm.

5 A I believe -- I don't know if it was during the administrative

6 investigation or just thereafter, you know. We did have a sit

7 down just to kind of discuss what had kind of transpired.

8 Q Is Mede still presently working as a -- at the sheriff's

9 office?

10 A He is.

11 Q What is his current position?

12 A He's a sergeant.

13 Q Have any of his duties changed over the last couple of years

14 that you're aware of?

15 A Yes. Just in reference to that each sergeant is tasked with

16 overseeing different specialty units or -- so I know that he

17 just did several of those.

18 Q Does he still do traffic stops?

19 A I believe so.

20 Q Do you know if when he does a traffic stop and that is

21 prosecuted, if a Brady letter goes out about him?

22 A I do not know.

23 Q Have you ever spoken with McEachran about Brady information?

24 A I have not.

25 Q Okay. I think that I'm almost done, give me one more minute.

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1 Oh, do you know a person by the name of Penny who works

2 for the Whatcom County Sheriff's Department or the jail?

3 A I believe she's at the jail now.

4 Q Is that Penny Goodman?

5 A Yes. So I think that might have been one of the first

6 questions you gave to me.

7 Q Sure.

8 A Because I actually brought up an incident with her as she was

9 working in the office.

10 Q Okay.

11 A Where she had potentially relinquished information on one of my

12 investigations to a relative, and I took issue with that, and

13 brought that to the administration.

14 Q Okay. So tell me about what information she -- what type of

15 information was it that she had given up?

16 A I was investigating a fairly significant -- I think that it was

17 over a $100,000 burglary and was tracking down the expensive

18 antiques.

19 Q Mm-hm.

20 A It had gotten to the point where I had found one of the

21 suspects and I didn't know the correlation to her. And in

22 trying to track him down and get information, he out of the

23 blue, called me. I ended up finding out that I believe that it

24 was -- I don't know if they were married -- but a son-in-law to

25 her. That was the only feasible way that he would have found

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1 out that, No. 1, I was looking for him and 2, what it was

2 regarding.

3 Q Do you recall --

4 A I believe that Murphy was the one that -- I know that he ended

5 up taking over for that case. I can't remember if he actually

6 spoke to Penny in regards to that.

7 Q Okay. Do you recall whether or not you were assigned to look

8 into Penny Goodman at any point?

9 A I was not. That was about the same time that the case was then

10 delivered to detectives. I don't recall the progression from

11 there. It was just shortly thereafter that the case was handed

12 over to the detectives and they handled it all from there.

13 Q Okay. Do you recall who you reported your concerns about Penny

14 Goodman to?

15 A I don't specifically remember who I brought it to.

16 Q Was it a supervisor?

17 A I believe there was several that I spoke to about it.

18 Q Okay. Do you know what came of that investigation?

19 A I do not.

20 Q Do you know how long after that investigation Penny no longer

21 worked at the sheriff's office?

22 A I think it was --

23 MR. KAMERRER: Objection, misstates his prior

24 testimony. Go ahead. In a deposition, you can answer the

25 question.

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1 MS. BESCHEN: Yes. He may object, but you can still

2 answer.

3 THE WITNESS: I think it was about a year and then she

4 was transferred to the jail. I believe that she's -- she's

5 still within the jail facility.

6 Q (By Ms. Beschen) Okay. Does that concern you?

7 A It does.

8 Q Do you know if there are other deputies who share that concern?

9 A I don't.

10 MS. BESCHEN: All right. I have no further questions.

11 He may have some for you.

12

13 EXAMINATION OF FRANK MICHAEL TADDONIO BY MR. KAMERRER

14

15 BY MR. KAMERRER:

16 Q When did you become employed by the Whatcom County Sheriff's

17 Office?

18 A It was November of 2003.

19 Q Did you have prior law enforcement employment?

20 A I was a reserve to Blaine for, I believe, three --

21 three-and-a-half years.

22 Q When did you start working with the criminal interdiction team,

23 as a member of that?

24 A I think 2008 or 2009 -- 2009 maybe.

25 Q Does that have a term for how long you're in an assignment like

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1 that?

2 A Yeah. The initial term is three years and then you have a two

3 year renewal.

4 Q Okay. So did your term end in 2013 prior to becoming a K9

5 officer?

6 A I actually left the interdiction team to become a K9 deputy.

7 Q Is the K9 position something that you applied for?

8 A It is.

9 Q Have you spoken to an investigator for Bob Butler or Ms.

10 Beschen here, or either of them before this deposition?

11 A I have not.

12 Q Have you talked to Paul Murphy since he was terminated?

13 A I have not.

14 Q With respect to the $100,000 burglary that you were

15 investigating, what steps had you taken to obtain a warrant for

16 the arrest of the suspect who subsequently contacted you?

17 A It hadn't been to that point. The breakdown for the

18 investigation was that it was a fairly significant group of

19 drug addicts and burglaries, so it was getting pieced out.

20 He came -- I'm sorry, I can't remember his name -- but

21 he popped up because he went and pawned and attempted to sell

22 at an antique store, so they had contacted me. So the next

23 step for me was to attempt to track him down.

24 So I don't -- other than the probable cause for other

25 possession, I did not do any steps to get a warrant yet. My

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1 next step would have been to attempt to locate and speak with

2 him. Just knowing that he didn't end up -- I didn't believe

3 him to be one of the main actors in the burglary, just somebody

4 who would have received the stolen property.

5 Q Okay. Did he end up being charged with any criminal offenses

6 related to that burglary?

7 A Unfortunately not.

8 Q When he contacted you, did he tell you information that

9 indicated that he was involved in the criminal activity?

10 A Sorry, I'm just trying to think. It was a long time ago. No.

11 The conversation, I believe, was just kind of the plead of

12 ignorance. He had two large totes of, you know, antique items

13 that I think that they estimated were over $20,000 or $25,000.

14 I believe that he made a claim that it was in trade for

15 some auto repair work. So to me, him having knowledge of

16 antiques, just as you said, that's what he did in his off time.

17 To me, that was the glaring moment of, you know, he knew what

18 he was getting and he knew that it was stolen.

19 Q So was it the fact that there was a large quantity of antiques

20 in these two totes that suggested that he knew that it was

21 stolen?

22 A The quantity and the -- more so the value. Just in speaking

23 with him, he spoke of antiques. I believe that he actually

24 referenced that he had a -- some sort of kind of guide for the

25 collectibles, so he would have -- should have known the value

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1 that he had as opposed to...

2 And then he also lied about the fact that I believe that

3 he said that he hadn't opened them. One of the big parts was

4 that when I went through each one, I was able to see that each

5 one was wrapped in newspaper that was very recently dated as

6 opposed to when he said that he got them.

7 Q Okay. Did you ever talk to Penny about your suspicions

8 regarding that person contacting you?

9 A Not in regards to my suspicions. I believe that the only

10 conversation that I had with her just was how she got the

11 information, maybe she even told me to call him. I can't

12 remember, but I think initially, I didn't take anything from it

13 just because she was the receptionist and got the phone calls.

14 So, again, that's a little foggy for me on that one. I

15 never went to her with any accusations or questions. At that

16 point, it was -- I was told to pass it onto the detectives who

17 then kind of ran with it from there and looked at all of the

18 aspects.

19 Q How would Penny have known you had developed this individual as

20 a suspect related to that burglary?

21 A Through our reports. Again, this is eight or nine years ago.

22 I don't know when we had our -- we have daily summaries in

23 which you put out information, which much of our support staff

24 gets and reads.

25 But at the same time, there was also calls coming into

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1 our office from the antique store who were then providing

2 information to our office. I don't know the channels that they

3 went through, so that was a viable option that they called. It

4 might have informed her of what they needed and what they

5 needed to report.

6 Q Is it safe to say that you don't know how Penny could have

7 known that this person that you had developed as a suspect had

8 some connection to that burglary?

9 A Yeah. It's unclear to me exactly how she knew what was going

10 on.

11 MR. KAMERRER: I think that that's all of the

12 questions that I have. Thanks.

13 MS. BESCHEN: Okay. We can go off the record.

14 (Signature Reserved)

15 (Deposition Adjourned)

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1 C E R T I F I C A T E

2

3 STATE OF WASHINGTON ) ) ss.

4 COUNTY OF ISLAND )

5 I, Kristen M. Uhlig, the undersigned CCR in and for the Stateof Washington, do hereby certify:

6 That the annexed and foregoing deposition of the witness

7 named herein was taken stenographically before me and transcribedby me;

8 I further certify that the witness examined, read, and signed

9 the deposition after the same was transcribed, unless indicated inthe record that the parties and the witness waive the signature;

10 I further certify that all of the objections made at the time

11 of said examination to my qualifications or the manner of takingthe deposition, or to the conduct of any party, have been noted by

12 me upon said deposition;

13 I further certify that I am not a relative or employee orattorney or counsel of any of the parties to said action or

14 counsel, and that I am not financially interested in the saidaction or the outcome thereof;

15 I further certify that the deposition, as transcribed, is a

16 full, true, and accurate transcript of the testimony, including allquestions and answers, and all objections, motions and exceptions

17 of counsel made and taken at the time of the foregoing examination;

18 I further certify that I am sealing the deposition in anenvelope with the title to the above cause thereon and marked

19 "Deposition Upon Oral Examination" of said witness and promptlycausing the same to be delivered or forwarded to Counsel for the

20 Opposing Party;

21 IN WITNESS THEREOF, I have hereunto set my hand and affixedmy official seal this ___ day of____________, 2014.

22

23 __________________________

24 Kristen M. Uhlig, #1934 Certified Court Reporter,

25 Residing in Clinton, Washington.

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deputy x7, wcso - deposition transcript (federal) - redacted

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