Request Judicial NoticeCal. Super. - 6th Dist.March 27, 2020O(DWNOUU'l-hWN-A NNNNNNNNNAAAAAAAAAA memAWN-‘OOWVQU'IAWN-A RICHARD DOYLE, City Attorney (88625) NORA FRIMANN, Assistant City Attorney (93249) l L EJULIA VAN ROO, Deputy City Attorney (274169) DOffice of the City Attorney 200 East Santa Clara Street, 16‘“ Floor MAR 2 7 2020 San José, California 951 13-1905 Telephone Number: (408) 535-1900 .C' 0f he Court Facsimile Number: (408) 998-3131 Bvsupm' C tyotSama cum E-Mail Address: cao.main@sanjoseca.gov DEPUTY Attorneys for CITY OF SAN JOSE K. NGUYEN SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA CITY OF SAN JOSE, .Case Number. 20 CH 00 9257 Petitioner, REQUEST FOR JUDICIAL NOTICE IN V SUPPORT 0F PETITION FOR - WORKPLACE VIOLENCE KAREN VORSTER aka JORDAN RESTRA'N'NG ORDER ASHLEY DREYER, Respondent. REQUEST FOR JUDICIAL NOTICE Petitioner City of San José (“City") respectfully requests that this Court take judicial notice of the following documents pursuant to Evidence Code sections 452(d) and Rules of Court, Rule 3.1306: 1. \AN-1 30 Workplace Violence Restraining Order After Hearing in the matter 0f City of San Jose v. Jordan Ashley Dreyer aka Karen Vorster, Santa Clara County Superior Court Case No. 1-07-CH000949, filed March 15, 2016, attached hereto as Exhibit A. 2. WV-1OO Petition for Workplace Violence Restraining Orders in the matter of City of San Jose v. Jordan Ashley Dreyer aka Karen Vorster, Santa Clara County Superior Court Case No. 1-07-CH000949, filed November 20, 2015, attached hereto as Exhibit B. 1 REQUEST FOR JUDICIAL NOTICE ISO PETITION FOR WORKPLACE VIOLENCE RESTRAINING ORDER 1701375 (DmVOVUI-boomg NNNNNNNNNAAAAAAAAAA membWN-KoomflmmbWN-‘O 3. Request for Judicial Notice in Support of Petition of Employer for Order Prohibiting Violence or Threats of Violence in the matter of City of San Jose v. Jordan Ashley Dreyer aka Karen Vorster, Santa Clara County Superior Court Case No. 1-O7-CH000949, filed November 20, 2015, attached hereto as Exhibit C. ARGUMENT This request is made pursuant to Evidence Code section 452(d). It is settled that a court may take judicial notice of its own records not only in the action pending before it (e.g. Verreos v. City and County of San Francisco (1976) 63 Cal.App.3d 86, 107) but also in other proceedings (Flores v. Arroyo (1961) 56 Cal.2d 492, 496 (disapproving prior cases to the contrary». This includes the power to take judicial notice of records in related actions. (E.g., Morson v. Superior Courf (2001) 90 Cal.App.4th 775, 778 (taking judicial notice of dispositional records in related cases though decisions on appeal); City of Merced v. American Motorists Ins. Co. (2005) 126 Cal.App.4th 1316, 1321 fn 2 (taking judicial notice of complaints filed in related cases).) The City requests the Court to take judicial notice of these documents filed in a previous restraining order matter involving Respondent and City employees, so that they are properly before the Court Then, pursuant to Code of Civil Procedure section 527.8, the Court may consider these documents and the factual matters contained therein as evidence submitted by the City in support 0f its position. Code of Civil Procedure section 527.8 contemplates a truncated proceeding in which the Court may consider declarations submitted by either side and consider the hearsay therein. (See, e.g., Kaiser Foundation Hospitals v. Wilson (2011) 201 Cal.App.4th 550, 557 (“Hearsay evidence clearly may be relevant, and if hearsay evidence is relevant, section 527.8 requires that the court receive it.”).) // // // // 2 REQUEST FOR JUDICIAL NOTICE ISO PETITION FOR WORKPLACE VIOLENCE RESTRAINING ORDER 1701375 O(Dm‘JOUUWAOON-t NNNNNNNNN-xgggdggggg mVOmAWNAOOmflmm-wa-K CONCLUSION These documents are judicially noticeable under Evidence Code sections 452(d)). Once before the Court, the Court may then consider the factual matters contained within in the under Code of Civil Procedure section 527.8 Respectfully submitted, Dated:W 2éfflojo RICHARD DOYLE, City Attorney Deputy City Attorney Attorneys for CITY OF SAN JOSE 3 REQUEST FOR JUDICIAL NOTICE ISO PETlTlON FOR WORKPLACE VIOLENCE RESTRAINING ORDER 1701 375 EXHIBIT A (. - I ‘ Workplace Violence RestrainingWV-130 Ordér After Hearing ' G) Judidal Coundl of California, www.mudsmgov Revised January 1, 2015, Mmdalory Form ' Code a1 CM! Procedwe, §§ 527.8 and $7.9 Petitioner (Employer) a. Name: CITY OF SAN JOSE Lawyer for Petitioner (ifany, for this case): Name: Shannon Smyth-Mendoza State Bar No.1188509 Finn Name: City Attorhey of San Jose Your Address (Ifyou have a lawyer, give yaw lawyer’s information): Address:200 E. Santa Clara Street, 16th Floor City: San Jose State: CA Zip: 951 13 Telephone: 408-535-1900 ‘ Fax: 408-99843131 E-Mail Addrws: cao.main@sanioseca.qov Employee (Protected Person) FullName: JASON TANNER Respondent (Restrained Person) Full Name: KAREN JORDAN VORSTER Description: Clerk stamps date here when form is filed. Fill in court name and street address: Santa Clara Superior Court 1.91 N. First Street San Jose, CA_ 951 13 Superior Court of California, County of Couri fills in case number when form is filed. Case Num ber: 107CH00949 51°07‘l-QfioDGJL}? Sex: E M -‘F Height: 5'4" Weight: 140 Date OfBirth'. 7/1 2/60 Hair Color: Blond Bye Color: Green Age:55 Race: Caucasian Home Address (zflmown): 11 11 Morse AveLApt. 34 City: Sunnvvale Relafionship to Employee: None State: CA Zip: 94089 E Additional Protected Persons . In addition t0 the employee, the following family 0r househdld members 0r other students are protected by the temporary orders indicated below: Full Name fi Age Household Mexfiber? Relation to Employee Richard Dovle M 60 DYes No Other empiovee ‘ :1 YesE No EYes [-l N0 E Additional protected persons arellisted at the end ofthis Order on Attachment 4. Expiration Date 3 ‘ l S " / '7 This Order, exceptfor any award ofltm’yer’sfees, expires at: Date: 3*LS"‘[ 9 This is a Court Order. After Hearing (CLETS-WHO) AppavedbyDOJ (Workplace Violence Prevention) Workplace Violence Restraining Order Time: lag: 6D i‘ m am. E p.111. I If no expiration date is written here, this Order expires three years from the date 0f issuance. a1 Sofiong Eé‘ Plus WV-13o, page 1 of s "é Case Number: 7 ”107CH009‘19V ® Hearing r, a. There was a hearing on (date). 3/1 5/16 at (time): 9:00 am in Dept: b Room: (Name 0f udicial oflicer). a1 O verton made the orders at the hearing. b. These p ople were at the hearing: . (1) The petitioner/employer representative (name): E.) H )Wg/ gwaréD VL (2) The lawyer for the petitioner/employer (name): Shannon vath~Mendoza (3) The emploYee (4) The lawyer for the employee (name):Shannon Smyth-Mendoza (5) E The reSpondent (6) [:I The lawyer for the respondent (name): D Additiohal persons present are listed at the end of this Order on Attachment 5. c. E The hearing is continued. The parties must return to court on (date): at (time):- To the Respondent: The courtrhas granted the orders checked below. If you do not obey these orders, you can be arrested ahd charged with a crime. You may be sent to jail for up to one year, pay a fine of up to $1,000, or both. Personal Conduct Orders a. You are ordered not do the following things to the employee-and to the other protected persons listed in®. (])X- Harass, mblest, stnke, assault (sexually or otherwise) batter, abuse, destroy personal property of, or disturb the peace of the person. (2) IE Commit acts of violence or make threais of violence against the person. (3) Follow or stalk the person dun'ng work houxs or while going to or from file place of work. (4) Contact the person, either directly or indirectly, in any way, including, but not limited to, in person, by . telephone, in writing, by public or private mail, by interoffice mail, by e-mail, by text message, by fax, 0r by other electronic means. 4 (5)X-.Entér the person’ s workplace (6)X-Take any action to obtain the person’s address or locations. Ifthis item is not checked, the court has found good cause not to make this Order \ ‘ (7)E Other (specifiz)- Other personal conduct orders are attached at the end of th1s Order on Attachment 7a(7). Respondent will not contact emplovees at the locations listed m the stav away orders below via phone. e-mail. fax. or bv anv other written means _ \‘f‘cu'd ' 1,3, cod 1 M‘r 0J- L //§¥~é [fl #LL Q/H‘KCLKA Addt*dv- 40 54117 Q wo-v 01mm“ 040’ Tim ear veJPtA elm; ”o7 Go yaw! flew ” Mvr“, o. 1L9 g I1¢cclxed Acwévfo. 0 b. Peaceful written contact through a lawyer or a process server or other person f01 service _0f legal papers related t0 a court case is allowed and does not violate this 01 der. This is a Court Order. Rewsedlanmtzms - ' Workplace Violence Restraining Order wv-130, Page2 ofs After Hea ring (CLETS-WHO) ‘ “-3 (Workplace Violence Prevention) ‘ ,Case Numbfir: 1 O7CH00949 Stay-Away Order a. You must stay at least 300 yards away from (Check a1] thaf apply): (l) The employee (7) E The employee’s chilaren’s place ofchild care (2) Each other protected person listed in® (8)E The employee’s vehicle (3) The employee’s workplace (9) Other (speczfil): Respondent must stay 300 (4) The employee»s home vards awav from the locations (34) listed in (5)E The employee,s school the Addendum to the Court's Stav Awav_Orders (paraqraph 7 of this O h dab (6)D The employee’s children’s school {1/3/ ' b. This stay-away order does not prevent you from going to or fiom your home or place ofemployment. @ No Guné or Other Firearms and Ammunition a. You cannot own, possess, have, buy or try t0 buy, receive 0r try to receive, or in’finy other way get guns, other firearms, or ammunition. ‘ b. Ifyou have not already done so, you must: (1) Sell to 0r store with a licensed gun dealer or tum in to a law enforcement agency any guns or other firearms in your immediate possession or control. This must be done within 24 hours 0f being served With this Older. (2) File a receipt with the court Within 48 hours of receiving this Order that proves that your guns have been turned in, sold, or stored. (You may use Form WV-800, ProofofFirearms Turned In, Sold, or Storedfor the receipt.) c. i: The court has received information that you own 01' possess a firearm. E] Costs t You must pay the followmg amounts for costs to the petitioner: Egg Amount I_te_1_n_ Amount $ $ $ $ $ ' * $ Q Additional amounts are attached at the; end owns Order on Attachment 10. ® E Other Orders (specifil): E Additional orders are attached at the end 0f this Order 011 Atiachment 11. This is a Court Order. mema'y‘flms Workplace Violence Restraining Order wv-130, Pageaors After Hearing (CLETS-WHO) ' % (Workplace Violence Prevention) Case Number: 107CH00949 TothePersonino: @ Mandatory Entry of Order Into CARPOS Through CLETS This Order must be entered into the California Restraining and Protective Order System (CARPOS) through the ‘ California Law Enforcement Telecommunications System (CLE ..[‘S) (Check one). a. [:3 The clerk will enter this Order and its proof-0f~service form into CARPOS. b. [E] The clerk will transmit this Order and its proof-of-service form t0 a law enforcement agency to be entered into CARPOS. c. D By the close of business on the date that this Order ls made, the petitioner or the petitioner’s lawyer should deliver a copy 0fthe Order and its proof-of-service fonn t0 the law enforcement agency listed below to enter into CARPOS: 1 I Name 0fLaw Enforcement) Agendy Address (Cigy, State, Zigz E Additional law enforcement agencies are listed at the end of this Order on Attachment 12. ® Seyé of Order on Respondent a. The respondent personally attended the hearing. N0 other proof0f service is needed b.E The respondent did not attend the hearing. (1) I: Proof of service 0fForm WV-l 10, Temporary Restraining Ordefi .was presented t0 the court. The judge’s orders in this form are the same as in Fonn WV-110 except for the expiration date. The respondent must be served with this Order Service may be by mail. (2) 1:: The judge’s orders 1n this form are different from the temporary restraming orders 1n Foml WV- 110. Someone-but not the petitioner 0r anyone protected by this order-must personally serve a copy of this Order on the respondent. No Fee to Serve (Notify) Restrainéd Person ‘ The sheriff or marshal will serve this Order without charge because the Order Is based on unlawful viol_ence a credible threat of violence, or stalking @ Number ofpages attached t0 this Order, if any: 1 Datesz/S-M,‘ i'} Q R Judicial Oficer Carol Ovemon V This is a Court Order. meJWtM Workplace Violence Restraining Order WV-130,Page4 °f5 After Hearing (CLETs-WHO) -> (Workplace Violence Prevention) (I ‘ (W Case Number: i 1070H00949 You Cannot Have Guns or Firearms You cannot own, have, possess, b_uy or 11y to buy, receive or try t0 receive, or otherwise get guns, other firearms, or ammunition while this Order is in effect. Ifyou d0, you can g0 t0 jail and pay a $1,000 fine. You must sell to 0r store with a_ licensed gun dealer or tum in to a law enforcement agency any guns 01' other firearms that you have or conto] as stated in item@ . The coult will require you to prove that you did so. Instructions for Law Enforcement Enforcing the Restraining Order This Order is enforceable by any law enforcement agency that has received the Order, is shown a copy 0f the Order, 0r has verified its existence on the California Restraining-and Protective Order System (CARPOS). Ifthe law enforcement agency has not received proof 0f service on the restrained person, and the restrained person was not present at the court hearing, the agency must advise the restrained person of the terms 0f the Order and then must enforce it. Violations of this Order are subj ect to criminal penalties. Start Date and End Date of Orders I This Order starts on the date next to the judge’s signature on page 4 and ends on the expiration date in item® on page l. Arrest Required If Order ls Violated If an officer has probable cause to believe that the restrained person had notice of this order and has disobeyed it, the officer must arrest the restrained person. (Pen. Code, §§ 83 6(c)(1), 13701(b).) A violation of the order may be a violation of Penal Code section 166 0r 273.6. Agencies are encouraged to enter violation messages into CARPOS. NoticelProof of Service The Iaw enforcement agency must first determine if the restrained person had notice of the orders. Consider the restrained person served (given notice) if (Pen. Code § 836(c)(2)): . The ofiicer sew a copy 0fthe ProofofService or confirms that the ProofofService is on file; or . The remained person was at the restraining order hearing or was informed of the order by an officer. An officer can obtain infomation about the contents of the order and proof 0f service in CARPOS. prroof of service on the wmained pelson cannot be verified and the remained person was not present at the court hearing, the agency must advise the restrained person 0f the terms 0f the order and then enforce it. If the Protected Person Contacts the Restrained Person . Even ifthe protected person invites or consents to contact with the restrained person, this Order remains in eflect and must be enforced. The protected person cannot be arrested for inviting or consenting t0 contact with the restrained person. = The orders can be changed only by another court order. (Pen; Code, § 13710(b).) This is a Court Order. Rafisedmvtzms Workplace Violence Restraining Order wv-130, Pagesore After Hearing (CLETS-WHO) 9 (Workplace Violence Prevention) Case Number: 107CH00949 Conflicting Orders-Priorities for Enforcement If more than one restraining order has been issued, the orders must be enforced according to the following priorities: (See Pen. Code, § 136.2, Fam. Code, §§ 6383(h)(2), 6405(b).) 1. EPO: If one of the ordels is an Emergency Protective Order (form EPO-OOI) and is more restrictive than other restraining or protective orders, it has precedence in enforcement over all other orders. 2. N0 Contact Order: If there is no EPO, a no-contact order that is included ifi a restraining or protective order has precedenCc over any other restraining or protective order. 3. Criminal Order: If none of the orders includes a n0 contact order, a domestic violence protective order issued in a criminal case takes precedence in enforcement bver any conflicting civil court order; Any nonconflicting terms of the civil restraining order remain in effect and enforceable. 4. Family, Juvenile, 0r Civil Order: If more than one family, juvenile, or other civil restraining or protective order has been issued, the one that was issued last must be enfomed. Clerk’s Certificate ‘ (Clerk willfill out this part.) THE F%kéggllllG INSTRUMENT IS A CORRECT cgEYTg'FGTngngEmNAL 0N FILE ‘ I ‘ " ' “'5‘” . . . . u “TEST: DAV") H‘ YAMASAK' I -' " v rkplace Vzolence Restrammg Order After Hearing ls a true MAR 15 zms ‘ Clerk, by 3 Deputy This is a Court Order. ' mewa'ymm" ‘ Workplace Violence Restraining Order » WV-130. Page 6 0f6 After Hearing (CLETS-WHO) ~ (Workplace Violence Prevention) ’ Pefifiofi fbrVWorkpri'ace Violence Réétraihihg Orderé, Addendum to Stay Awav Orders: Karen Vorster aka Jordan Ashley Dreyer must stay 300 yards away from the folfowing womplaces: (a) San Jose Police Department’s Main Station located at 201 West Mission Street in San Jose; '(b) San Jose Police Department’s South Substétion located at 6087 Great Oaks Parkway in San Jose; (c) San Jose City Hall located at 200 East Santa Clara Street in San Jose; (d) Airport Division Station located at 1387 Airport Boulevard in San Jose; (e) Family Violence Center, Reserve Unit, Community Services Unit, School Liaison Unit, School Safety Unit, and Po!ice VolunteerProgram located at 1671 The Alameda in San Jose; (f) PAL located at 680 South 34th Street in San Jose; (g) Community Policing Services Centers located at 1060 Taylor Street in San Jose, 947 Blossom Hill Road in San Jose, and 3707 Williams Road in San Jose; (h) Curfew Center located at 2175 Curtner Avenue in San Jose; (i) Evidence Warehouse at 1588-B Monterey Road, San Jose; (j) Personnel Unit located at 1661 Senter Road in San Jose; (k) Horse Mounted Unit located at 2525 Kenoga Drive in San Jose; and (l) Internal Affairs Unit, 777 N. 15' Street, Suite 666, San Jose, CA 95113 Tk-L § aegl'Vfilhflrgf WV, wykbks }5&+oé ‘LAGJL Q/‘4L CL/Co (S’Low-x in +1“ 44(quch 300 )(Cmdx 59-9243» Map ; Q/Q) 1265000.doc 1 r-.:q Community PEWMSEMM Cenler .' 1owTayuxsi . .usr ' .. “g * San Jose'CRy Ffall “2&6 Santa CIar'aSt «.nm‘u a ‘. QE 17s cu'mémve San Jasiriance Delot- sump 6087 GlealOaks Pkwy ci'mud _n 3‘1P Yul ‘63-? r cam, Fm EXHIBIT B ,.;.,v:i‘--' ' Petition for workplace ViOlence Clerk stamps date here when form is filed. Restraining Orders [3,; L} Read How D0 I Get an Order to Prohibit Workplace Violence (Form WV-JOO-INFO) before completing this foun. NOTE: Petitioner must be an employer with standing t0 bring this action under Code 0f Civil Procedure section 527.8. Also fill out Confidential CLETS Information (Form CLETS-OOI) with as much information as you know. ( : ) 'Péfi‘t'ibher (Enipibye'r) a. Name: CITY OF SAN JOSE isa :1 corporation D sole proprietorship Fill in court name and street address: (SPeCWZ)-‘munj-Cipal corporation Superior Court of California, County of and is filing this suit on behalf of the employee identified in item® . giggiigiaégurt 191 N. First Street b. Lawyer for Petitibner ([farzyfor this case): Name: Nkia D. Richardson State Bar N03- ____.193299 San Jose, CA 95113 FinnName-:Office of the City Attornev Coun‘ fills in case number when form is filed. Petitioner’s Address (fithe petitioner has a lawyer, give the lawyer ’s Case Num ber: information): . 2 l O '9 c. Address: 200 E. Santa Clara Street '07 9V City: San Jose State:CA Zipz95113 Telephone: (508)535-1900 Fax: (408) 998-3131 E-Mail Address: cao .main@san"; oseca . qov ® Employee in Need of Protection Full Name: Detective Jason Tanner Sex EM C F Age: 43 ® Respondent (Person From Whom Protection Is Sought) Full Name: KAREN JORDAN VORSTER AKA JORDAN ASHLEY DREYER Age: 5 5 Address (ifknown): 1 11 1 Morse Avenue ‘ City: Sunnyvale V State: CA Zip: 9 4 O 8 9 ® Additional Protected Persons a. Are you asking for protection for any family or household members of the employee or for any other employees at the employee’s workplace or at other workplaces of the petitioner? Yes E No (lfyes, list them): FullName S_e_§ AJQ Household Member? Relationship to Emplovee Richard Doyle M 60 DYes E No Other Employee D Yes E No E Yes E No E] Additional protected persons are listed in Attachm ent 4a. This is not a Court Order. JudaiaJCmmudCalm . n. . v ' ' ‘ ' ' xRmmmn 2mmmgmggg ”69° Petition for Workplace Violence Restraining Orders wv.1oo,page 1 o. s Code crown Procedure, §§ 527‘s and 527.9 (Workplace Violence Prevention) soffial -)u '$s (1 [Case Number: 10764000 91/9 b. Why do these people need protection? (Explain):E Response is stated in Attachment 4b. See Declarations of Richard Dovle, Steven Swanson, Jason Tanner,Marco Mercado, Nkia Richardson & Request for Judicial Notice filed concurrently Relationship of Employee and Respondent_ a. How does the employee know the respondent? (Describe): E Response is stated in Attachment Sa. See Declarations of Richard DoyleL Steven Swenson, Jason Tanner, Marco Mercado, Nkia Richardson & Request for Judicial Notice filed concurrently b. RespondentD is is not a current employee ofpefitioner. (Explain any decision t0 retain, terminate, 0r otherwise discipline the respondent): I Response- is stated in Attachment 5b. Venue Why are you filing in this county? (Check all that apply): a. CZ] The respondent lives in this county. b.E The respondent has caused physical or emotional injury to the petitioner’s employee in this county. c.E Other (specifi): Other Court Cases a. Has the employee or any of the persons named in@ been involved in andther court case with the respondent?E No E Yes Ifyes, check each kind afcase and indicate where and when each wasfiled:W Filed in (Countv/Staz‘e) Year Filed Case Number {ifknown} (1) Ea Workplace Violence Santa Clara/CA 2006 107CH000949 (2) E CiviIHarassment (3) C] Domestic Violence (4) D Divorce, Nuuity, Legal Separation (5) a Paternity, Parentage, Child Support (6) E Eviction (7) D Guardianship (8) a Smanclaims I (9) E Postsecondary SchooIViolence (1mm Criminal (IUD Other (specifi): b. Are there now any restraining orders or criminal protective orders in effect relating to the employee or any of the persons in® and the respondent? No E Yes (Ifyes, attach a copy ifyou have one.) This is not a Court Order. RevWJW-ZD“ Petition for Workplace Violence Restraining Orders WV-100. Pagez of6 (Workplace Violence Prevention) 9 [Caseo Number. :07 GHQOOQ‘M Description of Respondent's Conduct a. Respondent has (check one or more): (1) E Assaulted, battered, or stalked the employee (2) Made a credible threat 0f violence against the employee by making knowing or willful statements or engaging in a‘course' of conduct that would place a reasonable person in fear for his or her safety or the safety 0f his or her immediate family. b. One or more ofthese acts (check either or both)- ( 1)- Took place at the employee s workplace (2)- Can reasonably be construed to be carried out in the future at the employee’ s workplace Address 0f workplace:201 W. Mission Street San Jose, CA c. Describe what happened. (Provide details; include the dates ofall incidents beginning with the most recent; tell who did what t0 whom; idenrifi/ any witnesses):D Response is stated in Attachment 8c. See Declarations of Richard Doyle, Steven Swanson, Jason Tanner, Marco Mercado, Nkia Richardson & Request for Judicial Notice filed concurrentlv d. Was the employee harmed or inj ured? E Yes No (Ifyes, describe harm 0r injuries):D Response is stated in Attachment 8d. - e. Did the respondent use or threaten to use a gun or any other weapon? Yes E No (Ifyes, describe):D Response is stated in Attachment 8e. See Declarations of Richard Doyle, Steven Swensonl Jason Tanner, Marco Mercado, Nkia Richardson & Reauest for Judicial Notice filed concurrentlv This is not a Court Order. RWMW-ZW Petition for Workplace Violence Restraining Orders WV-100: P3983!“ Case Number: JWCHOOOQVQ f. For any of the incidents described above, did the police come? Yes D N0 D I don’t know Ifyes, did the employee or ihe respondent receive an Emergency Protective Order? DYes E No D Idon’t know [fyess The order protects (check all that apply): (1)E The employee: (2) E The respondent. c. E One or more ofthe persons-in® Attach a copy ofthe order ifyou have one. 'Check the orders you want M ® Personal Conduct Orders I ask the court to order the respondent not to do any of the following things to the employee 0r to any person t0 be protected listed in® : a. b. c. d. S“ Th Harass, intimidate, molest, attack, strike, stalk, threaten, assault (sexually or otherwise), hit, abuse, destroy personal property of, or disturb the peace of the person. Commit acts of unlawful violence on or make threats 0f violence to the person. Follow or stalk the person during work hours or t0 or from the place 0f work. Contact the person, either directly 0r indirectly, by any means, including, but not limited to: in person, by telephone, in writing, by public or private mail, by interoffice mail, by e-mail, by text message, by fax, or by ‘ other elecfionic means. I ' Enter the person’s workplace. D Other (specgfl): x i As stated in Attachment 9i Respondent will not contact emploVees at the locations listed in the stay awav orders, below, Via Dhone, email, facsimile ‘or bv any other written means The respondent will be ordered not to take any action to get the addresses 0r locations afanyprotectedperson unless the courtfinds good cause not t0 make the order. ® Stay-Away Order a I ask the court to order the respondent to stay at least 3 0 O yards away from (check all that apply): (1) The employee (8) EB The employee’s vehicle' . (2) The other persons listedin® (9)E Other (specifi): Respondent must lstay (3) The employee’s workplace 300 ards awa from all locations 4 - Th I , h (a-i) listed in Addendum to stav() eemp Oyees ome away orders in Daraqraph 1.0 of this (5) E The employee’s school ' petition. (6) E The school of the employee’s children (7) E The place ofchild care of the employee’s children This is not a Court Order. Rwi‘amflvm“ Petition for Workplace Violence Restraining Orders WV-TOO. Page4°f6 (Workplace Violence Prevention) "'9 .5 Case Number: £07 6490099 _ b. Ifthe comt orders the respondent to stay away from all the places listed above, will he or she still be able to get t0 hjs or her home, school, 0r job? Yes D N0 (Ifno, explain):E Response is stated on Attachment 10b. ® Guns or Other Firearms and Ammunition - . Does the respondent own or possess any guns or other flreanns? E Yes D N0 [ x . I don’t know Ifthejudge grants aprotective Order, the respondent will be prahibitedfrom owning possessing, purchasing > receiving, or attempting to purchase or receive a gun, otherfirearm, and ammunition while the protective order is in eflect. The respondent will also be ordered to turn in t0 law enforcement, or sell t0 0r store with a Iicensedgun dealer, any guns orfirearms within his or her immediate possession or control. ® Request for Immediate Orders Without Notice Do you want the court to make any of these orders now that will last unfil the hearing without notice to file ' respondent? Yes E] No (nyou answeredyes, explain why: » [:l ReSponse is stated on Attachment 12. See Declarations of Jason Tanner, Steven Swenson, Richard Doyle. Marco Mercado, Nkia.Richardson and Request for Judicial Notice filed concurrentlv ® [j Request for Less Than Five Days' Notice You must have yourpaperspersonally served 0n the respondent at leastfive days before the hearing, unless the court orders a shorter timefor service. Worm WV-200-INFO explains what isproofofpersonal service. Form WV-200, Proof of Personal Service, may be used to show the court that the papers have been served) Ifyou want there to be fewer than five days between service and the hearing, explain why: D Response is stated in Atta'chment l3. E3 No Fee for Fiiing I ask that there be no filing fee because the respondent has threatened violence against the employee, onstalked the employee, or acted or spoken in a manner that has placed the employee in reasonable fear ofviolence. ' ‘ .. . ,JZLfiTénv’ This is not a Court Order. Rev‘vedeH-ZW Petition for Workplace Vioience Restraining Orders WV-100, Page 5 of6 ‘ ' (Workplace Violence Prevention) V a Case Number: IOVU-feoogvg @ [:1 No Fee to Serve Orders I ask the court to order the shedfi or marshal to serve the respondent with the others for flee because this request for orders is based on a credible threat of Violence or stalking. D Court Costs I ask the court to order the respondent to pay my court costs. E Additional Orders Requested I ask the court to make the following additional orders (specifiz): E Additional orders requested are stated in Attachment 17. Number of pages attached to this form, if any: k .x Date: November 20, 2015 \ 2 / 9/'2 .\. ' I ' Nkia D. Richardson > / L/ / B %/‘ Lawyer ’s name (ifany) Lawye'r’s signature I declare under penalty ofpexjury under the laws of the State 0f California that the information above and on all attachments is true and correct. ‘ ' a Date: November 20, 2015 CITY OF SAN JOSE Name ofpetitioner Nkia D. Richardson, Sr. 'Deputv City Attv Title This is not a Court Order. Rewmmm‘ Petition for Workplace Vioience Restraining Orders wv-1oo, Pages ors (Workplace Violence Prevention) Petition for Workplace Violence Restraininq Orders. Addendum to Stay Away Orders: Karen Vorster aka Jordan Ashley Dreyer must stay 300 yards away from the following workplaces: ~ (a) San Jose Police Department’s Main Station located at 201 West Mission Street in San Jose; ‘ (b). San Jose Police Department’s South Substation located at 6087 Great Oaks Parkway in San Jose; (c) San Jose City Hall located at 200 East Santa Clara Streef in San Jose; (d) Airport Division Station located at 1387 Airport Boulevard in San Jose; (e) Family Violence Center, Reserve Unit, Community Services Unit, School Liaison Unit, School Safety Unit, ‘and Police Volunteer Program located at 1671 The Alameda in San Jose; (f) PAL located at 680 South 34th Street in San Jose; (g) Community Policing Services Centersjocated at 1060 Tayior Street in San ’ Jose, 947 Blossom Hill Road in San Jose, and 3707 Williams Road in San Jose; (h) Curfew Center located at 2175 Curtner Avenue in San Jose; U) Evidence Warehouse and Personnel Unit located at 1661 Senter Road in San Jose;and (j) Horse Mounted Unit located at 2525 Kenoga Drive in San Jose (i) Internal Affairs Unit, 777 N. 1“ Street, Suite 666, San Jose, CA 951 13 1265000.doc 1 (OWNODU'IAQJNA NNNNNNNNNAAAAAAAAAA mummAwNAOOmemwa-ko : a r ., I 2 RICHARD DOYLE, City Attorney (88625) ' "" ‘W’ NORA FRIMANN, Assistant City Attorney (93249) 7m 7mg an fiNKlA D. RICHARDSON, Sr. Deputy City Attorney (19'? 09y ‘2‘: ' 3; 58 Office of the City Attorney '3 200 East Santa Clara Street, 16th Floor - ' EMF San José, California 951134905 57': ' "" 2‘5" Telephone Number: (408) 535-1900 \“r Facsimile Number: (408) 998-3131 E-Mail Address: cao.main@sanjoseca.gov Attorneys for CITY OF SAN JOSE 1 SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA FAMILY COURT DIVISION CITY 0F SAN JOSE, Case Number; [07M 0309((9 Plaintiff, MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT 0F v. PETITION OF EMPLOYER FOR INJUNCTION PROHIBITING KAREN VORSTER aka JORDAN VIOLENCE OR THREATS OF ASHLEY DREYER, and DOES 1 to 10, VIOLENCE AGAINST EMPLOYEE(S) inclusive, Defendants. l. INTRODUCTION Plaintiff CITY OF SAN JOSE (“City”) brings the above-captioned action to seek a restraining order against Defendant KAREN VORSTER aka JORDAN ASHLEY DREYER (”Defendant") based upon Defendant’s threatening statements and behavior. ll. STATEMENT OF FACTS In July 2007, the City of San Jose (“City”) obtained an injunction against Karen Vorster aka Jordan Ashley Dreyer (“Vorster”) prohibiting her from making violent threats or engaging in violence against San Jose Police Officer Jason Tanner. The City sought such an order after Ms. Vorster spent months sending threatening and harassing emails and voicemails to Officer Tanner, who had been assigned to investigate aliegations that Vorster made criminal 1 MPAS ISO PETITION OF EMPLOYER FOR INJUNCTION PROHIBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE(S) 1264952 O(DQNIO)U1#OJN_\ NNNNNNNNNA-t-x-AAJAAAA memme-‘OCO@VO7CD#WN-K threats to someone eise. During the course of Officer Tanner’s investigation, Vorster was stopped by police and found with a concealed and loaded firearm. In recent months, Defendant has resumed sending emails and voicemails, not only to Officer Tanner, but to varipus other employees within the police department and at City Hall. _ The recipients of Vorster’s messages have included the Mayor, the Chief of Police and the City Attorney in addition to employees at other employment levels. Many of Vorster’s messages have been rambling profanity-Iaced recitations of her conspiracy theories. Over the last week. however, Vorstefs conduct has escalated and she has sent email messages regarding officers getting shot in the back and threats of killing officers. See Deciaration of Marco Mercado, Exhibit A. Witnesses to Vorster’s threats have concluded there is reason to be fearful for the safety of the members of the San Jose Police Department and other City 0f San Jose employees. Between November 16 and 18, 2015, Vorster has left multiple voicemail messages directed at C'rty empioyees, including the Chief of Police and the City Attorney. These messages include fhreatening statements that the Chief of Police should be careful because "someone killed a cop in Chicago and it looks like a suicide.” Swenson Declaration, 115. Vorster also gives notice of her intention to relentiessly continue her effons to contact the City Attorney and vows f0 “ruin” him. Id at 114. Identifying herself as the Interim President oflthe Hells Angels, she references wiretaps which listen to officers “slowly breathe [their] last breath." Id at 116.’ She also specifically targets Officer Tanner again, proposing she gets a guh to "duel it out” with him. Id at Ex. A. In addition to sending voicemail and email messages, Ms. Vorster’s conduct has escaiated in that she has made personal appearances at both the San Jose Mayor and City Council Offices as well as the Office of the San Jose City Attorney. Ms. Vorsters written threats as wen as her personal appearances, combined with her past threatening conduct against Officer Tanner and her history of possessing a concealed and loaded firearm have caused those monitoring her behavior to fear for the safety 0f San 2 MPAS ISO PETITiON OF EMPLOYER FOR INJUNCTION PROHIBJTING VIOLENCE OR THREATS OF VIOLENCE AGAiNST EMPLOYEE(S) 1264952 CDQNJODUI-hODN-l NNNNNNAAAAAAAAA...‘ Jose police officers'and other City employees. Mercado Declaration at 119,“ Swenson Decf. at fl9. Ill. ARGUMENT A. AN INJUNCTION SHOULD ISSUE T0 PROTECT CITY OF SAN JOSE EMPLOYEES FROM ANY ATTEMPT BY THE DEFENDANT TO CARRY OUT HER THREATS. An injunction is appropriate under Code of Civil Procedure Section 527.8 as City of San Jose employees have suffered credible threats of violence: (a) Any employer, whose employee has suffered unlawful violence or a credible ' threat of violence from any individual, that can reasonably be construed to be carried out or to have been carried out at the workplace, may seek a temporary restraining order and an injunction on behalf of the employee and, at the discretion of the court, any number of other employees at the workplace, and, if appropriate, other employees at other workplaces of the employer. (b) For the purposes of this section: (2) "Credible threat of violence” is a knowing and willful statement or course of conduct that would place a reasonable person in fear for his or her safety, or the safety of his or her immediate family, and that serves no legitimate purpose. (CCP §527.8 (emphasis added).) The statutory definition 0f an employer includes a city. (CCP §527.8(d).) Defendant's threats were made generally and specifically against City of San Jose employees. Accordingly, it is appropriate to impose'measures to protect impacted employees. Defendant made a credible threat of violence. A “credible threat of violence” is defined as a "knowing and willful statement or course of conduct that would place a reasonable person in fear for his or her safety, or the safety of his or her immediate family, and that serves no legitimate purpose.” (Huntingdon Life Sciences, inc. v. Stop Huntingdon Animal Cruelty USA, Inc. (2005) 129 Cal.App.4th 1228, 1250; CCP §527.6(b)(2); CCP 527.8(b)(2).) Defendant’s threats have recently grown scope and occurred following a history of simiiar 3 MPAS ISO PETITION OF EMPLOYER FOR INJUNCTION PROHIBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE(S) 1264952 threats against a San Jose police officer who, at the time of the threats was conducting an investigation that Defendant was making criminal threats. Defendant has proposed to “duel it out” with Officer Tanner and has warned the Chief of Police to be careful because. of the possibility he may be suffer a death similar to a Chicago police officer. Moreover, she has vowed to “ruin” the City Attorney and raises the possibility of killing him with a third party. Defendant’s threats indicate an intention to cause harm to City employees and follow mdnths of angry rants against City employees. Safeguards must be put into place to prevent Defendant from acting out her threats and to provide San Jose employees some. peace of mind in their workplace, where Defendant has already made more than one personal appearance within the last week. lt is correct and proper that the injunction cover Police Department facilities as well as City Hall. Defendant has threatened both San Jose police officers and other City employees, both particularly and generally (Mercado Decl. at Exhibit A; Swenson Decl. at ExhibitA). The legisiativ-e purpose behind Section 527.8 of the Code of Civii Procedure was to “prevent workplace violence.” (USS-Posco Industries v. Edwards (2003) 111 Cal.App.4th 436, 443.) V The workplace of San Jose police officers are City HaH and the various police facilities described in Addendum A to the attached petition. The workplace of San Jose public service workers is San Jose’s City Hail. It is proper, therefore to put in place protections at both locations to prevent the Defendant from carrying out her threats. 1. Defendant’s Broad Threats to Harm OffiCers and Pubiic Servants ls Actionable. r That Defendant threatened the San Jose police officers and employees generally does not alter the applicability of Code of Civil Procedure section 527.8. The Act expressly provides that a restraining order may be sought not just on behalf of particular employees, but also on behalf of “any number of other employees at the workplace, and. if appropriate, other 4 MPAS ISO PETITION OF EMPLOYER FOR INJUNCTION PROHIBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE(S) 1264952 A mflmmth-o-XOCOWNQUTAOJNA OCDmNQUI-hwm employees at other workplaces of the employer.” (Code Civ. Proc., § 527.8.) Defendant should be enjoined proportionately to the breadth and seriousness of her threat. The only requirement for relief under Section 527.8 is that the employees sought to be protected be threatened with unlawful violence. There is no requirement that the employees be particular identified by the enjoined-party. (USS-Posco Industries v. Edwards, supra, 111 Cal.App.4th at 443.) Thus Courts have issued injunctions to protect not just. particularly named parties, but also generally defined classes of employees. (Id. (enjoining not just contact with named individuals but also unnamed employees where threat was “I'll kill all the motherfuckers”); In re MB. (2011) 201 Cal.App.4th 1057, 1060 (enjoining notjust contactwith named employees but “[a]l! employees and staff” in Children and Family Services Depanment where threat was “to fuck aII you bitches up”)‘) In this case, the requested injunction is not overbroad as Defendant has threatened to harm police officers generally as well as the Chief 0f Poiice and City Attorney specifically. 2. Defendant’s Subjective Intent is Irrelevant The definition 0f a “credible threat of violence” in Section 527.8 does not include the speaker’s subjective intent. Before 1998, Section 527.8, subpart (b)(2), read as foliows: “Credible threat of violence” is a knowing and willful statement or course of conduct which would cause a reasonable person to belieVe that he or she is under threat of death or serious bodily injury, and which is intended to, and which actually causes, a person to believe that he or she is under threat of death or serious bodily injury, and which serves no legitimate purpose. (CCP §527.8, Historical and Statutory Notes (emphasis added).) The 1998 amendment rewrote subpart (b)(2) of Section 527.8, deleting, among other changes, the language highlighted above regarding the speaker’s subjective intent. Section 527.8 now provides: “Credible threat of violence’ is a knowing and willful statement or course of conduct that would élacela reasonable person in fear for his or her safety, or the safety of his or her immediate family, and that serves no legitimate purpose." (CCP §527.8(b)(2).) Because of 5 MPAS (SO PETITION OF EMPLOYER FOR INJUNCTION PROHlBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE(S) 1264952 A OCOWNOUILQJN this change, the Sixth District has held that subjective intent is irreievant to analysis under Code of Civil Procedure section 527.8. (City of San Jose v. Garbett (2010) 190 Cal.App.4th 526, 538.) Whether or not Defendant meant what she said is irrelevant so long as the ‘targets of her threats could reasonably fear for their safety. As expressed in their ' declarations, City employees read and heard Defendant’s threats and reasonably feared for their own safety as well as that of City employees. The irrelevance of subjective intent to this analysis is consistent with Supreme Court precedent related to “true threats.” The High Court stated in Virginia v. Black (2003) 538 U.S. 343, that “true threats” “encompass those statements where the speaker means to communicate a serious expression of an intent to commit an act of unlawful violence to a particular individual or group of individuals.” (Id. at 359) (emphasis added).) There appears to be no California Supreme Court case interpreting Blacks definition of "true threats,” but the court in People v. Lowery (2009) 180 Cal.AppAth 630, recently stated that the speaker’s subjective intent is irreIevant in “true threats" analysis: “‘True threats’ encompass those statements where the speaker means to communicate a serious expression of an intent to commit an act of unlawful vioience to a particular individual or group of individuals. [Citations] The speaker need not actually intend to carry out the threat. Rather, a prohibition on true threats “protects individuals from the fear _of violence’ and ‘from the disruption that fear engenders,’ in addition to protecting people ‘from the possibility that the threatened violence will occur.’ [Citation] . . , . (Virginia v. Black, supra, 538 U.S. at pp. 359-360.) In sum, “the only intent requirement for a true threat is that the defendant intentionally or knowingly communicate the threat.” (Planned Parenthood v. American Coalition (9th (Cir. 2002) 290 F.3d 1058, 1075) Lowery, 180 Cal.AppAm at 635 (emphasis added). In its interpretation of “true threats," the Lowery court relied on the Ninth Circuit’s test stated in Planned Parenthood ofthe ColumbiaA/Villamette, Inc. v. American Coalition of Life Activists (9th Cir. 2002). The Planned Parenthood court stated that the Ninth Circuit’s well-established standard for “true threats” is 6 MPAS ISO PETITION OF EMPLOYER FOR INJUNCTION PROHIBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE(S) 1264952 (DmVODO'l-bCON-X NNNMNMN-l-x-A-A-AAAAA-x ggmUI-FWN-IOKDQVCDO‘IAWN-‘O a simple objective reasonableness test: “Whether a particular statement may properly'be considered to be a threat is governed by an objective standard - whether a reasonable person would foresee that the statement would be interpreted by those to whom the m_aker communicates the statement as a serious expression of intent to harm br assault.” Planned Parenthood, 290 F.3d at 1074 (emphasis added). Thus, under the “true threats” analysis, Defendant’s subjective intent is not a factor. Similarly, under Section 527.8, Defendant‘s subjective intent is irrelevant. IV. CONCLUSION The City of San Jose respectfully requests that Defendant be enjoined so that protections can be put in place to prevent her from carrying out her threatened violence. N Respectfully submitted, Dated: ‘9‘“ka ?%3 20:? RICHARD DOYLE gity Atty / u ”3% NKiA D. RICHARDSON Sr. Deputy City Attorney Attorneys for CITY OF SAN JOSE 7 MPAS 180 PETITION OF EMPLOYER FOR INJUNCTION PROHlBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE(S) 1264952 (DmNODCD-ACON-A NNMNNNNNN-LAAAAAAAAA mflmU'l-h-OON-XOCDWVOCD-bWN-io RICHARD DOYLE, City Attorney (88625 A _ ‘ ~ ,_‘ NORA FRIMANN, Assistant City Attorne; (93249) 28%5 rsEi :6 56%:8 NKIA D. RICHARDSON, Sr. Deputy City Attorney (193209) - 1‘) Office of the City Attorney r m -‘ JQ/ 200 East Santa Clara Street, 16“ Floor a, 5 San José, California 95113-1905 v “" n! r Q Telephone Number: (408) 535-1 900 Facsimile Number: (408) 998-3131 E-MailAddress: cao.main@sanjoseca.gov Attorneys for CITY OF SAN JOSE SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA FAMILY COURT DIVISION CITY OF SAN JOSE, Case Number: ’07MUDgqg Plaintiff, . DECLARATION OF RICHARD DOYLE IN SUPPORT OF PETITION OF V. EMPLOYER PROHIBITING VIOLENCE OR THREATS OF KAREN VORSTER aka JORDAN VIOLENCE AGAINST EMPLOYEE ASHLEY DREYER and DOES 1 t0 10, inclusive, Defendants. l, RICHARD DOYLE, declare as follows: 1. i have personal knowtedge of the matters set forth herein and, if called as a witness, could and would competentiy testify thereto except as to those matters stated on information and belief. As to those matters, I believe them to be true. 2. I am the City Attorney for the City of San Jose. In this capacity, I am the legal adviser, attorney and counsel for the City of San Jose and an of its officers. 3. To my knowledge, my office has handled only one legal matter pertaining to Karen Vorster aka Jordan Ashley Dreyer (hereinafter “Ms. Vorster”). Specifically, in 2007, an attorney from my office sought and obtained a restraining order and injunction against Ms. Vorster arising from threats of violence against San Jose Detective Jason Tanner in Santa 1 DECLARATION OF RICHARD DOYLE ISO PETITION OF EMPLOYER PROHIBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST ‘ EMPLOYEE 1265071 (Dm‘flOUO‘I-hCDN-K NNNNNNM.NN-x-L-x_x-s-x-s-A_L_x mflmmAWNA'OOmNGCfibWN-éc Clara County Superior Court Case No. 1-O7-CH000949. Other than this case, my office has not been involved in any other civil litigation or administrative matters with Ms. Vorster nor has my office prosecuted any criminal charges against Ms. Vorster. 4. Starting November 14, 2015, Ms. Vorster sent multiple email messages V either addressed or copied to me. Many of her messages were profanity-Iaced, rambfing and paranoid rants regarding her conspiracy theories. lnterspersed in her messages; however, were violent and threatening statements directed at me: o The San Jose City Attoiney is in bed with Organized Crime. | bet he will Uy to hold up my reward money because that stops his dirty money...You know bonehead; we’ve been recording your conversations for over a year. You’re toast ~ now run out and yell “karen’s [sic] threatening my life - she said l was toast!” then yell "l’m a soaked little girl in a skirf’. [sic] ass wipe. (November 15, 2015 email) o As I asked Mike Sullivan. If you set me up, can lthen in turn set you up? lf you try to kiil me via a third party, can l then in then in turn try to kill you with a third party? Do you understand it is YOU that is threatening me while claiming I am threatening you? Do you understand you are not a_ man? (November 16, 2015 eman)‘ 5. Beginning November 16, 2015, Ms. Vorster also began Ileaving disturbing and threatening voicemail messages with my office. Her messages are aggressive and delusional and include the following statements: o Hi Ms. Clever, one more message for your yellow cowardly, douchebag boss... I’ve personafly requested to a high leve} friend of mine, who has the power to do it, to drive his career and his family and his children and everyone he knows into the ground. /// 1 True and correct copies of the emails referenced above are attached hereto as Exhibit A. 2 DECLARATION OF RICHARD DOYLE ISO PETITION OF EMPLOYER PROHIBITING VIOLENCE OR THRflTS OF VIOLENCE AGAINST EMPLOYEE 1265071 OCOmNImO'I-hWN-x NNNNNNNA-x-LA-LAAAAA §fimmthAO®mNmthN-& Every last penny removed. To ruin him, just like he ruined other people. An eye for an eye. A tooth for a tooth. (November 16, 2015 voicemail, 9:14 am) o Hi Dear. I’m going to call back and I’m going to talk slowly about wiretaps because I don’t think you have the bandwidth to catch on. Richard Doyle is a corrupt politician. He’s been lying about me and now! understand he’s got his corruptjudge. Thank you very much for handing him over to us. It makes my job just so much easier. Anyway, he's trying torget me blocked from the entire City ti) cover his sorry ass. What do you do with a man like that? The ultimate coward. l don’t know but I’ll come up with something. (November 16, 2015 voicemail, 9:17 am) c Hi. My name is Karen Vorster. I’m trying to get a hold 0f the idiot attorney, City Attorney Richard Doyle. He’s too much of a chicken shit to take my caH directly so I . dialed the next number up from his administrative assistant, an equally stupid person. Um, I Wanted to inform him the FBI . . . (unintelligible) his phones for over a year now and he’s toast. - (November 16, 2015 voicemail, 7:25 pm)‘ 6. On November 18. 2015, | am informed and believe Ms. Vorsfier appeared in the reception area of the City Attorney's Office demanding to see me. Security was called to address her behavior but she left before they arrived. Because of her threatening statements and her erratic behavior, including her persona! appearance at my office, lam concerned for my personal safety as well as the safety of my staff. Ms. Vorster appears to be very unstable and hostile and now she has demonstrated a fixation on me and my office. Other than. obtaining one restraining order against Ms. Vorster in 2007, my office has not been a party to any other litigation or administrative matters involving Ms. Vorster. With the exception of 1 A true and cqfiect copy of the transcribed voicemai} messages referenced above are attached to the Declaration of Steven Swenson at Exhibit A. 3 DECLARATION OF RICHARD DOYLE ISO PETITION OF EMPLOYER PROHIBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE 1265071 ©WNO§®AQN4 NNNNNNNNN-x-L-LAAAAAAA mNODU‘l-wa-toomflmmwa-éo Detective Jason Tanner’s 2006 investigation into criminal threats allegedly made by Ms. Vorster, I am unaware of any other City of San Jose involvement with Ms. Vorster’s criminal matters. 7. l am informed and believe Ms. Vorster has previously been stopped with a concealed and loaded firearm. A restraining order was previously granted for similarly threatening behavior and Ms. Vorster is engaging in violent and threatening behavior once again. Her history of instability and current harassing, aggressive and threatening conduct, including violent statements, all cause me great concern for my personal safety as well as that of my staff. ' I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed thisA day of November 201 5 at San Jose, California. z/ \ I RICH®OYLE 4 DECLARATION OF RlCHARD DOYLE ISO PETITION OF EMPLOYER PROHIBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE 1265071 EXHIBIT A Richardson, Nkia From: Employee Relations Sent: Monday, November l6, 2015 5:28 PM To: Richardson, Nkia Cc: Mercado, Marco (OER) Subject: FW: the set up.................again Please see betow. Thanks, ofiice of Employee Relations From: Jordan Tucker [mailto:hellsangelscops@hotmaiicom] Sent: Monday, November 16, 2015 5:14 PM To: Doyle, Richard Cc: Morales, Thomas (PD); Angei, Steven; san.franciscoga}Ec.fbi.gov; Esqu'wel, Larry; washingtonfleld @ic.fbi.gov; Liccardo, Sam; michae|.sul|ivan@sanioseca.gov; Tanner, Jason Subject: the set up .................again ' so first you went along with Mezzetti, a major douche bag, and lied about me making threats towards District Attorneys when in fact I am simply trying to recover money Mezzetti stole from me via your "justice system". How many times have you lied about these types of things while in office? Now you've gotten your dirty federal judge to make up some paperwork in an attempt to keep a lid on the truth and to keep your ili gotten gains. You are a major chicken shit, just like Mezzetti. My address is 141 South Taaf‘fe Street Unit 70040, Sunnyvaie, CA 94086. Now send me your faked paperwork signed by the judge so l can finish demolishing you. I know you did not send it because you'd prefer I just “showed up" so you can arrest me. Forjust ONE MINUTE I'd {ike you to reflect 0n what you have become. You have used all the power at your disposal to throw a honest person in jail that has not committed a crime. Which means you have done this many many times. How many men and women are wasting away in a jail cell because you wanted 10 more dollars? Who 'Is Sheriff Jennifer Gaian and why did someone sneak her phone number into my purse? She kill for you? You are going on up my National webpage now and l am detailing how you are trying to set me up. As l asked Mike Sullivan. If you set me up, can l then in turn set you up? If you try to kill me via a third party, can l then in turn try to kill you with a third party? Do you understand it is YOU that is threatening me while claiming‘ am threatening you? Do you understand you are not a man? Richardson, Nkja From: Employee Relations Sent: ' Monday, November 16, 2015 9:46 AM To: Richardson, Nkia Cc: Mercado, Marco (OER) Subject FW: Reward Please see below. Tha n ks, Ofiice ofEmployee Relations From: Jordan Tucker [mailto:hellsangelscops@hotmail.com] Sent: Sunday, November 15, 2015 1:56 PM To: Doyle, Richard Cc: Morales, Thomas (PD); san.francisco@ic.fbi.gov; Esquivel, Larry; washingtonfleld@ic.fbi.gov; Liccardo, Sam; michael.sul|ivan@sanjoseca.gov; Tanner, Jason; internalaffairs@sunnyvale.ca.gov Subject: FW: Reward FBI . The San Jose City Attorney is in bed with Organized Crime. [will bet he will try to hold up my reward money because that stops his dirty money. You know the District Attorney tried to set me up recently The Cops let me know. you see they are as tired of lazy dirty lawyers as we are You lied and said Iwas threatening the District Attorney You know bone head, we've been recording your conversations for over a year. You're toast - now run out and yell "karen's threatening my life - she said lwas toast!" then yell "I'm a scared little girl in a skirt". ass wipe From: heiisangelscops@hotmail.com To: internalaffairs@sunnwale.ca.gov Subject: FW: Reward Date: Sun, 15 Nov 2015 20:51:22 +0000 Please contact the Mayor if you can help. I am twitting crime tips. The Jubilee church is involved'in Child Porn. From: hellsangelscops@hotmail.com To: larrv.esquivel@sanioseca.gov CC: thomasmorales@sanjoseca.gov; san.francisco@ic.fbi.gov; washington.field@ic.fbi.gov; sam.liccardo@sanioseca.gov; michael.sul|ivan@sanioseca.gov; j_ason.tanner@sanioseca.gg; laurie.smith@sccsheriff.org Subject: Reward Date: Sun, 15 Nov 2015 00:18:17 +0000 Or Finder's Fee. Whatever you want to call it. While I did not use your lobby phone under all your cameras t0 make my "anonymous" crime tips (does that even work or was it a waste of money?) I am now ready for my reward money. The amount I am requesting is far lower than deserved but will suffice. First a warning. lfyOu do not pay for what you are responsible for breaking, you will be left out in the cold from here on out to flounder. All support will be withdrawn except to continue to take down your corrupt officers. if you do contribute to fixing what you broke, help will be continued until Lt. Morales breaks the death grip that Organized Crime has on your valley, with the help of his hand pECked officers. And Sam Liccardo can flourish as the Mayor of San Jose and break the death grip of poison politics. (Mayor, we are in the process of taking down Carl Berg - l used to report directly to him and know his dirty little secrets. He got into his position of prominence because he'owns some Judges‘) Mayor, later next year I will also need some of your officers to meet up with me in Las Vegas as the Las Vegas pofice are as corrupt as San Jose Police were and l need Lt. Morales' protection. Lt. Morales is head of cold crimes and most ofthe Murders started in Las Vegas and ended in San Jose or surrounding areas. He can coordinate a multi-jurisdictional take-down. The money he will seize will more than cover expenses but you will have to wait for that. Details and activities will become obvious as we move forward. Isuggest you get your own man on top of the financial recovery so you don't see that disappear. Someone you TRUST. Or ask the FBI for help. REWARD I need $12,000.00 to purchase an RV that I have already bid on and won. The Owner is getting impatient, he is also a fellow retired officer. I will purchase the cashier's check after receiving the money so it cannot be traced back to San Jose PD. ' l need $5000.00 cash. .Lt. Morales has my debt American Express. I need that returned with the reward money. [will put $3,000.00 of this cash on this card with the intent that Lt. Morales foilows my spending. | am going to lead him to Murder Inc. headquarters and the money laundering business. The intent is to SEIZE all the money and possessions that you can. We will not need to communicate, I will speak to him via my spending. I will be traveling to the Prison where Charles "Pee Wee" Goldsmith is incarcerated with the intent of rattling his cage, legally. Pee Wee is the current President of the Las Vegas Hells Angels and a member of the Las Vegas Teamsters. He is easy to piss off and when he gets angry he will get on the Prison phones and order my execution, thereby insuring his continued stay at Prison as well as handing law enforcement the Italian Mob. Why me? Because Pee Wee knows exactly who I am. We have communicated before. This does not work without me. in summary! require a total of $17,000.00. $12,000 will be used for the purchase of the RV $5000.00 is for gas and living expenses and to insure l can get to where Pee Wee is staying. Then I'm off to Vegas so the Mob can try to kill me with Lt. Morales and friends monitoring all oftheir activities. You have the chance of a life time, please don't fuck this up; Mail the money to 141 S. Taaffe Street, Unit 70040, Sunnyvale, CA 94086 QB email me to meet a representative to pick up the money or cash. [will only meet someone l can truSt so it can be at the Mayor‘s office or Lt. Morales. Or you can arrange for me to pick up the money and American Express debt card at the Sunnyvale Police Department. PS: The US Government would like to let you know that this is costing them MILLIONS. (OQNODO'IAWNA NNNNNNNNN-‘AAAJAAAAA memth-Jocomflmm#wN-\O RICHARD DOYLE City Attorney (88625) I , INORA FRIMANN, Asststant City Attorney (93249) £95 NKlA D. RICHARDSON Sr. Deputy CityyAttorney (193209) Office of the City Attorney m200 East Santa Clara Street, 16 Floor San José, Califomia 95113-1905 Telephone Number: (408) 535-1900 Facsimile Number: (408) 998-3131 E-Mail Address: cao.main@sanjoseca.gov Attorneys for CITY OF SAN JOSE SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA CITY OF SAN JOSE, Case Number; (07Wq9 Plaintiff, DECLARATION OF MARCO MERCADO IN SUPPORT OF v. PETITION OF EMPLOYER FOR INJUNCTION PROHlBlTING KAREN VORSTER, aka JORDAN VIOLENCE OR THREATS OF ASHLEY DREYER and DOES 1 to 10, VIOLENCE AGAINST EMPLOYEE(S) inclusive Defendants. I, MARCO MERCADO, declare: 1. l am an employee of the City of San Jose (“City"), and serve as Assistant to the City Manager in the City Manager‘s Office of Employee Relations (“OER”) and also serve as one of its Custodian of Records. 2. | have persona! knowledge of each of the facts set forth in this Declaration and can testify competently thereto, except as to matters stated on information and belief, and as to such matters, | believe them to be true. 3. Starting in June 2015, I was notified by City employees of concerning emails being sent from Karen Vorster aka Jordan Ashley Dreyer (hereinafter “Ms. Vorster“). l am informed and believe the emails were arriving with such frequency that they were interfering with employee resources and were disruptive to the workplace. I began observing Ms. 1 DECLARATION OF MARCO MERCADO IN SUPPORT OF PETITION OF EMPLOYER FOR INJUNCTION PROHIBITING VIOLENCE OR THREATS 0F VIOLENCE 1254450 (DmNODU'I-hOON-A NNNNNNNMMAAJ-L-bgé-L-xd NNOU‘LGN-‘OOWNOWLWN-éo Vorster’s email messages to various City employees to ascertain if any further action needed to be taken. 4. Between June 2015 and November 18, 2015, I observed more than 130 emails from Ms. Vorster to City employees across multiple departments, including the Mayor, the Chief of Police, other police department employees, the City Attorney and other employees within the Office of the City Attorney. Ms. Vorster also sent emails to Jason Tanner, a San Jose police officer on whoée behalf the City previously obtained a restraining order against Ms. Vorster in 2007. 5. The emails were sent from various email addresses: (1) ikvorster@gmail.com; (2) hellsanqelscops©hotmail.com; and (3) Y kvorster@tsmc.com. lwas able to confirm that Ms. Vorster was the party responsibie for sending messages from each of the above addresses because her name was contained within the email address or because she signed the messages with her name. Attached hereto as Exhibit A are true and correct copies of some of the emails l have observed over the last few months, including those referenced in this declaration. Due to the volume of emails sent by Ms. Vorster, the majority of them are not included herewith. 6. Many of the emails I observed express Ms. Vorster’s conspiracy theories regarding various government and law enforcement agencies, such as the FBI and the San Jose Police Department, and reference various organizations such as the mafia. Ms. Vorster’s rambling messages frequently include profanity and fantastical and itlogical accusations of corruption and illegal activity. 7- On or about November 16, 2015, I observed several email messages from Ms. Vorster to City Attorney Richard Doyle. Multiple other city employees were copied on the emaii. ln an email sent by Ms. Vorster to Mr. Doyle at 5:14 pm on November 16, she stated 1f you try to kin me via a third patty, can l then in turn try to kill you with a third party? Do you understand it is YOU that is threatening me while claiming I am threatening you? Do you understand you are not a man? 2 DECLARATION OF MARCO MERCADO 1N SUPPORT OF PETITION OF EMPLOYER FOR INJUNCTlON PROHIBITING VIOLENCE OR THREATS 0F VIOLENCE 1254450 (DmNODO‘l-hOON-A NNNNNNNNN-A-A-t-xggéa-x-s m N 0) U‘I h 00 N -i- O‘CO m \I O) U1 b CO N A O l interpreted Ms. Vorster’s statement “If you try to kill me a via third party, can I then in turn try to kill you with a third party?” as a Violent threat against Mr. Doyle and it caused me to be concerned for Mr. Doyie’s safety and that of his staff. 8. On November 18, 2015, I observed an email message which was sent at 12:27 pm from hellsanqelscops©hotmail.com. This is an email address which has been used repeatedly by Ms. Vorster over the last few months. The email was addressed to Brandon Sanchez, a San Jose police sergeant and was signed by Karen Vorster aka Jordan. It read, in relevant part, as follows: Also if this level of corruption got out cops would start getting shot in the back and frankly a lot of people would say they had it coming. The problem is the wrong cop may get shot in the back. [t is a littie known fact that six officers were shot. ..Brandon, l do hope you can read between the lines and pass this around. l took this comment as a threat of violence against San Jose officers and it caused me to be concerned for their safety. 9. Based on Ms. Vorster’s prior behavior which resulted in the issuance of a restraining order on behalf of a San Jose police office and, because 0f her increasingly threatening emails to various'empioyees in City Hall and the San Jose Police Department, l am fearfui for the safety of San Jose police officers and employees at San Jose City Hall, including my own safety. I declare under penalty of perjury of the laws of the State of Caiifornia that the foregoing is true and correct. Dated thisMday of November 2015, at San Jo - . Iifornia. 3 DECLARATION OF MARCO MERCADO 1N SUPPORT OF PETITION OF EMPLOYER FOR INJUNCTION PROHIBITING VIOLENCE OR THREATS 0F VIOLENCE 1264450 EXHIBIT A Richardson, Nkia From: Employee Relations Sent: I Wednesday, September 02, 2015 4:35 PM To: Richardson, Nkia Cc: Mercado, Marco (OER) Subject FW: Hard ball Piease see below. Thanks Office of Employee Relations Fram: Karen Vorster [m_ai3to:ikvorster@gmail.com] Sent: Wednesday, September 02, 2015 12:43 PM To; Tanner, Jason Subject: Hard ball So you are a fan 0f hard ball Jason. I find that interesting as you personally can‘t handle hard ball, you have others do it for you. How deep in over your head are you? Richardson, Nkia From: Sent: To: Cc: Subject Please see below. Thanks, Ofiice of Employee Relations Employee Relations Wednesday, September 30, 2015 8:24 AM Richardson, Nkia Mercado, Marco (OER) FW: russia mafia, nevada mafia, hells angels From: Jordan Tucker finaElto:hellsangelscogs@hotmail.com] Sent: Tuesday, September 29, 2015 8:38 PM To: michael.sullivan@5811§gseca.gov Subject: russia mafia, nevada mafia, hells angels ps - san jose is totally out of control under your watch. You worthless piece of shit. Richardson. Nkia From: Employee Relations Sent: Fn‘day, October 23, 2015 4:52 PM To: Richardson, Nkia Cc: Mercado, Marco (OER) Subject: FW: Worthless humans getting paid for doing nothing except dirty deeds done cheap. Please see below. Tha n ks, Office of Employee Relations From:Y KVORSTER@tsmc.com [mailto:Y KVORSTERfltsmcxom] Sent: Frid'ay, October 23, 2015 8:16 AM To: Tanner, Jason Subject: Worthless humans getting paid for doing nothing except dirty deeds done cheap. Ever doing my bidding. By making sure you could not hear bad news you switched to a cell fony-business that lets Uncle Sam - heck lets word ii differently. It lets everyone have access to your "personal" business voice mail. Hey what is that CUNT Rush LIM BA‘s email I have a surprise for him. How to build a community within a community that keeps others out. How to build a society within a society that keeps others out and make idiots think they are when the); are not lee them a TASTE of Not working for a living ‘ whiie NOt ALLOWING THEM IN use them LET THEM PPROTECT THBR “MN OF UFE SOTHEYGET THEEASY RIDE CONGRADUCATIONS jAsON yOU WON THE IOTTORY hELPlNG TO "FIX" THE ELECTIONS SO OTHERS not you CAN UVE ON YOUR DIME THANK YOU FOR BEING SOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOO OOOOOOOOOOQOOOOOOOOO SWPID CALL ME AT 844 906 0568 Karen Vorster Receptionist TSMC - North America 2851 Junction Avenue San Jose, CA 95134 Tele: 408 382-8041 TSMC PROPERTY This email communication (and any anachments) is proprietary information for the sole use of its intended recipient. Any unauthorized review, use or distribution by anyone other than the intended recipient is strictly prohibited. If you are not the intended recipient, please notify the sender by replying to this email, and then delete this ‘ 61.11811 and ”anprPiés 0f it immfiiat§1¥:rma¥fls you w .. . , . , . ‘ Richardson, Nkia From: Employee Relations Sent: Tuesday, November 10, 2015 8:04 AM To: Richardson, Nkia Cc: Mercado, Marco (OER) Subject FW: Pugnacious Please see below. Thanks, ofiice of Employee Relations From: Jordan Tucker [mailto:hellsangelsccps@h0tma§Lcoml Sent: Monday, November 09, 2015 7:10 PM To: Morales, Thomas (PD) Subject: Pugnacious Hello Lt. Well that was a fun ride ....... I was sent to the police department to report that some San Jose Pofice Officers were involved with smuggling drugs into the jail. As I was driving up to the front of your station, a Sheriff's jail bus was pulling out around from the back and passed me. [parked in four hour parking and walked up the stairs. At the top of the stairs was one of your officers involved in smuggling drugs into the jail. I said to him: "Please stop smuggling illegal drugs into the jails". He glanced at me and kept walking while saying you have the wrong guy or something to that affect. [said No, l have the right guy and you need to stop smuggfing illegai drugs into the jail. He turned around and said harshly "Lady, you need to get out of here". I continued to follow him and told him his phone and all theVSan Jose Police phones had been recorded for over one year so everything was already known and he was a dead duck. He said harshly again, Lady you need to get offthe property. He got into his car, fastened his seat belt, put the.keys in his ignition looked up at me again and told me to go and get off the property while glaring at me. He looked "pugnacious". l [was afraid of him as he finds a fight easily. [started to walk to my car. Then as I reached my carl realized l should also go into the police station and tell the front desk to tell the cops to stop smuggling illegal drugs into the jaii. (Because they need to hear this out loud) And to mention that Pugnacious did not have on his video camera. As he saw me walking back towards the station he yelled OK THAT‘S IT! and unfastened his seat bell pufled his keys out of the ignition and opened his door and climbed back out of his car. Came at me quickly and demanded my licence. the rest is history. When | finally got to the mentaf health facility curtsy of Pugnacious, he had pulled a "Jason Tanner". While he clearly proved that he understood that what I had said was NOT a threat to him, became a threat all of a sudden because of his fear of being exposed. He ran with that lie so hard he exposed everyone that allows this cheap trick t0 happen. Because of his illegal activity he was ready to ruin my life. After my 72 hour hold he had it extended with hopes 0f gaining permanent incarceration due to how dangerous I was to him when in fact it is Pugnacious that is the liar and the danger to all others. Then throw in the drug dealing and the vioiation of the body camera i must question your hiring practices and retention. This man is clearly not fit to work as a crossing guard Iet alone an cop with a gun. When [tell you that I have met a lot of men in my life both in the US and overseas and I have to tell you Pugnacious, Jason and al! their little friends are like shit on my shoe. And they get paid to lie, cheat and‘ steal. He lost today. But you are getting this email because he embellished some more. He knows that whatl REALLY said was he was a dead duck as in his career is OVER. He added on that I said He was a dead officer. l did not say that and l'd like to once again comment on the cowardly level of some of your officers. As ltold your Chief, you need braver cops. Thank you for not towing my car. I'd have it now but Pugnacious punctured my tire with a knife so l could not drive it off the lot. Tomorrow l will have to find a way to get a new tire etc and pay for it. lcannot fathom a man SO ANGRY while getting his way ALL 0F THE TIME that he lashes out like a three year old. Perhaps he is using his product as well as selling it, that wouid explain the extreme hostility. Regards, Jordan Richardson, Nkia _L From: Employee Relations Sent: Monday, November 16, 2015 5:28 PM To: ' Richardson, Nkia Cc: Mercado, Marco (OER) Subject: FW: the set up .................again Please see below. Tha nks, - omce ofEmployee Relations Ffom: Jordan Tucker [mailto:hellsangelscops@hotmail.com] Sent: Monday, November 16, 2015 5:14 PM To: Doyle, Richard ' Cc: Morales, Thomas (PD); Angei, Steven; san.francisco@ic.fbi.go ; Esquivei, Larry; washingtonfieid @ic.fbi.gov; Liccardo, Sam; michael.sul!ivan@sanioseta.gov; Tanner, Jason Subject: the set up .................again so first you went along with Mezzetti, a major douche bag, and lied about me making threats towards District Attorneys when in fact | am simpfy trying to recover money Mezzetti stole from me via your "justice system". How many times have you lied about these types ofthings while in office? Now you've gotten your dirty federal judge to make up Some paperwork in an attempt to keep a lid on the truth and to keep your ill gotten gains. You are a major chicken shit, just like Mezzetti. My address is 141 South Taaffe Street Unit 70040, Sunnyvale, CA 94086. Now send me your faked paperwork signed by thejudge so | can finish demolishing you. I know you did not send it because you‘d prefer | just "showed up" so you can arrest me. Forjust ONE MINUTE I'd like you to reflect on what you have become. You have used all the power at your disposal to throw a honest person in jail that has not comm'rtted a crime. Which means yep have done this many many times. How many men and women are wasting away in a jail cell because you wanted 10 more dollars? Who is SheriffJennifer Galan and why did someone sneak her phone number into my purse? She kill for you? Yell: are going on up my National webpage now and l am detaifing how you are trying to set me up. As I askéd Mike Sullivanflf you set me up, can I then; in turn set you up? If you try to kill me via a third party, can I then in turn try to kill you with a third party? Do you understand it is YOU that is threatening me while claiming | am threatening you? Do you understand you are not a man? Richardson, Nkia From: Jordan Tucker Sent: Wednesday, November 18, 2015 12:27 PM To: Sanchez, Brandon Cc I Liccardo, Sam Subject: Hello Brandon Follow Up Flag: Follow up Flag Status: Flagged WWW.VOIR-DlRE.NET Will send you the other website later. Afier Jasdn Tanner set me up to protect Steve Tausen [called my ex lover, Terry Tucker, Chief Engineer of the F16 Fighter Program. He called the Secret Service. The Feds havebeen recording th'e conversations of all the cops and lawyers and Judges in this area for over one year. it's over. Now cops like Jason and Mike have very few choices. If the feds came in today and arrested all the corrupt cops they would haVe to let out all the prisoners that these guys put into jail. Then the prisoners would sue and they would win and San Jose would go bankrupt. Also if this level of corruption got out cops would start getting shot in the back and frankly a lot of people would say they had it coming. The problem is the wrong cop may get shot in the back. ' lf you recall, when New Orleans got hit with Katrina the Court House got flooded and they ended up having to - release lots of prisoners as their records were destroyed. It is a little known fact that six officers were shot a short time after) Brandon, I do hope you can read between the lines and pass this around. Your corrupt cops are playing with fire and your lives - not theirs. The two.detectives that were murdered in Santa Cruz were investigating the influx of Organized Crime and their murders were a hit. That is who your corrupt cops are in bed with. Regards, Karen Vorster AKA Jordan (DmVQU'l-th-l N N N N [\J N N N M ._L .._x .4 .4. _.\ .4 .4 .x _.\ .3 m N O) U1 A (.0 N'A O (0 m N O) U1 A (A) N --¥ O RICHARD DOYLE, City Attorney (88625) NORA FRIMANN, Assistant City Attorney (93249) NKIA D. RICHARDSON Sr. Deputy City Attorney (193209) Office of the City Attorney 200 East Santa Clara Street, 16th Floor San José, California 95113- 1905 om???” Telephone Number: (408) 535-1900 ‘ 7‘) Facsimne Number. (408) 998-3131 ‘ C9, E-MailAddress: cao.maan@sanjoseca._gov Q’ Attorneys for CITY 0F SAN JOSE 7 SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA FAMILY COURT DIVISION CITY OF SAN JOSE, . _ Case Number: ~ I 0 gM0003‘8 P'aint‘ff: DECLARATION 0F NKiA V RICHARDSON IN SUPPORT OF ' PETITION OF EMPLOYER FOR KAREN VORSTER aka JORDAN INJUNCTION PROHIBITlNG ASHLEY DREYER and DOES 1 to 1o V'OLENCE 0R THREATS 0F . . I ' VIOLENCE AGAINST EMPLOYEE(S) mcluswe, Defendants. I, NKIA D. RICHARDSON, declare as follows: 1. l am a Deputy City Attorney for the City of San Jose and one of the attorneys of record in the above-captioned case. 2. I make this declaration of my own knowledge and, if called upon to testify, could competently testify to the facts stated herein. 3. Pursuant to Code of Civil Procedure Sections 527 and 527.6, the City of San Jose is requesting a temporary restraining order and injunction against Karen Vorster (aka Jordan Ashley Dreyer). V 4. In or about July 2007, the City of San Jose obtained an injunction against 1 DECLARATION OF NKIA RICHARDSON ISO PETITION OF EMPLOYER FOR INJUNCTfON PROHIBITING VIOLENCE OR THREATS OF VIOLENCE 1284435 (DWNOUI-AWM-K NNNNNNNNN-x-x-x-‘AAAAA‘ mVOU‘#CfiN-XOCDW\IO301#OJN~AO Jordan Ashley Dreyer aka Karen Vorster on behalf of San Jose police‘officer Jason Tanner in Santa Clara Superior Court Case No. 1-O7-CH000949. The injunction was based on multipte threatening emails and voicemail messages from Jordan Dreyer aka Karen Vorster to Officer Tanner and were made after Officer Tanner conducted in investigation into criminal threats éllegedfy made by Ms. Dreyer (Vorster). During the course of Officer Tannel’s investigation, Ms. Vorster was found with a concealed and loaded firearm. A true and correct copy of the Amended Order After Hearing on Petition of Employer for Injunction Prohibiting \fiolence or Threats 0f Violence Against Employee and Petition of Employer for InjunctiOn Prohibiting Violence Prohibiting Violence or Threats 0f Violence are attached to the City of San Jose’s Request for Judicial Notice at Exhibits 1” and 2, respectively. 5. l conducted an index search of the Santa Cfara County Superior Court _ website aflnd also‘caused a search to be conducted of the prior and current cases with the San Jose City Attorney’s Office. Other‘than the superior court case referenced in paragraph four (4) of this declaration, the City of San Jose has not been a party to any other litigation matters in which Karen Vorster aka Jordan Ashley Dreyer was a party. See City of San Jose’s Request for Judicial Notice at 113. 6. My search of City Attorney cases as well as an index search of Sanvta Clara County criminal cases did not locate any criminal matters in which the City Attorney’s Office criminally prosecuted Karen Vorsteraka Jordan Ashley Dreyer. I am informed and believe San Jose Detective Jason Tanner conducted a criminaI investigation of Karen Vorster aka Jordan Ashley Dreyer which was turned over to the District Attorney’s office for prosecution. 7. Pursuant to Code of Civil Procedure Section 527(0), l have not notified Defendant‘Karen Vorster (aka Jordan Ashley Dreyer) of the ex parte hearing in this matter. l am informed and believe that, if she was advised of the City’s ex parte request for a temporary restraining order, it could potentiallyjeopardize the safety of San Jose police officers and City employees at San Jose City Hail. No significant burden or inconvenience to Defendant Karen Vorster (aka Jordan Ashley Dreyer) will result from the orders requested. 2 DECLARATION OF NKIA RICHARDSON ISO PETITION OF EMPLOYER FOR INJUNCTION PROHIBITiNG VIOLENCE OR THREATS OF VIOLENCE 1264435 ©mNmm#WN-¥ NNNNNNNNNAAAAAAJJAA mflmmAWN-iotomflmm#wN-¥O Therefore, Plaintiff requests that the Court grant this temporary restraining order without notice to Defendant. i declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 20th day of November 2015, at San Jose. California. ,g/ . _/ ' NKIA D. RICHKRDSON 3 DECLARATION OF NKlA RICHARDSON ISO PETITION OF EMPLOYER FOR INJUNCTION PROHIBITING WOLENCE OR THREATS OF VIOLENCE 1 264435 O(DmNCDO‘l-bQDN-‘k NNNNNNNé-k-A-A-xd-Aggd ggmwkwwdommflmmth-L ‘ ,.,:T? i H ’-..-_...I2 - ism .; RICHARD DOYLE, City Attorney(88625) . Zijifi Wag D 3 SqNORA FRINLANN, ASSIStant City Attorney (93249) ' NKIA D. RICHARDSON Sr. Deputy City Attorney (193209» Office of the City Attorney h m 200 East Santa Clara Street, 16’ Floor I 3L” San José, California 95113-1905 ' ‘ Teiephone Number: (408) 535-1900 Facsimile Number: (408) 998-3131 E-MaHAddress: cao.maln@sanjoseca.gov Attorneys for CITY OF SAN JOSE SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA P'a‘m‘ffl DECLARATION 0F STEVEN V SWENSON lN SUPPORT OF ' ‘LEUT'8%1§§E£"§h.%TTE§F°R I J N l G EQEEE‘YVSSE’YTEE 2E%J§o%%A¥1o WOLENCE-OR THREATS 0F . . ' ’ VIOLENCE AGAINST EMPLOYEE mciusuve, Defendants I, Steve Swanson, declare: 1. l am a Sergeant with the San Jose Police Department and currently assigned as an investigator for the Office of the San Jose City Attorney. 2. l have personal knowledge ofreach of the facts set forth in this declaration, and can testify competenfly thereto, except as to the matters stated on information and belief, and as to such matters | believe them to be true. 3. ln the course of my reguIar duties, I collected and reviéwed 15 voicemail messages left by Defendant Karen Vorster with employees within the City Attorney’s Office and the San Jose Police Department. l knew Ms. Vorster was the person speaking L DECLARATION OF STEVE SWENSON ISO PETITION FOR INJUNCTION PROHIBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE 1264780 O(OQNOCB-LOJN-A NNNNNNN‘AAJAAAAAAA ggmm-fiWN-‘OCOmNODUT-hQN-I in each message because she either identified herself by name or | was able to recognize her voice based on listening to her other messages. The 15 voicemail messages I reviewed were received between Monday, November 16 and Wednesday, November 18, 2015. ' 4. I first became aware of Ms. Vorster’s voicemail messages on Monday, November 16, 201 5. I reviewed messages which were left by Ms. Vorster on the Office’s main telephone line as well as with two individual senior deputy city attorneys. in the messages, Ms. Vorster referred to City Attorney Richard Doyle in derogatory terms and stated her intent to drive “his career and his family and his children and everyone he knows into the ground.” She explicitly vowed to “ruin” him. Ms. Vorster telephoned repeatedly on November 16, calling various attorneys in the office and indicating she was looking for Mr. Doyle and would “call every singie number until [she] found that yellow- bellied coward.” ln a message to on the senior deputy attorneys, she stated someone had “made it their persona! agenda to drive {their} boss into the ground.” True and correct copies of transcripts of Ms. Vorster’s voicemails referenced in this deciaration are attached hereto, collectively, as Exhibit A. 5. ln addition to the voicemail messages Ms. Vorster left for employees within the City Attorney's office, l also reviewed a voicemail message she left for the Chief of Police in which she referred to a “cop that was murdered, and it looks like suicide, in Chicago.” She went on to tell the Chief to “be careful when you answer the door” because “you don’t know who’s crazy out there and you don’t know what they’re going to do.” Ms. Vorster then made a connection to her earlier comments regarding a murdered officer in Chicago, stating ‘you should be careful because someone killed a cop in Chicago and it looks like a suicide.” l interpreted these comments to be viofent threats directed toward the Chief of Police and police officérs in general. Based on my experience and training, . Ms. Vorster’s comments caused me to fear for the safety of San Jose police officers. 2 DECLARATION OF STEVE SWENSON ISO PETITION FOR lNJUNCTlON PROHIBmNG VIOLENCE OR THREATS OF V1OLENCE AGAINST EMPLOYEE 1264760 (DmVODU'l-thA NNNNNNNNN-«x-A-LAAAAAAA mflmm-me-AOQOmNOUUI-hWN-AO 5. On November 18, 2015, l was informed by staff at the Office of the City Attorney that Ms. Vorster was making a pefsonal appearance in the office’s reception area and demanding to see City Afiomey Richard Doyle. By the time l arrived ih the area, Ms. Vorster had left. I am informed'and believe Ms. .Vorster came to the Office of the City Attorney after making a personal appearance at the Office ofthe Mayor and City Council moments before and that she had made a similar personal appearance in the reception area of the Mayor and City Councii Offices on Friday, November 13, 201 5. 5. l am inform-ed and believe the City of San Jose obtained an injunction against Ms. Vorster in 2007 arising from violent threats against a San Jose police officer assigned to conduct a criminal investigation of Ms. Vorster in 2006. I am also informed and believe that, during the course of the officer’s investigation, Ms. Vorster was found with a concealed and loaded firearm. Details of the investigation and threats mentioned above are contained in Exhibits 1 and 2 to the City of San Jose’s Request for Judicial Notice. 6. l have also reviewed arseries of messages Ms. Vorster left for the San Jose Police Department, Homicide Unit on November 18, 2015. In these messages, Ms. Vorster identifies herself as the “Interim president of the Hells Angeis” and rambles iIlogicaliy about her theory that poiice officers are not doing theirjobs and are being monitored by wiretaps. Ms. Vorster states those with ihe wiretaps are listening to officers “slowly breathe your last breath.” Despite Ms. Vorster’s assertion to the contrary, I interpreted her statement to be a threat against San Jose police officers. 7. In the voicemail messages left on November 18, 2015, Ms. Vorster specificaliy targets Jason Tanner, the San‘Jose Police Officer on whose behalf the City of San Jose previously obtained a restraining order against Ms. Vorster. In her recent messages! Ms. Vorster violently challenges Sgt. Tanner, stating “I am telling you now, Jason, you little pussy, how about l get a gun and you get a gun and let’s do the Western 3 DECLARAT‘ON OF STEVE SWENSON 180 PET1T10N FOR INJUNCTION PROHIBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE - ‘ 1254750 ©QNO§LD¢OJNA MNNNNNNNN-AAAAAAAqAA m V C) mvh (D N -¥ O CO m N O) U"! ~F 0) N _\ O thing." I interpreted this statement as a violent threat againét Sgt. Tanner and it causes me to be fearful for his safety. 8. In the course of my investigation into the actions of Ms. Vorster, l also reviewed two pofice reports. Report Nb. SJ 2015451730448 documents Lt. Mike Sullivan’s June 2015 interaction with Ms. Vorster in response to Ms. Vorster’s telephone cans to various police depagtment units. Report No. SJ2015-1 53080129 documents Ms. Vorster's interaction with an officer at the San Jose Police Department information Center and includes an allegation that Ms. Vorster told the officer “You’re a dead cop.” True and correct copies of San Jose Police Report Nos. SJ2015-151730448 and SJ2015- 153080129 are attached hereto, collectively, as Exhibit B. 9. l am fearful for the my own safety, the safety of employees at San Jose City Hall as we” as the safety of San Jose PoIice Officers at the various police facilities where they carry out theirduties based yon the foltowing: (1) my understanding of Ms. Vorster’s prior threatening behavior possession of a firearm; (2) Ms. Vorster’s voluminous email and voicemail messages, which haVe include violent and aggressive threats; (3) Ms. Vorster’s personal appearances at San Jose City Ha" and police facilities; and (4) my experience and training as a police officer. l declare under penalty of perjury 0f the laws of the State of California that the foregoing is true and correct, dated this Z 2 day of November at San Jose, Cafifomia. ,gg @J’v'v 3005 / 4 DECLARATION OF STEVE SWENSON ISO PETITION FOR lNJUNCTlON. PROHIBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE 1254760 EXHIBIT A KAREN JORDAN VORSTER PHONE MESSAGES NOVEMBER 16, 2015 - NOVEMBER 17, 2015 [Message left at (408) 535-1 954 at 9:14 am] Hi Ms. Clever, one more message for your yellow cowardiy, douchebag boss. Iwant him to be real clear on the knowledge that the homeless people that are increasing are directly related to him and his policies. He is so stupid. He does not understand that his decisions have directly led to ruining other people fives. I’ve personally requested to a high level friend of mine, who has the power to do it, to drive his career and his family and his children and everyone he knows into the ground. Every iast penny removed. To ruin him, just like he ruined other people. An eye for an eye. A tooth for a tooth. So l’m going to call back and since he’s so hard to set me up, breaking all the laws, l don’t want t0 hear any gifly whining about us breaking the law while fucking him over. Okay? Are we clear on that? Now look up Gordian Knot. That’s organized crime. The Gordian Knot, which is your boss, a judge, some cops, the Russian mafia, the Italian mafia, Mezzetti, Hells Angels. You got it, right? That’s the Gordian Knot. AH of you holding hands, doing sex trafficking, blocking over rape, child porn. it’s all good as long as you make your house payment. Right, douchebag? Well the Gordian Knot can be resolved two ways, thinking outside the box or cheating. So how about we play by your rules and we’ll cheat. Fuck you. [Message left at (408) 535-1 954 at 9:17 am} Hi Dear. I’m going to call back and I’m going to talk slowly about wiretaps because l don’t think you have the bandwidth to catch on. Richard Doyle is a corrupt politician. He’s been lying about me and now! understand he’s got his corruptjudge..Thank you very much for handing him over to us. It makes my job just so much easier. Anyway, he’s trying to get me blocked from the entire City to cover his sorry ass. What do you do with‘a man like that? The ultimate coward. l don’t know but I’ll come up with something. Anyway, he’s been lying about me and l’d like to discuss that with him, man to man. Assuming, of course, he is a man. I’m not too sure he is. I think he‘s sucked his balls so far up into his chest cavity he can’t even walk straight anymore. So, you my dear, you need to stop getting in the messagesdoc "I way and let me get through to Richard. He’s a lying piece of shit. And$ while he handed the corrupt judge over t0 me, i’m not quite through with both of them yet. He has my address. I have not received a notice in the mail. And the reason l have not received a notice in the mail is he’s trying to set me yet once again so l come down and he can arrest me. The probiem is the FBI is tistening to all of your phone conversations and tens me not to go down and when. You are all a bunch of fucking idiots. Now Richard, I‘m going to be calling you back and I want you to pick up the phone with your yellow little fingers. You’re day of ruining people’s lives is over! [Message left at (408) 535-1954 to at 9:18 am) Now I‘m going to try and speak slowly so you can understand. There’s something called an FBI wiretap. That’s what makes the FBI able to listen in on corrupt politicians and corrupt city attorneys, corrupt police officers, corrupt lawyers, corrupt administrative assistants. Okay. So, are you graSping that concept yet? What happened was, over a year ago, somebody found out that your city attorney and a bunch, whole bunch of other people in Silicon Valley were corrupt. Basically, when l called the Secret Service, I said the Sificon Valley justice system has been compromised and you can thank your boss for being a part of that and the corrupt judge he’s working with now in his second attempt, which he will fail at to set me Up. Now you need to explain to him, since he’s hiding behind all the women in the office, because that‘s what Beta men do, is that he’s already been caught. Everything’s been recorded. He might expect a Knock on a door at any moment. But you need to realize is you need to stop protecting him. He put innocent people in jaii. He ruined innocent peopie’s life. He didn’t think about it much because he’é not that bn'ght. He graduated from the University of Chico. That was the number one party school when he went to college. So he didn’t realty get an education. He’s an ignorant man with an ignorant agenda. And he is in Nguyen’s pocket. I can’t imagine anything more stupid than that. Vietnam is a third wortd country. And your stupid ass boss just jumped into bed with a third world. leader because he’d iike California to be a third world country. Good God! The corruptness and the ineptness of you and him and your entire group sickens me and sickens everyone else. And he has made someone so mad that they messages.doc 2 have made it their personal agenda to drive your boss into the ground. [November 16, 2015 - Message left from (408) 885-1000 t0 (408) 535-1 955 at 7:25 pm] Hi. My name is Karen Vorster. I’m trying to-get a hold of the idiot attorney, City Attorney Richard Doyle. He’s too much of a chicken shit to take my call direcfly so l dialed the next number up from his administrative assistant, an equally stupid person. Um, [wanted to inform him the FBI . . . (unintelligible) his phones for over a year now and he’s toast. Unfortunately, he’s not willing to take the calls personally because he’s too busy trying to set me up again. Um. If you could give him this message, tell him to pick up the phone when l call him. Since he’s going to so much trouble to set me up the least he can do is grab his balls and taik to me! [November 17, 2015-Message left from (408) 885 1000 to (408) 535- 1955 at 11.45 am] Uh yes, the case is Richard Doyle. This is Karen Vorster. Richard Doyle, l think, fled the crime scene after he found out he had been caught committing numerous felonies. Uh, and I’m calling for my reward. I turned in him and several other criminals and nd I‘m due a reward now. I’m trying to locate Richard. I don’t know. ls he on a plane somewhere to Mexico or the Caribbean? Where is Richard? Anyway, if you can tell him I’m looking for him, I’d appreciate it. Meanwhile, I’m going to call every singie number until I find that yellow-bellied coward. [Message left ~ unknown time and phone number] Hi Larry. This is Karen Vorster | m going to tell you the way this is going to go down. You’ re a psychopath and so is Mike Suuivan and we already know it. So um telling you what a shithead you are and how crazy you are isn t going to help Appealing to your empathy and sympathy isn’t going to help, see, because you arranged innocent people to die. So, l got rid of Sheriff Markarami [sic] in San Francisco and i’m going to get rid of you. He made the mistake of transferring a perfectly good officer off the shooting range to the jail system just like messagesdoc I 3 you got rid of Lt. Morales in homicide. See, Lt. .Moraies couldn’t solve any crimes because all of the people in his department were working for you and not solving murders on your behest and Mike’s behest. There was a cop that was murdered,rand it looks like suicide, in Chicago. You seem to think you’re the only people that can murder people outside the law and get away with it. But there’s another group, it’s called Blackwater, they actually do that for a living and they get paid for it just like you do (laughter). Interestingly enough, it’s legal for them to do it and it’s illegal for you to do it. Those darn details. So, I don’t know. l don’t know how that guy died. The cop, he was stealing from little kids. And it looked like a suicide but it turned out to be a murder. This must sound very familiar to you because you and Mike do this. So I think you can think this through. See, what happened was, the military got involved and they looked at you and they took a good long look at you and they Hstened to your recordings for hours and hours and hours, realized you were a psychopath and then realized you can only move in one direction because you don’t obey the law anymore so you’re highly predictable. So then they begin setting up markers for you to hit and you hit every single one. So, don’t be" surprised if all of your actions here on out are not really your own idea. You’ve just been following a plan. And you’ve been following it to the perfect goosestep of a Nazi. Now | need to find Mike. No one seems to be able to be able to find his special investigations number. Ijust don’t understand why you guys are such big shots but yet such cowards. You hide behind your handcuffs and guns and thejail and the mental institution. But you can’t hide from the military, the CIA and the NSA. Now, they’re giving you full range to hang yourself. Just be careful when you answer the door. l am. You know I’m careful when you answer the door. You don’t know who’s crazy out there and you don't know what they‘re going to d0. l just personally, you know, I’m being careful. You know, if I’m being careful, you should be careful because someone killed a cop in Chicago and it looks like a suicide. l think the CIA does that too. Anyway (unintelligible) [November 16, 2015 - Message to (408)535-1900 at 4:15 p.m.] i’m trying to get to Richard Doyle and since all of your men are hiding behind the chicks in the office, I’m going to have to keep calling until I get through to Richard Doyle. What Richard Doyie did is trying t0 set messagesfioc 4 me through a federal judge, or a judge, your Ioca! dirty judge. He has my address. Apparently, he’s put a some sort of I can’t contact anybody because it might expose Richard Doyle to his corruptness. And being the usual coward that he is did this whatever he did. Ijust heard about it through a call. Of course, Iwon’t tell who because l don’t kiss and tell, Richard. It’s your (unintelligible). Everyone’s after you now, dear. We’re all ganging up on you. You piece of shit. So, anyway, why don’t you just forward that document to me so you can try to arrest me again. Okay Richard? See, you didn't go to a very good law school so you’re not that very bright. | think that judge you’re working with, l don’t think he’s so bright either. I also know that he’s the one Carl Berg owns and Mezzetti owns. So, tell your judge he’s going t0 jail. And like l told the assistant who’s probably throwing up in the bathroom now, the FBI has had all your phones tapped for over a year. And we’re getting real tired of you acting like a little schoolboy thinking you can get away with the big man’s game. So Richard, the next time I call I expect you to pick up the fucking phone, okay? You little girl. And, yes, I am going to post t0 the website that is international - t does have international attention but mostly domestic - every single FBI office and aH the law enforcement. You’re going up there, dear, and I’m going to rain all over your parade. [On November 18, 2015 - Message from (650) 940-9327 to (408) 277-5283 at 11:08 a.m.] Hi yes, 'one of your unprofessional officers just hung up on me. You guys do that a lot because you are not solving any crimes. Anyway, | need to speak to my new husband Lieutenant Spamonte. I am the interim president of the Hells Angel World Wide and whoever l marry becomes head of the Hells Angels and that is head of the Homicide at your organization. Now l know all you boys don’t do anything all day and you are covering up murders. What we are going to do is we are going to take you all down. 1 am married to the head of Homicide whiIe we go through this so I am going to need to be able to speak to him, okay, and I know this is a major bummer for you guys. I mean you have gotten away with this so much and uh, there is people fighting a war over in Afghanistan and they are getting shot at and they are getting killed while you fucking cowards are pretending to be cops but you are actually Reno 911 and you are an embarrassment messagesdoc 5 to the United States of America and since your phones are tapped we are all Hstening to you slowly breathe your last breath and I know you guys are going to think that is a threat and all because you guys are yellow and you are not very brave and you are a bunch of fucking chickens but that is not a death threat. That is simply telling you that we are tired of lazy men who collect money and bitch about not making enough money while not solving any crimes. Now I don’t know whether it is because you are stupid or rather because you are ~ corrupt. I don’t reaily care ljust want you out of there. So we arejust going to keep doing this until you fold and trust me you are going to fold. [On November 18, 2015 - Message from (408) 851-1 000 at 10:09 a.m.] Nancy, I need you to 100k around a bit and pay attention, l am not under arrest. You say you are not taking calls from me, yeah you are. You are getting a call right now because you don’t have the power you had anymore. Now, l don’t know if you are doing Mike Sullivan, I think you are. You are probably doing Jason too and that is why you went to the dark side but I have been emailing steadily all the Iawyers, the prosecutors and the defense attorneys, the mayors . . . you are famous dear and I already said, she is sieeping with somebody. Anyway, um, I need to talk to Spamole, the new homicide guy. l guess he and I are in business now tracking down cold cases now that Lieutenant Morales isn’t there. I don’t mind changing partners, l do it all the time but meanwhile, lwant to talk more about you and your lack 0f ethics so I wilI just keep calling back and I need it in writing. You say, “you can’t call here anymore and report homicide” because police doesn‘t take homicide reports right, you guys don’t do that, you guys don’t solve crimes. So, I am going to need it in writing okay. got that Nancy? I am going to call back and see if you pick up [November 16, 2015 - Messae from (408) 851-1 000 at 12:04 p.m.] You better hope you didn‘t make a bad decision in firing the wrong person because the people who aren’t solving crimes is the homicide cops in homicide. Now I don’t know if Lieutenant Morales is dirty or not but I don’t think he is. That means all you dirty cops ganged up on messagesdoc 6 the wrong guy so you better hope you made the right decision. Now pick up the phone cause I am calling you back little girly girl. {November 13,2015 - Message from (408) 851-1000 at 4:53 p.m.] So, my first ca" was about 10 to 5:00 and the entire Homicide Department is off, out, left Friday. Right, you are all gone. Lieutenant Morales is not around so you all left. lt is not like you guys actually report to Lieutenant Morales anyway, do ya? So, this is what you are doing, some of you arrested the same guy probably Jason Tanner was involved in this, because he doesn’t work for a living. You arrested a Mexican man seven times even though his middle name was different from the person that actually murdered five families. The reason why you arrested the same man seven times is because you did not want to arrest the real man that killed five families. Everybody knows that you are allowing murder to take place, you are covering up crimes and you are activety involved in it. Everyone knows. We can’t arrest ah of you because the City can’t handle it and you know that so that why you are sticking around getting your salaries cause no one knocked on the door yet; So, if we anested all 50 of you there is not enough officers to replace you and then we would have to let all the peopie you arrested out because you are all a bunch of idiots. So, you have some innocent people in jail, Jason you know all about that don’t you, and then you have some guilty people in jail that can say they are innocent because you are all inept. Then they will turn around and sue the City and bankrupt the City a little bit sooner then you assholes were planningon bankrupting the City. And then Sam Liccardi, your Mayor, will lose all credibility and then We will have anarchy. So, I want to thank you very much for ruining the City 0f San Jose and none of you deserve a salary and you are all just fucking around doing whatever you want undermining Lieutenant Morales because you are all involved in conspiracy to commit murder organized crime and other crap. So, in case you haven’t heard all of your telephone conversations have been recorded the last year, over a year, this includes you sittingin your car when your phone is not on and you are not on it when you are taiking. If you are talking to a buddy, that Was recorded too because the FBI can record alt your conversations through an off cell phone and all the equipment in your car. On top of that the NSA was also masagwdoc 7 listening in 0n you and the CIA. Every single crime you have committed in the last over a year has been documented and recorded and systematically we are going to take every single one of you down, one by one. [November 13, 2015 - Message left from (408) 851-1000 at 4:48 p.m.] Hi, yes, I am calling for Nancy. I am really surprised and disappointed she did not pick up. This is Karen Vorster Nancy. Um, you and l need to have a littie chat. l need to know how tong you have been undermining Lieutenant Morales. Clearly you lied to me on the phone numerous times today with the clear intent of finding an officer who could come down and arrest me. Um, Ithink you are sleeping or having sex or fucking Mike Sullivan or Jason Tanner. You are fucking somebody. You are fucking over Lieutenant Morales and you are fucking Somebody else. So, you are up to something. You are not a good employee. You are not a good steward of Homicide. You are on the wrong side and I am going to get you fired. [October 23, 2015 ~ Message left from (408) 770-8041 at 11:20 am. ] To avoid Homicide being the continued laughing stock of Caiifornia, let me tell you a little secret. Safeway has an insider to the Hells Angels and when a Safeway patron uses their card while they are shopping they then will investigate to see where they live and What their money is and what their money habits are and this one particular individual, an insider, a friend of a friend wiH keep track and when they start shopping at South Lake Tahoe and buying baby food and dog food, he knows that the entire family is up in South Lake Tahoe. So then he puts into gear his litfle burglary, Inc. division and they go rob the house and that is done under the protection of the police. I am not saying all the police, l am saying it is a very few number ofthe police but the problem is that it works because all of you are afraid of the few. So, this also works for murder so if you want to murder somebody and you know they are going to South Lake Tahoe or Lofiand or something like that you can assassinate them whiIe they are out of your territory. San Jose has a nice little deal that they can assassinate people in the Bay area and then all your cops are induded and they don’t investigate certain murders. They all got the nod, wink wink, we don’t investigate that one. So, I jokingly said if like messagesdoc 8 say you know Mike Sullivan ends up dead, don’t bother investigating because we will all know who does it. Mike Sullivan is someone who does it. Okay, weH | am st“! trying t0 get his threat in writing and 1 am still trying to get him on the phone and I am still trying to get that wetback, pussy motherfucker Jason on the phone and you know it is amazing he just won‘t pick up. He is such a manly man when he is questioning you in that sort of half ass way but when it comes to push and shove and you have to man up, you can’t find Jason. So, I don’t know you guys got to be careful. if l were you I would not go on a call with Jason, you know. He can’t be trusted you know he can’t be trusted. Can you guys pass on to Mike SuHivan that Bill Murray in the Stripe when psycho guy says . . . (unintelligible) and the lieutenant interrupts and says one of these days this guys might have to protect 'you. [October 23, 201 5 -Message from (408) 770-8041 at 8:26 a.m.] I want to be reaHy specific so let’s make sure we get this recorded. Cops who don’t have other cops backs could be a problem. Jason Tanner you don’t play by the rules. You pretend to have cops backs but you don’t. You let them take the fall for you. You let people die. You are a cop that does not have other cops backs. You are dangerous. You Iet peopie die. There was that BiH Murray movie. Oh it was hilarious. You remember Stripes. The sergeant cans everybody together and says this guy might have your back. He might be the one to save you. Bill Murray goes, and then again, maybe not. Tanner you are the maybe not guy and not in a good way. You are not funny, you are not a comedian, you are just an idiot who lets other. people take the fall. So l am telling your fellow cops here, all your brothers in there, Jason Tanner will fuck you guys over. Jason Tanner does not have your fellow cop's backs. If you do not do what Tanner tells you to do he will murder you. He is involved in organized crime. He is the one that makes your people die so if you do not do what Tanner does, you will get killed. So I am thinking, maybe everyone should not do what Jason Tanner tells them to do. Cause maybe l will just take care of Jason Tanner. Now what does that mean, taking care 0f Jason Tanner. Well, Jason, iet me'tell you straight up, let me spell it out for you, just like I did with Steve Townsend, l am going to do exactly to you what you did to me. That seems fair. So you can go to a prosecutor and try and get the law on messagesdoc 9 [November 20, 2015 - Message from (408) 851-1000 to (408) 277- 5283 at 10:30 a.m.] Tell my new husband to meet me at the PAL, San Jose organization playoffs today, whatever it is. I will be there at 5:30 and tell him the CIA will be watching his every move messages.doc 1 1 EXHIBIT B i SAN JOSE POLICE LPT LAW ENFORCEMENT/CRIMJNAL JUSTICE AGENCIES HARDCOPY G0# SJ 2015451730448 , INFO-l INFORMATION ONLY General Offense Information Reported on: Jun-22-2015 (Mom) 1340 Occurred on: Jun-22-2015 (Mom) 1340 Report submitted by: 3301 Address: 260 COMMERCIAL ST Place: INNVISION COMMERCIAL ST Municipality: SAN JOSE District: DV Beat: V2 Grid: ‘132 Offenses (Completed/Attempted) Offense: # 1 INFO-l INFORMATION ONLY - COMPLETED 2015451730448 Page of SAN JOSE POLICE D’JT LAW ENFORCEMENT/CRIMINAL JUSTICE AGENCIES HARDCOPY GO# SJ 2015451730448 INFO-l INFORMATION ONLY Related Person] s) 1. Other # 1 - VORSTER, KAREN (Case Specific Information) Sex: FEMALE Race: Caucasian Date of birth: Jul-12-1960 Address: 260 COMIVIERCIAL ST Place: INNVISION COMMERCIAL ST Municipality: SAN JOSE , California District: DV Beat: Grid; 132 2015451730448 Page of SAN JOSE POLICE LHPT LAW ENFORCEMENT/CRIMINAL JUSTICE AGENCIES HARDCOPY (30¢; SJ 2015451730448 INFo-l INFORMATION ONLY Related Text Page(s) Document: NARRATIVE Author: 3301 - TRAYER TODD L Related dateftime: Jun-22-2015 (Mom) Narrative: On 06/22/15 at approximately 1340 hrs, I was assisting Lt. Sullivan #2782 on an annoying phone calls investigation. I observed Lt. Sullivan speaking with Jordan Ashely Dryer or Jordan Vorster, or Karen Vorster as they stood on Commercial St. at 7th purposes ofmemorializing the contact. St. I advised Lt. Sullivan that I would document this interaction for the Lt. Sullivan advised me that Ms. Vorster had made a series of calls to many different units and that the number of constant calls was interfering with employee?s work as well as were vaguely threatening in nature. Lt. Sullivan advised that he had spoken to the City Attorney‘s Office who recommended he speak to Ms. Vorster and advise her to only make calls when it was pertinent to the daily functions of police service. Refer to his supplemental for details of the issue. Today I saw Lt. Sullivan speaking professionally to Vorster as I stood across the street. Icreated this event with Communications t0 document the contact. As I walked across the street, Iheard Ms. Vorster say, "You were sent to shut me up!" to Lt. Sullivan. Iheard him explain that she has been calling so many times and the nature of those calls are interfering with work at the San Jose Police Department. Ms. Vorster asked for Lt. Sullivan's name and badge number. He ofl‘ered to write that information down and she said, "Just write it on a piece ofpaper." He said he did not have a piece ofpaper, but would get one. Lt, Sullivan went into the InnVision business located on Commercial St. t0 get paper. Lt. Sullivan returned with his name and badge number (perhaps a phone number?) vm'tten on a piece ofpaper and provided it to Ms. Vorster. She took the paper fiom Lt. Sullivan and kept repeating that she thought he (Lt. Sullivan) was working for Det. Jason Tanner. She thought Lt. Sullivan was flying to intimidate her by him going into InnVision (where he went to get a piece ofpaper.) 2015451730448 Page of SAN JOSE POLICE LAPT LAW ENFORCEMENT/CRIMINAL JUSTICE AGENCIES HARDCOPY Go# SJ 2015451730448 INF0-1 INFORMATION ONLY Ofc. Dan Anderson was present and had a brief conversation with Ms. Vorster while Lt. Sullivan went into the InnVision to get that paper. I ensured the event captured that Ms. Vorster was not under arrest, not curb-sat, and not handcuffed Her items were not searched by any officers during this contact. This was Lt. Sullivan’s opportunity to speak to her about the numerous phone calls and advise her that if she continues to do so, she could be held accountable for cn'minal 653m Violations. A END OF NARRATIVE 2015451730448 Page 0f SAN JOSE POLICE LAPT LAW ENFORCEMENT/CRIMINAL JUSTICE AGENCIES HARDCOPY Go# SJ 2015451730448 INFo-l INFORMATION ONLY Related Text Page(s) Document: SUPPLEMENTAL Author. 3301 - TRAYER TODD L Subject: LT. SULLIVAN'S SUPPLEMENTAL Related date/time: Jun-22-2015 (Mom) Supplemental: Lt. Sullivan provided me the following supplemental to put into this report. On 6-22-15, at approximately 1340 hrs., I was working in a plainclothes capacity attached to the San Jose Police Department's Special Investigations Unit. At this time, Ofc. Dan Anderson #3 177, Sgt. Todd Trayer #3301 and I made consensual contact with Other Vorster on Commercial St at N. 7th St. The purpose of this contact was t0 Ask Other Vorstcr to stop calling and/or emailing Lt. Tom Morales and Ofc. Jason Tanner from the San Jose Police Dcpaflment's Homicide Unit. Since April, 15, 2015 Other Vorster has emailed the Homicide Unit over 50 times and has called approximately 20 times. The emails talk about an imaginary murder conspiracy plot involving Ofc. Tanner and an outlaw motorcycle gang. Other Vorster also believes the San Jose Police Department is covering up numerous other crimes involving their officers. These emails and calls have gotten t0 the point where it is affecting the efficiency ofthe Homicide Unit. In 2007, Other Vorster was sending similar but more Threatening emails to Ofc. Tanner, when he was a member of the Assaults Unit. The San Jose City Attorney‘s Office was forced to obtain a restraining order against Other Vorstcr. Once the restraining order was served, all communication between Other Vorster and Ofc. Tanner ceased for the duration of that order. In April, 201 5, Other Vorster began initiating communication again with Ofc. Tanner and Lt. Morales of the Homicide Unit. I made contact with the City Attorney's Office who directed me to contact Other Vorster and explain to her that she should only call or email the police department With real emergencies, crimes in progress, follow-up 0n a case 0r with a citizen complaint. Officer Anderson and I made contact with Other Vorstzr at her vehicle, which was parked near Inn-Vision. I introduced myself and Other Vorster pleasantly agreed to talk to me. I explained I was there to ask her on behalf 0f the San Jose Police Department t0 please stop calling and emailing the Homicide Unit, specifically Lt. Morales and Ofc. Tanner. Other Vorster immediately denied ever calling or emailing anyone frOm the Homicide Unit. Itold Other Vorster thatI have seen numerous emails showing she in fact has made contact with members of the Homicide Unit, which she replied "Lt. Morales said it was 0k for me to call, and I have only sent two emails." I again reminded Other Vorster to not contact the San Jose Police Department unless she had oficial/legitimate business. Vorster became upset and told me "I want that in writing." Other Vorster then called Ofc. Tanner a coward for sending me to do his dirty work and asked for my business card. I didn't have a business card or an 201 5-151730448 Page of SAN JOSE POLICE LdPT LAW ENFORCEMENT/CRIMINAL JUSTICE AGENCIES HARDCOPY G04: SJ 2015451730448 INFo-l INFORMATION ONLY orange card on my person so I got a pen and paper fiom Inn-Vision staff. Iwrote my name, badge number and City cell phone down for Other Vorster. I also gave the Inn-Vision staff the same information just in case Other Vorster misplaced my contact info. I returned to Other Vorster and handed her my contact information. Other Vorster was telling Sgt. Trayer that she emailed Ofc. Tanner twice and that I showed up to try t0 intimidate her by going into Inn-Vision. Other Vorster related to me that she will be complaining to IA since I was jumping to Ofc. Tanner’s defense while he is being accused ofbeing involved in organized crime and conSpiracy t0 commit murder. She also stated that Santa Clara Police and Santa Clara County Sherifi‘s Office personnel were part of the conspiracy. As she walked away, Other Vorster glared back zmd stated that she will not be intimidated by me. During my Consensual contact with Other Vorster, she asked if I was recording our cbnversation and I answered "yes." I attempted to retn'eve the conversation offmy personal cell phone. I found a one minute and 18 second conversation that cut off after I said hello to Other Vorster. End of Report 2015-] 51730448 Page 0f SAN JOSE POLICE 1. .JPT LAW ENFORCEMENT/CRIMINAL JUSTICE AGENCIES HARDCOPY Go# SJ 2015151730448 . INFGI INFORMATION ONLY m END 0FHARDCOPYm 2015451730448 Page of SAN JOSE POLICE DEPT LAW ENFORCEMENT/CRLMINAL JUSTICE AGENCIES HARDCOPY *** OFFICIAL USE ONLY *** GO# SJ 2015453080129 » 5150-1 5150 WI 72 HR MENTAL HOLD m OFFICIAL USE ONLYm Purpose: SJPD OFFICER COPY Date released: Nov-05-2015 ('I‘hu.) 839 Authorized by: 3177 Released by: 3177 RELEASED TO Business name: SJPD Surname: D. ANDERSON #3 177 ***DISCLAIMER*** For official use only. Pfinted On: Nov-OS-ZOIS (Thu) l SAN JOSE POLICE LAPT LAW ENFORCEMENT/CRIMINAL JUSTICE AGENCIES HARDCOPY *** OFFICIAL USE ONLY *** 5150-1 5150 WI 72 HR MENTAL HOLDGO# SJ 2015453080129 General Offense Information Reported on: Nov-04-2015 (Wed.) 721 Occurred 0n: Jul-21-2015 (Tue.) 721 Report submitted by: 3319 Address: 201 W MISSION ST Municipality: SAN JOSE District DV Beat: V1 Gri¢ 135 Offenses (Completed/Attempted) Offense: # 1 5150-1 5150 WI 72 HR MENTAL HOLD - COMPLETED 2015453080129 Page of SAN JOSE POLICE LMPT *** OFFICIAL USE ONLY *** LAW ENFORCEMENT/CRIMINAL JUSTICE AGENCIES HARDCOPY GO# SJ 2015-153080129 V 5150-1 5150 WI 72 HR MENTAL HOLD Related Persomsz 1. Suspect # 1 - VORSTER, KAREN JORDAN (Case Specific Information) Sex: FEMALE Race: Caucasian Date 0f birth: Jul-12-1960 Address: 1111 MORSE AV Apartment: 34 Municipality: SUNNYVALE , California 94089- 32mm Drivel’s license: N6687801 California Ethnicity: CAUCASIAN Language(s) spoken: English Height: 5'04 Weight: 140 lbs. Build: Heavy Complexion: LIGHT Eye color: GREEN Hair color: BLOND 0R STRAWBERRY Hair style: Collar Length Related Vehicleis) 1. Suspect # 1 - 6ZZN195, CA (Case Specific Information) License number: 6ZZN195 State of issue: California Vehicle type: AUTOMOBILE Make and model: Honda Accord / Accord Crosstour Style: 4BR AUTOMOBILE Year: 2013 2015453080129 Page of SAN JOSE POLICE L&PT LAW ENFORCEMENT/CRIMINAL JUSTICE AGENCIES HARDCOPY *** OFFICIAL USE ONLY *** GO# SJ 201 5-153080129 5150-1 5150 WI 72 HR MENTAL HOLD Related Text Page(s) DmmnwmINARRAflIVE Author: 3319 - ENDERLE,ERICK H Related date/time: Nov-04-2015 (Wed.) 1404 On the listed date and time I was walking out of the SJPD info center located at 201 W. Mission St. and was approached by Sl. S1 began speaking to me by saying,"Can I ask you something?" Sl became agitated and began raising her voice and stated that I needed t0 stop selling drugs and stop smuggling drugs into the jail. I advised Sl that she needed t0 leave the police campus and I directed Sl towards the stairs; Sl began walking down the stairs and continued accusing me of selling drugs and smuggling drugs into the jail. As we got to the bottom of the stairs, Sl turned towards the parking lot and I again directed Sl to leave. Sl started walking towards her vehicle. Sl continued walking, Sl stopped and looked at me and stated, "You're a dead cop." Sl also stated, "You're a dead duck." I perceived Sls threat as real due to her aggressive and belligereht behavior and I feared for my safety. I placed Sl in handcuffs and Sl began to shout, "Kill me, somebody shoot me. I want to die. The police are trying to kill me." AS I went to place Sl into my patrol vehicle, Sl kneeled down and began to vpray and spoke incoherently. After a few minutes Sl collapsed to the ground and laid on her side- ' Paramedics responded to the scene and provided medical attention to Sl. I placed Sl on a 5150 hold due to her statements of saying I was a dead cop. It is apparent that Sl is an ongoing threat and danger to the community and to the safety of officers. Sl was transported to VMC EPS. 2015453080129 Page of SAN JOSE POLICE 1,“va LAW ENFORCEMENT/CRIMINAL JUSTICE AGENCIES HARDCOPY Ht OFFICIAL USE ONLYm G0# SJ 2015453080129 5150-1 51 50 WI 72 HR MENTAL HOLD w END 0F HARDCOPYm 2015453080129 Page of RICHARD DOYLE, City Attorney (88625) NORA FRIMANN, ASSIstant City Attorney (93249) NKlA D. RICHARDSON, Sr. Deputy City Attorney (1 93209) Office of the City Attorney h 200 East Santa Clara Street, 16* Floor San José, California 95113-1905 Telephone Number: (408) 535-1900 Facsimile Number. (408) 998-3131 E-MaitAddress: cao.main@sanjoseca.gov Attorneys for CITY OF SAN JOSE SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA FAMILY COURT DIVISION CITY 0F SAN JOSE, Case Number: '07wmgqg ' P'ainfiffl DECLARATION 0F JASON TANNER V IN SUPPORT 0F PETITION 0F - EMELOYER FOR INJUNCTION - PR HIBmNG VIOLENCE 0RKAREN VORSTER aka JORDAN ASHLEY DREYER and DOES 1 to 1o, EfiEgSEaFSy'OLENCE AGA'NST inclusive, Defendants. l, JASON TANNER, declare as follows: 1. l have personal knowledge of the matters set forth herein and, if called as a witness, could and wo’uld competentiy testify thereto except as to those matters stated on information and belief. As to those mattérs, l believe them to be true. 2. l am a detective assigned to the Homicide Unit of the San Jose Police Department. l met Karen Vorster aka Jordan Ashley Dreyer (hereinafter Vorster) dun'ng the course of my investigation into criminal threats (a violation of Penal Code seétion 422) allegedly made_ by Vorster against a female victim, the wife of a man with whom Vorster had an affair years prior. The threats communicated by telephone included threats of violence. l DECLARATEON OF JASON TANNER ISO PETITION OF EMPLOYER PROHIBITING VIOLENCE OR THREATS OF VIOLENCE 1265070 (0 m N O) U‘I A (.0 N’A NNNNNNNNN-l-La-xAA-xqu QNOU’IAwN-LOOmNQUI-hWN-IO Vorster had.also allegedly made several threatening phone calls to one of the man’s friends, culminating in her leaving some items including a hammer and a doll’s head outside his place of employment. When she was stopped by police leaving that location, the officers found a loaded firearm in her vehicle and arrested her for possession of a concealed firearm and canying a loaded firearm. 3. On December 13, 2006, I first made contact with Vorster in connection with the criminal threats investigation. DUring the course; of my interview of Vorster, she acknowiedged making some calls and spoke about numerous conspiracy theories. Based on my interviews with Vorster and others, I came to believe, and continue to believe she has a mental illness. 4. After my initial interview with Vorster, she immediately began to contact me in a persistent, annoying and harassing manner that continued for several months until my employer; the City of San Jose, sought and obtained a restraining order against Vorster on my behalf in July 2007. A true and correct copy of the 2007 Petition of Employer for V Injunction Prohibiting Violence or Threats of Violence Against Employee (hereinafter “2007 Petition") is attached as Exhibit 1 to the City of San Jose’s Request for Judiciél Notice. 5. Vorstefs 2006 and 2007 contact with me consisted of paranoid, delusional and rambling emails and voicemails entirely unrelated to the underlying criminal threats investigation. Her emails and voicemaiis contained statements about her numerous conspiracy theories but also contained violent and disturbian references. I included copies. of some of the emails as an exhibit to the declaration I submitted in support of the City’s 2007 Petition. A true and correct copy of the 2007 Declaration of Jason Tanner (hereinafter “2007 Declaration") is included as part of Exhibit 1 to the City of San Jose’s Request for Judicial Notice. 6. Although I made numerous requests that Vorster stop contacting me, she continued to send strange emails, which eventually changed in tone and became‘threatening in nature. Over a three month period from May through July 2007, Vorster sent profanity- 2 DECLARATION OF JASON TANNER ISO PETITION OF EMPLOYER PROHIB‘ITING VIOLENCE OR THREATS OF VIOLENCE 1265070 CDWNODU'IAQJN-J NNNNNNNNNA-xéd-Ldggég mem$c0NAOCDmVO3m$WNAO laced, aggressive and threatening emails and voicemails to me which inciuded statements such as: o The noose is getting tighter and tighter FOR YOU. .. (May 31, 2007 email, 5:50 pm) o Now let’s not find you dead in someone‘s backyard. BACK OUT NOW. And that's a warning and a promise. (June 18. 2007 voicemail, 8:21 am) o Apparently you didn’t realize the game you were playing. It‘s called a bullet between the eyes [unintelligible]. Now strap your board on tight because this is a game you chose when you [unintelligible] and .you’re now not ailowed out of the game. So tomorrow we want the Chief of Police on a platter and we will get what we want bitch; (June 20, 2007 voicemail) I o Someone is cutting your throat Tanner - now I want you to go to the little b'oys room and look in the mirror - so you can see who is cutting your throat. (July 3, 2007 email entitled “who’s slitting your throat?”) A more detailed account of‘the numerous threats l received from Vorster in 2006 and 2007 is contained in my 2007 Declaration which is attached to the City‘s Request for Judicial Notice at Exhibit 1. 7. As of Juiy 2007, l had been a police officer for fourteen years and, deSpite years of dealing with upset and angry people, l had never come into contact with someone who caused me as much concern for my safety as Vorster did. Her behavior was erratic, hostiie and highly unstable and she appeared to have no boundaries. She was found with loaded firearm after being stepped regarding cn'minal threats to others. I 8. Earlier this year, Vorster began resumed sending emails t0 me. At first the emails again expressed paranoid conspiracy theories. Recently, however, Vorster has resumed ieaving threatening voicerfiail messages in addition to sending emails. InterSpersed in her lengthy rants are references to vioience directed toward me and police officers in general: 3 DECLARATION OF JASON TANNER ISO PETITION OF EMPLOYER PROHIBITING VIOLENCE OR THREATS OF VIOLENCE 1265070 NNNNNNNNN-AAAAAAAAAA mVOU‘IbWN-‘OOQNQUIAOJN-IO (DWNQU'IAOJNA Hi Tanner. Why did you try so hard to put me in jaii when | was in South Dakota? Jason ~ Assume the worst. ‘ .. .Chief, (Jason - this would be your chief)...l wanted to add to my recorded statement. l mentioned a mental institution in South Dakota. [was in that mental institution because of Jason Tanner...| was sewed Jason's restraining order while locked in 'this place. The Doctor told me not to worry about it because l was not able to defend myself. l plan on defending myself now. (June 23, 2015 email) After Jason Tanner set me up to protect Steve Tausen l called my ex lover, Terry Tucker, Chief Engineer of the F16 Fighter Program. He called the Seéret Service. The Feds have been recording the conversations of all the cops and lawyers and Judges in this area for over one year. It’s over. Now cops like Jason and Mike have very few choices. If the feds came in today and arrested the corrupt cops they would have to let out all the prisoners that these guyé put into jail. Then the prisoners would sue and they would win and San Jose would go bankrupt. Also if this level of corruption got out cops would start getting shot in the back and frankly a lot of people would say they had it coming. The problem is the wrong cop may get shot in the back. (November 18, 2015 email about Jason Tanner to Sgt. Bran‘don Sanchez) You cannot bring on the new police auditor. He is corrupt. Steve Angel of Internal Affairs is corrupt. Nancy of Homicide is corrupt. They are bring [sic] in their ringer from LA so they can keep Mike Sullivan, Jason Tanner, Steven Angel, Nancy and Richard Doyle. You must break the back of this organized clan. They are in too deep and have only one choice. To go down with the ship. True and correct copies of the June 23 and November 18, 2015 emails referenced above are attached hereto as Exhibit A. l/l 4 DECLARATION OF JASON TANNER ISO PETITION OF EMPLOYER PROHIBITING ViOLENCE OR THREATS OF VlOLENCE 1265070 COWNODU’IACON-L NNNNNNNNN-AAAAAA-xgga memkWN-‘OCDWNC’UT#WN~¥O 9. On October 23, 2015, Vorster made the following threatening Statements in voicemail messages she left with my office: 0 I want to be really specific so let’s make sure we get this recorded. Cops who don’t have other cops backs could be a problem. Jason Tanner you don’t play by the rules. You pretend to have cops backs but you don’t. You letthem take the fall for you. You let people die. You are a cop that does not have other cops backs. You are dangerous. You let people die... So I am telling your fellow cops here, all your brothers in there, Jason Tanner will fuck you guys over. Jason Tanner does not have your fellow cop‘s backs. If you do not do what Tanner tells you to do he will murder you. He is involved in organized crime. He is the one that makes your people die so if you do not do what Tanner does, you will get killed. So l am thinking, maybe everyone should not do what Jason Tanner tells them to do. Cause maybe I will just take care of Jason Tanner. Now what does that mean, taking care of Jason Tanner. Well, Jason, let me tell you straight up, let me spell it out for you, just like I did with Steve Townsend, I am going to do exactly to you what you did to me. That seems fair. So you can go to a prosecutor and try and get the law on your side because you know, they are all set up for that, but l am thinking mono y mono, fair is fair. I called Steve Townsend up and I said, hey Pussy, you are fucking all these girls over and you are raping everybody and kiHing everybody, how about you get a gun and I get a gun and we w_ill just duel this out. ‘So, he called you. So, l am telling you now, Jason, you little pussy, how about l get a gun and you get a gun and let’s do the Western thing. Oh, are we taping me now little pussy. (October 23, 2015 voicemail, 8:26 am)1 10. Based on Vorster's history of erratic, hostile and unstable behavior, her prior possession of a loaded and concealed firearm and her recent threatening emails and voicemails, I am fearful for my safety. I am concerned that Vorster’s fixation with me has not ceased. l am informed and believe she has made personal appearances at police department facilities and at City Hall, ah of which I frequently access in order to carry out my job duties as a detective. | am fearful for my safety as well as that of my feilow employees who Work in the facilities to which Vorster has sought access, not only because of her volatility but because l am informed and believe Vorster has expanded the reach of 1 A true and correct copy of the transcribed text of the referenced voicemail is attached as Exhibit A to the Declaration of Steven Swenson‘ 5 DECLARATION OF JASON TANNER ISO PETITION OF EMPLOYER PROHIBITING VIOLENCE OR THREATS OF WOLENCE 1265070 O(DWNGO‘IAOJNA NNNNNNNNN-L-x‘x-LAAAAAA mflmm-hWN-AOCDWNOUI#OON-‘ her threatening communicationsgas demonstrated by the other people who are copied on and referenced in the emails Vorster has been sending to me. I declare under penalty of perjury that the foregoing is true and accurate and that this declaration was executed this Zamday of November 201 5, at San Jose, California./_ QQQSk \C‘uku/L/ wnner 6 DECLARATION OF JASON TANNER ISO PETITION OF EMPLOYER PROHIBITING VIOLENCE OR THREATS OF VIOLENCE 1265070 EXHIBIT A Larcher, Mafiie From: Sullivan, Michael E (PD L‘D Sent: Tuesday, June 23, 2015 11:38 AM To: Richardson, Nkia Subject: Fw: South Dakota Cops did not follow through with Jason's requests Last one for now. Sully From: Morales, Thomas (PD) Sent: Monday, June 22, 2015 3:24 PM To: Suilivan, Michae! E (PD LT) Subject: Fw: South Dakota Cops did not follow through with Jason's requests Lt. Tom Morales #2907 San Jose Police Department Bureau of Investigations I Homicide Unit Commander Ofice: 408-2 77-5283 Direct Line: 408-537-1465 From: Jordan Karen Vorster ' Sent: Saturday, June 20, 2015 4:52 PM To: Tanner, Jason Cc: san.fra ncisco@ic.fbi.gov Subject: Fw: South Dakota Cops did not follow through with Jason‘s requests Hi Tanner. Why did you try so hard to put me in jail when lwas in South Dakota? Jason - Assume the worst. Chief, (Jason - this would be your chief) Further updates for the Office of the Independent Police Auditor and you get the update also l wanted to add to my recorded statement. I mentioned a mental institution in South Dakota. | was in that mental institution because ofJason Tanner. l 1 l sat for hours in the South Dakota police station Without handcuffs and the door open while the younger cops waited for their boss to come in. Soon l could see an older man clearly in charge on the phone for hours sorting things out. In the end a woman cop came in and asked ifl was comfortable and told me San Jose Police wanted me back but they decided they were going to keep me. (Guess those South Dakota cops are more brave than your basic San Jose cop) They said San Jose wanted me injail, (but it was just Jason and his boss that wanted me in jail, Tommy) they put me in a mental institution instead. A very nice one | might add, until they could sort out what San Jose Police were doing. That is a quote. Jason's friends sent lots and lots of documents t0 the doctor. The doctor told me after we talked how impressed he was with me, my sense 0f humor and my social skills. He released me saying l was harmless. lwas served Jason's restraining order while locked in this place. The Doctor told me not to worry about it because l was not able to defend myself. l pian on defending myself now. [was asked why I was I was in South Dakota and l said to meet the hells angels since they were running the San Jose Police and l was going to ask Pee Wee if he could please get his vices under control. As you all now know that is exactly what I am doing so I was telling the truth. Jason, do you still have a job? Does anyone respect you? Richardson, Nkia From: Jordan Tucker Sent: Wednesday, November 18, 2015 12:27 PM To: Sanchez, Brandon Cc: Liccardo, Sam Subject Hello Brandon Follow Up Flag: Follow up Flag Status: Hagged WWW.VOlR-DIRE.NET Will send you the other website later. AfterJason Tanner set me up to protect Steve Tausen I called my ex lover, Terry Tucker, Chief Engineer of the F16 Fighter Program. He called the Secret Service. The Feds have been recording the conversations of all the cops and lawyers and Judges in this area for over one year. It's over. Now cops like Jason and Mike have very few choices. If the feds came in today and arrested all the corrupt cops they would haVe to let out all the prisoners that these guys put into jail. Then the prisoners would sue and they would win and San Jose would go bankrupt. Also if this Ievel of corruption got out cops would start getting shot in the back and frankly a lot of people would say they had it coming. The problem is the wrong cop may get shot in the back. If you recall, when New Orleans got hit with Katrina the Court House got flooded and they ended up having to release lots of prisoners as their records were destroyed. It is a little known fact that six officers were shot a short time after. Brandon, I do hope you can read between the lines and pass this around. Your corrupt cops are playing with fire and your lives - not theirs. The two detectives that were murdered in Santa Cruz were investigating the influx of Organized Crime and their murders were a hit. That is who your corrupt cops are in bed with. Regards, Karen Vorster AKA Jordan EXHIBIT C A OLDmVODOIAOON RICHARD DOYLE, City Attorney (88625) {5; {jNORA FRIMANN, Assistant City Attorney (93249) NKIA D. RICHARDSON, Sr. Deputy City Attorney (193209) 2915 NU” 29 p 1 Office ofthe City Attorney m 6 ‘ - J-200 East Santa Clara Street, 16 Floor '- a San José, California 951 13-1905 Telephone Number: (408) 535-1900 Facsimile Number: (408) 998-3131 7) m . E-Mail Address: cao.main@sanjoseca.gov 0/ Attorneys for CITY OF SAN JOSE Q? SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA FAMILY COURT DIVISION CITY OF SAN JOSE: Case Number: IOQGH900qu Plaintiff: REQUEST FOR JUDICIAL NOTICE IN V SUPPORT OF PETITION OF ' EBRAIO’IEHOYER FOR ORDER BITING VIOLENCE ORKAREN VORSTER aka JORDAN ASHLEY DREYER, and DOES 1 -10, THREATS 0F VIOLENCE inclusive, Defendant. REQUEST FOR JUDICIAL NOTICE Plaintiff City of San Jose respectfully requests that this Court take judicial notice of the foilowing items, pursuant to Evidence Code § 452: 1. Amended Order After Hearing on Petition of Employerfor Injunction Prohibiting Violence or Threats of Violence Against Employee in the matter of City of San Jose v. Jordan Ashley Dreyer aka Karen Vorster, Santa Clara County Superior Court Case No. 1-07- CH000949, attached hereto as Exhibit 1 . 2. Petition of Employer for Injunction Prohibiting Violence or Threats of Violence Against Employee in the matter of City of San Jose v. Jordan Ashley Dreyer aka Karen 1 REQUEST FOR JUDICIAL NOTICE ISO PETITION OF EMPLOYER FOR ORDER PROHlBlTlNG VKOLENCE OR THREATS OF VIOLENCE 1264501 (Dmflmm-wa-3 NNNNNN-x-LAAaAdggg. Vorster, Santa Clara County Superior Court Case No. 1-07-CH000949, attached hereto as Exhibit 2. 3. The court files, including complaints and parties, in the following Santa Clara SuperiorCourt Cases: 1-07CH000621, 1-99-CV782157, 1-02-CV808427,’1-11-CV203898. ‘ Specifically, the City of San Jose‘requests the court take judicial notice that the City of San Jose is not a partyto any of the above matters. Respectfully submitted, Dated: [OOV‘OMW 20) “ZOE 2 - RICHARD DOYLE, City Attorney I: l, By. I ' --{ ‘3 '/'L‘ NKIA D. RICHARDSON Sr. Deputy City Attorney Attorneys for CITY OF SAN JOSE REQUEST FOR JUDICIAL NOTICE ISO PETITION OF EMPLOYER FOR ORDER PROHIBITING VIOLENCE OR THREATS OF VIOLENCE 1264501 EXHIBIT'1 WV~1 00 AlridRNEY OR PARTY WZTHOUT ATYORNEY (Name, Slefe Bar numbel, and address)’ ' FOR COURT USE ONLY RICHARD DOYLE, City Attorney (#88625) ”GEORGE RIOS, Assistant City Attorney (#77908) _ SANDRA LEE, Deputy City Attorney (#203703) . {Lg ?f'gg’figjygtD Office of the City Attorne n-z \...-s luzm 200 E. Santa Clara St. 1 th FL, San Jose, CA 95113 ' . TELEPHONEHO; (408) 5354900 FMNo.r0pumaoz (408) 998-3131 ng wi- I J q“ Q I 5E-MA IL ADDRESS (Op.?bnai): ATTORNEY Fonmame): Plaintiff CITY OF SAN JOSE SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SANTA CLARA smasnoorzsss; 170 Park Center Plaza MAEUNG ADDRESS: cnrvmozw CODE: San Jose, CA 951 13 BRANCH NAME PLAINTIFF; CITY OF SAN JOSE DEFENDANT JORDAN ASHLEY DREYER aka KAREN VORSTER EMPLOYEE: JASON TANNER PETITION OF EMPLOYER FOR INJUNCTtON PROHIBITING VIOLENCE a: Q , . 2R THREATS 0F \(JOLENCE AGAINST EMPLOYEE a ' AND [1L] APPLICATION FOR TEMPORARY RESTRAINlNG ORDER Read the Instructions for Petitions to Prohibit Workplace Violence (form WV-150) before completing this form. NOTE: Plaintiffmust be an employer with standing to bn’ng this action under Code of Civil Procedure section 527.8. -1. Plaintiff (name): CITY OF SAN JOSE is'a L: corporation l: sole proplrietorshipE other (specify): municipal corporation and Is filing this suit on behalf of the employee idenfified in item 2. 2. Employee (name): JASON TANNER (Use a separate petition for each employee you are seeking Sex: : x M. F Date of birth; to protect. Identify related actions in item 5.) 3. Defendant (name).- JQRDAN ASHLEY DREYER aka KAREN VORSTER Sex:D ME F Ht.-5'4" Wt: 140 Hair color: Bind Eye color: Hazel Race: Caucasian Age:i§_Date of birthz7/21/1960 a. Resides at (address, ifknown): 111' Morée Ava, #34 ' Sunnyvale. CA 94089 b. Works at (address, if known): c. i ls ls not a current employee of plaintiff (explain if defendant is stil! an employee): 4.’ This suit is filed in this county because a. x I defendant resides In this county. b. 1 x defendant has caused physical or emotional injury to plaintiffs employee in this county. c. E: other (specify): - 5. Related Actions a. I Plaintiff has asked, or is asking, for restraining orders against the defendant in (specify): ' County, case no. (specify): ‘ _ b. E Employee has asked, or is asking, for restmining orders against defendant in (specify): , County, case no. (specify): - . c. I Other related actions (describe): - (This is not a Court Orden) Paga1 on F AdoptedforM nda Us a I I 1 . i’r‘flwCMw °;'Cafi;7m e PETITION OF EMPLOYER FOR INJUNCTION PROHIBITING Sogaefgffigfidw Pmd‘eafizgg wwoomeviiamarv mam VEOLENCE OR THREATS 0Fmm FNCF Aamug'r :um nvm: r: r , ' . ‘. ‘ wv-1oo e '_’ PLAINTIFF(Name)- CITY OF SAN JOSE use NUMBER- * ’ A "‘7 r“ 27x f" «1” fl f3 r DEFENDANT(Name) JORDAN ASHLEY DREYER aka KAREN VORSTER 5 r U «,3. ~39 2/ =5 g‘ EMPLOYEE (Name), JASON TANNER '6. Defendant has [:1 assaulted, [:3 battered E stalked E3 made a credible threat of violence against the empioyee by knowing or willing statements or a course of conduct that Would place a reasonable petson in fear for his or her safety, or the safety of his or her immediate family. a. One or more of these acts can reasonably be construed to be carried out or to have been carried out at the employee's workplace at (address): 201 W. Mission Street San Jose, CA 951 10 b.' Describe what happened (including the dates, who did what Io‘whom, and any injuries): See attached Deciaration of Jason Tanner E Continued on Attachment 6b. , 7. Employee Will suffer great and irreparable harm before this petition can be heard in court unless the court makes those orders requested below effective now and until the hearing. (Specify the ha/m and why it will occur before the hearing): Based on Defendant’s paSt conduct stalking and threatening other victims, and her increasingly hostile and bizarre behavior, instability, fixation on City employee Jason Tanner and'persistence in contacting him despite instructions to cease contact Plaintiff'Is informed and believes that once notified of these proceedingsE Continued on Attachment 7 Defendant's conduct will jeopardize the safety of Tanner. 8. Defendant’s conduct has been directed against employee and :s knowing and willful, rs not constitutionally protected, and does not constitute lawful acts of self-defense or defense of others. _ PMKN‘UFF REQUESTS THE COURT TO MAKE THE ORDERS INDICATED BY THE CHECK MARKS IN THE BOXES BELOW. 9. i x ’ PERSONAL CONDUCT ORDERS [E To be ordered now and effective until me hearing a. Defendant shall not engage in unlawful violence or make threats of violence against the em ployee and the_ following members of employee's family or household who reside with the employee: (1) (Name): Sex: _ D M f: F Date of birth: (2) (Name): Sex CjM ET: Date of birth:- (3) (Name): eX‘ .E M [:3 F Date of birth: Continued on Attachment Ba. b. Specifically, defendant (1)- shall not assauit. batter or stalk the employee and other protected persons. (2) E: shall not follow or stalk the employee and other protected persons to or from the piace of woxk. , (3) C] shall not follow the employee and other protected persons dun'ng hours of empioyment. (4) shat! not telephone or send correspondence to the employee and other protected persons by any means including, but not limited to, the use of the public or private mails. interoffice mail, fax. or email. (5) E] shall not enter the workplace of the empioyee and other protected persons. (6) E] other (specify): The court shall order that the defendant is prohibited from taking any action to obtain the address or location of the empfoyee, or of any of the employee's family members or caretakers, unless the court finds that there is good cause not to make that 0rd er, . (This is nota Court Order.) VW-WRW- Jame” 115°" PETmON 0F EMPLOY_E.R 503INJchTipN PROHIBmNG Ham" s ' : wv-1oo "L" PLAlNTOFF (Name). CITY OF 5AN JOSE , CASE NUMBER. 7CH 000949DEFENDANT (Name); JORDAN ASHLEY DREYER aka KAREN VORSTER 1 € EMPLOYEE (Name): JASON TANNER 10. i X STAY-AWAY ORDERS E To be ordered now and effective until the hearing a. Defendant shali’ stay at least (specify): 300 yards away from the following places and persons (the addresses of the places are optimal and may be kept confidential): (1) Employee [X] and other protected persons identified in item 93. 2) ij Residence of employee and other protected persons (address optional): (3) [a Place of work of employee and other protected persons (address optional): (4) Q School or place of child care of children of empioyee or other proiegted persons {address optional): (5) 8:1 Vehicle of employee or other protected peréons (specify): ' (6) S Other (specify): b. Will granting of any of the stay-away orders'In item 10a depn‘ve defendant of access to his or her residence or place of employment?E Yes [a No (Ifyes, explain): 11. FIREARMS PROHIBITION AND RELINQUISHMENT ORDER Plaintiff requests an order under sectidn 527 9 of the Code of Civit Procedure that the restrained person is prohibiked from‘ owning, possessing purchasing, or receiving, or attempting to purchase or receive a firearm, and must relinqu:sh any firearm that he or she owns or possesses. 12. E OTHER ORDERS (specify other orders you request to help carry out the orders previously requested): 13. DELIVERY TO LAW ENFORCEMENT Plaint‘rff requests that copies of orders be given to the following law enforcement agencies: Law enforcement agency Address San Jose Police Department 200 W. Mission Street, San Jose, CA 95110 Santa Clara County Sheriff's Office 55 W. Younger Ave., San Jose, CA 95110 . 14. -TIME FOR SERVICE Plaintiff requ ests that time for service of the Order to Show Cause and Temporary Restraining Order (CLETS) (form WV-1 20) and aocgmpanying papers be no less than (check one): - 5 days D (specify numbed. days before the date set for the hearing. (lfyou need an order shortening the time to fewer than 5 days, explain the reasons): (This is not a Court Order.) WV4°°|REV-Januam-mn PEWION 0F EMPLOYER FOR INJUNCTION PROHIBmNG "9°“ °” VIOLENCE 0R THREATS 0F VIOLENCE AGAINST EMPLOYEE (\hlnrlrniehn \' In Inna.“ i é; m fi are fa ' JM®O ””3"? ‘ V m g r? {a ‘7 I “‘ PLAINTIFF (Name).- CITY OF SAN JOSE e i‘ gaséggwlgfla: i4? “:j U :4 r , _, -.:1;:‘:~. " k ' t DEFENDANT (Name); JORDAN ASHLEY DREYER aka KAREN VORSTER EMPLOYEE (Name): JASON TANNER 15. “z COSTS Defendant should be ordered to pay costs as follows (specifid: 16. Plaintiff requests additional relief as rfiay be proper. 17. i X NO FEE FOR FILING~ Plaintiff is not required to pay a fee'for filing this petition beCause the petition alleges that the defendant has inflicted or threatened violence against an employee ofi the plainfifi, or stalked the employee, or acted or spoke in any‘other manner that has placed the employee In reasonable fear of violence, and seeks protective or restraining orders or injunctions restraining stalking or future violence or threats of violence in an action brought under Code of Civfl Procedure § 527.8. 18. Plaintiff understands that 'n‘the court issues an Order to Show Cause (form WV-120), a hearing Wm be held on the date showh in item 2 of the Order to Show Cause. At that hearing, plaintiff WU! be prepared to present evidence supporting the petition. 19. Number of pages attached:& ‘ SANDRA LEE ' _ >WW Lag (rvr-IE 0R PRINT NAME 0FAmRNEY) (SIGNATURE 0F Anemia) l declare under penaz’ty of perjury under the laws of the State of California that! am aware ofthe facts stated, a. C] on the basis of my own personal knowledge. b. i X on the basis that I have been informed and believe that the facts stated are true. (NOTE: If this petition is made solely on the basis ofplaintiiTs information and belief, plaihtiff must attach declarations by'one or more persons who have personal knowledge of the facts stated.) Date: July 9, 2007 b WWWSANDRA LEE ' V (SIGNATURE 0F PLAINTIFF)(TYE OR PR(NT NAME) Title of person signing: Deputy City Attorney, City of San Jose (This is hot a Court Order.) WV'WRW-Janm‘: 20°71 PErmON 0F EMPLOYER FOR INJUNCTION PROHIBITING VIOLENCE 0R THREATS 0F VIOLENCE AGAINST EMPLOYEE {Wnrknlarc \Iirdnnrnl Page 4 cf 4 ATTACHMENT 9A PETiTlON OF EMPLOYER FOR INJUNCTION PROHIBITING - VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE Defendant shall not engage in unlawful vioience 0r make threats of viotence against the employee and the foilowing persons who work with the employee: (1) (Name): Jarrod Nunes Sex: Male L-1 1599-0714124759 ocomwcnmhwmé NNMMNNMNM¢444A RICHARD DOYLE, City Attorney (#88625 E. £Efrif‘F-“D GEORGE RIOS; Assistant City Attorney (.77908) “ U SANDRA LEE, Deputy City Attorney (#203703) Office of the City Attorney 200 Eas’z Santa Clara Street San José, California 95113-1905 Telephone Number: (408) 5354900 ~ Facsimile Number: (408) 998-3131 'mfi-mwa 'E~Mail Address: cao.mam@sanjoseca.gov ' ' 'Attomeys for CITY QF SAN JOSE SUPERIOR, COURT 0F CALIFORNIA COUNTY OF SANTA CLARA ‘ FAMILY COURT DMSION CITY 0F SAN JOSE, Case Number: ' Plaintims), DECLARATION 0F JASON TANNER V. ASHLEY JORDON DREYER aka KAREN VORSTER, and DOES, inclusive, Defendant(s). l, JASON TANNER, declare as follows: 1. l have personal knowledge 6f the matters set forth herein, and if cafled as a witness. could and would competently testify thereto except as to those matters stated on information and belief. As to those matters, I believe them to be true. V ~ 2." | am. a detective assigned to the Assaults Unit of the San Joée Police Department. I met Jordan Ashley Dfeyer aka Karen' Vorster (hereinafter “Dreyer’) in the course of my investigation into ériminal threats (a vioiation of Pena} Code Section 422) allegedly made by Dreyer against a fema’le'vicfim, the wife of a man with whom Dreyér had had an affair years before. Thé threats communicated by telephone included threats of vioience. Dreyer had also aliegedly made severa! threatening phone calls to one of the 1 , DECEA‘RATION OF JASON TANNER 424450 co'coxloumhwmg NMNNNN_NMNA-&A.¢_s.x_x.x.x_x memeN-koomflmmth-‘O man’s friends, cmminating in her Eeaving some items including a hammer and a dou’s head outside his place of employment. When she was stopped by police leaving that location, the officers found a loaded firearm in her vehicle and arrested her for possession of a concealed’firearm and carrying a loaded-firearm. 3. On December 13, 2006, l first made contact with Dreyer in' connection with the criminal threats investigation; In the course of the interview, Dreyer acknowiedged that she made some calls, though she claimed not to recall the precise content, and spoke at length about numerous conspiracy theories involving an unknown or fictitious organization called Murder, Inc. as We” as the Heils Angels. l advised Dreyer not to contact the victim and provided her with my business card and the case number. Based on my interviews with Dreyer and others, I believed and continue to believe she has a mental illness. ‘ 4. Afiér the interview, Dreyer immediately began contacting me in a persistent. annoying and harassing manner that continues to this day. Within three days of the interview, she had sent me six rambling emails and left four voicemail messages. Shé briefly touchedpn the investigation, but the calls and emails were pn'marily paranoid, delusional and rambfing communications entirety unrelated to the investigation. Dreyer most commonly wrote about variofis conspiracy theories, but also sent a lengthy email about a dream in which she broke a man’s neck, among other strahge and disturbing subjects, (Attached hereto as Exhibit A are true and correct copies of some of the emails mentioned in this declaratioh. However, due to the volume of the emails received, the great majority of them are not included herewith.) - 5. On December 20, 2006, l sent Dreyer an email requesting that she stop ‘ contacting me, specifically, stating that the criminal threats case had been sent to the District Attorney’s Office for review and that any communications unrelated to that case would have to go through normal reporting channels. She immediately responded to my request‘to cease contact by sending me three emails within a half hour. Among other things, she denied making threats, claimed thevictim’s son married into a Colombian drug (D&NmU‘I-bwh) 10 11 12. 13 .14 15 16 17 18 19 2O 21 22 23 24 25 26 27 28 cadel, and demanded to speak to a supervisor. That same day, Dreyer sent an email to ' Sgt. Jarrod Nunes, who l had copied on my Email to her. 6. Dreyer thereafter sent numerous strange emails addressed t0 me and Sgt. Nunes about conspiracy theories. What she cafled organized crime, and other subjects unrefated to her cn‘minaf threats case. She also continued to call and leave messages. 7. At some point, the tone of her communications changed. Initially, she appeared to want to give us information so that, presumabiy, we wouid take action on her various conspiracy theories. HoWever, after she was advised to stop contacting us, she became increasingly hostile. She also wrote about instructions her “boss," sometimes referred to as “Aristotle,” gave her. On JanLgary 18, 2007, she sent me an email with the subject line “Brain Dead Detective." On January 23, 2007, she sent an email in which she wrote, “I sure hope your [sic] not the cop my boss is after. Sometimes he drops me right in front of the criminal he is after.” An hour later, she sent anothe? email in which shé said, “The United States Government is involved in a major sting operation that is taking down all of organized crime and that includes‘YOU, the Cops, Judges and dirty politicians"... There is NOTHING worse then [sic] a dirty cofi, they are WORSE then [sic] the people they ~ look. down on.‘ But we’re all lucky. My boss believes firmly in treatinq dirty cops exactly as they deserve to be treated ~ by sending them to iail. Unless of course you are quilty of Murder - then vou alreadv know what that sentence don’t you. l HATE FUCKiNG BULLYS." _ ' V V 8. On January 30, 2007, an arreét warrant was issued for Dreyer in connection with the'criminal threats case as well as the gun possession case. Two days later, on February 1, Sgt. Nunes, another detective and I found Dreyer at the computers at San Jose State University/San Jose Main Public Library. She had just sent a'nother email to me and Sgt. Nunes. Dreyer was uncooperative and physically resisted arfest, but was eventually taken into custody and booked. She was informed of the restraining order obtained by the victim in the criminal threats case and was again told to stop contacting DECLARATION OF JASON TANNER ' 47.4450 Assaults Unit detectives and, if necessary, to report criminai activity through normal procedures, i.e., calling 911 or 31 1. She said‘she understood. 9. Forthreé‘ months, l did not receive any communications from Dreyer. I am > informed and believe that she was inca'rceratedfor some or all of this period 0f time. However, in May 2007, Dreyer resumed emailing me, for the most part going on about the victim in the criminal threats case, the Chief of Police, the police generally, the Hells V Angels, all 0f whom she claimed were involved in organized crime, and making numerous other seemingty unrelated allegations. That month, she sent me twenty-two (22) emails, e!even (1 1) of she sent on May 31. lnterspersed in her lengthy rants were references to death, including the following: I o Worthless PD - You are being watched: The noose is getting tighter and tighter FOR YOU. (Email sent May 31, 2007, 5:50PM) o We are watching you NOT do you [sic] job. It’s timerto fall on your ' knife.“ (Email sent May 31, 2007, 2:05PM) 10. In June 2007, in addition to sending more emails, Dreyer made numerous annoying‘ harassing and increasingiy disturbing and threatening phone calls to me at my ‘ workplace. Sihce June 12, 2007, éhe has made at {eastthirteen (13) phohe calls to1me, including three calls on June 28, 2007. 1n her profanity-laced voicemails, she sounds- angry, aggressive and unstable, often screaming. (Attached hereto as Emibit B are true and correct copies of several of the voicemaiis on CD and transcripts of the same.) The‘ voicemails include the following: o It's because pieces of shit, crook ass, do nothing, lazy good for ‘ nothing shitheads fike you that iay a trail a mile wide ~ easy to ‘ follow it’s gonna make this job easierfor the rest of us cleaning ,up 4 DECLARATION 0F JASON TANNER . ‘ 424450 A NNNNNNNNNAAAAA-AAAAA mNOJUT-wadOCDmNCJU‘l-hwmfi-‘O (DOOVOUmgw'M fucking society. So bring those tapes Tanner and prepare to haVe your ass wiped and humiliation for the chief. It‘s going down boy. Right on a public stage. The 215‘ get your chicken ass there. ‘ ' (Voicemail. June 16, 2007) o Okay, Tanner. Now you get your fuckin’ ass down on the 215‘ and listen t0 the can 0f worms get opened. 'Cuz you’re done! You‘re done. Ya fuoked everyone else over. You’re done Tan'ner. No one’s got your ass 'and Rob, for Christ sakes. Gawd. Just, when you're a ioser, you’rexa loser. okay? We’re done. We’re done! HOW LONG DO WE HAVE TO SAY YOU’RE FUCKlN DONE? You’re like vulture. The bfack prick that brought a non- profit to its knees; You're OVER, OVER, OVER, OVER [unintelligible] OVER. [Unintelligible] OVER. You’re OVER‘ GARDEN CITY, YOU’RE OVER. You’re flushed down the toilet. Now let’s not find you dead in someone’s backyard. BACK OUT NOW. And that’s a warning and a promise. (Voicemail, June 18, 2007, 8:21 a.m.). . . o h Hi, ah, this is a general melésage to the entire assaults team since l don’t tmst Detective Tanner enough to leave a message in his personal mailbox and we ail know why now, don’t we?l License ptate number 5XOS1 12. Tanner’s nemesis. He’s driving a nice, fancy BMW. just like you Tanner, all dressed up real spiffy, I walking around with a girffriend‘ with real!y,_really high heels, real real pointy toes and uhm Aristotle told me to follow him. FolloWed them right to their really fancy, fancy SUV BMW and then he said, take the ficense piate down Jordan. (Voicemai), June 19, 2007, 6:29 am.) DECLARATION OF JASON TANNER r ' 424450 (O m.V O3 0'1 -h OJ M _.L NNNNNNNNNAAAAAAAJ.AA OONO)Ol-hOJN-AO£DWNODO1-hOJN-AO | got arrested by you ~ you know Why? They call it aversion therapy. Aristofle cars it, cause, caHed it aversion therapy. So I get used to getting arrested by dirty cops. Whoever arrests me is guilty of murder. That’s it, baby. Whoever arrests me in metro is guilty of murder, but he wants me to. handle it with pride and sophistication because I earned it and being shit on by you is what l don’t deserve so he’s trying to salvage something from me. But listen my little [unintelligible] we are taking you down hard because you aré a worthless, callous piece of shit. (Voicemail, June 19, 2007, 6:29 am.) Pandora’s box has been opened. You are responsibb for opening it [unintelligible] so you tuck your tailbone into your pocket if you can find it and pretend you’re ready for life going down because When f signed up baby doll, I already knew what was‘ coming down the tracks at me. A bullet between the eyes. Apparentiy you didn’t realiZe the game you were playing. it’s called a bullet between the eyesA [unintelligible]. Now strap your board Aontight because this is a game you chose when you [unintelligible] and you’re now not allowed out of the game. So tomorrow we want the Chief of Poiice on a platter and we wit! get what we want bitch. (Voiceman, June 20, 2007) I’ve got 900d news for you Tanner. You’re going to prison. Let me explain something to you. The reason why the Wodd Trade Center was bombed on 911 is because President Bush got tired of dirty cops like‘you'. It’s your fault dear. It’s attributed to you; Now, you piece of shit, we want yoUr résignation and then you’re going ' to prison. You are the reason that the World Trade Center-had to be bombed. Ya piece a crap. (Voicemail, June 21, 2007) 6 DECLARATION OF JASON TANNER 424450 (OODNO'DCNAOON-i mVODU‘l-PCON-AOCDQNOJU'I-th-éo o Jason, it’s Jordan. Uhm,-the 063219513 - Aristotle had me call you just now and he wanted me to tell you specifically he will not forgive you for putting me in jail. Jason, Aristotle will not forgive you for putting me in jail. You know what that means. (Voicemail, June 28, 2007, 7:16 pm.) o Hi asshole. We lefta message on the genera} mailbox ah, to confirming that you were a pathologicai Har and tomorrow I will be coming in and we wiII be going over the vérbal uhm, ah, recordings that we have as Wei] as yourjoke of a wn'tten report. So listen ya little prick, be present to win. Tomorrdw we’re gonna carry your head out on a. pole. You will not be forgiven for what you did and your career is over. We are gonna recor. . . we are gonna go over the recordings and your pathetic written report and I’m gonna hang you out to dry. (Voicemail, Ju‘ne 28. 2007, 7:25 pm.) o Tanner, uhm, one iast [unintelligible] message from Jordah uhm, Aristotle wants to make Clear ah, you had a heyday ruining I someone elsefs life. Mine. Withoutthought, reason or investigation. You did it on a whim, you did it for a favor, you did it cover your own ass someplace elée. And your facts weren’t quite correct. You were caught being s!oppy and you were caught working outside the reatm of'yourjdb duties. So now you’ve been caught. And we’d like you to face it like a man, if yofi can figure out what a man is. And that doesn’t mean going to Starbucks on a break n'ght in the middle of the intense part of this. What you’re gonna have to do is briri‘g out the the orai recordings that you have and ’compare them to your pathoiogical lying on your report. And you’re gonna have tQ face it and yOu‘re gonna have t0 face it in real time tomorrow. You’re gonna have to be man Tanner. You're 7 DECLARATlON OF JASON TANNER 49445!) gonna haVe to pretend to be a man. lt was easy for youto pretend to be a detective, but néw you're getting caHed on the carpet now the heats being turned and this is where the boys get separated from the men. So grab your crotch dear, it’s gonna get rough. And no one, and 1 do mean no one has any sympathy for you because you brought this 0n yofirself; I’ll be Calling you tomorrow t0 make an appointment and I don‘t want to hear that girly'voice of yours saying, l told you not to call me anymore, when you didn’t. You got this coming prick. And. you got it coming hard. '(Voicemail, June 28. 2007, 7:43 pm.) ' 11. On June 25, 2007, Dreyer called and l briefly spoke to her on the phone. I reminded herth>at I had told her not to cal! me anymore. She responded, “No, you didn’t tell me shit, Lieutenant, and you ain’t in charge.» You ain’t fn' charge dickhead.” 12. In one of the recent emails, entitled "first l will destroy you," she again makes inferences to death, talking about ripping the head off-a snake, and stating, “Getting rid of your deadWood has been a bloody experience. Any idea of how embarrassing you are to the City of San Jose?" (June 26, 2007, 4:33PM) Another email she sent the same day was entitied “loading,” which I took to refer to loading a gun. On July 3, 2007, she sént an email entitled, “who’s slitting youf throat?" in which she stated, among other things, “Someone is cutting your throat Tanner - now I want you to go to {he little boys room and look in the mirror- so you can see who is cutting your throat." - 13: In recent weeks, Dreyer’s contacts have intensified and become increasingly angry, aggressive and threatening in tone. ! have told her numérous times to stop contacting me, but she has only'continued calling and emailing. She appears to have ,fixated on mé, as she had the victims in the case that I had investigated. In my fourteen years as a police officer l have dealt with people who have been upset and angry, but none have caused me as much concern for my safety as Dreyer. I am concerned because her conduct is erratic and hostile, she appears highly unstable, and she has no boundaries. In 8 DECLARATION OF JASON TANNER 494450 (DmVCDUW-DOON-i N N N N- N M M [\J N A _-L' «A .4. ..; .3 _\ _\ ....x .3 m '\l O) O'l -b LO N -‘ O (.0 m N O? U1 -§ OJ N _L O -1- the past when she was fixated on others, specifically the victims discussed above, her harassing phon'e caHsgoptinued unfit her conduct became criminal, she was arrested, ahd ‘ at least one ofthe victims got a restraining order. Dreyer was ‘also able to obtain a firearm and had it loaded when the police originafly stopped her after her threats to the other victim. Her past ability‘and willingness to obtain and cérry a loaded firearm and‘ her increasingly hostile contacts, her instability, and the persistent and threatening I communications, bften with references to death, all cause me great concern for my personal safety". I declare under penalty of perjury that the foregoing is true and correct and that this Deciaration was executed thisfl day 0f July 2007, at San Jose, California. 393”:\ JASON TANNER DECLARA'HON OF JASON TANNER ‘ 424450 EXHIBIT A ,- _ :7: Jason ‘. Q j A .. 3111. JD Dreyer [thepracticea1@yahoo com] 4. gent": Saturday, December 16, 2006 10:33 AM To: jason.tanper@sanjoseca.gov Subject: Murderinc. Connections had a dream again last night Iwas 1n a field sunoupded by barbed wire. Inside this field with me were two arge goats Both of them were stating at me Their eyes were red and filled with anger and frustration Igot he Impression they wanted to harm me but were unaware 0fwhy- they were just angry Both ofthem kept Tying t0 ram me at separate times Iworked my way towards a fence and a building - slowly becauseI kept having to hold off their attack They never attacked at the same time and seemed unaware of the others intent ~ hey were both focused on me Both were large goats, like the size ofa small horse [ finally scrambled over a wire fence and entered into a house like shelter. I locked a half door to keep the goats out (like a swinging bar door). I hoped that would work as I was getting tired offighting them off [went into the bathroom to wash my hands and when I returned fofthe main room a man was locking and ' Jolting a large doc_r Where the swinging bar door use to be Only this man and I were in the room together and he was locking me in the room alone with him -- - I moved up behind him and grabbed him by the back of the neck and began twisting his neck .- it was very hard £0 do I heard a powerful voice say ”Jordan, break his neck please." I tn'ed harder and used all my strength and slowly the man‘s neck kepf turning. I realized that the man was Mr Bacon (Kevin Bacon from six degrees of separation police?) Then a voice said to me again (only I could hear it) "You must try harder Jordan; use a}! of your strength.” I reached down inside of myself and used all of my strength and gave his neck one final tum and heard a large “’Csnap The man fell at my feet and I saw the look of surprise in his eyes as he fell t0 the floor unable 1:0 get back up He hadhot seen it coming Istepped over his body and did not look back. Iwas happy that this man, Who used others to enn ch himself now, would depend upon others for his very life. I also know that the rest of the United States of Am'en' c'a would agree Detective Tanner: Iuse to date a cop. I also use t0 party with an undercover narc-cop. He's the one that brought the best drugs to the parties. Ihave names and dates and the list ofpafiies. Chn's would take crank and coke off of criminals and then "share" with us. Murder Inc. can not exist wtihout the tack approval of some dirtycops; dirty lawyers and perhaps a Judge or tWo. And maybe thé United States Government knows exactly Who they are.. And these dirty cops, lawyers and judges have :10 one to blame for their'downfail but their own GREED. Cheap Talk? Check out Yahoo! Messengefs low PC-to-Phone call rates 12/20/2006 Tanner, Jason From: Aristofle Dreyer [thepractice91 @yah oo.com] Sent: Thursday, January 18, 2007 12:45 PM To: Jason.tanne‘r@sanjoseca.gov Cc: jarrod.nunes@sanjoseca.gov Subject: Brain Dead Detective Jason: My boss asked mé t0 pass on amessage to you- please don’t stht the messenger. He wants you to understand that the' next time you hear the foliowing Words in ONE SENTENCE he’d like a different response beside you suddenly getting to your feet and announcing that you and your partner need to “get to another meeting” in a few minutes when you are actually going down the street to go to Starbucks t0 get a cup of Coffee. You know that’s where I caught you about 20 minutes later afier you interrupted me While I was talking to you about an unsolved c-n'me (MURDER) - t0 say to your partner that you had another meeting to get too? My boss told me to wall to‘the Library and there, you were front and center sitting at the Window sear at Starbucks. I waved at you and felt sick to my stomach because our entire conversation had been a complete waste 0f time. Those words he’s like you to pay attention to are: Hell’s Angels * Murder Inc. Murder One . UNSOLVED MURDER VICTIM (mentioned by NAME.) Got it? You aré anogant and you are condescending. Your smartly matching suit, spifiy shoes a_nd neat haircut is useless ifyou don’t have a brain. Don'tget soaked Take ag__u:ick peak at the forecast With fheYahoo! Seaxch weather shoxtcut. - Page I ofi Nunes, Jarrod From: Aristotle Dreyer [thepracticem @yahoo com] Sent: Tuesday, January 23, 2007 2:40 PM To: jarrod.nunes@sanjoseca.gov; jason tanner@sanjose'ca.gov Subject: Brain Dead Pan 2 Sorry Det‘s. Iknow you told me not to email you anymore after my description about my encounter last night With the image of a Hell's Angel trying to kill me (just an image - the guys work for us now and not for you anymore) but my boss just told me to s p e I I it out for. you. We need the Chief of Police‘s email address to copy him on all the emails you failed to address (unless he is involved also). You know the email about Murder Inc. and Murder fOr Hire? This time your on the "to” list and everyone else is on the "blind" copy - get it? We're on the other side dfthe hill now. ‘Look into the Mirror. . . You see boys, either you are unable to read, are choosing to ignore the obvious, or the FED's are blocking your email due to their OWN investigation. The United States Government Is involved m a maj or sting operation that ls taking down all 0f organized crime and that includes YOU, the Cops Judges and diny politicians We hired the Hell's Angels and they are working for us Maybe that's Why the microphone was taped OUTSHDE ofthe counsel m my car instead of INSIDE after parked IN YOUR TOWING facility You also had a low-jack installed. Ping away dear. Please feel free to contact the FBI, The White- House, Thé State Department, The CIA,‘ The NSAfi and of course HOmeIand Security. There is NOTHING worse then a dirty cop, they are WORSE then the people they look down on. But we‘re all lucky. MV boss believes firmly in treating dirty cops exactly as'theLdeserve to be treated - bv sending them to-Lail Unless of course you are guilty ofMurder ~ then you already know what that sentence don‘t. you. I HATE FUCKING BULLYS TV dinner still cooling? Check out "Tonight‘s Picks” 0n Yahoo! TV Tanner, Jason From: Aristotle Dreyer [thepracticeQ1@yahoo.com] Sent: Thursday, May 31, 2007 2:05 PM T9: jason.tanner@sanjoseca.gov; jbaldwin@scu.edu; Sgt. Nunes; Arnold Schwarzenegger, cybercop@sanjoseca.gov Subject: Murder Inc is San Jose Police Department chief rob this tacuc of flying to call my boss should be familiar with you You want to see ifyou can arrest me instead of * doing your job. . rob - Hells Angels Murder ‘ can't get a call back We call this the wake up and smell the cbfi‘ee moment Or becoming Comfortable With the facts. You can't see the forest for the trees A1] we see is the Chiefnot doing his job What you see is hiding behind proccedures Wé are watching you NOT do you job". It's time t0 fall on your knife. Need Ia vacation? Get ggeat deals to amazing places on Yahoo! Travel. h t j“ “ Pagelofl‘ Nunes, Jarrod :mew~w 1.-mm «. From: Aristotle Dreyer [thepracfice91@yahoo com] Sent: Thursday, May 31, 2007 5:50 PM To: jason.tanner@sanjoseca.gov; Sgt. Nunes; Arnoid Schwarzenegger; cybercop@sanjoseca.gov; jbaldwin@scu.edu SUbject: who's tracking who? 'Worthless PD - You are being watched: idon't think that you (Rob) are receiving all ofyour communications so I am going to call you and leave a message Perhaps your men want you to fail because you backed the wrong horse- one that had to be destroyed Go outside and look at the Amen can flag and then understand why you are not "in" "When you wag the big dog's tail you must first make sure it will fail" How dare you not investigate MJRDER Who do you think you are? Who do you think you know? A boston Hell's Angel that set you up? 1 8 Million dollar law suit to the HA's How expensive is your "leadership?" Steve Taus'en--- in on your line's This noose-is getting tighter and tighfer FOR YOU. Now hear this UGLY- Steve Tausen Is the President of the Hell's Angles and you are his "bitch" Song offhe ‘ day- Goo Goo Dolls -- In's «down load it fiom I-umes You are being set up by your friends MAD-- - Mutually assured Destmction. Got a little couch potato? Check out fun summer activifies forkids.‘ ‘ .. . "W I ¢ Tanner, Jason From: Aristotle Dreyer [thepractice91@yahoo com] Sent: Tuesday, June 26, 2007 4:33 PM To: jason.tanner@sanjoseca.gov Shbiect: first! will destroy you ID‘d had an image sharp and clear several days ago when my eyes were closed I saw me grabbing and holding the head of a snake. We stared at each other, but While I could not kill the snake it could not longer move either The snakeDs head was now no longer effective but I decided not let go -- and- I started planning on how to 'np ofithis snakes head Ineed time and I will not let go. _ . sent to your chief today. His days are numbered Getting rid of your deadwood has been ”a bloody experience Any idea of how embarrassing you are to the City of San Jose? . Don't get soaked. Take a ggick peak at the foxecast with theYahoo! Search weather shortcut. r»,'~ Tanner, Jason 4-...- .. From: Aristotle Dreyer [thepractic991@yahoo com] Sent: Tuesday, Juiy 03, 2007 8:15 AM To: jason.tanner@sanjoseca.gpv; cybercop@sanjoseca.go.v; Amoid Schwarzenegger Subject: who's slitting your throat? Det. Tanner: You not going to believe this but Ijust got back from the emergency room in El Camino Hospital. I have two h ID’s there ejust like the crooks you run drugs with - and I lied about being one ofthe ID’s -just like you did. h Anyway I digress: I Axistofle has not allowed me to have dental care for about four years now. The reason is he was waiting for me to ha‘ve an abscessed tooth (very vely painful) at this precis moment The last four days have been a nightmare filled With Excedrin and Aspirin 1n an attempt to control the pain. What drove me to the emergency room in an ambulance (hard paper trail) 15 a reaction to the Excednn- 1 thought I was dying- but it was actually just too much caffeine ‘ I met With some very nice firemen, then t_he paramedic; then the ambulance in downtown Mountain View near Castro Street (hard paper trail) Then I was transported t0 the Hospital where the Doctor on duty immediately did blood work 0n me t0 see if I had liver damage from the Excedrin. We all waited- me on an IV drip- (hard paper trail) to find out that I am as healthy as a horse My stats were fantastic excelient- was the exact quote - according to the emergency stafi Jethro opps I mean Tamera you and your fellow crime nitwits afe invited to your own copy ofmy blood - tested by real doctors (hard paper trail) While you Will be able to tamper With the evidence - like you normally do when you frame someone- it won tmatch the original taken from me Someone is cutting your throat Tanner - now I want you to go to the little boys room ‘and look in the mirror - so you can sce‘ who is cutting your throat. You ale not allowed in the metfs room, because you are not a man. This whole operation exists because men like you do not do their job -- you are dealing with men that put a man 0n the moon - they are dealing with men that can’t wipe their ass properly. You: career is over - you just have not admitted it yet. And you are unemployable. Welcome t0 the real world. Be a better Heartthrob. Get better relationship answers_from someone who knows. Yahoo! Answers - Check it out. EXHIBIT B Z“. ’ JORDAN DREYER PHONE MESSAGE 6-1 6-07 ' [To fon/Iva'rd this message press (beep) MeSsage received Saturday, June 16‘“ at . 2:01 pm] Well, I’m iooking at the American flag right here at Castro Street and I wanted to thank you for coming in the B team, the Asian mob (laugh). There’s a reason why Vietnam isn’t running the world, it s because Vietnamese people can ’t get their head out of the ass. So listen Tanner, i want you to bring all the tapes that you said you recorded and a” the tapes that ah, my very, very gbod friend Leslie Voss recorded to the media about the police brutality behavior uhm, on the 215‘. I plan 0n Speaking there and ah, we’re gonna compare the tapes 0f what you wrote and what! actuaily said because you think no one really cares enough to check your lack of work ethic and we’ re planning on doing it m front of you whiIe we take down the chief 0f police. ‘ It’s because pieces 0f shit, crook ass, d0 nothing, lazy good for nothing shitheads like you that lay a trail a mile wide - easy to follow-it’s gonna make this job easier for the rest of us cleaning up fucking society. So bring those tapes Tanner and ‘ prepare to have your ass wiped and humiliation forthe chief lt’s going down . boy. Right on a public stage. The 215 get your chicken ass there 423390 var; DREYER'PHONE MESSAGES JUNE 18419, 2007 "Message received yesterday at 8:21 am, Tanner, it’s Jordan Ashley Bush. 571-33-4841. You’re FUCKED! So here’s the deal. We’re gonna have a meeting the 21st. And everyone expects you to be a man. And they expect Chief Davis; good ‘ol boy Rob, to be a man. This is your chance to stand up and grab your balls. This is the future that you created for yourself. You have no one to blame but-yourself. No dodging, n0 shadow boxing.” This is the coming to Jesus party. This is the future you created. The future that does not include you. You made bad choices and you have t0 pay for it, but you don’t get to make everyone else pay for it too. You backed rich peop1e a not powerful peopie. Powerful people aren't so happy with rich people here. You back pedophiles, thiefs, crooks, B’s, weak people. B’s - you’re a B, a B personality. A B is a V follower. A’s are leaders. Alphas are leaders. You’re all B’s. Chief Rob,'as ih Rob you blind, is gone. He’s done. His career is over. You career is over. Your boss’ career is over, it’s done. Now be a man for once in your pathetic well- dressed fife. Get over it. It’s over. And this Stare down win continue until it’s done. But you have t0 know you’re no lbnger in the race. It’s out. You’re out, out, out. You’re out. N0 one respects you anymore. You’re done. We have pictures on you. You’re done. Okay, Tanner. Now you get your fuckin‘ ass down on the 213‘ andvlisten to the can of worms get opened. ’Cuz you’re done! Youfre done. Ya fucked‘everyone else over. You're done Tanner. No one’s got your ass and Rob, for Christ sakes. Gawd. Just, when you’re a loser, you’re a. loser, okay? We're done. We’re done! HOW LONG DO WE HAVE TO SAY YOU'RE FUCKIN DONE? You’re like vulture. The black prick-thatlbrought a non-profit t0 its knees. You're OVER, OVER, OVER, OVER (unintelligible) OVER. (unintelligible) OVER. You’re OVER GARDEN CiTY, YOU’RE OVER. You’re flushed down the toilet. Now let’s not find you dead in someone’s backyard. BACK OU-T NOW. And that’s‘a warning and a promise. (To play the next message press 1. There are no more messages ih that direction. Your first message is message received yesterday at 8:21 am) (Message received today at 6:23 am.) . Hi, uhm, this J's Jordan Ashiey Dreyer,. social security number 571-33-4841. Ah, we just need everyone to know that Tanner, Nunes and your Chief Davis all killed innocent women so that they'coufd be initiated intothe little boy‘s Club associated with the Hells Angels. Now they’ve covered each other’s ass. That’s why we “can’t seem to pry the incompetent ass that runs your department into the ground ‘ -" Chief Davis -- out of his throne of shit that he sits on every day. 423296 -~DREYER PHONE MESSAGES JUNE 18-1 9, 2007 First, we’d like to point out that the reason this incompetent boob is stil! running the piace is because he murdered somebody and he can't leave without, ya ' know, the appropfiéte retaliation. But no one but an idiot would get themselves into a situation like that in the first place. - So this little prick is going to get thrown out the hard way. 'l’m the Trojan horse, Rob. I‘m the Trojan horse. I’m the one that said sacrifice me to take that miserable talentle'ss, worthless, selfish, crappy piece of horseshit down. N0 one ' and l MEAN NO ONE has the Chief of Police’s back. Now we want him to resign and it is an ONLY a matter of time until he does because we are not through yet. There is a longer fist of names 'In your pathetic, cowardly Club of police without balls. Boys with guns is how my boss in Washinton . . . she refers to you, you incompetent, stupid, low LQ. The reason why it was so easy to round you‘ up is becauseyou are so incredibly stupid. This is going to be like taking CANDY from a baby and then after I'm gonna visit Tanner behind bars t will be visiting the Chief of Police behind barsl Him, this time we’re changing positions and I’m going t0 sit across from you Rob and you’re going to be hysterical and desperate knowing that you have destroyed your entire life, your friends’ fife and everyone’s going to know about it and I‘m goingto look in your pig eyes and see - well you know 'what I’H see. An incompetent pussy. See ya Rob. Ooooh, I’m just‘getting starte'_d and as my ma says, how do you like me now? {to play the next. . . message deleted. Message received today at 6:29 a.m.] . Hi, ah, this is a genera! message to the entire assaults team since l don’t trust Detective Tanner enough to leave a message in his personal mailbox and we all know why now, don"t we? License ptate number 5XOS1 12. Tanners nemesis. He’s dn’ving a nice, fancy BMW, just like you Tanner, all dressed up real spiffy, walking around with a girh‘riend with reaily, reaHy high heels, rea! rea} pointy toes and uhm Aristotle told me to follow him. Foilowed them right to their really fancy, fancy SUV BMW and then he said, take the license plate do_wn Jordan. And you wouldn’t be surprised, this guyjumped out like a cat on a hot tin roof. Why are you taking my license plate number down? And I thought to myself, my ' goodness, gracious a what an interesting reaction. Never bothered me when anyone took my license ptate down. So | said to him, if you haven’t down anything Wrong you have nothing to worry about, do ya? And as I walked away Aristofle s'aid he’s goingto be following you. Sure enough he did ~ all the way down the street. And you know what Tanner? He’s got this biocked out kind of faded screen over his license plate, a smoggy cover so it’s hard to read and ah, he’s your nemesis, Tanner. AH spiffy, spiffy, spiffy, all cheese taped n0 substance, n0 thought process -just whatever you do don't accuse me of anything. Don’tfin'd me out; Because I’m weak and I'm a (unintelligibte) male and I’ll (unintelligibb) periods and I bleed constantly. So BITCH - plan on being 423296 .A,’ ' DREYER PHONE MESSAGES JUNE 18-1 9, 2007 there the 215‘ when we let out your secrets. You’re weak. I got arrested by you - you know why? They call it aversion therapy. An'stofle cars it, cause, Called it aversion therapy. So I get used to getting arrested by dirty cops. Whoever arrests me is guitty of murder. That's it, baby. Whoeverarrests me in metro is guiity of murder, but he wants me to handle it with pride and sophistication because i earned it and being shit on by you is what l don’t deserve so he’s trying to salvage something from me. But listen my little (unintelligible) we are taking you down hard because you are a worthiess, callous piece of shit. Now I’m going to, Henry Highlife and I’m gonna have a really good meal. Saturday PD everyone, and l do mean everyone needs to be in attendance on the 215‘ because that’s when your chief of shit is going down. [to play the next message press 1,: to replay. . .message received today at 6:30 a.m.] ‘ 423296 JORDAN DREYER PHONE MESSAGE 6-20-07 ..,_ [Received Wednesday, June 20‘“ at 4:42 p.m.] My boss in Washington D.C., President George W. Bushshhhhhhhhhhhh has a message for you Mr. passive/aggressive maaale. I’m going to be calling Jeff Dreyer and you are going to be doing nothing about it. You know why? Because that’s what you d0 (unintelligible) is nothing. Now iisten here (unintelligible) from here on out you are following orders from your superiors. You know why? Because when you lead you fuck everything up. We are not playing a game here Mr. eyes too close together Mr. over bred, ‘Mr. concerned about how he looks. We want the keep his head on a piate and it is over. We aren’t playing dungeon rules now which means no (unintelligime) like you (uninteiligibie) and do not think for a second that we are giving up. Pandora’s box has been opened. You are reSponsible for opening it (unintelligible) so you tuck your tailbone into your pocket if you can find it and pretend you’re ready for life going down because when l signed up baby doll, I already knew what was' coming down the tracks at me. A bullet between the eyes. Apparently you didn‘t realize the game you were playing. It’s called a buLlet between the eyes (unintelligible); Now strap your board on tight because this is a game you chose when you (unintelligible) and you’re now not allowed out of the game. So tomorrow we want the Chief of Police on a platter and we will get what we want bitch. [To play the next message press 1, to re . . .] 42.3393 K JORDAN DREYER PHONE MESSAGE 6-20-07 [Received Wednesday, June 20‘” at 4:42 pm] My boss in Washington D.C., President George W. Bushshhhhhhhhhhhh has a message for you Mr. passive/aggressive maaala I’m going to be calling Jeff Dreyer and you are going to be doing nothing about it. You know why? Because that’s what you do (unintelligible) is nothing. Now listen here (unintelligible) from here on out you are following orders from your superiors. You know why? Because when you lead you fuck everything up. We are not playing a game here Mr. eyes too close together Mr. over bred, Mr. concerned about how he looks. We want the keep his head on a plate and it is over. We aren’t playing dungeon ruies now which means no (unintelligible) like you (unintelligible) and do not thinkfor a second that we are giving up Pandora’s box has been opened. You are responsibie for opening it (Unintelligible) so you tuck your tailbone into your pocket if you can'find it and pretend you’re ready for life going down because when I signed up baby don, i already knew whatwas‘ coming down the tracks at me. A bullet between the. eyes. Apparently you didn’t realize the game you‘ were playingf It’s called a builet between the eyes (unintelligibie); Now strap your boatd on tight because this is a game you chose when you (unintelligible) and you’re now not allowed out of the game. So tomorrow We want the Chief of Police on a platter and we ' will get what we want bitch. [To play the next message press 1, to re . . .] 423393 JORDAN DREYER PHONE MESSAGE 6-21 ~07 [Received Thursday, June 215‘ a_t 9:22 a.m.] I’ve got good news for you Tanner; You’re going to prison. Let m_e explain - something to you. The reason why the World Trade CenterWas bombed on '911 , is becausePresident Bush got tired of dirty cops like you. It's your fauk dear. It’s attributed to you. Now, you piece of shit, we want your resignation and then you’re going to prison. You are the reason that the World Trade Center had to be bombed. Ya piece a crap. 423397 JORDAN DREYER 6-25-07 Dreyer: Do you know anything about that? Tanner: Uh, Jordan. ! told you not to call me any more. Dreyer'. No, you didn’t tell me shit, Lieutenant and you ain’t in charge. You ain't in charge dickhead. Tanner: Okay. 423388 JORDAN DREYER 6-28-07 (received Thursday June 28‘“ at 7:16 p.m.) Jason, it’s Jordan. Uhm, the 06321 951 3 -- Aristotle had me call you just now and he wanted me to tell you specifically he will not forgive you for putting me in jail. Jason, Aristotle win not forgive you for putting me in jail. You know what that means {to play the next me . . ,) Received Thursday, June 28’” at’7:25i p.m. Hi asshole. We left a message on the general mailbox ah, to confirming that you were a pathological liar and tomorrowl will be coming in and we will be going over the Verbal uhm, ah, recordings that we have as well as yourjoke of a written report. So listen ya little prick, be present to win. Tomorrow we’re gonna carry your head out on a pole.' You will not be forgiven for what you did and your career is over. We are gonna recor. . . we are gonna go over the recordings and your pathetic written report and I’m gonna hang you out to dry. (received Thursday, June 28‘” at 7:43 p.m.) Tanner uhm, one last (unintelligible) message from Jordan uhm, Aristotle wants to make clear ah, you’h'ad a heyday ruining someone else‘s life. Mine. Without thought, reason or investigation. You did it on a whim, you did it for a favor, you did it cover your own ass someplace else. And your facts weren’t quite correct. You were caught being sloppy and you were caught working outside the realm Of your job duties. So now you’ve been caught. And .we’d like you to face it like a man, if you can figure dut what a man is. And that doesn’t mean going to Starbucks on a break right in the middle of the intense part of this. What you’re gonna have to do is bring out the the orai recordings that you have and compare them to your pathological lying 0n your report; And you’re gonna have to face it and you're gonna have to face it in real time tomorrow. You’re gonna have to be ' man Tanner. Ydu’re gonna have to pretend to be’a man. H was easy for you to pretend to be a detective 'but now you re getting called on the carpet now the heats being turned and this ls where the boys get separated from the men. So grab your crotch dear, it’s gonna get rough. And n0 one and l do mean no one has any sympathy for you because you brought this on yourself Ht be caning you tomorrow to make an appointment and I don t want to hear that gifly voice of yours saying, I told you not to call me anymore, when you didn’t You got this coming prick And you got it coming hard ‘424481 EXHIBIT 2 WV-140 ATTORNEY 0R PARTY WITHOUT AWCRNEY (Name. 51818 Bar number. and address): _ RICHARD DOYLE, City Attorney (#88625) GEORGE RIOS, Assistant City Attorney (#77908) SANDRA LEE, Deputy City Attorney (#203703) Office of the City Attome ' 200 E. Santa Clara St 16t F1., San Jose, CA 951 13 ‘ TELEPHONE No; (408) 535-1 900 FAX no. (Optimal): (408) 998-3 1 31 am ADDRESS (Optima: ‘ ATrORNsv FOR (Name): . CITY OF SAN JOSE FOR COURTUSE ONLY SUPERIOR cou'RT 0F CALIFORNIA, coum'v oE SANTA CLARA smzsr ADDRESS: 170 Park Center Plaza MAILING ADDRESS: cm AND zyp cope: San Jose, CA 95 1 13 BRANCH NAME: PLAINTIFF: CITY OF SAN JOSE I DEFENDANT: JORDAN ASHLEY DREYER aka KAREN VORSTER EMPLOYEE: JASON TANNER AMENDED ORDER AFTER HEARING ON PETITION OF EMPLOYER FOR lNJUNCTlON PROHIBITlNG VIOLENCE 0R THREATS OF VIOLENCE AGAINST EMPLOYEE (CLETS) CASENW 107CH000949 1. THIS ORDER SHALL EXPIRE AT MIDNIGHT 0N (date).- lF NO DATE IS PRESENT, THlS ORDER EXPIRES THREE YEARS FROM THE DATE 0F ISSUANCE. 2. This proceeding came on for hearing as fouows: Date: 7/24/07 ' Time: 9:00 am. Dept: 101 Room: 3. Judge (name):SHAWNA SCHWARZ [:3 Temporaryjudge 4. a. LT) Plaintiff present E] Attorney present (name): Saudis. Lee, Deputy City Attorney b.D Defendant present E] Attorney present (name): THE COURT FINDS 5. a. The defendant is (name): JORDAN ASHLEY DREYER aka KAREN VORSTER Sex: EM -F HL: 5'4" Wt; 140 Hair odor. Blnd Eye coiortHzl Race: Caucasian Age:47 Date ofbirth:7/12/60 b. The protected employee is (name): JASON TANNER 36X: M D F. Date of birth: ‘ . J c. Protected famiiy or househoid members who réside with employee are: (1) (Name): Sex: [3M D F Date ofbirth: (2) (Name): Se>c D M E F Date ofbirth: (3) (Name): Sex [:1 M D F Date ofbirth: AMENDED [a Continued on Attachment 5c. Page 1 of: mmmmmml’” ORDER AI-TER HEARING 0N PETITION 0F EMPLOYER S Rial Fafidgggg’mfigggJudlcm Councu deallfomh Appmw: by no.1 ’ FOR $NJUNCT‘ON PROH‘BITING VIOLENCE “’V‘140lR9V'm'Y1-2wn . OR THREATS QF VIOLENCE AGAINST EMPLOYEE (CLETS) (Workplace Vloience) Gigi}; WV-1 4O PLAiNTxFF (Name).- CITY OF SAN JOSE CASE NUMBER: . 107CH000949 DEFENDANT (Name). 'ORDAN ASHLEY DREYER axa KAREN VORSTER EMPLOYEE (Namey JASON TANNER THE COURT ORDERS 6 E] PERSONAL CONDUCT ORDERS Defendant is prohibited from further violence or threats of vloience against the employee listed ‘m Item 5b and the protected persons listed in item 5c Specifically, defendant a. E] shall not assault, batter, or stark the emp§oyee and other protected persons b. shafl not foliow or stalk the employee and other protected persons to or from the place of work c. shall not fol!ow the employee and otherlprotected persons during hours of empioyment d.E shall not telephone or send correspondence to the employee and other protected persons by any means inciuding, but not‘limited to the use of the pubiic or private mans, interoffice mail fax, or computer e-mail e. shall not take any action to obtain the address or location of the employee or any of the employee‘s family members or caretakers DE shall not enter the workplace of the employee and other protected persons g.a other (specify):I-h 7. STAY AWAY ORDERS r a. Defendant is ordered to stay at least (spechy): 300 yards away from the foilowing persons and places (the addresses of the places are optional and may be kept confidential): ' (1)E Employee and other protected persons named in item 5c. (2) E1 Residence of employee and other protected persons (address opb'onal): (3) I Z l_ Place of work of emplbyee and other protected persons (address optional): (4) E3 School or place of child care of children of employee or other protected persons {address opfional): (5)E Vehicles of employee and other protected persons. ‘ (6) C: Other (specify): b. [j Contacts retafing to pickup and deiivery of children under a court order or a oourt-approved sflpulafioh of the parties anived at dunng mediation are permftted untess a criminal protective or other restraining order prohbits such contacts wv-uogaev. Jammy 1.20071 ORDER AFTER HEARING ON PETITION 0F EMPLOYER m” °” FOR INJUNCTiON PROHIBITING VIOLENCE OR THREATS 0F VIOLENCE AGAINST EMPLOYEE {CLETm l WV-140 PLAINTiFF (Nam): CITY OF SAN JOSE CASE NUMB ER: 107CHOOO949 DEFENDANT (Name) JORDAN ASHLEY DREYER aka KAREN VOP STER EMPLO‘.'EE (Name).- JASON TANNER 8. MANDATORY FIREARM RELINQUISHMENT ORDER The restrained person must surrender to local law enforcement or sell to a licensed gun dealer any firearms In, or subject to, hls or her immediate possession or control wiflwin 24 hours of belng sewed with this order lfthe restrained person owns possesses, or controls any firearms, he or she must file a receipt with the court show1ng compbiance with this order within 48 hours of receiving this order (Fonn WV- 145 Is avaiiable for this purpose) 9. E] OTHER ORDERS (special): E Continued on Attachment 9. ‘10. DELIVER TO LAW ENFORCEMENT By the close of business on the date o‘ this order. a copy of this order and any proof of service shan be give I _- agencies listed beiow as follows: a. E] Plaintiff shall deliver b. Plaintiff's attorney shall deliver. Law eflforcement agengy ‘ _ A-ddress Santa Clara County Sheriff‘s Office San Jose Police Department 55W YoungerAve” Sanlose, CA‘9; 201 W. Mission St, San Jose, CA 95110 $2:u . LLIE% E0»- 3%.”; l CT. ST; Km: JUL 2 4 2007 ”HEGOEN’G INSTR‘J f‘N L F THE F Date: 7/24/07 i MWSCJMJa/m Juorcm0:? SHAWNA SCHWARZ INSTRUCTIONS FOR LAW ENFORCEMENT This order ts effective when made. It Is enforceable anywhere In all 50 states the District of Columbia, all tribal lands, and all U.S. territories and shall be enforced as if it were an order of that jurisdiction by any 1aw enforpement agency that has received the order is shown a copy of the order, or has verified its existence on the Callfomia Law Enforcement Telecommunications System (CLETS). Violations of this rmtralning order are subject to criminal penalties. . ‘ . NOTICE REGARDING FIREARMS . . Any person subject to a restraining order is prohibited from owning, possessing, purchasing or attempting to purchase, receiva or attempting to receive, or otherwise obtaining a firearm. Such conduct is subject to a $1,000 fine and imprisonment. The person must surrender to local law enforcement or sell to a licensed gun dealer any firearm'm or subject to his or her immediate possession or control m accordance with item 8 above. MNDED ORDER AFTER HEARING ON PETiTION OF EMPLOYER I “9‘3““ FOR lNJUNCTlON PROHIBITING VIOLENCE 0R THREATS OF VIOLENCE AGAINST EMPLOYEE (CLETS) Aflb-u-bxlq-n \l:,..l.-....~-\ WV-140 (RSV.hnm 1,2007] ATTACHMENT 50 ORDER AFTER HEARING ON PETITION OF EMPLOYER FOR lNJUNCTiON PROHiBITING VIOLENCE OR THREATS OF VIOLENCE AGAINST EMPLOYEE 10LETS) =- Protécted persons who work with the employee are: (1) (Name): Jarrod Nunes Sex: Male ‘ L-1 1599-07/424759
