CERTIFIED COPY SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF ORANGE - CENTRAL JUSTICE CENTER THE PEOPLE OF THE STATE OF CALIFORNIA, Plaintiff, vs. No. 30?2014?00727728 TOWNSEND STREET CRIMINAL STREET GANG, et al., Defendants. DEPOSITION OF JEFF LAUNI, EXPERT September 15, 2015 MICHELLE LOTT-MEYERHOFER, CSR NO. 8226 395503 BARKLEY 1. CourtReporters 197,2. barkleyeom [3101 207-8000 Los Angelas {415} San Francisco [949] 955-0400 lrvine {353] 455-5444 San Diego [310] 201-8000 Century City {403] 885-0550 San Jose (760] 322-2240 Palm Springs {300] 222-1231 Carlsbad [9161 922-5777 Sacramento {800] 222-1231 Martinez 1702] 366-0500 Las Vegas 222-1231 Montarey (551] Riverside {818] 702-02102 Woodland Hills {702) meson Henderson [516] 376494 Garden City [212} BOB-3500 New York City 3214611 Brooklyn {513) 490-1910 Albany [914) 510-9110 White Plains [312} 319-5556 Chicago 222 1231 Paris 00+1+800 222 1231 Dubai 222 1231 Hong Kong 1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 2 IN AND FOR THE COUNTY OF ORANGE - CENTRAL JUSTICE CENTER 3 4 5 6 7 8 9 10 THE PEOPLE OF THE STATE OF CALIFORNIA, ) ) ) Plaintiff, ) ) vs. ) No. 30-2014-00727728 ) TOWNSEND STREET CRIMINAL ) STREET GANG, et al., ) ) ) Defendants. ) _____________________________) 11 12 Deposition of JEFF LAUNI, taken on behalf of 13 Defendants, at 700 W. Civic Center, Department C14, 14 Santa Ana, California, commencing at the hour of 15 9:26 a.m.; 16 At 11:56 a.m., the deposition was moved to the 17 District Attorney's Office at 401 Civic Center West, 18 Santa Ana, California, ending at 3:11 p.m., on Tuesday, 19 September 15, 2015, before MICHELLE LOTT-MEYERHOFER, 20 CSR 8226, RPR. 21 22 23 24 25 2 JEFF LAUNI, EXPERT 1 APPEARANCES: 2 FOR PLAINTIFF: 3 4 5 DISTRICT ATTORNEY'S OFFICE BY: SUSAN J. ECKERMANN, DEPUTY DISTRICT ATTORNEY 401 Civic Center West Santa ana, California 92701 (714) 834-3600 6 FOR DEFENDANTS: 7 8 9 10 11 12 AMERICAN CIVIL LIBERTIES UNION OF SOUTHERN CALIFORNIA BY: BELINDA ESCOBOSA HELZER, ATTORNEY AT LAW -ANDBY: CAITLIN W. SANDERSON, ATTORNEY AT LAW 1851 East First, Suite 450 Santa Ana, California 92705 (714) 450-3962 bescobosahelzer@aclusocal.org 13 14 ALSO PRESENT: SHELLY ARONSON, ATTORNEY AT LAW 15 16 17 18 19 20 21 22 23 24 25 3 JEFF LAUNI, EXPERT INDEX 1 2 WITNESS 3 JEFF LAUNI 4 EXAMINATION BY MS. HELZER PAGE 5 5 6 7 EXHIBITS 8 DEFENDANTS' 9 1 PAGE Color copy of Facebook pages; 37 pages 56 Copy of note by Detective Launi of definition of active participation; 1 page 96 Note sheet prepared by Detective Launi; 3 pages 98 10 2 11 12 3 13 14 15 INFORMATION REQUESTED 16 17 PAGE 137 LINE 5 18 QUESTIONS INSTRUCTED BY COUNSEL NOT TO ANSWER 19 20 PAGE 9 131 LINE 16 17 21 22 23 24 25 4 JEFF LAUNI, EXPERT 1 Santa Ana, California, Tuesday, September 15, 2015 2 9:26 a.m. - 3:11 p.m. 3 * * * * 4 JEFF LAUNI, 5 having been duly sworn, testified as follows: 6 7 8 EXAMINATION BY MS. HELZER: 9 Q Good morning. 10 A Good morning. 11 Q We met a little earlier, but I'm Belinda 12 Escobosa Helzer. 13 case. 14 15 16 17 18 19 I represent Daniel Antunez in this And if you could, sir, please state and spell your name for the record. A My name is Jeff Launi. First name is J-e-f-f. Last name is L-a-u-n-i. Q And, Mr. Launi, you are a Santa Ana Police Department officer; is that correct? 20 A Yes. 21 Q And your rank is detective? 22 A Yes. 23 Q So I'll refer to you as "Detective Launi." 24 25 Is that okay? A You can call me whatever you want. 5 JEFF LAUNI, EXPERT I take no 1 offense. 2 Q Have you ever had your deposition taken before? 3 A Yes. 4 Q I'll just go real quickly through some ground 5 rules so we're on the same page about how we're going to 6 proceed this morning. 7 So as you know, the court reporter is here and 8 she's taking down everything that's said in the room. 9 And so because she needs to capture everything that's 10 said in the room, it's really important that only one 11 person talk at a time. 12 some questions and you'll be answering those questions. 13 And if you could, even if you anticipate what my 14 question will be, if you'll just let me complete my 15 question before you give your answer. 16 do the same; I'll let you complete your answer. 17 that will help the court reporter just make sure she 18 gets everything on the record. So I'm going to be asking you And then I will And Okay? 19 A Okay. 20 Q Also, you're under oath, as the court reporter 21 just put you under oath. 22 informalities of this room, that oath has the same force 23 and effect as if you were testifying in front of a judge 24 and jury. 25 A And even though we're in the Okay? Understood. 6 JEFF LAUNI, EXPERT 1 Q If you don't understand a question that I ask 2 you, please, let me know and I can rephrase it for you. 3 The point today is to get the most accurate testimony 4 from you as we can. 5 tell me you don't understand my question and give me an 6 answer, I'm going to assume that you understood my 7 question and that you are answering that question. But if you tell me -- if you don't 8 A Okay. 9 Q It's also important to verbalize your answers. 10 So if you nod your head or shake your head, that's 11 something the court reporter can't capture on the 12 record. 13 "Is that a no". 14 it on the record. So if you do that, I'll say "Is that a yes" or And I'm just trying to make sure we get Okay? 15 A Okay. 16 Q I don't want you to guess at anything. If you 17 don't know the answer to my question, let me know you 18 don't know. 19 So if you do have an estimate that you can give me, I am 20 entitled to that. 21 can't give me an estimate, just let me know you don't 22 know. But I am entitled to your best estimate. But, otherwise, if you don't know and Okay? 23 A Okay. 24 Q We can have breaks. 25 This isn't a marathon. if you need a break, just let me know. 7 JEFF LAUNI, EXPERT So The only time I 1 will not allow a break is if I've asked a question and 2 you still haven't answered it. 3 want you to answer the question I asked you and we can 4 take a break. In that sense, I would Okay? 5 A Okay. 6 Q Do you understand everything I've said so far? 7 A Yes. 8 Q Is there any reason why you can't provide your 9 best and most truthful testimony here today? 10 A No. 11 Q Have you taken any medication in the last 24 12 hours that would affect your testimony here today? 13 A No. 14 Q Any alcohol in the last 24 hours that will 15 affect your testimony today? 16 A No. 17 Q What is your understanding of why you're having 18 19 your deposition taken here today? A Because I am the primary police contact 20 pertaining to the Townsend Street Gang Injunction. 21 There were a number of people enjoined in that process 22 and some of them are disputing their active 23 participation, their inclusion and so on. 24 25 Q Okay. And is it your understanding that you've been designated by the District Attorney's Office as an 8 JEFF LAUNI, EXPERT 1 expert witness in this case? 2 A Yes. 3 Q Did you talk to anybody in preparation for your 4 deposition here today? 5 A Yes. 6 Q And who did you talk with? 7 A The DA. 8 Q And specifically what DA? 9 A Susan Eckermann. 10 Q Anyone else? 11 A No. 12 Q And when did you talk to Ms. Eckermann about 13 14 15 your deposition? A Last Thursday, which would have been September 10th. 16 Q 17 about? Okay. And what did you talk with Ms. Eckermann 18 MS. Eckermann: 19 privileged information. 20 MS. HELZER: Objection. Relevance and Because the witness is an expert 21 in this case, the conversations that he has with you, 22 Ms. Eckermann are not privileged. 23 MS. Eckermann: 24 25 I'm going to instruct him not to answer that. MS. HELZER: Okay. So, I think, we'll just 9 JEFF LAUNI, EXPERT 1 mark -- if you can just mark the instruction not to 2 answer and we'll address that later. 3 4 Q Did you review any documents in preparation for your deposition here today? 5 A Yes. 6 Q What documents did you review? 7 A My expert declaration in the Townsend Street 8 Gang Injunction and gang background on a particular 9 individual. 10 Q What individual was that? 11 A Daniel Antunez, A-n-t-u-n-e-z. 12 Q Any other documents that you reviewed in 13 preparation for your deposition? 14 A No. 15 Q And I see that you have some binders in front 16 of you that are open in front of you. 17 me what are the binders that you have in front of you? 18 A And can you tell One of them is my expert declaration in the 19 Townsend Street Gang Injunction and the other one is 20 background on Daniel Antunez. 21 22 Q Did you prepare any notes in preparation for your deposition? 23 A No. 24 Q So I would like, at a break, to take a look at 25 what you have in front of you. So we'll just set that 10 JEFF LAUNI, EXPERT 1 aside for now. 2 A Okay. 3 Q So when the District Attorney's Office asked 4 you to be an expert witness in this case, what was the 5 assignment you were given? 6 A I was assigned to investigate and initially 7 make a determination and assemble documentation for a 8 gang injunction. 9 Q And when were you given that assignment? 10 A Probably over a year ago or thereabouts. 11 Q So it's September 2015. 12 13 So about September 2014? A No. I'd say it was the latter part of 2013, 14 because I actually started the project on a particular 15 date after New Years of 2014. 16 Q After New Years of 2014? 17 A Yes. 18 Q And have you completed your assignment? 19 A No. 20 Q What is left to do? 21 A To enjoin Daniel Antunez, for one thing, and a 22 couple other individuals. 23 anticipating more work. 24 we're not done. 25 Q And in that process, I'm So in that regard, I'd say Now, What are the areas in which you will be 11 JEFF LAUNI, EXPERT 1 offering an opinion at Daniel Antunez's active 2 participation hearing? 3 A You asked me what are the areas? 4 Q Yes. 5 A His gang background, prior documentation of 6 Mr. Antunez of his gang involvement. 7 8 Q Will you be offering an opinion about whether Mr. Antunez is an active participant of the gang? 9 A No doubt. 10 Q I'm sorry. 11 clarify your answer? 12 13 Will you be? Yes or no? A I would anticipate doing so. So I would say Q And what is your definition of "active yes. 14 15 Could you give me -- could you participant of a criminal street gang"? 16 A My definition fits the legal ramifications of 17 that. 18 significant amount of time devoted to, participating in 19 the gang's activities, be they criminal or not. 20 the flip side of that, we also know that there is no 21 legal gage to determine one's active participation. 22 23 It's basically beyond passive or in name only; Q And on Now, I see that you had flipped over a piece of paper and were reading some written notes on the back? 24 A Yes. 25 Q Did that assist you in giving your answer just 12 JEFF LAUNI, EXPERT 1 now? 2 A I would say it did, yes. 3 Q Can I see that? 4 A Sure. I just wrote those when I was out of the 5 room in anticipation of that question so I could give it 6 to you logically. 7 8 Q Right. So on the note it says: "Beyond passive or in name only, significant amount --" 9 "A-m-t" is for amount; correct? 10 A Amount, yes. 11 Q " -- of time devoted to participating in gang 12 activities, be they criminal or not and no legal -- " 13 14 Could you help me with that word? A 15 16 17 18 19 20 21 22 23 What? You can't read my writing? "No legal gage to determine active participation." Q So what do you mean then by "beyond passive or in name only"? A I interpret that as being more than nominal, the bulk of one's time. Q And how do you -- how do you describe or how would you equate the bulk of more than one's time? A In talking to gang members and my past 24 experience and discussing these things with people that 25 have claimed gang membership or association to me have 13 JEFF LAUNI, EXPERT 1 told me certain things that have allowed me to make that 2 determination or use that language. 3 Q Okay. So the bulk of more than one's time is 4 determined by your conversations with alleged gang 5 members? 6 7 8 9 A Gang members that basically told me they lived the lifestyle. Q So an admission by an individual that they lived the gang lifestyle? 10 A "Individuals," plural. 11 Q Individuals? 12 A Yes. 13 Q And so when you say "individuals plural," can 14 that be individuals gang lifestyle admission of his own 15 as well as his telling you that there's other people who 16 also lived a gang lifestyle? 17 A When I obtain those statements, I'm talking to 18 an individual. 19 take them as kind of a blanket description of the gang 20 lifestyle. 21 but other members in his gang. 22 Q But in many of these conversations, I So not only the individual I'm talking to, So also just going back to the bulk of more 23 than one's time, in determining that, is there anything 24 other than admissions by individuals of living the gang 25 lifestyle that you take into consideration when 14 JEFF LAUNI, EXPERT 1 assessing whether a bulk of more than their time is in 2 gang membership? 3 4 5 A Well, I make certain observations in my travel and duties, conversations and observations. Q And what observations would help you in 6 assessing whether an individual is spending a bulk of 7 his or her time? 8 9 10 A I look at what they're doing or what might have drawn our attention to them. I look at their documented past and I talk to people. 11 I've also made some potentially pretty shocking 12 statements about this very subject in court. 13 opinion, when gang members are together, they're 14 involved in gang activity in one form or another. 15 Q Be my So we have admission by individuals, your 16 observations of what they're doing, what brought them to 17 your attention, their documented past, your own 18 statements about when they're together, they're involved 19 in gang membership. 20 Anything else that goes into your consideration 21 about whether an individual is spending a bulk of his 22 time in living the gang lifestyle? 23 A Possibly. That's all I could think of at the 24 moment. Incidents are all different. 25 at the whole picture. You have to look So I guess what I'm saying is 15 JEFF LAUNI, EXPERT 1 there could be additional things. 2 Q Okay. 3 A Can I have that back, please? 4 Q Sure. And before I give this back to you, 5 where did you -- now referring back to Detective Launi's 6 written notes that we read into the record, Detective 7 Launi, where did you get this information that you wrote 8 here about "beyond passive or in name only"? 9 10 A I believe jury instructions. I'd have to check that, but I think that's where I got it originally. 11 Q And what was the jury instruction on? 12 A Gang membership, determining gang membership 13 14 and levels of membership, as I recall. Q Is there any other jury instructions that you 15 can think of that assisted you in writing these notes 16 that are helping you in defining active participation in 17 a gang? 18 A 19 No. Can I have that back? 20 Q Sure. 21 A Thank you. 22 Q Is there a difference between gang membership 23 and active participation in a gang? 24 A I would say there is in my mind. 25 Q And what is that difference? 16 JEFF LAUNI, EXPERT 1 A You can be a gang member and not be active. In 2 fact, in any gang structure, at any given time, I would 3 say about half or maybe less than half, depending on the 4 size of the gang, individuals associated with that gang 5 are active. 6 individual would float in and out of gang activity or 7 active participation within the gang. 8 9 10 Q And there are other reasons why an So before we go on that train of questioning, let me go back a little bit to the definition of "active participant." 11 In addition to the jury instruction that helped 12 you define "active participation," is there any other 13 documentation or writings that you have studied or 14 reviewed that help you in defining "active 15 participation"? 16 A No. 17 Q So going back to gang membership versus active 18 participation, just to see if I understood what you 19 testified to, did you testify that in any given gang 20 structure, that half or less than half would be 21 considered active participants? 22 A I would say so, you know, talking in basics. 23 Some gangs everyone's active, would be my opinion, at 24 certain times. 25 gang is active within that gang structure all the time. But what I see is not everybody in the 17 JEFF LAUNI, EXPERT 1 Even though they're gang members, they may not be active 2 participants. 3 reasons or situations. 4 Q And, again, for a number of potential And then with respect to -- let's talk about 5 Townsend Street in particular, because that's why we're 6 here, so that we have a context in which to discuss 7 these concepts. 8 9 10 11 In Townsend Street, would your testimony be that half or less than half of Townsend Street gang members are active participants? A I would say probably more than half, because 12 it's a more active gang. 13 exceptions to what I am saying. 14 flip side of that, I believe there's people that claim 15 Townsend Street that are not active at the present time. 16 17 Q As I said, there are I would also say on the So let's talk about that a little bit, about not everyone being active all the time. 18 A Uh-huh. 19 Q First, let me ask: In talking about the active 20 participation and whether someone's active or nonactive, 21 what is it, in your education or experience, that 22 informs your opinion that you're testifying here today? 23 24 25 A Well, me, as a police officer, would be law enforcement contacts. Q Anything else? 18 JEFF LAUNI, EXPERT 1 2 A Might also consider statements made by other people to me. 3 4 Might also use observation. Q And when you say "other people," does that include gang members as well as non-gang members? 5 A Yes. 6 Q Does it include conversations with like other 7 police officers as well? 8 A Yes. 9 Q Any other types of people that you converse 10 with that feed into your education and experience that 11 gives you the basis of making your opinion here today? 12 13 A Possibly other people in the system such as probation and parole officers. 14 Q Okay. Anyone else? 15 A No. 16 Q So anything else in your education or 17 experience that informs the basis of -- or leads to the 18 basis of your opinion here today? 19 20 21 A Not that I can think of, other than what I've said. Q Now, going back to not everyone is active all 22 the time, how do you make the determination whether a 23 person is an active or inactive member of Townsend 24 Street? 25 A By the ways I just stated. I would say 19 JEFF LAUNI, EXPERT 1 possibly a little more by their number of direct police 2 contacts or sightings. 3 contacts and observations. 4 Q Okay. I mean, observations, police And just so I have the list, when you 5 say what you referred to before, were you referring to 6 the admissions by individuals, what they're doing, the 7 attention -- how they got the attention of the officer, 8 their documented past, your statements about people 9 being together who are in gangs are involved in gang 10 activities, the number of police contacts and then other 11 observations? 12 13 A The only other thing I might add would be an individual's own statements to law enforcement possibly. 14 Q Anything else? 15 A Not that I can think of. 16 Q And where does this -- and just for lack of a 17 better term -- criteria or factors in considering 18 whether someone is active or inactive, where do you get 19 this criteria or factors from? 20 A If I understand your question correctly, it 21 would be from experience, contacting these individuals 22 and, again, from observations. 23 in there again, too. 24 potential gang member or other people that know him or 25 her. I might throw statements Statements can be from the 20 JEFF LAUNI, EXPERT 1 Q So is there any books or articles or other 2 writings regarding gang membership and the dynamics of 3 gang membership that you have studied or referred to in 4 coming up with this criteria or factors in determining 5 whether someone is active or inactive? 6 A Well, I would first answer that by saying I 7 read a lot of books in other things. But what I'm 8 testifying to here today is basically my amount of 9 experience, direct knowledge. I read a lot of books. A 10 lot of the books I read aren't specific to, you know, my 11 situation or what we're doing, you know. 12 As an example, gangs here are different than 13 possibly gangs on the East Coast or Midwest. I read 14 those books, but they don't apply to what we're doing 15 here. 16 experience. 17 Q I gage this more on my own knowledge and So the books you've read on gang structures are 18 not going into your -- the basis of the opinion that 19 you're giving with respect to Townsend Street; is that 20 correct? 21 A I would say that's probably correct, yes. 22 Q Okay. When you are making a determination 23 about whether someone is an active participant of a gang 24 or is inactive with using these factors or criteria, do 25 you weigh them in a particular way? Are some more 21 JEFF LAUNI, EXPERT 1 important than others? 2 A Yes. 3 Q And which ones are more important than others? 4 A Actions for one thing. 5 Q And what do you mean by "actions"? 6 A Well, if we contact or arrest somebody for 7 comitting a gang crime, that would have more weight than 8 maybe somebody telling me something about this 9 individual. 10 Q Is there any other factor or situation that you 11 can give me that you weigh more heavily on evidence of 12 active participation than others? 13 A Probably. 14 Q And what other factors are criteria would those A I'd have to think of situations or scenarios. 15 16 be? 17 And, again, an individual who's always out there, always 18 being observed, always present with other gang members 19 out on the street. 20 maybe a new gang-specific tattoo that maybe the 21 individual didn't have the last time I spoke to him or 22 her, things like that. I might also consider something like 23 Q Are there any other examples? 24 A Probably, but that's what I can think of 25 initially. 22 JEFF LAUNI, EXPERT 1 2 Q Okay. You can see I'm just trying to exhaust what your memory is. 3 A You're getting background. I understand. 4 Q And you had mentioned earlier in your 5 testimony -- and if I get your testimony wrong, please 6 correct me. 7 right. 8 9 I want to make sure that I'm getting it But you had mentioned that active participation, that not everyone is active all of the 10 time. 11 mean by that? 12 Can you explain a little bit more to me what you A Gang members like gangs themselves cycle. And 13 one status within his gang structure may cycle. 14 be active or a gang may be active for a certain amount 15 of time. 16 disappear for a period of time. 17 We're not contacting them out there. 18 examples of that with individuals and with gangs. 19 Q He may Then all of a sudden they go dormant or We don't see them. I can give you And is there a general timeframe in which 20 you -- passes in which you consider that an individual 21 has now moved from active to inactive status? 22 A No. 23 Q And how do you base then where the line is from 24 active to inactive depending on that you're not seeing 25 them anymore, you're not contacting them anymore? 23 JEFF LAUNI, EXPERT 1 A It's not a finite line or situation. An 2 individual may be at the forefront of things for a 3 period of time and then he disappears. 4 we haven't seen him in a few months or we haven't 5 observed him out on the street or, you know, interacting 6 with the gang. 7 things like that. 8 removal from the gang structure. 9 that. You know, maybe He hasn't been arrested for a while, Inactivity generally involves one's I guess I could say 10 Q And what do you mean by "one's removal"? 11 A Well, if they're not present, then they're not 12 available to interact with the gang. 13 probably going to go inactive with us, as far as that's 14 concerned. 15 Q Then they're You just gave an example of, you know, you 16 haven't observed someone, you haven't seen somebody in a 17 few months. 18 situations, for you to consider someone going from 19 active participant to inactive participant? Is "a few months" enough time, in some 20 A No. 21 Q So is there any time, any minimum time that you 22 look at? They have to not have contact within six 23 months? 24 you consider this noncontact, not seeing them to inform 25 whether they're active or -- from active to inactive? Within a year? Is there any minimum time that 24 JEFF LAUNI, EXPERT 1 A No. 2 Q And what is the basis of your opinion that 3 individuals cycle within the status of the gang from 4 active to inactive? 5 A I don't understand your question. 6 Q Is your testimony with respect to that opinion 7 based on your experience and observations and statements 8 just like you had testified before with respect to 9 active participants or is there something more that 10 11 helps you form your opinion? A It's pretty much what I've already said. The 12 bottom line is we're not having the contacts with them, 13 as far as we know they're not offending, and they're not 14 visible within the neighborhood or within the gang 15 structure. 16 17 Q And when you say "they're not offending," what do you mean by that? 18 A They're not getting arrested. 19 Q Is that getting arrested for any crime or 20 particular crimes? 21 A Well, I'm hesitant to say anything is always or 22 never. 23 situation -- it would depend on the crime and the 24 situation and the facts involved in whatever that crime 25 may have been. It would depend. It would depend on the 25 JEFF LAUNI, EXPERT 1 Q And are there some crimes that you consider to 2 be very clear evidence that they're still active 3 participants? 4 A I think there are. 5 Q And what would those be? 6 A It may not be specific to the Townsend Street 7 gang, but gang crimes in general. 8 have primary activities and primary activities can 9 change rather dramatically sometimes between gangs. 10 if an individual is committing one of their primary 11 activities or one of the crimes that we know to be their 12 primary activities of that gang, then that's something I 13 have to look at. 14 that arrest, that situation and see what else was 15 involved. 16 Q Okay. We know certain gangs So So I would investigate that crime, And in assessing whether a particular 17 crime is a primary activity of the gang and, therefore, 18 this person's involvement in that crime shows you that 19 he is an active participant, is there any set criteria 20 that you look at or is it really based on just your 21 experience and your own observations over the course of 22 being a police officer? 23 A There is no set criteria. We would look at it 24 and weigh the totality of the circumstances in that 25 incident. In other words, the facts of what happened. 26 JEFF LAUNI, EXPERT 1 Was he with someone? 2 did it occur? 3 repeating myself -- what kind of crime it was. 4 What kind of crime was it? Where What kind of crime -- sorry, if I'm I would look at everything involved in that 5 situation or incident that I could find or see or was 6 documented, and I'd make probably some kind of 7 determination. 8 specifically written down or through policy or anything 9 like that. 10 Q There is no real bar or criteria And do you run your conclusions by anyone -- 11 let's talk about Townsend Street specifically. 12 run your conclusions about who is an active participant 13 of Townsend Street by anyone else? 14 is either a peer or a supervisor or someone you 15 supervise that you run your opinions by? 16 17 A Do you Is there someone who No, other than fellow detectives or possibly the District Attorney's Office. 18 May I counter that? 19 Q Absolutely. You have something to add? 20 A A lot of this, if not all of it, is left to our 21 determination as a detective. And our willingness to 22 testify as experts to one's gang activity is weighed by 23 us on an individual -- by individual basis. 24 personally -- and I know of other detectives that I 25 would work with who probably turn more of those cases 27 JEFF LAUNI, EXPERT I 1 down for expert testimony and gang enhancements than we 2 go on. 3 Q Okay. So just to clarify, when you say it's 4 "left to our determination," do you mean you as a police 5 officer? 6 A Yes. 7 Q And that it's "weighed by us," you mean you as 8 a police officer? 9 A Yes. 10 Q And how -- well, let me move on to -- let's 11 talk about Townsend Street more specifically. Did you 12 participate in the creation of the enforcement list that 13 was submitted with the Townsend Street Gang Injunction 14 paperwork? 15 A Yes. 16 Q Did anyone assist you in putting together that 17 enforcement list? 18 A Yes. 19 Q Who assisted you? 20 A A civilian individual at the Santa Ana Police 21 Department. 22 Q And who was that person? 23 A Sheryl Calbert, S-h-e-r-y-l, C-a-l-b-e-r-t. 24 Q And you said she's a civilian employee of the 25 Santa Ana Police Department? 28 JEFF LAUNI, EXPERT 1 A Yes. She is a -- it's a class we have at the 2 police department. 3 position. 4 5 6 Q It's a civilian investigative And what was Ms. Calbert's role in helping you put the enforcement list together? A Basically, assisting me on pulling background 7 on the individuals and clerical-type duties such as 8 typing and assisting me in things like that. 9 not making enforcement or legal decisions of any kind. 10 She was assisting me. 11 appropriate for enjoining. 12 Q She was I was more determining who was Did you have any conversations with Ms. Calbert 13 about the determinations that you were making with 14 respect to who is an active or an inactive participant 15 of Townsend Street? 16 A I probably did. They were not decision-making 17 kind of conversations. 18 have on an individual or individuals, things like that. 19 We discussed timeframes and, you know, things like that. 20 21 Q We conversed with what we had or Did she help you in reaching your conclusions on who should be on the enforcement list? 22 A No. 23 Q Now, in your process of identifying Townsend 24 Street gang members, just from your declaration, I 25 understand that you were able to identify 40 individuals 29 JEFF LAUNI, EXPERT 1 whom you consider to be the most active individuals in 2 Townsend Street; is that right? 3 A 4 thing. 5 Q As I recall, yes. I haven't re-read that whole And that these 40 individuals were from more 6 than 200 individuals who you believed to be gang 7 members; is that right? 8 A Probably so, yes. 9 Q And of the 40 individuals that you originally 10 considered, you eventually determined that 29 of those 11 40 individuals were the most active in Townsend Street 12 and those 29 were put on the enforcement list; is that 13 right? 14 A At the time, yes. 15 Q And you concluded that Daniel Antunez was one 16 of the 29 individuals who you opined was an active 17 participant of Townsend Street; is that right? 18 A Yes. 19 Q So how did you narrow the individuals you 20 believed to be gang members from more than 200 to the 21 40? 22 determination? 23 24 25 So that first cut, how did you make that A Well, first of all, I had no intention of enjoining 200 people. Q Why not? 30 JEFF LAUNI, EXPERT 1 2 A It was too many to handle, too many to deal with in that process. 3 Q What do you mean by that? 4 A Well, the simplest way I could put it is, I 5 wouldn't want to be in deposition on 200 people. 6 just too many people. 7 people to these injunctions. 8 efficient to start with a smaller number. 9 focusing on the worst of the worst at the time. 10 11 Q Okay. It's There's processes to adding I thought it's more So I started So one of them was efficiency, one of the reasons you narrowed it down to 40; is that correct? 12 A Was what? 13 Q Was efficiency? 14 A What do you mean by that? 15 Q Meaning, you didn't want to deal with 200 16 people? 17 A I think more practicality but, yes. 18 Q Okay. 19 20 How else did you determine to cut the 200 people down to 40 people? A Again, through background checks. We actually 21 backgrounded everyone. I may have to correct that 22 slightly. 23 what their active participation levels were and weren't. 24 So if we had somebody we knew was more active than 25 somebody who wasn't, we would eliminate the one that A lot of these people we knew and we knew 31 JEFF LAUNI, EXPERT 1 wasn't. 2 to eliminate people to get down to this number. 3 4 5 There were probably a number of things we did Q And when you say "we," who are you referring A Sheryl Calbert and myself. to? Basically, it was 6 background, the amount of background, and people that we 7 knew were out there doing things on a near daily basis 8 and we got the number down significantly. 9 Q So in reviewing the background checks of the 10 200 people and narrowing it down to 40, what was it in 11 the background checks that were helping you to decide 12 that this person should be not on the 40 -- not part of 13 the 40, but this person shall be? 14 A Lack of gang related law enforcement contacts. 15 Q And what is a gang related law enforcement 16 17 contact? A A gang-related contact would be a contact of an 18 individual while he's involved in some type of gang 19 activity when he's with other gang members. 20 a number of things. May be in the gang area if he 21 doesn't live there. May be what he's wearing. 22 know, it could be a number of things. 23 talking about gang-related contacts, investigations of 24 crimes or, you know, infractions. 25 Q It could be You Primarily, I'm Is there anything else that you can think of 32 JEFF LAUNI, EXPERT 1 that you considered in parsing down these background 2 checks from 200 to 40 individuals? 3 A I think I looked at who was currently 4 incarcerated for what and how long. 5 probation and parole and contacted those supervisors 6 that had people from the Townsend Street gang on their 7 caseloads. 8 doing under that direct supervision. 9 well, I eliminated those. 10 11 I consulted with We looked back and considered how they were If they were doing That's probably about it. That's all I can think of at the moment. Q When you say the "near daily basis," are you 12 referring to the -- if they're having police contact on 13 a near daily basis, that would go in your more active 14 participant pile of people? 15 A No doubt, yes. 16 Q Anything else that you considered in reducing 17 18 19 20 the 200 people to 40 people? A I think that's about it, at least that I can think of sitting here right now. Q And then you made another cut from 40 people to 21 29 people, which was the ultimate enforcement list. 22 you tell me what it is that you considered in making the 23 cut from 40 people to 29 people? 24 25 A I would say a couple people were killed. Can Couple people went to prison that would be out of the 33 JEFF LAUNI, EXPERT 1 neighborhood where, for a period of time, it wouldn't be 2 a factor or a problem in the neighborhood for us. 3 then probably just all the other criteria just under 4 maybe a more focused microscope. 5 Q And So when you're doing the more focused 6 microscope, do you weigh, for example, the gang 7 activity? 8 than other activity to narrow from 40 to 29 individuals? Do you put more weight on certain activity 9 A I probably did, yeah. 10 Q Do you recall anything, specific? 11 A Yes. Whereas, prior to this elimination 12 process, we had -- just as an example -- an individual 13 or individuals that were always out there on the street 14 mixing with the other gang members, hanging out. 15 might have put him in this list. 16 this list -- 17 Q I'm sorry. That When we got down to Just to interrupt you. When you 18 say "this list" as opposed to "this list" and you're 19 making some hand gestures, can you just explain it 20 verbally so the court reporter can get it on the record? 21 22 A Okay. There weren't lists, per se, but we were in a process of elimination. 23 Q Correct. 24 A Okay. 25 And one thing I may have looked at is if somebody was always out there and hanging out in the 34 JEFF LAUNI, EXPERT 1 mix. 2 okay, they're out there, but are they getting arrested 3 when this guy isn't but this guy is, maybe the go who 4 is, at this point, would be a better source of our time 5 or better focus of our time. 6 one who is probably still out there and hanging out, but 7 isn't being arrested as compared to somebody who is. 8 And that's a hypothetical kind of explanation. 9 recall, you know, basically we just started paring the 10 11 12 13 And then at the next cut, I might have looked at, And as I list down in those ways. Q Okay. And when you say "hanging out in the mix," what do you mean by that? A Well, on Townsend Street specifically, these 14 guys are always hanging out. 15 street. 16 the food trucks. 17 breezeways, on stairwells. 18 street. 19 doing these things. 20 So I would eliminate the Q They're out there on the They're in the allies. They're hanging out by They're hanging out in courtyards and They're hanging out in the And we see consistently the same individuals And in hanging out in these various places in 21 the Townsend Street area, are they committing crimes 22 while they're hanging out or is it just an observation 23 that they're present in the area? 24 25 A This kind of goes back to your question and my answer that when gang members are together, they're 35 JEFF LAUNI, EXPERT 1 usually comitting crimes. 2 statement sometimes to individual shock, dismay when I 3 say that. 4 I mentioned I make that To answer your question, I'd say when gang 5 members are hanging out in groups, more often than not 6 they're committing crimes. 7 may be minor. 8 gang injunctions are attained on. 9 out-and-out criminal. Now, some of those crimes They may be the nuisance activities that They may be They're smoking dope. They're 10 drinking in public against the law, underage drinking. 11 They're doing graffiti while they're hanging around 12 these areas. 13 know, those are all minor things, but this is what gang 14 members do when they hang out. 15 Q They're vandalizing cars. They're -- you So in your statement that usually when gang 16 members are hanging out, they're usually committing 17 crimes, where do you -- is there anything in particular 18 that supports that opinion? 19 A Yes. 20 Q What is that? 21 A Information contained in my expert declaration 22 and documentation that I laboriously copied, turned over 23 to the D.A.'s Office for discovery to you, and my own 24 experience, observations and experience. 25 Q Okay. 36 JEFF LAUNI, EXPERT A 1 Trespassing would be another one. Blocking 2 free passage on streets and sidewalks would be another 3 one. 4 together. 5 members consider safety in numbers, and they can be more 6 brazen in doing things, intimidating the neighborhood 7 residents, hanging out on properties or trespassing they 8 don't belong on because no one's got the nuts, you know, 9 to tell them to leave, things like that. 10 They're doing all these things when they're Q And they're also bold and brazen. Gang So I guess my question was just a little bit 11 more specific than that. 12 there's any, you know, articles, books, education that 13 you have that helps you to support the opinion that when 14 gang members are hanging out, they're usually committing 15 crimes? 16 17 A Other than -- I'm wondering if Thirty-two years of experience and observations. 18 Q Anything else other than that? 19 A As far as the sources you mentioned, such as 20 21 22 23 books and things, nothing I can think of, no. Q Okay. Can you tell me then how you made the cut -- or let me go back. Excuse me. We were talking about cutting from 40 to 29. 24 You had mentioned that there were a couple of people 25 killed, there were a few people that were out of the 37 JEFF LAUNI, EXPERT 1 neighborhood and weren't in that daily contact or seen 2 hanging out; is that right? 3 A Yes. 4 Q And then you made a more focused analysis of, 5 well, they might be hanging out, but are they comitting 6 any -- are they being arrested for any crimes; correct? 7 A Yes. 8 Q Any other criteria or factors that you 9 10 considered in cutting the list from 40 to 29? A I know I got it down. I'm trying to think of 11 all the things I considered. 12 probably could have enjoined more than 29 originally, 13 but I didn't want to, again, because of that 14 practicality factor. 15 criteria and things I looked at and considered and 16 that's what I got our initial list to. 17 I can only say that I So, eventually, those are the I might have also considered -- in fact, I know 18 I did. Le me correct that -- who we could find to 19 serve, because I knew we didn't have good addresses or 20 locations on a few people. 21 the service aspects of this, I may have eliminated a few 22 people in that regard. 23 Q 24 you met him? 25 A And due to time constraints, Do you know Daniel Antunez personally? Not that I can recall. Have So I would say no. 38 JEFF LAUNI, EXPERT But 1 I have met other members of his family, specifically 2 Daniel. 3 So when you see them or talk to these people -- I don't 4 recall, I'll say. 5 6 Q And then on top of that, you know, he's a twin. And then I'm just going to ask you some questions just to clarify the record a little bit. 7 A Okay. 8 Q So you can't recall ever meeting Daniel; is 9 that right? 10 A Yes. 11 Q But you do recall meeting members of his 12 family? 13 A Yes. 14 Q Have you met his twin brother whose name is 15 Sergio? 16 A I think I have. 17 Q Do you recall when you met him? 18 A Yes. 19 Q And when was that? 20 A I would say two to three years ago in the west 21 alley of about 800 South Townsend Street. 22 Q And what was the reason for the contact? 23 A He was with a group of individuals and he fled 24 25 and basically I chased him down. Q And why did you approach the individuals in the 39 JEFF LAUNI, EXPERT 1 first place? 2 A 3 were watching. 4 5 There was a murder suspect among them that we Q Other than that time, did you have any other contact with Sergio, Daniel's twin brother? 6 A Not that I can recall. 7 Q What other members of Daniel's family have you 9 A I think I met the mom. 10 Q Do you remember that contact? 11 A I think I do. 12 Q And when was that? 13 A Let me premise my answer by I'm not sure, but 8 met? 14 it was prior to my other contact, and I think it was 15 during a probation home compliance check. 16 17 Q And do you know who the probation compliance check was on? 18 A One of the brothers, but I don't remember. 19 Q Was it on Daniel? 20 A I don't think so. 21 Q Anyone else that you've met from Daniel's 22 family? 23 A Not that I could recall. 24 Q Have you met his younger brother Armando? 25 A I don't think so. 40 JEFF LAUNI, EXPERT 1 Q Now, in considering whether Daniel was an 2 active participant of Townsend Street gang, did you 3 review the Santa Ana Police Department Gang Details 4 Target List? 5 A I might have. 6 Q What is the Santa Ana Police Department Gang 7 8 Details Target List? A It's a list that, at the time, was compiled on 9 individuals that were members or associated with target 10 gangs, and those individuals in gangs were, again, the 11 worst of the worst and that's why they were targeted. 12 Not every gang is targeted, not every individual in 13 every gang is targeted. 14 15 Q So is there a target list that relates to the Townsend Street gang? 16 A Yes. 17 Q And is there any policies or procedures to 18 determine who ends up on that list? 19 A Yes. 20 Q And can you explain to me what are those 21 22 23 policies and procedures? A Levels -MS. Eckermann: I'm going to object, unless 24 it's established that your client is on some sort of 25 target list. We've gone kind of far afield as to how 41 JEFF LAUNI, EXPERT 1 these determinations are made, and I've allowed that 2 without objection. 3 MS. HELZER: I understand. 4 Q Is Daniel Antunez on the target list? 5 A No. 6 Q In considering whether Daniel Antunez was an 7 active participant of the Townsend Street gang, did you 8 review any Field Interview Cards? 9 A Probably, yes. 10 Q And were there any Field Interview Cards you 11 reviewed relating to Daniel Antunez? 12 A I believe there was. 13 Q And what is a Filed Interview Card? 14 A What is the card? 15 Q Yeah. 16 17 Can you describe what it is just generally? A Yes. It's a pocket-size card that we use to 18 document, well, a number of things; individuals, 19 vehicles, associates, clothing, dates and times, 20 locations, addresses, things like that. 21 Q And why did you review the Field Interview 22 Cards when you were considering Daniel Antunez and 23 whether he was an active participant? 24 25 A To see if there were any Field Interview Cards on file on him, first of all, and then what the facts 42 JEFF LAUNI, EXPERT 1 and circumstances of that Filed Interview Card or the 2 completion of that Filed Interview Card were. 3 4 Q And are there any policies or procedures that relate to completing a Filed Interview Card? 5 A When you refer to "policies," are you talking 6 about department policies or just the way they're done 7 or -- 8 Q Let me be more specific about it. When you're 9 capturing this information on the Filed Interview Card, 10 presumably you have contact with the individual; is that 11 correct? 12 A Most generally, yes. 13 Q So when you have contact with the individual 14 who ultimately results in a Filed Interview Card being 15 written out, is there any level of cause that the police 16 officer needs in order to contact this individual? 17 A Yes. 18 Q And what is that level cause? 19 A Cause to detain. 20 Q So there has to be some cause to detain in 21 order for the officer to complete a Filed Interview 22 Card; is that correct? 23 A In my opinion, the most important line on that 24 card is "reason for contact." 25 yes. So my answer would be I'm sorry. 43 JEFF LAUNI, EXPERT 1 2 Q So is the Filed Interview Card ever completed in a consensual contact? 3 A Yes. 4 Q Other than cause to detain and consensual 5 contact, is there any other policies that govern when a 6 police officer can approach an individual that then 7 ultimately results in a Filed Interview Card being 8 completed? 9 A No. 10 Q In considering -- excuse me. 11 12 Strike that. Are officers trained on completing Field Interview Cards? 13 A Yes. 14 Q And what is, generally, the training that they 15 16 receive? A Basically, when one can be filled out, what we 17 might use them for and completeness. 18 how to fill it out. 19 20 Q In other words, And what is the training the officer receives regarding completeness? 21 A Just fill out every box. 22 Q Now, in considering whether Daniel Antunez was 23 an active participant of Townsend Street, did you review 24 any Notices of Determination? 25 A Yes. 44 JEFF LAUNI, EXPERT 1 2 Q And were there any Notices of Determination relating to Daniel Antunez? 3 A Yes. 4 Q And what is a Notice of Determination? 5 A A Notice of Determination, I would describe 6 that as a more gang-specific field interview report 7 form. 8 Similar to an FI, but more gang specific. 9 Q Is this also something sometimes referred to as a STEP Notice? 10 A Yes. 11 Q And are there minimum kind of requirements that 12 a police officer have before they can approach somebody 13 in completing a STEP Notice? 14 A I would say it's the same as completing the FI 15 Card. So, again, you know, we use the FI Card for many 16 reasons, purposes. 17 when we're talking to them and things like that. 18 sometimes I'll pull one out just to make notes on for 19 lack of having anything better to write on. 20 We even fill them out on victims And Where a STEP Notice generally involves some 21 kind of detainment to fill it out and a different type 22 of action or activity that drew us to the individual to 23 fill one out. 24 25 Q So the STEP Notice is more specific and requires a little bit more reason on filling out; would 45 JEFF LAUNI, EXPERT 1 that be correct? 2 A Yes, a little bit more gang specific. 3 Q Did you have any conversations with anybody in 4 considering whether Daniel Antunez was an active 5 participant of the Townsend Street gang? 6 A Yes. 7 Q Who did you speak with? 8 A I don't remember who exactly, but it was one or 9 more members of our Stop 2 gang enforcement team. 10 Q Did you say "Stop 2"? 11 A Yes, S-t-o-p. 12 Q And what is Stop 2? 13 A It is our street level gang suppression team 14 that is attached to -- maybe I should explain. I'm 15 sorry. 16 Q And what is Stop 1? 17 A Stop 1 is -- has lesser people assigned to it We have Stop 1 and Stop 2. 18 and more of their assignments are, for lack of a better 19 term, I'd say administrative. 20 have those administrative duties. 21 the street, not get caught up on admin-type work, to be 22 out there doing gang suppression. 23 Q Okay. To where Stop 2 doesn't Their job is to hit So you spoke to one or more people in 24 the Stop 2 gang enforcement team regarding Daniel 25 Antunez; is that correct? 46 JEFF LAUNI, EXPERT 1 A You know, I don't remember specifically doing 2 that, but I know I did that on most of the people that 3 were enjoined. 4 on him as well. 5 determine activity levels, things like that. 6 Q So I'm going to say I probably did that And the reason for that was input, Do you recall any information that you received 7 through these conversations about Daniel Antunez that 8 helped you in considering whether or not he was an 9 active participant of a gang? 10 A Again, I don't recall specifics, but I strongly 11 suspect I was told something to the effect that, yes, 12 he's out there, we see him out there, he's with the gang 13 members, we've seen him here, we've seen him there. 14 Q Why do you strongly suspect you were told that? 15 A Because I enjoined him, in addition to other 16 things that I looked at. 17 started with and then we paired it down by background 18 documentation and things. 19 Q Those are the type of things I So talking to the Stop 2 officers was part of 20 your process of paring it from 200 to 40 and then from 21 40 to 29? 22 A I would say it probably was, yes. 23 Q Do you know if it was? 24 A I talk to these guys a lot. 25 "Probably it was" probably is going to be my best answer. 47 JEFF LAUNI, EXPERT Q 1 Okay. Other than talking -- possibly talking 2 to Stop 2 gang enforcement team officers, did you have 3 any other conversation in considering whether Daniel 4 Antunez was an active participant of Townsend Street? 5 A Other than the background documentation I 6 considered? 7 Q Yeah. So now we're just focusing on 8 conversations. So other than possibly having 9 conversations with Stop 2 officers, did you have any 10 other conversations regarding whether or not Daniel 11 Antunez was an active participant? 12 13 A officers. 14 15 Again, I may have spoken to our probation Q Do you recall whether you spoke to a probation officer regarding Daniel Antunez? 16 A No. 17 Q Is your answer "probably" because that was part 18 Again, my answer would be probably. of your process generally? 19 A Yes. 20 Q But you have no specific recollection? 21 A No. 22 25 It might be on other people, too. 23 24 And it's not just on Daniel Antunez. Q Right. So there's a lot of information you've A Yeah, yeah, going back almost two years ago. got? 48 JEFF LAUNI, EXPERT 1 2 So -Q Okay. Other than Stop 2 officers, possibly a 3 probation officer, any other conversations you had in 4 considering whether Daniel Antunez was an active 5 participant of Townsend Street? 6 7 A We're just talking specifically conversations in that regard? 8 Q Yes. 9 A I think that was probably about it. 10 Q Do you recall anything you learned about Daniel 11 Antunez from any conversations you had? 12 A No. 13 Q In considering whether Daniel was an active 14 participant of Townsend Street, did you review any gang 15 registration forms? 16 A Yes. 17 Q And were there any gang registration forms 18 relating to Daniel Antunez? 19 A No. 20 Q In determining that Daniel Antunez is an active 21 participant of Townsend Street, did you consider his 22 interactions with other individuals? 23 A Yes. 24 Q And what interactions did you consider in 25 reaching your conclusions that he was an active 49 JEFF LAUNI, EXPERT 1 2 participant of a gang? A I'd have to look at his gang documentation, 3 which fills this book right here. 4 it committed to memory. 5 MS. HELZER: I actually don't have So for the record, the witness is 6 referencing one of the binders that's in front of him 7 that he has opened that has a photograph of Daniel 8 Antunez in front of him. 9 We'll get back to that. 10 11 12 THE WITNESS: Okay. BY MS. HELZER: Q In considering -- because I just want to go 13 through your memory first. In considering whether 14 Daniel Antunez was an active participant of a gang, did 15 you consider any interactions that he had with his 16 brothers Sergio and Armando? 17 A Yes. 18 Q And how much did you take into consideration 19 the interactions that he had with his brothers Armando 20 and Sergio? 21 A Not much. 22 Q And why not? 23 A I guess my best answer would be you can't hold 24 25 one's family against somebody. Q So -- Did you consider postings on social media 50 JEFF LAUNI, EXPERT 1 websites in determining whether Daniel Antunez was an 2 active participant of Townsend Street? 3 A Yes. 4 Q And why was that part of your consideration? 5 A Because we're in the new era of net banging. 6 Q And what does "net banging" mean? 7 A Basically, they're doing their gang stuff 8 online. In many cases, they're not shy about it. 9 throw a lot of information out there. They And social media 10 has become an investigative resource and tool for us in 11 this day of age. 12 13 14 Q When you say they do their gang stuff online, what do you mean by that? A They'll post photos of themselves involved with 15 various activities with various other individuals. 16 speaking slowly so you can write. 17 I'm They'll post gang paraphernalia, display it, to 18 include weapons. They will issue disrespects and 19 challenges to rivals. 20 monikers. 21 activities, latest retaliations and brag about conquests 22 and things they might do to rivals. 23 bunch of other things. They'll quite often use gang And sometimes post and talk about latest And probably a 24 Q Can you think of any of them? 25 A That's a pretty good list. 51 JEFF LAUNI, EXPERT 1 Q It is a good list. 2 A It's something new all the time. 3 best answer. 4 Q 5 And where did you learn about this term "net banging"? 6 A 7 don't know. 8 Q 9 10 11 That's my I don't remember. I might have made it up. Do you recall reading any literature or articles or books about this kind of new concept of net banging? A You know, I've taken some classes and training, 12 you know, in cyber investigations and things and I 13 probably heard the term there. 14 Q 15 there? 16 A 17 I Do you recall specifically hearing the term No, but I probably did somewhere along the line in that regard. 18 Q Have you also heard the term "web banging"? 19 A Yes. 20 Q Is that synonymous with "net banging"? 21 A I would think it is. 22 Q Now, you listed a whole array of things that 23 individuals do their gang stuff online. 24 single post on social media that would meet a definition 25 for you of active participation or is it a totality of 52 JEFF LAUNI, EXPERT Is there a 1 the circumstances? 2 A Again, it would probably be totality. I 3 seldom, if ever, consider just one indicator in these 4 regards. 5 6 Q With respect to Daniel Antunez, did you do any investigation on social media websites? 7 A Yes. 8 Q Did anyone else do any investigation on social 9 media websites with regard to Daniel Antunez? 10 A I think so. 11 Q And who would that be? 12 A A representative of the District Attorney's 13 Office. 14 did. I'm not sure, but I'm going to say he probably 15 Q And who would that be, if it was? 16 A Investigator Kevin Ruiz, R-u-i-z. 17 Q Anyone else do any investigation regarding 18 Daniel Antunez on social media websites? 19 A I don't have any direct knowledge of anybody in 20 that regard. 21 Q Okay. 22 A You know what? Let me back up. Hang on. I 23 may have been told of another DA investigator that was 24 looking at these things. 25 found I don't know. Now, what she may or may not 53 JEFF LAUNI, EXPERT 1 Q And who was that other DA investigator? 2 A I think it was Kira Baker, K-i-r-a, Baker 3 common spelling. 4 Q Anyone else? 5 A No. 6 Q Now, when you're doing your investigation on At least that I know of, no. 7 social media with respect to Daniel Antunez, how do you 8 distinguish between a regular post on social media 9 versus a post that's net banging? 10 11 12 13 A Because the individual wouldn't be -- there would be no gang references. Q Anything else that would distinguish between a regular post and a social media web-banging post? 14 A Not that I know of, no. 15 Q I'm going to hand you a document. And for the 16 record, I'm handing the witness a multipage document 17 that has been produced to us by the District Attorney's 18 Office, and it's Bates stamped 000108 consecutively to 19 00143. 20 Go ahead and review that document. And I see, Detective Launi, that you're also 21 looking through the binder in front of you with respect 22 to Mr. Antunez, and you have it opened to, like, the 23 first page that I have. 24 reference the packet that I gave you as opposed to 25 what's in the binder. If I could just ask you to 54 JEFF LAUNI, EXPERT 1 A Okay. 2 Q The reason why is because I'm going to attach 3 the document that I gave you as an exhibit to the 4 deposition transcript and so I want to make sure we're 5 referencing the same pages? 6 A Okay. 7 Q Also on the document I gave you, you can see on 8 the left-hand side there's a red notation there, and 9 that is identifying each page of the document. So if 10 we're referring to certain pages, we can use those 11 numbers so that we're all working off of the same 12 document. Okay? 13 A Okay. 14 Q Now, prior to the deposition, we had asked 15 Ms. Eckermann to get a note to you to ask you to review 16 this portion of Mr. Antunez's file to familiarize 17 yourself in anticipation of questions that I would ask. 18 Did you have a chance to do that? 19 A Yes. 20 Q And do you recognize this document? 21 A Yes. 22 Q And what is this document? 23 A These are Facebook pages. 24 Q And prior to you reviewing them in preparation 25 for your deposition today, have you seen pages that are 55 JEFF LAUNI, EXPERT 1 contained in this document before? 2 A I'm going to say yes. 3 Q Were these pages a result of an investigation 4 that you did with respect to Daniel Antunez and whether 5 he was an active participant of the Townsend Street 6 gang? 7 A Yes. 8 Q And what is it in this document that indicated 9 10 to you that Mr. Antunez was an active participant of the Townsend Street gang? 11 A I'm going to have to look at them, obviously. 12 Q Okay. 13 14 Why don't we take a brief break and then that will give you some time. A 15 Okay. MS. HELZER: Off the record. 16 (Off the record at 10:45 a.m.) 17 (Back on the record at 10:59 a.m.) 18 MS. HELZER: Back on the record. 19 So during the break, Detective Launi took a few 20 moments to review the document I handed him before the 21 break. I'd like to mark this as Exhibit 1. 22 (Whereupon Exhibit 1 was marked for 23 identification and attached hereto) 24 25 BY MS. HELZER: Q So, Detective Launi, I had asked if you could 56 JEFF LAUNI, EXPERT 1 go through the document, which is marked Exhibit 1, and 2 just point -- can you reference to me the first page 3 that gives you an indication that Daniel Antunez is an 4 active participant of Townsend Street gang? 5 A Page 108. 6 Q And that's the first page of the document? 7 A Yes. 8 Q And could you let me know why it is that you 9 consider this to be information that informs you that 10 Daniel Antunez is an active participant of Townsend 11 Street? 12 A Because he's disrespecting -- in the verbiage 13 on the right side of the photo, he's disrespecting the 14 Townsend Street gang's primary rival. 15 16 17 Q There's, I think, four different posts. Can you read which one it is you're referring to? A Yes. It's the one that says: Danny Antunez 18 Lame ass Turtles always hiding "on" "der" shell f-k-n, 19 fucking, turtle Townsend Gang ruthless side of town 20 puto, p-u-t-o. 21 Q When was this post made? 22 A You know, I anticipated this line of 23 questioning, and I'm going to say I'm not sure, because 24 the dates that appear on these aren't necessarily the 25 date the particular things I'm referencing were posted. 57 JEFF LAUNI, EXPERT 1 There are dates on a lot of these, though. 2 you that date if you want. 3 networking works. 4 5 Q Okay. I can give That's the way that social So are you referring to the date right underneath what you just read? 6 A No. I'm referring to the date at the very top 7 where it says "Danny Antunez follow" and there's a date 8 there. 9 Q Okay. 10 A I can see the "2nd, 2012." Although, it's kind of hard to see. Is it June 2nd, 2012? Would that -But I don't know if 11 it's June or not, but that would be my reference for 12 date. 13 Q Okay. So in looking at this, as a person who 14 is investigating whether or not Daniel Antunez is an 15 active participant of the Townsend Street gang, what is 16 the date that's relevant to you with respect to the post 17 that you indicated was evidence that he was an active 18 participant in the gang? 19 A It would be that June 2nd, if that is June, 20 2012, and then the date under that particular post, 21 which looks to me like November 3rd of 2012. 22 probably going to be all the way from no dates to 23 several dates on these pages. 24 25 Q There's So -- Is there anything else on this page 000108 that is information for you in determining that Danny Antunez 58 JEFF LAUNI, EXPERT 1 is an active participant of the Townsend Street gang? 2 A No. 3 Q And what is the next page, sir, that you find 4 information that's helpful in your opinion that Daniel 5 Antunez is an active participant? 6 A The next page would be 110. 7 Q And that's a picture of a little boy wearing 8 sunglasses; is that correct? 9 A Yes. 10 Q And what is it about this photograph or this 11 page that gives indication to you that Daniel Antunez is 12 an active participant of the gang? 13 14 A I know this kid to be Daniel Antunez's son and he's wearing the blue shirt. 15 Q And what does the blue shirt indicate to you? 16 A It's Townsend Street gang color. 17 He's got the mad-doggers on, too. 18 Q And what do you mean by "mad-doggers"? 19 A The dark sunglasses. I would have to look at 20 that time. 21 form an opinion. 22 inference is there with the dark sunglasses and the blue 23 shirt. 24 Q 25 Although, that by itself wouldn't really Okay. In conjunction there, I think the gang So just to clarify your testimony, so the inference that you make in looking at this 59 JEFF LAUNI, EXPERT 1 photograph is that because it's Danny Antunez's son, 2 he's wearing a blue T-shirt and he's wearing sunglasses, 3 dark sunglasses, that that's indication to you that 4 Danny Antunez is an active participant of Townsend 5 Street; is that correct? 6 7 A Well, you may be formulating that question in a self-serving mode. Okay. 8 Q I'm sorry. I don't mean to do that. 9 A Everything I'm looking at here goes to that 10 opinion, not just one picture, one typed entry or 11 something like that. 12 Q But to answer your question, yes. So you're looking in this document as part of 13 the totality of the circumstances in determining whether 14 Daniel Antunez is an active participant in the gang; is 15 that right? 16 A 17 Yes. And in this picture specifically, it would be the color blue. 18 Q Okay. And would it be the sunglasses as well? 19 A Yes, but not so much. 20 Q And why not so much the sunglasses? 21 A I don't know where this picture was taken, time 22 of day or anything else. 23 and maybe he needed sunglasses. 24 25 Q Okay. It might have been a sunny day Is there anything on this page or in your investigation that indicates when this picture was 60 JEFF LAUNI, EXPERT 1 taken? 2 A I don't think so. 3 Q Have you ever met Daniel Antunez's son? 4 A No. 5 Q Do you know that this little boy is Daniel 6 7 8 Antunez's son? A Some of that may be assumption on my behalf. I'm pretty sure this is Daniel Antunez's son. 9 Q And what is the basis of your assumption? 10 A Other pictures and things, references and 11 things I've seen over time. 12 Q Over time relating to Daniel Antunez? 13 A Yes. 14 Q Okay. 15 And is that other information within this document or information outside of this document? 16 A Probably outside this document. 17 Q So have you seen pictures of Daniel Antunez's 18 son before? 19 A 20 21 Not since my investigation into this injunction project. Q Okay. So just to -- because I'm not sure I 22 understand your testimony. 23 this photograph is a photograph of Daniel Antunez's son; 24 is that right? 25 A You make an assumption that Yes. 61 JEFF LAUNI, EXPERT 1 Q And your assumption is based on other 2 photographs that you've seen of Daniel Antunez's son; is 3 that right? 4 A Yes. 5 Q And when did you see those photographs of 6 7 8 9 10 Daniel Antunez's son? A Over time while researching Daniel Antunez's gang background. Q And that's information outside of this document? 11 A Yes. 12 Q And do you recall specifically where you saw 13 14 15 photographs of his son that indicated it was his son? A What I'm thinking of right now was not a photograph, it was a tattoo. 16 Q And what is it about the tattoo? 17 A It was his son's name. 18 Q And is there any indication on this piece of 19 paper about what this little boy's name is? 20 A No. 21 Q Okay. 22 23 24 25 So how do you make the connection between the tattoo and the photograph? A The tattoo was on Daniel Antunez and it was on another document, not on these photos. Q Okay. So would it be correct -- and, again, 62 JEFF LAUNI, EXPERT 1 tell me, if I'm wrong. 2 understand. 3 4 I'm just trying to make sure I You know that Daniel Antunez has a son because of the tattoo; correct? 5 A No. A lot of it is assumption on my behalf. 6 Q Is there anything else about this photograph 7 that you considered in determining whether Daniel 8 Antunez was an active participant of a gang? 9 A No. 10 Q And the next page that gives you information? 11 A That would be 111, 111. 12 Q Okay. 13 A Yes. 14 Q This is a photograph of, looks like, two little Which is the next page? 15 boys. What is it about this photograph that gives you 16 indication when considering whether Daniel's an active 17 participant of the gang? 18 A Colors. 19 Q And can you be more specific? 20 A The Dallas Cowboys jersey that the child has on 21 in the front, which again is blue, and then possibly the 22 older of the two in the picture also has a blue shirt 23 on. 24 25 Dallas Cowboys is something the Townsend Street gang -- let me back up. Dallas Cowboys sports regalia 63 JEFF LAUNI, EXPERT 1 is something the Townsend Street gang identifies with 2 heavily and primarily because of the blue color. 3 4 Q And do you know who these little boys are in this picture? 5 A No. 6 Q And if you don't know who they are, why is it 7 that you make -- that this is information that goes into 8 your consideration about Daniel Antunez and his active 9 participation? 10 11 A they're wearing. 12 13 Because these photos came off his page and what Q Okay. So did you print the photo off of his page? 14 A I don't know if I printed this photo, but I 15 printed a lot of photos. 16 photo. 17 me. 18 I may have printed this same Obviously, it's a copy, because you gave it to I don't remember if I did. Q I very well might have. And just flipping back to the photo before on 19 110, do you know where this photograph came from? 20 that on his website as well or Facebook? Was 21 A Yes. 22 Q Okay. 23 A Because I've been on his page when it was up. 24 Q So you have a specific recollection that this 25 And how do you know that? photograph on 110 was on Daniel Antunez's page? 64 JEFF LAUNI, EXPERT 1 A Yes. 2 Q And do you have a specific recollection that 3 4 5 6 the photograph on 111 was on Daniel Antunez's page? A It'd be my opinion that everything in this packet you gave me came from his page. Q But the question I'm asking is: Do you have a 7 specific recollection of seeing this photograph on 8 Daniel Antunez's page? 9 A I don't remember seeing this photograph. 10 Q And "this photograph" meaning the one on 111? 11 A Correct. 12 Q And is there anything else on this page 111 13 that is information that you consider in determining 14 that Daniel Antunez is an active participant in Townsend 15 Street? 16 A No. 17 Q Do you know when this photograph was taken? 18 A No. 19 Q And the next page? 20 A That would be 113. 21 Q Okay. 113. And can you tell me what it is 22 about this page that gives you information about Daniel 23 Antunez being an active participant of Townsend Street? 24 A The picture on that page and what it 25 represents. 65 JEFF LAUNI, EXPERT 1 Q Okay. Can you be more specific? 2 A Well, there's only one picture on the page, and 3 in that picture is a continuing pattern of "CT for Twin 4 Cities. 5 Townsend Street gang identifies heavily with it as one 6 of their identifiers. 7 8 9 10 11 12 Q It's a baseball reference, but, again, the Okay. And do you know when -- so is this like a screen shot of his web page? A A single photo? I don't know. I would suspect it probably is. Q Do you have a specific recollection of seeing this TC logo on Daniel Antunez's page? 13 A Yes. 14 Q And with respect to CT, what is the basis of 15 16 your opinion that that's Townsend Street gang reference? A Having seen these hats and shirts on various 17 members of the Townsend Street gang when I've been down 18 in that neighborhood, knowing what it represents, "Calle 19 Townsend." 20 21 22 Q C-a-l-l-e. Okay. And how do you know what it represents, Calle Townsend? A Just as I've said, I've seen the Townsend 23 Street gang members wearing this in at least a couple 24 forms. 25 Q And other than wearing it, does your 66 JEFF LAUNI, EXPERT 1 information come from anywhere else? 2 3 A Just my knowledge of Townsend Street gang and the neighborhood, yeah. 4 Q Okay. Anything else on this page that gives 5 you information about whether Daniel is an active 6 participant of Townsend Street? 7 A No. 8 Q And when did you see this on his website or web 9 10 11 page? A I don't know exactly when, but it's been sometime ago. 12 Q Can you give me an estimate? 13 A Six months or more. 14 15 16 17 18 19 Yeah, six months possibly. Been a while. Q When is the last time you went on Daniel Antunez's web page? A I don't remember, but it's also been a while, because he took it down. Q Okay. So let's just start with the -- if you 20 can give me an estimate of when is the last time you 21 went to Daniel Antunez's web page? 22 2014 (sic) now. 23 A 24 months ago. 25 Q So it's September of I'd say approximately -- just approximately six Six months ago? 67 JEFF LAUNI, EXPERT 1 A Yes. 2 Q And was this TC page on 113 on his website when 3 4 5 6 you looked six months ago? A Whenever the last time was I looked or prior to that, yes. Q Well, let's start with, six months ago when you 7 looked at Daniel Antunez's web page, was this TC that's 8 indicated on 113, was that on his website? 9 A I don't know if I can answer it yes or no. 10 mean, this was on his page. 11 It's been quite a while. 12 13 14 Q Yes or no? I I don't remember when. That's all I can say. You don't recall whether it was on there six months ago when you last went on? A It might have been eight or ten months ago. 15 I'm just using the six months as a time reference. 16 been quite a while. It's So -- 17 Q Okay. The next page? 18 A That would be 115. 19 Q Okay. And what is it about this page that 20 gives you information that Daniel Antunez is an active 21 participant of Townsend Street? 22 23 24 25 A There's a reference with a photo on the top right that says: "Can't Stopp (sic) us." And then in the lower part of the page, again, is a reference to Dallas Cowboys. 68 JEFF LAUNI, EXPERT 1 Q Okay. And what is the reference to "Can't 2 stopp us"? What does that tell you about whether or not 3 Daniel Antunez is an active participant of the gang? 4 A That, in itself, is a common gang statement. 5 Q Okay. 6 A Now, I will say, I've seen it on other gangs as 7 well. 8 it's a bad copy, but that's a gang mentality. 9 10 11 And I can't really make the picture out, because Q And then what is the basis of your opinion that it's a basic gang mentality? A Because I've seen it in graffiti and other 12 forms of writing indicia in position of gang members or 13 things gang members have generated. 14 Q And is that with respect to Townsend Street? 15 A Yes. 16 Q And is this something that Daniel wrote, "Can't 17 stopp us"? 18 A I don't know. It's just on his page, though. 19 Q The fact that it says "Works at Male 20 Strippers," does that mean anything to you about whether 21 it's related to gang or not? 22 A No. 23 Q And when was this on his web page? 24 A I don't know. 25 Q You also noted the Dallas Cowboys star? 69 JEFF LAUNI, EXPERT 1 A Yes. 2 Q That goes back to prior testimony that gangs 3 often use the Dallas Cowboys as part of their gang 4 paraphernalia or -- 5 A The Townsend Street gang specifically does. 6 And, again, it goes back to the color blue, because 7 that's Dallas' color. 8 Let's go back to the date thing, if we could? 9 Q Sure. 10 A As I said, there's all the way from zero to 11 possibly two or three dates on some of these pages. 12 there is a date at the bottom of this page. 13 answer your question, I don't know if that's when it was 14 posted or not. 15 16 17 Q Okay. And But to And you're referring to, on page 115, the date beneath it as 7-1, 2014? A Yes. And I would say that is going to be kind 18 of a blanket statement for all of these photos for the 19 purposes of the -- 20 21 22 Q And the blanket statement is that that's when this page was printed from his web page? A No, I don't know. There could be anywhere from 23 one to three dates on some of these pages, but unless 24 it's right under that entry or something, I'd be 25 hesitant to say that's when it was posted, taken or put 70 JEFF LAUNI, EXPERT 1 2 up there. Q Anything else on this page that gives you 3 information about Daniel Antunez being an active 4 participant? 5 A No. 6 Q And the next page? 7 A That would be 117. 8 Q 117? 9 A Yes. 10 Q And what is it on 117 that indicates to you or 11 gives you information that Daniel Antunez is an active 12 participant? 13 A Again, the top left photo appears to be gang 14 members posing in a group, and it says "Can't stopp us." 15 I thought there was something else. 16 again. 17 18 Let me look at this On that same vertical line of photographs, there's one down there that says "Arny Carachure." 19 Q Yes. 20 A Hardcore Townsend Street gang member I know 21 personally. 22 Don't know if it's pertinent or not at the moment. 23 that would be it for this page. 24 25 Q There's history there I can give you. And Now, I have to apologize, because I'm not savvy with all of this techie Facebook stuff. 71 JEFF LAUNI, EXPERT I'm a little 1 old and uninformed. 2 A I'm learning, too. 3 Q So how does this work with these different 4 names and photographs of these different individuals 5 posting on to Daniel's Facebook page? 6 A These are friends. And to be a friend -- like 7 I could get on to your Facebook page theoretically, but 8 I couldn't get into your page unless you friended me. 9 Q Okay. 10 A So somebody who is more into a page is a friend 11 of that individual or has to be known to that individual 12 because I wouldn't -- I don't have a Facebook page, but 13 if I did, I wouldn't give somebody I don't know access 14 into my page unless I knew them or knew more about them. 15 So these are friends. It also says "Friends" 16 at the very top of that aisle of photographs. 17 have to be friended to get into a page and be able to 18 post on that page, put pictures on somebody else's page 19 and that kind of thing. 20 Q Okay. So you So how much control then did Daniel 21 Antunez have about whether these people are his friends 22 or not? 23 A He let's them in and he can block them 24 somewhere down the road. If something becomes offensive 25 or somebody's doing something to your page or posting 72 JEFF LAUNI, EXPERT 1 something you don't like, you can block them and they 2 can no longer do that. 3 Q So then just looking at the two that you 4 indicated, the "Can't Stopp Us" on the top left-hand 5 corner, that's somebody, your understanding is, that 6 Daniel added to and gave access to his page; is that 7 right? 8 A 9 know. 10 11 12 She's trying to pass you a note, just so you It would be my opinion that those are Daniel's friends. Q Okay. And does the control that Daniel has 13 over adding friends or giving access to his page to 14 certain people, does that give you information about 15 whether Daniel's an active participant of the gang? 16 A It's another certain indicator I would look at 17 and consider. 18 with gang members. 19 that's something that would be of note for me. 20 Q Like I said, gang members hang around If he's friending gang members, So just to be clear, you consider "Can't Stopp 21 Us" as friending some sort of gang reference; is that 22 right? 23 A Yes. 24 Q And then you consider him friending Arny 25 Carachure as indication that he's an active participant 73 JEFF LAUNI, EXPERT 1 of a gang, because you know Arny to be a hardcore gang 2 member; is that right? 3 4 A Yes. And you pronounced his last name very well. 5 Q Anything else on this page that indicates to 6 you or gives you information about whether Daniel is an 7 active participant of Townsend Street? 8 A No. 9 Q Now, just before we move on, if you can help me 10 with the "Add Friend" on the side. 11 A I'm not sure. What does that mean? If you click on that, it would 12 give you or give somebody some additional permission, I 13 would assume, but I'm not sure. 14 Q And the next page? 15 A Would be 118. 16 Q Okay. 17 A And immediately in the middle -- 18 19 20 I'm sorry. Do you want to ask me the question or -Q 21 Sorry about that. We're getting a little lazy. So the question is: What on this page 22 indicates to you information that Daniel Antunez is an 23 active participant of Townsend Street? 24 25 A the CT. In the middle of the photos, second one down, That's also a post by Julio Medrano, who I know 74 JEFF LAUNI, EXPERT 1 to be a hardcore Townsend Street gang member. 2 And then the photo under that, Gilbert Townero, 3 that would be a reference to Townsend Street. 4 Gilbert's associating or identifying with Townsend 5 Street. 6 Townsend Street gang member. 7 And I know Gilbert. So He's also a hardcore And there might have been something else. 8 me look further. 9 but that's secondarily. Let Robert Roman is a gang member, too, 10 Q And where is that? 11 A The first row on the left, about three-quarters 12 of the way down, Robert Roman. 13 couple pages we've already passed. 14 anything. 15 16 17 18 Q His photo's been on a I didn't say So you know him to be a gang member of Townsend Street? A Yes. I'm still looking. I think that was it. It was primarily the CT and Gilbert Townero. 19 Q Okay. 20 A I'm sorry. The middle row, about halfway down, 21 Casper Townero, too. 22 that, to me, they're identifying with Townsend Street. 23 That's not their last name. 24 25 Q These individuals, when they say Oh, I see what you mean. Townero is not his last name? 75 JEFF LAUNI, EXPERT 1 A No. 2 Q And do you consider Julio Cesar Medrano to be 3 an active participant of Townsend Street? 4 A Yes. 5 Q And do you consider Gilbert Townero to be -- or 6 referred to as Gilbert Townero to be an active 7 participant of Townsend Street? 8 A Yes. 9 Q And do you do consider Casper Townero to be an 10 active participant of Townsend Street? 11 A No. 12 Q Why not him? 13 A Because I don't know him that well. 14 15 I'd have to look at more stuff on him before I would say yes. Q And then you indicated Robert Roman on the 16 left-hand side of this page, but you seem to be a little 17 less sure of him or what is it about Robert Roman that 18 is different than the gentleman on the right-hand side? 19 A Because without having something in front of me 20 to consult, I wouldn't want to say too much about Robert 21 Roman or Casper without looking at any proof of their 22 active participation. 23 with the Townsend Street gang. 24 I'm not sure. 25 Q I know them both to be associated As I sit here right now, You're not sure -- 76 JEFF LAUNI, EXPERT 1 A Of what level. I'm pretty sure Casper is, 2 because he's allover social networking, too. 3 a lot of stuff on him, but I would have to look further. 4 Q Okay. We've got Anything else on this page that gives 5 you information that Daniel Antunez is an active 6 participant? 7 A No. 8 Q Do you know when this page was printed off of 9 Daniel's site? 10 A No. 11 Q Do you know that it came off of Daniel's site? 12 A Yes. 13 Q How do you know that? 14 A Basically, I remember seeing this. The problem 15 is a lot of these same guys post the same things on 16 other sites and -- I'm gonna say I've seen it before. 17 18 19 20 21 22 Q You have a specific recollection of seeing this on Daniel Antunez's site? A I'm pretty sure. I have this stuff piled up and I'm pretty sure I have. Q Okay. The page before, 117, do you know when this was on Daniel Antunez -- strike that. 23 Let me ask you this question first: 24 have a specific recollection of seeing this on Daniel 25 Antunez's site? This is 117 now. 77 JEFF LAUNI, EXPERT Do you 1 A I'm going to say yes. And for the purposes of 2 this whole package you gave me, I'm going to say yes. 3 Again, timeframes would be the original timeframes I 4 gave you, you know, that variance in time. 5 there's going to be some dates on this, some are not 6 going to have dates. 7 applicable to this entire package you gave me to the 8 best of my knowledge and recollection. Again, So those answers I say would be 9 Q Okay. And what is the next page? 10 A Where did we leave off on? 11 Q We left off on 118. 12 A 119? 13 Q Uh-huh. And what is it about this page that 14 gives you information about Daniel Antunez being an 15 active participant? 16 A 17 Let me look at it. Just one minute, please. The middle row of photographs, halfway down, 18 "Listo T'd Up" would be a reference to he's up for 19 Townsend. 20 21 Brandi Lee Adams or Brandi Adams' photo is on this same row of photographs. 22 Q Is that two photographs down? 23 A Yes. I know her to actually be a pretty 24 hardcore Santa Nita gang member, but there's a direct 25 correlation and allied aspect between Santa Nita and 78 JEFF LAUNI, EXPERT 1 Townsend Street. 2 hood rat. 3 gang member. 4 Q Brandi Adams is what we refer to as a She's allover the place. So definitely a And that's it on that page. Okay. And same question: Do you have a 5 specific recollection seeing this on Daniel Antunez's 6 Facebook page? 7 A Yes. 8 Q And do you know when it was on -- 9 A No. 10 Q And the next page? 11 A That would be the next page, 120. 12 Q Okay. 13 A Danny Gallegos, fourth photograph down in the 14 No. middle column, has the CT hat, Twin Cities hat on. 15 16 I'm sorry. Q Do you know Daniel Gallegos to be an active participant of Townsend Street? 17 A 18 Yes. And that's it for that page I would say. 19 Q And same question: Do you have a specific 20 recollection of seeing this on Daniel Antunez's Facebook 21 page? 22 A Same answer, yes and no. 23 Q So, yes, you have a specific recollection, but 24 25 you don't know what date? A Correct. 79 JEFF LAUNI, EXPERT 1 Q Okay. And the next page? 2 A The next page is 121 and -- 3 Q And what is it about this page that gives you 4 information that Daniel Antunez is an active participant 5 of Townsend Street? 6 A It's on his page and it's the intersection of 7 Townsend and Monta Vista. 8 That's the heart of the Townsend Street gang 9 neighborhood, core of the neighborhood. 10 11 12 Q That's 800 South Townsend. And what about that gives you information about whether or not Daniel's an active participant? A The fact that it's on his page. It's 13 something -- Townsend Street gang is fiercely proud of 14 their neighborhood and their street, protected to that 15 extent. 16 that intersection? 17 18 19 Q I mean, who else would take that picture of Okay. You know. And how do you know this was on Daniel's Facebook page? A Well, in all honestly, I don't recall having 20 seen this in the past. 21 my answer, because there's nothing else on here to 22 indicate that. 23 Q Okay. And that's going to have to be Now, on this page, it says -- there's 24 something, it looks like, attached to the back of what I 25 think is a Stop sign. It says we are -- 80 JEFF LAUNI, EXPERT Can you make that out? 1 2 A No. And I've looked at it. Obviously, you can I can see "we" and "not". I'd be hesitant 3 see "not." 4 to say that's "are" or anything else. 5 Q If it said "We Are Not Criminals," would that 6 change your interpretation or the weight of the evidence 7 that you would give it in determining whether Daniel 8 Antunez was an active participant? 9 10 11 A No. I mean, that could say anything and it probably wouldn't change my opinion. Q Anything else about this page that gives you 12 information about whether or not Daniel's an active 13 participant? 14 A It might say "We Are Not Criminals." 15 pretty good, if you can make that out. 16 would be no. 17 Q And the next page? 18 A Let's see. 19 Q Okay. That's But the answer It would be the next page, 122. And what is it about this page that 20 gives you information that Daniel Antunez is an active 21 participant of Townsend Street? 22 A Just that it is anti-gang injunction. 23 Q So could you explain more what your thought 24 process is in evaluating this page and connecting it to 25 active participation? 81 JEFF LAUNI, EXPERT 1 A Well, if you're enjoined in the gang 2 injunction, I don't know anybody who is that's for it, 3 with this gang anyway. 4 tell me that it was a good thing, not associated with 5 Townsend Street gang, though. 6 I did have one other gang member So with that being said, I think it's general 7 knowledge and common sense that somebody enjoined in the 8 gang injunction wouldn't be happy about it. 9 appears to have been painted on a wall someplace. 10 11 12 13 Q This And what makes you opine that it was painted on a wall? A It just looks like it to me. And there appears to be a Townsend reference in it. 14 Q And what's the Townsend reference? 15 A Well, it's a circle crossed with the "X" 16 through it, "No Gang Injunction," and the bottom word 17 appears to be Townsend. 18 little hard to read, but I think that's what it says. 19 20 Q Again, in all honesty, it's a Do you have a specific recollection of seeing this on Daniel's Facebook page? 21 A No. 22 Q Have you seen this written on a wall in the 23 24 25 Townsend Street area? A Not this particular one, but I have seen others. 82 JEFF LAUNI, EXPERT 1 Q "Others" in? 2 A Anti-injunction type of graffiti. 3 Q I'm just trying to understand, going back to a 4 previous question I asked you about how you make a 5 determination between a regular post and a net banging 6 post. Would you consider this to be a net banging post? 7 A It could be. 8 Q Okay. 9 A Yes, and we got it off the internet. 10 Q Do you know who got it off the internet? 11 A I'm going to say somebody in the DA's Office. Because it's anti-gang injunction? 12 It was either Kevin Reece or Kira Baker. 13 can say that. I didn't. I 14 Q Is that a guess or do you -- 15 A All I can tell you is I didn't pull it off the 16 17 computer. Q And do you know -- would these individualized 18 pictures that we've been looking at in this packet, do 19 you know whether Daniel posted these photographs or 20 whether people posted them to his website on his 21 Facebook page? 22 A They were on his page, and he has the ability 23 to eliminate them. And if they're not eliminated and 24 they're on there, I would say he posted them. 25 it might also be reasonable to assume maybe somebody 83 JEFF LAUNI, EXPERT I think 1 doesn't read everything that's on their page that 2 somebody might post. 3 he did or does. 4 Q I think I would, but I can't say So the fact if there is a picture on there you 5 consider to be information about active participation in 6 a gang, if he doesn't delete it from his post, you 7 consider it to be information that indicates he's an 8 active participant; is that right? 9 10 A I would say it's evidence of, yes, in my opinion, potentially evidence of. 11 Q Okay. 12 A 123. 13 Q Okay. And what's the next page? And what is it about this page that 14 gives you information that he's an active participant of 15 Townsend Street? 16 17 18 19 A Well, I'm going to assume it came off his page and it's anti-gang injunction rhetoric. Q Okay. So is everybody that's anti-gang injunction an active participant of Townsend Street? 20 A No. 21 Q It's just one factor that you consider in 22 23 24 25 determining active participation; is that correct? MS. ECKERMANN: I think that misstates what he's testified to. MS. HELZER: And I'm trying to clear it up. 84 JEFF LAUNI, EXPERT THE WITNESS: 1 No. The fact that that would be 2 on his page at all would indicate to me he has some ax 3 to grind with the injunction. 4 things off or agree with them, not agree with them. 5 know, just the fact that it would be on there would be a 6 potential indicator that -- in addition to other things 7 that I might consider as to his active participation. 8 BY MS. HELZER: 9 Q Again, he can take these You Well, did you consider this photograph in 10 determining whether Daniel was an active participant of 11 the gang? 12 A No. 13 Q So what do you mean by that? 14 15 All this came long after that. So -- When did this come? A When we were doing our background on the 16 individuals, that's when I made those determinations, 17 not on stuff based afterwards. 18 afterwards may have bolstered my opinion of his active 19 participation, but it wasn't taken into account at the 20 time he was initially enjoined or considered for 21 enjoinment. 22 Q When did you create the enforcement list? 23 A Probably around January 2013. 24 Q And what's the next page? 25 A The next page would be 124. Things I've seen 85 JEFF LAUNI, EXPERT 1 Q And what is it about this page that indicates 2 to you that Daniel Antunez is an active participant of 3 the Townsend Street gang? 4 A Although it's not laid out on this page so 5 much, I interpreted the information on this page as, 6 again, being opposition to the gang injunction, and 7 that's the only reason. 8 9 Q Do you have a specific recollection of seeing this on Daniel Antunez's page? 10 A No. 11 Q And do you know when this was discovered by 12 Santa Ana Police Department? 13 A Yes. 14 Q When? 15 A It would have had to have been sometime after 16 17 18 the first service of the gang injunction. Q And when you say "first service of the gang injunction," what do you mean by that? 19 A The date of the first service. 20 Q The date the complaint was filed and served, 21 22 23 the big packet? A No. I would say this is the first service because -- 24 Q Do you know when the first service was? 25 A I can look at my book here and get it for you. 86 JEFF LAUNI, EXPERT 1 Q Okay. 2 A Hopefully, I have it. 3 Q Why don't we wait. 4 I'm going to star that and go back so we don't lose our momentum. 5 A Okay. 6 Q What's the next page? 7 A 125. 8 Q What is it about 125 that gives you information 9 that he is an active participant in the gang? 10 11 A Photographs in the lower left corner of the page. 12 Q What photograph is that? 13 A "Td Up T" and then the CT again. 14 Q And anything else? 15 A Daniel Antunez's picture on the front of that 16 17 18 19 page. Q And why does the picture indicate to you that he's an active participant of Townsend Street? A That front page would indicate to me that this 20 is his page, because his picture's on it, and the other 21 things I just talked about. 22 Q The picture itself isn't relevant. It's just 23 relevant to the extent that it confirms to you that this 24 is his page? 25 A Yes. 87 JEFF LAUNI, EXPERT 1 2 Q Do you have a specific recollection of seeing this on Daniel Antunez's page? 3 A Yes. 4 Q And do you know what the date is? 5 A No. 6 Q And what's the next page? 7 A 127. 8 Q And what is it on this page that indicates to 9 you that -- 10 A Down the center of the page, there is a 11 photograph that appeared on the prior page of Daniel 12 Antunez, and he references about gang-banging and he's 13 "T'd up all day." So "T'd up" would be -- represents 14 Townsend all day. That's how I would interpret that. 15 Q Okay. 16 A No. 17 Q And, now, this is Robert Roman's page; is that 18 right? 19 A 20 21 of his. Q Yes. Anything else on this page? So Daniel Antunez is, obviously, a friend So he allows him in and vice versa. So does the association between Robert Roman 22 and Daniel Antunez also give you information that he's 23 an active participant of the gang? 24 A It could, yes. 25 Q And I'm sorry if I asked you this already: 88 JEFF LAUNI, EXPERT Do 1 you have a specific recollection of seeing this on 2 Robert Roman's page? 3 A He's not enjoined. So I wasn't looking at his 4 page that hard. I'm sure I've seen this before, because 5 I remember -- I don't know if I saw it on Daniel's or 6 Robert's page. 7 Q And do you know the date that Daniel posted? 8 A I see a date under that posting. 9 May 17th. It says There's no year. 10 Q Do you know what year? 11 A I'm going to say 2014. 12 Q And why do you say that? 13 A Because that's when I was getting hits and 14 results from a lot of these queries. And then after I 15 received hits and queries like these, most other pages 16 went down. 17 come back up under false or secondary names or under 18 somebody else's name and I found them again, but there 19 was timeframes when all that occurred. Some of them have come back up. Some have 20 Q Okay. And what's the next page? 21 A Let's see. 22 Q Okay. 23 A Again, photos in the upper left, "Calle 129. 24 Townsend" with the Cincinnati "C." 25 Dallas Cowboy star. The Dallas star, 89 JEFF LAUNI, EXPERT 1 Q And, again, this is Robert Roman's page? 2 A Correct, appears to be. 3 there, Casper Townero. 4 Q I'm sorry. 5 A (Indicating). 6 Q Oh, I see. 7 A I know his last name. 8 Casper's also on When are you? I can't think of it right now. 9 MS. HELZER: And just Detective Launi helped me 10 see in the top left-hand side of the page, the bottom 11 picture, bottom right-corner picture of the square 12 pictures. 13 14 Q is an active participant of Townsend Street? 15 16 And how is this indication that Daniel Antunez A Because he's networking with other gang members, which in this case would be Robert Roman. 17 Q Okay. Because he has posted something on 18 Robert Roman's website, Robert Roman's website is now -- 19 or Facebook page is now relevant to whether Daniel 20 Antunez is an active participant of Townsend Street? 21 A I think we can show that they're communicating, 23 Q And what's the next -- 24 A 130. 22 25 yes. "Thug life," and that kind of goes without saying. 90 JEFF LAUNI, EXPERT 1 Q So his reference to "2Pac Thug Life"? 2 A Yes. 3 Q Okay. 4 A Brandi Adams is posting on this again. 5 So, again, gang members communicating. 6 Q Oh, I see, uh-huh. Anything else? 7 A That's all. 8 Q And the next page? 9 A 131. 10 Q Okay. 11 A Let me look here again. Well, Uber Santana, 12 the second-to-the-top post is a Townsend Street gang 13 member. 14 again. 15 gang members. Let me look here. Brandi Adams is on here And Danny Villa, the last one. So they're all 16 Q So this, again, is Robert Roman's website? 17 A Right. 18 Q So just to be clear in trying to understand 19 your process in determining whether Daniel is an active 20 participant of Townsend Street gang, if Daniel posts on 21 Robert's website or Facebook page, then anybody that 22 Robert associates with can also be attributed to Daniel; 23 is that the thought process? 24 25 A to him. Yes, but I'm not attributing everybody on there It's just the gang members, the gang 91 JEFF LAUNI, EXPERT 1 2 association is what I'm contributing specifically. Q Right. So if Robert Roman has posts from gang 3 members on his site, those gang members are attributed 4 to Daniel Antunez, because Daniel posted on Robert's 5 site as well? 6 7 A Yes. I think we can show the nexus of the friends and, thus, the association. 8 Q Okay. And the next page? 9 A 135. 10 Adams again. Doesn't have a direct correlation with 11 Mr. Antunez. I think that was it. 12 else on there. Let me see here. 13 Q And the next page? 14 A I marked 136. Right away I see Brandi I don't see anything Let me look again. I think I 15 flagged this one for down towards the bottom. Robert 16 Roman specifically has posted a particular entry there. 17 Q What one is that? 18 A "Fuck I'm pissed fucken got down and the only 19 thing I'm mad about is cuz they ripped my shirt. 20 Fuck you still 'T' motherfuckers." 21 was a reference towards the police. 22 things about that. 23 24 25 Q Okay. Ha, That, by the way, I know some other And when was -- or is it fair to say that this was posted on or around April 12th of 2012? A I don't have anything to base that on, but I 92 JEFF LAUNI, EXPERT 1 2 would say that's probably fair. Q Anything else about this page that indicates to 3 you that Daniel Antunez is an active participant of 4 Townsend Street? 5 A No. 6 Q Next page? 7 A 138. 8 Q Okay. 9 A Brandi Adams communicating with Daniel Antunez. 10 Q Anything else? 11 A Hang on. I'm looking. Just a second. I'm 12 trying to remember, just so you know, the significance 13 of the "B" in the Boston Baseball cap. 14 significance there with Townsend. 15 it is. 16 this, I'd say, no, that's all. Q Okay. 18 A 139. 19 20 I can't remember what I'll have to research that. 17 There's a For the purposes of The next page? Brandi Adams again. Mr. Antunez references "Habing a firme" Cinco de Mayo with "da" family and "da homies." 21 Q Where is that? 22 A About a third of the way down in the post. 23 term "homies," that may be a little generic, but when 24 this individual uses it, I would say it's more gang 25 referenced. The 93 JEFF LAUNI, EXPERT 1 Q Anything else? 2 A I'm looking. No, that would be it. 3 140. Brandi Adams. Gang association again. 4 About halfway down, Mr. Antunez: "Chugging 5 some pistos wid da homies nd bumping some jams. 6 for da 15 to start." "FK" is fuck it. 7 Q So what is it about that post? 8 again? 9 A The homies. 10 Q Anything else? 11 A Further down: 12 brew with the homies. 13 it." Is it "homies" "Getting stoned nd drinking some Hearing to some G music. 14 Q So is it "homies" again? 15 A Homies again. 16 gang music. 17 Q And how do you know that? 18 A It's kind of a common reference, gang 19 Fuck "G music" would be, you know, subculture, from "G down," and "G up," "What up G?" 20 Q And is that from your experience? 21 A Yes. 22 That's it. 23 Q What's the next one? 24 A 141. 25 Waiting Brandi Adams again. was something else on this. But I thought there I'm looking. 94 JEFF LAUNI, EXPERT Hold on. 1 That must have been it. Don't see anything else that 2 jumps out at me on that one. 3 Q Next page? 4 A I have marked 142. 5 I think it's all coming apart now. 6 Q 7 142 and 143. 8 A 9 I think there's two pages left in the packet, So on 142? Brandi Adams. He's in that one post talking about the 10 probation officer and the gang unit having just went to 11 his house. 12 Q Can you tell me where you're referring to? 13 A Third post down. It says: "FKN PO nd G 14 units --" gang units "-- went in da pad trying to FK 15 around wid uss pero --" dog " -- se la -- haha Putos --" 16 He's making fun of the police in his spiel. 17 18 Q So what does that last "pero se la pelaron ha ha ha putos" mean? 19 A He's insinuating that the gang unit and the PO 20 are fucking with him. He says "wid uss." 21 assume, his family, but that could be a general kind of 22 term. 23 he's calling us fuckers. "Pelaron" I don't know. Would be, I "Ha ha ha Putos." So 24 Q Okay. So do you speak Spanish? 25 A Enough to order in the drive-through line at 95 JEFF LAUNI, EXPERT 1 2 3 Taco Bell. Q That's all I'm going to admit to here. Would it be fair to say that this was posted on March 29, 2012? 4 A I would take it that way. 5 Q Okay. 6 A Let me look further. 7 nothing. Anything else on this page? No, last page there was Last page would be 143; right? 8 MS. HELZER: 9 Let's go off the record. 10 Right. (Recess at 11:56 a.m. At which time, the 11 proceedings is move to the DA's Office) 12 (Back on the record at 12:48 p.m.) 13 MS. HELZER: 14 Let's go back on the record. Before we start, Detective Launi was kind 15 enough to make copies of the written note he made with 16 respect to active participation and how he defines it. 17 Q 18 that paper. 19 of your writings in defining active participation that 20 we discussed earlier today? 21 22 A Detective Launi, I'm just handing you a copy of And if you could just verify this is a copy It is. MS. HELZER: Okay. I'd like to attach this one 23 page document as Exhibit 2 to the deposition transcript. 24 (Whereupon Exhibit 2 was marked for 25 identification and attached hereto) 96 JEFF LAUNI, EXPERT 1 2 BY MS. HELZER: Q Detective Launi, is it your opinion that Daniel 3 Antunez is an active participant of Townsend Street gang 4 today? 5 A Yes. 6 Q And what do you base that opinion on? 7 A Results on the background check I ran on him in 8 preparation for various purposes in this process. 9 Q And when did you run that background check? 10 A First part of the year 2013, I would say. 11 Q Like January 2013? 12 A It could have been January through March. 13 were running backgrounds on everybody. 14 would have been run, sometime in that timeframe. 15 16 Q We That's when his Have you run a background check on him since January through March 2013? 17 A No. 18 Q Other than the background check that you ran in 19 early 2013, what else, if anything, do you base your 20 opinion that Mr. Antunez is an active participation of 21 Townsend Street today? 22 A Well, statements he's made and residential 23 address or addresses he's had and people he's been 24 contacted with, activities he's been involved in during 25 police contact or what drew the police attention to him. 97 JEFF LAUNI, EXPERT 1 2 That's probably about it. Q And when is the last time you reviewed the 3 information relating to Mr. Antunez that assisted you in 4 reaching your conclusion that he's an active participant 5 of Townsend Street gang today? 6 A It's been some time. Probably back when I 7 typed this note sheet up, and that would have been, say, 8 several months ago. 9 10 11 Q And can I see the note sheet that you're referring to? A 12 (Witness complies). MS. HELZER: 13 Can we go off the record. (Off the record at 12:52 p.m.) 14 (Back on the record at 12:57 p.m.) 15 MS. HELZER: Back on the record. 16 So, Detective Launi, you had mentioned that you 17 had typed up some notes, and I think I will go ahead and 18 include these notes as Exhibit 3 to the deposition. 19 (Whereupon Exhibit 3 marked for 20 identification and attached hereto) 21 BY MS. HELZER: 22 Q Did you get your original back? 23 A Yes, thank you. 24 Q And the question I had asked, to refresh kind 25 of where we are in the deposition, is when was the last 98 JEFF LAUNI, EXPERT 1 time you looked at information related to Daniel Antunez 2 and whether he's an active participant of the Townsend 3 Street gang today. 4 when you typed up a note sheet. 5 sheet that's Exhibit 3 that you were referring to; 6 correct? 7 8 A And your answer was probably back And this was the note Yeah, I think I -- correct me if I'm wrong, but I think I said when I ran the background check on him. 9 Q So did you run another background check on him 10 after 2013? 11 A No. 12 Q And you mentioned that you ran the background 13 check in 2013. And other information that you 14 considered in determining that he was an active 15 participation of the Townsend Street gang today are 16 statements that he made, his residential address or 17 addresses, people that he associated with and activities 18 that he was involved in; is that right? 19 A Yes. 20 Q Were there any other categories of information 21 that you considered in determining whether he's an 22 active participant today? 23 A Probably not, no. 24 Q And when is the last time that you looked at 25 all of that information, including the background check 99 JEFF LAUNI, EXPERT 1 2 3 4 regarding Daniel Antunez? A Well, completely back when I ran it. I've not re-read it or studied it in depth since. Q And in referring to what's Exhibit 3, which are 5 the notes you indicated that you took regarding Daniel 6 Antunez, when did you take those notes? 7 A You mean when I wrote those up in that form? 8 Q When did you write up Exhibit 3? 9 A I would estimate that timeframe to be maybe 10 just before summer or beginning of Summer 2015. 11 Q And why did you write up the notes? 12 A In preparation for potential court testimony. 13 I refer to these notes as kind of a cheat-sheet to keep 14 any testimony I might have to render in court kind of on 15 track and flowing. 16 Q And in preparing these notes around before 17 Summer of 2015, did you review any documents related to 18 Daniel Antunez and whether he's an active participant of 19 Townsend Street? 20 A Yes. 21 Q But it wasn't a whole in-depth review that you 22 23 did back in 2013; is that right? A I may have misspoke. I would say it was, 24 because I looked at everything I had, every piece of 25 documentation I had. 100 JEFF LAUNI, EXPERT 1 2 Q Okay. When is the last police contact that Daniel Antunez has had? 3 A Sitting here right now, I don't know. 4 Q Okay. 5 Would it be easier if I narrowed it down to Santa Ana Police Department? 6 A No, I assumed that's what you meant. Without 7 running, you know, a fresh query on him, I wouldn't know 8 that. 9 Q In your Exhibit 3, which is your notes, it 10 looks like it's in reverse chronological order; is that 11 correct? 12 A Yes, most current would be first. 13 Q And so according to your notes, what is the 14 15 16 17 last police contact that Daniel Antunez had? A That I'm aware of, as I sit here right now, would have been July 16, 2013. Q And if you need to refer to your notes during 18 the next line of questioning, I'm fine with that. 19 might indicate, for the record, that you're looking at 20 your notes, just to distinguish it from independent 21 recollection that you have. 22 A Okay. 23 Q Now, one of the criteria factors we were I 24 talking about earlier today in your deposition is that, 25 in addition to the background check and what they 101 JEFF LAUNI, EXPERT 1 reveal, one of the indicators to you that you consider 2 is gang activity; is that right? 3 A Yes. 4 Q And what gang activity do you attribute to 5 Daniel Antunez in forming your opinion that he is 6 currently an active participant of Townsend Street? 7 A It would be a conglomeration of all gang 8 documentation we have on file of him. 9 be any one piece. 10 Q It wouldn't just And gang activity, does that include criminal 11 activity as well as activity that's not criminal, like 12 hanging around or associating with certain people? 13 14 15 A It would include all of those activities, criminal and noncriminal. Q And the notes that you wrote on Exhibit 3, is 16 that all of the information -- a summary of all of the 17 information that you are aware of and considered in 18 determining that Daniel Antunez is currently an active 19 participant of Townsend Street? 20 A No. 21 Q There's more information in addition to what's 22 summarized in the notes? 23 A Yes. 24 Q And what additional information? 25 A Police reports, possibly STEP Notices, possibly 102 JEFF LAUNI, EXPERT 1 2 FI Cards, Field Interview Cards. Q And do you have a specific recollection of 3 police reports that exist relating to Daniel Antunez 4 that are not summarized or indicated in some way in your 5 notes that is Exhibit 3? 6 A Yes. 7 Q What police report is that? 8 A 3-29-09, a STEP Notice. 9 Q Okay. 10 A If I may interrupt. And what is it about -If you're going to ask me 11 about each of these, I'd have to refer to them maybe to 12 answer your question, because I don't have them right in 13 front of me. 14 Q 15 go quicker. 16 outside of what's written in Exhibit 3, which are your 17 notes, that are not referenced in your notes. 18 there any information that isn't indicated in your notes 19 that exist? 20 A Yes. 21 Q Okay. 22 Maybe you can help me so that we can make this I'm wondering if there's any information So is So you referenced a STEP Notice of March 29, '09? 23 A Yes. 24 Q That's in your notes? 25 A It's not in my notes. 103 JEFF LAUNI, EXPERT 1 Q Because you handwrote them? 2 A No. 3 Maybe I can explain? 4 Q Yes, please, explain. 5 A This only goes back -- this is exhibit what? 6 Q This is Exhibit 3. 7 A Exhibit 3 only goes back three years. He has 8 gang documentation that goes well beyond that three-year 9 limit. For purposes of the gang injunction and what I 10 know from experience what the court's like or what they 11 generally will accept is about three years back, give or 12 take. 13 prior to that. 14 But Mr. Antunez has gang activity documented well Q And so on the first page of Exhibit 3 it says: 15 On informal probation until 3-12-16. 16 "gang documentation goes back to 2005." 17 you're referring to when you say it goes back well 18 before? 19 20 21 A Yes. And then it says Is that what It's not just the probation aspect. There's other STEP Notices and stuff like that. Q Okay. In forming your opinion that Daniel 22 Antunez is currently an active participant of Townsend 23 Street, did you consider documentation that goes all the 24 way back to 2005? 25 A Correct. 104 JEFF LAUNI, EXPERT 1 2 Q But you're limiting the evidence -- excuse me. I shouldn't assume. 3 Are you limiting the evidence that you are 4 presenting in support of your conclusion to a certain 5 timeframe? 6 A 7 No. If I may add? Exhibit 3 goes back three years. 8 The gang discovery that we gave you goes back to '05 9 timeframe. 10 11 Q And you considered all of it in determining whether he's currently an active participant? 12 A Yes. 13 Q So what is the gang activity that Daniel 14 Antunez has been involved in that you consider to be 15 relevant to determining that he's currently an active 16 participant of Townsend Street? 17 A All of it. 18 Q And when you mean "all of it," can you be more 19 20 specific? A I can go through each piece, if you'd like, but 21 it includes STEP Notices, police reports, FI Cards and 22 general contact. 23 24 25 Q And so in your binder regarding Mr. Antunez, we have Bates stamped numbers 1 through 193; is that right? A I'm going to say, yes, but let me look. 105 JEFF LAUNI, EXPERT 1 Q Of course. 2 A Yes. 3 Q And so when you say "all of it," is all of it 4 5 I want you to be accurate. included in Bates stamp numbers 1 through 193? A I think it is, because in here we have the 6 social networking stuff we looked at. 7 by saying, this is all we know of. 8 9 Q I might answer it So, yes. Now, with respect to Daniel Antunez, you had mentioned more generally that when you were making the 10 cut between 240 and then 40 and 29, one of which is 11 Mr. Antunez, that you looked at hanging out with 12 different gang members and then you narrowed it by 13 whether they were arrested or not; is that right? 14 A That was one of the things I considered, yes. 15 Q And did you consider that with respect to 16 Mr. Antunez? 17 A I'm sure I did. 18 Q Do you recall what it was about Daniel Antunez 19 specifically that made you put him in the list, the 20 enforcement list, as opposed to the 200 or the 40 that 21 you -- that was the larger list? 22 A Yes. 23 Q And what was it specifically about Daniel 24 25 Antunez? A His activity level and police contacts, 106 JEFF LAUNI, EXPERT 1 2 frequency of police contact. Q And how was his activity level and frequency of 3 police contacts different than the individuals who you 4 decided were not active participants of the gang? 5 A Generally, it was more. However, I may have 6 had people that had more contacts than him, but maybe 7 they were in custody or something like that so it wasn't 8 an appropriate time to enjoin them. 9 looked at levels of activity and who's in or who's out. 10 And he was among that group that was, you know, in the 11 higher end and not in custody. 12 at people who are not going to be a detriment to the 13 neighborhood. 14 those determinations. 15 Q You know, so I Obviously, we're looking Those are some of the ways we would make And, again, if you need to refer to your notes 16 and if your notes help you refer to documents. 17 it that you would consider the most significant piece of 18 evidence with respect to determining that Daniel Antunez 19 is currently an active participant of Townsend Street? 20 A What is If I understand your question right, you're 21 asking for the primary incident or document that, in my 22 mind, put him over the top? 23 Q If there is one, yes. 24 A I don't think there is one. 25 If there is one, I wouldn't remember it, but it's everything included in 107 JEFF LAUNI, EXPERT 1 this book, I can tell you that. 2 discovered, just the totality of everything, all the 3 documentation. 4 Q Okay. Everything we When you look at your notes on 5 Exhibit 3, if you could just take a look at them, and if 6 there was something that you would weigh more heavily as 7 indicating that he's an active participant of Townsend 8 Street today, what incident or incidents would that be? 9 A If you gave me just a minute to look? 10 Q Sure. 11 A I would say probably an incident that occurred 12 on September 19, 2012 in which Mr. Antunez was with 13 another gang member who was arrested for possession of 14 narcotics for sales at 805 South Townsend Street. 15 16 Q And is that indicated on the second page of Exhibit 3 with the date 9-19-12? 17 A Yes. 18 Q 12-27804? 19 A Correct. 20 Q And why would you weigh that more than other 21 22 incidents? A Well, I'm weighing it more than other incidents 23 on this two-page typed sheet here, because, you know, 24 he's obviously with this guy standing out there dealing 25 dope in the alley, and this is one of the primary 108 JEFF LAUNI, EXPERT 1 activities of his gang. 2 mind -- although, I don't have the evidence sitting 3 right here, there's no doubt, in my mind, he was 4 involved in it. 5 And there's little doubt in my Now, in other instances that are not on this 6 two-page document, it might have been something more 7 serious, but I don't know. 8 the background that's in the book here. 9 10 Q Okay. I'd have to look at those in And were you present during the contact on September 19, 2012? 11 A No. 12 Q And in reaching your conclusion about 13 Mr. Antunez's involvement in the contact, did you obtain 14 that through a police report? 15 A What? 16 Q You had mentioned that it was your 17 understanding that or your belief that Mr. Antunez was 18 involved in the sale of drugs? 19 A Correct. 20 Q And what is the basis of your belief that he A I'd have to re-read that report to see if 21 22 was? 23 there's anything in that report about his specific 24 activity. 25 particular, when they're dealing drugs, they usually But in general, I know this gang, in 109 JEFF LAUNI, EXPERT 1 have lookouts or somebody that runs smaller quantities 2 of dope out to the prospective buyer, things like that. 3 They don't deal dope down there by themselves. 4 Generally, they do it in two or more or even groups. 5 that's general knowledge from my training and experience 6 of this gang in particular, knowledge of this gang. 7 So I'll also say that narcotic -- sales and 8 narcotic activity is far and away the number one primary 9 activity of this gang. 10 11 Q Okay. And so you read the police report with respect to this incident; correct? 12 A I must have at one time, yeah. 13 Q Did you have any conversations with 14 Detective Zuniga regarding this incident? 15 16 17 A I probably did. He worked the gang unit at the time. Q Do you have a specific recollection about 18 whether you talked to Detective Zuniga about this 19 incident? 20 A No. 21 Q Are you aware of any tattoos that Daniel 22 Antunez has? 23 A Yes. 24 Q And what tattoos does he have? 25 A He has, on his left arm, "Nathan 9-2-08." 110 JEFF LAUNI, EXPERT 1 That's his son. 2 Telesforo," T-e-l-e-s-f-o-r-o. 3 has "OC." 4 5 And on his right arm he has "Gabriella And on his right shin he And he may have others I'm unaware of, but I'm aware of those. 6 MS. HELZER: And just for the record, 7 Detective Launi is referring to the back page of the 8 first page of Exhibit 3. 9 Q Which is your handwriting; is that correct? 10 A Yes. 11 Q And where did you get the information that you 12 just read regarding Daniel Antunez's tattoos? 13 A From police records. 14 Q And do you consider any of the tattoos that you 15 believe Daniel Antunez has to be gang tattoos? 16 A No. 17 Q Do the tattoos indicate anything to you with 18 respect to your opinion that Daniel is an active 19 participant of Townsend Street gang currently? 20 A No. 21 Q Now, in your opinion, has Daniel Antunez had 22 repeated or ongoing associations with other Townsend 23 Street gang members? 24 A In my opinion? 25 Q (No audible response.) 111 JEFF LAUNI, EXPERT 1 2 3 4 A Probably. I don't have any basis for that. You said my opinion. Q Well, you had mentioned that you don't know Daniel? 5 A Best of my knowledge, right. 6 Q So you haven't had any contact with him as a 7 police office; is that correct? 8 A Correct. 9 Q So since you have never met him and you haven't 10 had police contact with him, is it your opinion that he 11 has repeated ongoing associations with other Townsend 12 Street gang members? 13 A Based on my training and experience and what 14 gang members have told me, in numerous interviews and 15 conversations with gang members, gang members have other 16 gang members as friends. 17 assume that he continues to have contacts and interact 18 with fellow Townsend Street gang members. 19 my opinion based on those things. 20 Q Okay. So I think it's logical to That would be So do you have any specific basis for 21 that opinion other than just a general gang members have 22 gang members as friends? 23 24 25 A If you're asking me, does he continue to talk to gang members? Q Yes. 112 JEFF LAUNI, EXPERT 1 A I don't know. I don't have any proof of that. 2 Nobody has told me that. I also know that gang members 3 don't live in a bubble or vacuum. 4 Q And what do you mean by that? 5 A They talk to whoever they want. They have 6 conversations just like you and I. 7 logical, these are his friends, that he would continue 8 contact with his friends. 9 10 Q I think it's But you don't know one way or another whether he has or not? 11 A No. 12 Q Since you haven't met Daniel Antunez 13 personally, do you have any knowledge about how he 14 dresses? 15 16 A I'm going to assume you're referring to gang attire, things like that. I do not. 17 Q You don't? 18 A I mean, I know the guy wears clothes, you know. 19 20 What he wears, I don't know. Q The reason, in your declaration, your expert 21 declaration that you submitted in support of some of the 22 allegations that the District Attorney made, you had 23 mentioned that one of the criteria is the manner of 24 dress, an individual's manner of dress? 25 A It can be, yes. 113 JEFF LAUNI, EXPERT 1 Q And so is there any evidence that you know of 2 suggesting that Daniel dresses in a way that would 3 inform your opinion that he's currently an active 4 participant of Townsend Street? 5 A I think we have documentation of him either 6 wearing or in possession of some gang indicia. 7 to go back and refresh my recollection what that is. 8 want to say its clothing, but I would have to look. 9 10 Q I'd have We talked earlier about gang clothing and gang indicia being the color blue; is that correct? 11 A Yes. 12 Q Dallas Cowboys? 13 A Yes. 14 Q Twin Cities; correct? 15 A Yes. 16 Q Anything else other than those three things? 17 18 I And I could be missing something. A Yeah, there's a lot of other identifiers, 19 things they identify with that relate out of my expert 20 declaration. 21 you, I'd have to look at them again. 22 Q To remember them all, to be honest with Just in the context of the manner of dress or 23 possession of gang clothing or indicia with respect to 24 Townsend Street, do you have any independent 25 recollection other than blue, Dallas Cowboys and Twin 114 JEFF LAUNI, EXPERT 1 2 3 4 Cities? A I don't understand. Relating to Mr. Antunez specifically? Q Well, let's just step back and just generally 5 talk about -- just get the baseline for what is regarded 6 as Townsend Street gang affiliated clothing? 7 A Identifiers? 8 Q Identifiers. 9 A Okay. 10 Q Sure. 11 A Find that for you. 12 May I refer to this? Bear with me. It will take a minute to find it here. 13 I'm ready to continue when you are. 14 Q Okay. 15 A I don't know how it's numbered in there. 16 17 18 What page? I'm looking at page 16 of my expert declaration. Q And just for the record, are you looking at a declaration that's approximately -- well, 145 pages? 19 A I would say so, yes. 20 Q And you're on page? 21 A Sixteen. 22 Q And it's entitled, for the record, Expert 23 Declaration of Detective Jeff Launi of the Santa Ana 24 Police Department; is that correct? 25 A Yes, yes. 115 JEFF LAUNI, EXPERT 1 Q Okay. Does that help refresh your recollection 2 as to the gang indicia or indicators for Townsend 3 Street? 4 5 6 7 A Yes. Just so you know, there's half a page of them. Q We don't need to go through them. I'm trying to save some time here. 8 A Okay. 9 Q But is there any indication with respect to 10 Daniel Antunez wearing any of this gang indicia that 11 formed your opinion that he's currently an active 12 participant of Townsend Street? 13 A There may have been. As I said, I would have 14 to look at the documentation, and I could probably do 15 that pretty quick. 16 MS. HELZER: 17 (Off the record at 1:26 p.m.) 18 (Back on the record at 1:32 p.m.) 19 20 Off the record. MS. HELZER: Q Back on the record. So, Detective Launi, do individuals with no 21 gang ties wear gang styles and colors for the perceived 22 cool factor? 23 A In past years, I would say, yes, because 24 gangster style was a style. It was sold at, you know, a 25 lot of the young people's clothing stores and things 116 JEFF LAUNI, EXPERT 1 like that. 2 gang colors worn or specific indicators or 3 advertisements for a particular gang. 4 know, there's potential repercussions for that if one's 5 caught doing that. 6 What we typically don't see are specific As I'm sure you So the gangster style that was out there was 7 very generic and it's kind of passed, seem to be kind of 8 past that. 9 10 11 Q We don't see that as much. And when is this shift from past years where gangster style was in to this shift that it's not? A I would say five or seven years ago it probably 12 ran its course. 13 members are identifiable by gang clothing or any of the 14 stereotypes, baggy clothing, high knee-socks. 15 guarantee you, any of us in this room could rub elbows 16 with a hardcore gang member at the mall and not realize 17 who he is. 18 exist, to a large extent they don't exist. 19 Q And I will say that not all gang I So a lot of the stereotypes, while they do So knowing that individuals could be dressed 20 the way you and I are dressed today and be gang members, 21 as well as individuals could be dressed in the 22 stereotypical long shorts, high socks, how do you make a 23 distinction between who is and who isn't a gang member 24 with respect to the clothing? 25 factor? How do you weigh that 117 JEFF LAUNI, EXPERT A 1 Okay. At least five times during this 2 deposition today -- and I'm not complaining. 3 making a point -- I've said we look at the entire 4 package. 5 dressed down, you know, like a vato loco on the corner 6 and label him a gang member unless I stop and talk to 7 him. 8 don't look at any one indicator. 9 to be a style. 10 I'm just I'm not going to look at some guy who's I look for other things during the contact. Q Okay. So I Like I said, it used And with respect to Daniel Antunez, is 11 it your opinion that if he is indicated in the 12 documentation as wearing gang indicia or gang colors, 13 that you would consider that to be consistent with him 14 being an active participant with a gang? 15 A I would say it would be consistent. I would 16 have to see, you know, what it is, because gang members 17 then tend to wear more specific things to their gangs 18 that are identifiers. 19 20 21 22 Q And in this case, that is the Cowboys or the Twin Cities; correct? A Any reference to Townsend Street, the gang's history, the park they claim nearby, things like that. 23 Q Okay. 24 A The things I know from experience to look for 25 and look at. 118 JEFF LAUNI, EXPERT 1 Q Okay. Now, you indicated, in your notes that 2 we marked as Exhibit 3, that Daniel is on informal 3 probation until March 12 of 2016? 4 A Yes, that's what it says there. 5 Q And to your knowledge, is he still on 6 7 probation? A I don't know. I'd have to run them again. If 8 somebody is doing well on probation, of course, there's 9 early termination and things like that. So I wouldn't 10 want to say yes or no as I sit here right now. 11 said, I haven't done any background on him in a while. 12 Q As I If you learned that he was taken off of 13 probation early, would that affect your opinion about 14 whether he's an active participant of the gang today? 15 A No. 16 Q Why not? 17 A Because people are early terminated from 18 probation and parole for a million reasons. 19 Prop 47. 20 that have flooded all our systems with an overage of 21 people that can't be dealt with. 22 people released from supervisions of various types 23 early. 24 gang members or whatever. 25 in the system. We have AB 109. We have We have all kind of things There's a ton off It doesn't mean they're still not criminals, There's no way to handle them So they're released and out there. 119 JEFF LAUNI, EXPERT And I'm not saying that occurred with 1 2 Mr. Antunez, but that's a possibility why I say it 3 wouldn't affect my opinion. 4 5 6 7 Q And what information would you need to know more in order for it to affect your opinion? A Why he was released or terminated early if he, in fact, was. 8 9 I might also add he was on informal probation. You may as well not be on probation if you're on 10 informal probation. 11 supervised. 12 probation in our system. 13 I would have to know more. Q It's so useless. He's not even I don't even know why they have informal So does the fact that he's on informal 14 probation as opposed to formal probation indicate to you 15 whether or not -- in any way whether or not he's an 16 active participant of Townsend Street today? 17 A No. It might have been a first offense, 18 low-level offense. 19 doesn't mean he's not an active participant of a gang. 20 Q Okay. There's a number of reasons why. So does the probation issue provide It 21 information to you about whether or not he's a current 22 active participant of Townsend Street? 23 A It can. 24 Q And that's the reason why? 25 A (No audible response.) 120 JEFF LAUNI, EXPERT 1 Q I'm sorry. Why can it be? 2 A Well, because it might cause me to look further 3 and find out what caused him to be on probation. 4 Usually, it's going to be a crime of some sort, and I'll 5 delve into that incident and I'll see what was involved, 6 who was involved, that kind of thing. 7 affect my opinion one way or another or that might be 8 one piece of something that might affect my opinion 9 along with other pieces of similar documentation down 10 11 That's what may the road. Q Okay. And is there a certain level of -- if he 12 was on probation for personal drug using, possession of 13 a small amount of drugs for personal use, does that 14 weigh one way or another about whether he's an active 15 participant of Townsend Street today? 16 A It might. 17 Q And why might it? 18 A Because the primary activities of all gangs -- 19 and I've worked gangs for over 25 years -- are narcotic 20 offenses and vandalism offenses. 21 "vandalism," I'm speaking primarily of graffiti. 22 I'm talking about narcotic offenses, it could be 23 anything from personal possession of a dime of whatever 24 for personal use all the way up to sales. 25 number of people that sale drugs that use drugs, things When I say 121 JEFF LAUNI, EXPERT When We have a 1 like that. 2 consider. 3 4 Q Those are things I have to look at and Okay. Now, you made the enforcement list back in January of 2013, I think you testified to earlier? 5 A Yes, first part of 2013. 6 Q Has your opinion about who should be included 7 on that enforcement list changed over time? 8 A 9 Yes. MS. ECKERMANN: 10 THE WITNESS: 11 MS. ECKERMANN: I -- 12 I'm sorry. I want to object. I don't think that's relevant. 13 MS. HELZER: You can still answer the question. 14 MS. ECKERMANN: 15 MS. HELZER: No, I prefer you not answer. Ms. Eckermann, relevance is not an 16 appropriate objection and instruction not to answer in a 17 deposition. 18 MS. ECKERMANN: It's not relevant to this 19 particular hearing that you were granted this deposition 20 for. 21 MS. HELZER: 22 MS. ECKERMANN: 23 24 25 Can you mark that, please. -- Daniel Antunez active participation only and this Detective's opinion -MS. HELZER: You don't know what my follow-up question is. 122 JEFF LAUNI, EXPERT 1 Will you mark that, please. 2 THE REPORTER: 3 MS. HELZER: 4 THE REPORTER: 5 6 7 What was it? "Yes." BY MS. HELZER: Q Have you changed your opinion about whether Daniel should be on that enforcement list? 8 9 There was an answer. MS. ECKERMANN: I'm going to object. That's already been asked and answered at least two times 10 during this process. 11 BY MS. HELZER: 12 Q You can answer the question. 13 A I'm going to do what she says. 14 Q She hasn't instructed you not to answer, and if 15 she does, it's improper. 16 MS. ECKERMANN: 17 THE WITNESS: 18 19 Go ahead and answer. No. BY MS. HELZER: Q Does the fact that Daniel Antunez works 20 full-time affect your opinion on whether he's currently 21 an active participant of Townsend Street? 22 23 MS. ECKERMANN: because we don't have any evidence before us. 24 25 I'm going to object as to that, MS. HELZER: opinion. He's an expert. He's giving an I'm giving him information that may or may not 123 JEFF LAUNI, EXPERT 1 affect his opinion and that's what I would like to know. 2 I'm entitled to that. 3 4 MS. ECKERMANN: does it affect. 5 6 7 I understand that, but you said MS. HELZER: I'll rephrase -- I'll rephrase that. Q If you discovered that Daniel Antunez worked 8 full-time, would that affect your opinion about whether 9 or not he's an active participant of Townsend Street 10 today? 11 A No. 12 Q Why not? 13 A A lot of gang members have jobs. 14 Q So it wouldn't affect your opinion at all? You 15 wouldn't need any more information about the kind of job 16 or how long he's had the job? 17 A Certain information in that regard might. Like 18 if this guy worked 24 hours a day and didn't have time 19 to do anything else, things like that, but I don't have 20 that in front of me. 21 Q If Daniel Antunez worked a full-time job, would 22 that affect your opinion about whether he's an active 23 participant of Townsend Street? 24 A No. 25 Q If Daniel Antunez worked a full-time job where 124 JEFF LAUNI, EXPERT 1 he had to travel an hour to two to the job and an hour 2 to two back from the job, would that affect your opinion 3 on whether Daniel Antunez was an active participant of 4 Townsend Street today? 5 6 A I hate to answer a question with a question, but I would say no. 7 Q And why not? 8 A Does he have days off? 9 10 11 He has time available. Everybody has days off. He has personal time available to him. Q So if he has days off, what would affect -- and 12 he was supporting his family on those days off or 13 hanging out with his children on those days off, would 14 that change your opinion about whether Mr. Antunez is 15 currently an active participant of the gang? 16 A With the question posed that way, possibly. 17 Q And why are you hesitant about it? 18 A Well, because everybody here knows people have 19 personal time. With that personal time, they can hang 20 out, go or do whatever they want. 21 working, he has kids, so on and so forth. 22 that and I still had time to do some of the things I 23 wanted to do. 24 the neighborhood, hanging out and associating, that kind 25 of thing. I understand he's I had all Potentially, he could still be over in 125 JEFF LAUNI, EXPERT On the flip side of that, a large -- I don't 1 2 want to say a large percentage, but a percentage of gang 3 members that we contact on a daily basis are employed 4 full-time. 5 It doesn't mean they quit being gang members because 6 they have a job. 7 Q It doesn't mean they're not gang members. So what percentage of Townsend Street gang 8 members who are on the list of 29 are full-time 9 employees? 10 A I don't know. 11 Q Did you look into that? 12 A No. 13 Q If you discovered that Daniel Antunez supports 14 his two children, would that affect your opinion on 15 whether he's an active participant of Townsend Street? 16 A No. 17 Q Would any of these factors be part of your 18 totality of the circumstances that you determine in 19 deciding whether someone's an active participant of 20 Townsend Street? 21 22 23 24 25 A It might be something I would consider, but I would still have to know more or look at more. Q And what weight would you give these other more seemingly positive aspects of participating in life? A Are you asking like for a percentage of what I 126 JEFF LAUNI, EXPERT 1 2 would attribute it to? Q No. You said there's a totality of the 3 circumstances. 4 factors or criteria more than others. 5 to know is: 6 full-time employment, financially supporting two 7 children, you know, having lots of travel time in 8 between, you know, getting to and from work? 9 you weigh that information? 10 A We established that you weigh some What I would like What weight, if any, would you give to How would I would, certainly, consider that. I would 11 have to know more about that specifically, but I would 12 have to consider that in addition to what else I know. 13 Q Okay. And that still doesn't answer -- because 14 there is certain weight that you had testified to 15 earlier with regards to different factors. 16 know, gang activity, for example, was a factor that you 17 weighed heavily, is that correct, in determining whether 18 somebody was an active participant of a gang? Like, you 19 A Gang what? 20 Q Activity. 21 A Yeah, contacts and activity. 22 Q You would weigh that factor heavily? 23 A Yes. 24 Q And so I'm trying to determine how you would 25 weigh full-time employment, financially supporting 127 JEFF LAUNI, EXPERT 1 children, how would you weigh those factors when you're 2 looking at the totality of the circumstances about 3 whether someone's an active participant? 4 A I think I would look at an individual's record 5 over a period of time under those circumstances. 6 that might be a good answer. 7 8 9 Q That What is it about the period of time that would be significant to you? A Well, the longer without police contact or him 10 not comitting a crime or re-offending I think would be 11 something I would have to consider. 12 Q 13 sorry. 14 And do you know when the last time -- oh, I'm I asked you that question. Strike that. Would living outside of the Townsend Street 15 safety zone, would that be a consideration in 16 determining whether or not Mr. Antunez is a current 17 participant of Townsend Street? 18 A Not really, no. 19 Q Why not? 20 A A lot of these gang members don't live in the 21 22 23 24 25 neighborhood. Q They live outside the safety zone. Would it have any -- would you weigh it at all in your consideration or is it just an irrelevant point? A You know, I might weigh it, but it would be a very small consideration. We have a lot of gang 128 JEFF LAUNI, EXPERT 1 members -- unfortunately, in Santa Ana we're very gang 2 impacted. 3 within each gang, we have a number of individuals that 4 claim that gang that don't live in the core 5 neighborhood. 6 would be low-level consideration. 7 outside the city and county claim these gangs. 8 9 Q We have a lot of gangs allover the city. And So it would be considered, but I think it We even have people So -- Now, have you testified as an expert witness on the issue of whether an individual is an active 10 participant? 11 A Yes. 12 Q How many times? 13 A Fifty to a hundred. 14 Q Is that the best estimate you can give me? 15 A I'll say over 50. 16 Q Over 50? 17 A Yes. 18 Q But less than a hundred; is that correct? 19 A You know, for the purposes of everything I do, 20 court testimony, depositions, everything, I tend to be 21 conservative in those figures. 22 after so many, you know, you quit. 23 been over 50. 24 times I've testified in court. 25 Q I used to log them, but I know for sure it's It could be 300 times. That's how many I'm in court constantly. And what I'm asking you is a very specific 129 JEFF LAUNI, EXPERT 1 question about testimony about whether an individual is 2 an active participant of a gang? 3 A I would answer that with more than 50 times. 4 Q Okay. And in the more than 50 times that 5 you've testified on the issue of whether an individual 6 is an active participant of a gang, how many times did 7 you conclude that she or he was not an active 8 participant? 9 A Zero. And there's a reason why. 10 Q Okay. And what's your reason why? 11 A Because the process we have for rendering that 12 expert testimony would not have allowed me to have 13 gotten that far in the process if I didn't think the 14 person was an active participant. 15 charges probably would not have been filed on that 16 individual and those decisions are made way before 17 anything goes to court, any testimony is given or 18 anything else. 19 Q In fact, the gang And I'm assuming you've always testified on 20 behalf of the District Attorney's Office or the people 21 of the State of California; is that correct? 22 A Yes, I would say that's probably correct. 23 I'll testify for you anytime you want to give me a 24 subpoena. 25 Q And you've worked for the Santa Ana Police 130 JEFF LAUNI, EXPERT But 1 Department for over 29 years? 2 A No, it's been 30 years and nine months. 3 Q And how long have you been in the gang unit? 4 A Probably more than 25 years. 5 Q And is having the gang injunction against 6 Townsend Street helpful to you in your job? 7 8 MS. ECKERMANN: I'm going to object. It's not relevant, again, to your client's active participation. 9 MS. HELZER: 10 It is relevant. MS. ECKERMANN: The sole issue that you're 11 entitled to depo him on is your client's active 12 participation. 13 relevant. 14 So the gang injunction itself is not MS. HELZER: The credibility of the witness is 15 relevant to the overall question. 16 the question again so you have it fresh in your mind. 17 18 Q Is having a gang injunction against Townsend Street helpful to you in your job? 19 MS. ECKERMANN: 20 MS. HELZER: 21 So I'm going to ask And I'm going to object -- You can object. instruct him not to answer? 22 MS. ECKERMANN: 23 Don't answer the question. 24 MS. HELZER: 25 Are you going to unethical. I am. Okay. That's improper and it's So I'd like you to, please, mark that. 131 JEFF LAUNI, EXPERT 1 2 Q Is having individuals subject to the provisions of the gang injunction helpful to you in your job? 3 A Yes. 4 Q And why is that? 5 A Because there's less gang activity out in the 6 open and visible in the neighborhoods where we have gang 7 injunctions. 8 9 Now, I will say specific to Townsend, first of all, we haven't had the injunction long enough to see 10 any stupendous results from it in the last quarter stats 11 that I did. 12 hindered by these ongoing processes. 13 concerned, that injunction is not in full swing. 14 tell you from prior experience with another injunction, 15 it had great, positive effects in the neighborhood. 16 17 Q And, secondly, some of our enforcement is So, as far as I'm I can But if it was in full swing, it would be helpful for you? 18 A I would say it would be. 19 Q That's what you want? 20 A Yes. 21 Q I promise I'm almost done with the exception of It would be another tool for us. 22 what I mentioned about coming back to talk more 23 specifically about the gang packet. 24 25 I want to go back to what we deemed Exhibit 2, which is your handwritten notes on the definition of 132 JEFF LAUNI, EXPERT 1 active participation. 2 A Yes. 3 Q And I think that we talked about "beyond 4 passive or in name only" was -- and I apologize if I 5 don't say it exactly the way that you said it, but 6 it's -- that it's the bulk of someone's time is 7 dedicated to gang activity, gang hanging out; correct? 8 That's what makes them an active participant? 9 10 A That would be my interpretation of the instruction, yes. 11 Q And so the next part of this Exhibit 2 is: 12 "Significant amount of time devoted to participating in 13 the gang"? 14 A Yes. 15 Q And how do you gage what is a significant 16 amount of time devoted? 17 18 A the individual, statements maybe from the individual. 19 20 Generally, through documentation, contacts with Q So let me -- I'm sorry. Let me, just so I can get a little bit clearer on my questioning. 21 In the span of someone's time that, you know, 22 with work and with kids, what is a significant amount of 23 time? 24 someone is devoting time to participating, but how do 25 you gage whether it's a significant amount of time? Not necessarily how you would determine whether 133 JEFF LAUNI, EXPERT A 1 I don't know. 2 either. 3 gage. Apparently, the court doesn't That's part of the instruction. I know what I use and what we use. 4 Q In your experience? 5 A You may or may not accept that. 6 But apparently the law doesn't know. 7 8 There's no Q So what is it you use in determining what is a significant amount of time? 9 A I would say whenever that individual or an 10 individual has free time, he's out on the street. 11 may live in the neighborhood. 12 members. 13 members do when they're together. 14 gage an answer on this is my experience and in my 15 conversation with gang members and what I know gang 16 members do. 17 Q He He's with other gang I already testified or spoke about what gang And all I have to And do you know currently whether Daniel 18 Antunez, on his free time, is out on the street hanging 19 out with other gang members? 20 A I don't know what he does in his free time. I 21 have not seen him in a while. But then, again, I 22 haven't been out there working, because I've been doing 23 administrative things. 24 now. 25 other contacts, people have. My job is not a street position So I have to go by what other people generate, 134 JEFF LAUNI, EXPERT 1 Q Now, we talked about Daniel's two brothers 2 being alleged to be active participants of the gang; is 3 that right? 4 A Well, "alleged" is your terminology. 5 Q Right. 6 A I understand. 7 Q Now, when there's an immediate family member Yes. 8 who is alleged to be an active participant, how do you 9 tell the difference between association that's 10 gang-related and association that's due to family 11 membership? 12 A I'm not sure -- and maybe I lost the first part 13 of that question. You're talking about the brothers 14 hanging out? 15 Q Yeah. 16 A Personally, I wouldn't consider that, because 17 as I said early on in this deposition, that you can't 18 hold one's family against them. 19 Q Right. 20 A Now, we might look at, if we catch them 21 together, what they're doing, who else they're with, 22 where they are, like I said, all the number of other 23 indicators. 24 brothers and they're, you know, doing whatever, it's not 25 something outwardly illegal, I'm not going to consider But if he's just with one or more of his 135 JEFF LAUNI, EXPERT 1 that, because they're family. 2 It's the same thing, we probably wouldn't 3 enforce the injunction against brothers for associating 4 and that kind of thing. 5 inappropriate unless they're comitting a law violation 6 or something like that or violating one of the 7 prohibitions in the injunction. 8 keep family from associating. 9 And sometimes that's a problem for us. 10 Q Exhibit 2 that: 12 active participation." 14 You know, you can't That would be my opinion. And you also wrote in your notes here on 11 13 That's, in my opinion, "There's no legal gage to determine What do you mean by that? A There's no standard to make the determination. 15 I think that's what the instruction says. 16 had the instructions back at my office. 17 brought them. I, actually, I should have 18 Q Do you know what the instruction number is? 19 A No. 20 21 22 It's on there, but I don't have it memorized. Q I'm going to ask the reporter to leave a blank. You will get a transcript of the deposition. 23 A Right. 24 Q And if could you find me the number of the jury 25 instruction and write that in for me? 136 JEFF LAUNI, EXPERT 1 A Sure. 2 Q It's like an errata. 3 4 You just do a little -- any changes or additions. A No problem at all. 5 (Information requested: 6 _____________________________________________ 7 ____________________________________________ 8 ____________________________________________) 9 MS. HELZER: 10 Thank you. Let me go off the record. 11 (Off the record at 1:59 p.m.) 12 (Back on the record at 2:11 p.m.) 13 14 MS. HELZER: Q Back on the record. Detective Launi, I just wanted to go back to 15 Exhibit 3, which are the notes that you typed up to help 16 you in providing any court testimony. 17 front of you? You have that in 18 A Yes. 19 Q On the first it says 7-16-13, and under that 20 section there's a summary and it says that Antunez 21 stated that he walked into the Townsend Street gang 22 three years ago. Do you see where I'm referring? 23 A Yes. 24 Q What does "walk into" mean? 25 A It means he didn't jump in. 137 JEFF LAUNI, EXPERT 1 2 3 Q And what's the difference between walking in and jumping in? A Typically, you walk in if you have other 4 relatives, typically older siblings in the gang or maybe 5 your father's a gang member or something like that. 6 can forgo other rituals and rights to get into the gang. 7 If you live in the neighborhood, maybe you went to 8 school with these individuals and kind of grew up with 9 them or you've known them for years, you're trusted, 10 11 You things like that. Q And the fact that he allegedly stated that he 12 walked into Townsend Street, how does that influence, if 13 it does at all, your determination about whether he's an 14 active participant of Townsend Street? 15 16 17 18 A He just admitted he's a Townsend Street gang member by that statement. Q And whether it's walked in or jumped in it's not significant? 19 A 20 often. 21 Q Gang members will play semantics with you quite Walking in, to me, means he's a gang member. What if there is a -- between STEP Notices or 22 FI Cards, what if there's an inconsistency with what the 23 individual had stated in different FI Cards or STEP 24 Notices? 25 in one FI Card, and another one I was jumped in three For example, I was walked into Townsend Street 138 JEFF LAUNI, EXPERT 1 years ago or I was jumped in five years ago. 2 there's an inconsistency between the statements in the 3 FI Card and STEP Notices, how do you deal with that 4 inconsistency? 5 A And I look at documentation overtime, if it exists, 6 and then I look at -- if it does or doesn't, I might 7 also look at dates, because somebody might say, "I don't 8 claim. 9 later he says, "I claim for six months." I just kick it with them." And then six months It means 10 they've crossed that threshold from hanging out with the 11 gang to a gang member. 12 like that. 13 So I'll look at dates, things Typically, though, I would look at more than 14 one piece of documentation and compare the claims or the 15 statements. 16 I'm usually able to figure it out or get a little better 17 picture. 18 the documentation out, the guy's lying to him, not 19 telling him the truth. 20 21 Q And we usually have it on these people and It could also be whatever officer's filling So the documentation could be incorrect if the person is lying to him; is that right? 22 A I think it could be, yes. 23 Q To your knowledge, has Daniel Antunez ever 24 25 denied membership in Townsend Street? A I'll have to look at all the documentation. 139 JEFF LAUNI, EXPERT 1 Not that I can recall or remember. 2 straightforward. 3 he is, what he is or where he's from. 4 Q He's usually pretty He's a proud guy. He's proud of who He'll claim. And the fact that your opinion is that he's a 5 proud guy, he knows where he's from, he likes to 6 proclaim where he's from, that's an opinion that you get 7 based on your review of the pages 1 through 193; is that 8 right? 9 A I would say so. I mean, there's a lot of 10 people that will never tell you anything. 11 get a claim out of him pretty easily. 12 honest or proud, you know, or maybe both. 13 14 15 Q We seem to So he's either I don't know. Do individuals ever lie about being part of the gang? A Not really. We don't see that. There's 16 potential repercussions from that if it's discovered or 17 found out by the gang or a member of that gang. 18 really don't have people claiming gang membership when 19 they're not gang members. 20 21 Q We Is there a difference -- well, claiming gang membership, does that tell you -- I'm sorry. 22 Claiming gang membership as opposed to claiming 23 active participation in the gang, is that something that 24 you see as a distinction in some of the STEP Notices and 25 FI Cards? 140 JEFF LAUNI, EXPERT 1 A You know, you're playing off words or 2 statements. 3 we would identify through documentation and an 4 individual's history as opposed to -- what did you say? 5 A claim? Participation, I think, is something that 6 Q Yeah, or gang membership. 7 A Yeah, I think they're two different things. 8 have a lot of gang members that don't commit crimes. 9 So -- 10 Q We I'm just trying to distinguish between the 11 wording that individuals may use in admitting or 12 denying. 13 A Well, you know, they use all kinds of wording. 14 Q Do they use the word "active participant"? 15 A No, that's a legal term, in my opinion. 16 Q Okay. Now, in the next entry here in your 17 notes that's 5-28-13, you state at the end there that: 18 "He may have been one of the individuals who fled." 19 Do you see that? 20 A Yes. 21 Q And that's a conclusion that you make or is 22 23 that a conclusion that's in -A I think that's actually in the documentation, 24 because just based on that I wouldn't make that 25 determination. 141 JEFF LAUNI, EXPERT Q 1 Okay. In the next section, 5-23-13, it says as 2 part of the second sentence: "When asked what gang he 3 was from, Antunez stated he was from Townsend and they 4 call him 'Rhino'." 5 moniker. And it says in parenthesis: That's his brother)." 6 A 7 difference. 8 have to look at their thumbprint. 9 10 Q "(Bogus I put that on there, because I know the The only problem is they're twins. So I Did you look at the thumbprint on this documentation? 11 A No, but I know I had -- I knew which brother I 13 Q And how did you know that? 14 A By other documentation or by their information 12 15 16 17 had. on the piece of documentation. Q Okay. Can you find that document in there, in the packet in front of you? 18 A Yes. 19 Q Tell me what Bates number that is. 20 A Six. 21 Q And so what is it in this documentation that 22 23 indicates that this is Daniel as opposed to his brother? A I'm looking at here trying to remember. 24 know what? 25 his brother. You The more I look at this, I think this was His brother was using Daniel's name based 142 JEFF LAUNI, EXPERT 1 on tattoo. Because I know Rhino has his last name on 2 his back and Daniel doesn't. 3 possibility. 4 Q But looking at this document today -- 5 A To be perfectly honest, right now I think -- 6 Q -- it looks like this was his brother? 7 A Yeah, we may have them confused here. I'd have to check that further. 8 what, though? 9 their thumbprints. 10 11 12 Q I would say that's a You know I can tell you pretty quick, look at Are you doing a thumbprint analysis right now off a Xerox copy? A Yes. I do have some expertise in it. I am certified CSI. Please 13 don't voir dire me on it. So, I 14 think we had his brother here to be honest with you. 15 Sorry about that. 16 Q Okay. So let's -- 17 A I'll check that further. 18 Q Let me turn to your declaration that we Let me make a note. 19 referred to before, and I'll refer you to page 104. 20 this is the Expert Declaration of Detective Jeff Launi 21 for the Santa Ana Police Department and it's dated 22 June 4th of 2004. 23 A 24 declaration? 25 And Now, is that my page 104 on the bottom of the MS. SANDERSON: Yes. 143 JEFF LAUNI, EXPERT MS. HELZER: 1 2 "Townsend Street Gang Active Participant." 3 4 At the top of the page it's called THE WITNESS: Yes. BY MS. HELZER: 5 Q At the bottom of 104, starting on line 27, it 6 says: "Each of these individual Townsend Street gang 7 participants -- " 8 You see that? 9 A Yes. 10 Q If you could read that just to yourself, just 11 to the end of that paragraph which ends on 105. 12 A Okay. 13 Q So one of the criteria that you determine in 14 active participation is the individual's own admission 15 in gang membership or active participation; is that 16 right? 17 A Yes. 18 Q And there's some indication here that Daniel 19 Antunez admitted that he was a gang member; is that 20 right? 21 A Yes. 22 Q And other than what's indicated here, which is 23 your summary, I'm sorry, and by "here," I'm referring to 24 your written notes, which is Exhibit 3, is there any 25 other documents where he admits gang membership? 144 JEFF LAUNI, EXPERT And if 1 you need to refer to -- 2 A I believe there is, yes. 3 Q And can you tell me where else he admits gang 4 5 6 membership other than what's indicated in Exhibit 3? A Did you get the plain writing of mine on the bottom of Exhibit 3? 7 Q So STEP Notices? 8 A Yes. 9 10 11 And there may be some other police reports that go to '05 I'm thinking. Q And can we turn to the March 29 of '09 STEP Notice? 12 A Let me see if I have it. Okay. 13 Q And can you tell me from this STEP Notice -- 14 I'm sorry. So this STEP Notice -- let me clarify 15 something. Is the Notice of Determination and the Filed 16 Interview Card the same thing as you're using these? 17 A No. 18 Q Is this a Filed Interview Card or is this a 19 STEP Notice? 20 A This is a STEP Notice. A Field Interview Card 21 may have been filled out in conjunction with a STEP 22 Notice, but this is a STEP Notice. 23 Q Okay. So we are looking at a document that's 24 Bates stamped 000016, part of the 193 pages that the DA 25 had produced to us previously. 145 JEFF LAUNI, EXPERT And can you tell me, Detective Launi, what on 1 2 this document indicates to you that Daniel Antunez 3 admitted that he was a gang member? 4 A At the bottom of the front of the page, under 5 Statement, Conduct, Indicia showing affiliation, there's 6 a handwritten record of his statement to the issuing 7 officer. I can read that for the record, if you'd like. 8 Q Go ahead. 9 A "Self-admitted gang member for the last three 10 years. 11 about -- " this is a bad copy here "-- 15 to --" I can't 12 see the other number -- Antunez said he was jumped in and there is 13 Q 20 maybe? 14 A 20 maybe, could be 30. 15 16 It's hard to read. " -- members of Townsend. Antunez knows and understands the concept of a gang gun." 17 Q What's a gang gun? 18 A It's a gun that's shared amongst the gang and 19 hidden and maintained, secreted by the gang for the 20 gang's use, that kind of thing. 21 Q And in a STEP Notice like this, is the police 22 officer writing down verbatim what Daniel is saying to 23 him or is what is included in here some of the police 24 officers's knowledge of Daniel? 25 A You know, I've seen both. In this particular 146 JEFF LAUNI, EXPERT 1 one, I would say this is typically what we see as a 2 fairly accurate record of verbatim. 3 4 5 Q And what tells you that it's verbatim as opposed to what the officer's experience with Daniel is? A Just the way it's written I would say. I don't 6 know for sure, but I'm assuming that by the way it's 7 written. 8 would consider not verbatim. 9 10 Q Other things I can give you examples of what I Okay. What would be an example of not verbatim? 11 A "Claimed for 8 years," something like that. 12 Q "Self-admitted gang member for last three 13 years," would you consider that a verbatim statement 14 from Daniel? 15 A 16 17 No, but I would say "Antunez said he was jumped in" as verbatim. Q 18 Because it says "Antunez said." Okay. And there's other STEP Notices where you 19 look at and you determined that he's admitting gang 20 membership? 21 A Yes. 22 Q Okay. 23 24 25 Do you want to -- do you know that they're included in all of these STEP Notices? A I'm pretty sure about my recollection. all do. 147 JEFF LAUNI, EXPERT They 1 2 Q Okay. Do you want to take a quick review and let me know what other notices? 3 A Okay. 4 Q Let me just real quick -- 5 A Sure. 6 Q So that's 000018 Bates stamp? 7 A Yeah. 8 Q 18 and 19? 9 A Yes, that statement is on the 18 side. 10 Q And would you consider that to be a verbatim 11 The one from 11-09-07 does. Go ahead. Well, 18 and 19, it's front and back. statement? 12 A Yes. 13 Q Okay. 14 A Let me look here. 15 And the next one? I would say parts of it probably are verbatim. 16 Q Are you still on 000018? 17 A No, 20. 18 Q And what part of it is verbatim, would you 19 20 That's the STEP Notice from 7-9-07. consider verbatim? A "Rhino from Townsend" because that's in -- 21 appears to be in quotations anyway, at least beginning 22 quotations. 23 from Townsend Street and never jumped in." 24 that's probably verbatim just by the way it's written. 25 Q And the last sentence, "He said he was twin What's the next one? 148 JEFF LAUNI, EXPERT I would say 1 A The next one would be 1-22-07. 2 Q And this is 000022 is the Bates stamp? 3 A Yes. I would say the bulk of this statement, 4 in my opinion, would be verbatim. I mean, there might 5 be some abbreviations or someone abbreviated what was 6 actually said, but just the way it's written there I 7 would say is probably verbatim. 8 was filled out. 9 claimed." I wasn't there when it My best estimate. 10 Q Okay. 11 A 4-15-06. 12 Q And this is on page 000024? 13 A Correct. And, again, "He And the next one? This is one where Daniel Antunez did 14 not outwardly claim, and I think the statement is based 15 more on the issuing officer's observations of his 16 contacts. 17 18 19 20 Q Okay. And that was the last one on your handwritten list; correct? A I think so, yes. There are more. I just didn't have them written on there. 21 Q What other ones are there? 22 A From 4-22-05, and that would be looking at your 23 page 26. 24 Q So that's 000026 then? 25 A Yes, bunch of zeros in front. 149 JEFF LAUNI, EXPERT During a 1 trespassing curfew investigation, he was with another 2 Townsend Street gang member wearing Townsend colors. 3 claim. 4 Q There's no claim of admission in that one? 5 A No. 6 Q Okay. 7 A Next one would be dated 10-7-05, and that would And what's the next one? 8 be item number 28, 000028 for a trespass violation. 9 would say that was a verbatim statement: 10 "Who you kicking with?" 11 "Townsend Street gang." 12 Question and answer. 13 Q No Okay. I And then is this when we were talking 14 about before that some people say "kick it with" and 15 then at some point they pass over the line and then they 16 become more active? 17 18 19 A I would say this is probably a pretty good example of that. Q So when you look at this information on this 20 STEP Notice, does this tell you that he's an active 21 participant of the gang as far as just that admission of 22 "kick it" or do they use "kick it" as more of just 23 association with? 24 A I would take that as more of a claim of 25 association. Another thing is you have to look at how 150 JEFF LAUNI, EXPERT 1 far back this was done, he was younger and he's still 2 coming up, where they don't necessarily claim and at 3 some point they fall off that side of the fence and 4 claiming the gang. 5 Townsend Street gang member here or not, but at a 6 minimum, you know, he's saying he associates with them. 7 I still think there's a difference between member and 8 associate. 9 10 Q You don't use that. And this is more of a claim of a member or an associate not a -- 11 12 I don't know if he was actually a A I would take this as more of a claim of an associate. 13 Q Okay. 14 A There's some FI Cards and things. Let me see 15 the dates on these, because some of these include an FI 16 Card. Let me see here. 17 We go back to more current documentation than 18 the FI's. 19 conjunction with a STEP Notice. 20 arrested, a report is associated with the STEP Notice, 21 things like that. 22 23 24 25 Q Lot of times an FI Card is done in Sometimes they're And so starting on 000030, where it's a card, is this an FI Card? A That's an FI Card. And if you look at the date on it, it's 1-18-13, and that goes back to, you know, 151 JEFF LAUNI, EXPERT 1 more recent times. 2 Notice with that date on it. 3 probably done without a STEP Notice being done along 4 with it. 5 questions asked and similar responses obtained on FI 6 Cards. 7 There's not necessarily a STEP So this FI Card was And there's also information, similar Want me to keep going? 8 Q I think I'm getting an understanding. 9 A Okay. 10 Q Let me refer you to page 000092. 11 A Okay. 12 Q And you see down there in the fourth paragraph 13 it says "I asked"? Do you see where I'm at? 14 A Start again, please. 15 Q The fourth paragraph, it says "I asked"? 16 A Okay. 17 Q And then mine's redacted or it has a redaction 18 code on it. 19 Street gang members and they said, no, we just hang out 20 with them." 21 A Yes. 22 Q So what does that tell you in determining "I asked M3 and Daniel if they're Townsend Do you see that? 23 whether Daniel is currently an active participant of the 24 gang? 25 A Based on this, back in '05, I probably wouldn't 152 JEFF LAUNI, EXPERT 1 render the opinion based on this piece of documentation 2 that I'm rendering today. 3 This, to me, is a claim of association, not membership. 4 I think he's still coming up. However, you know, a lot of times there's a 5 fine line between member and associate. I think I have 6 to say that as well, not necessarily that it applies to 7 this. 8 when they are and there's a bunch of people that will 9 never claim anything to us. And then, again, people want to claim membership 10 Q Okay. So if we can go then to 146, 0000146. 11 A I'm getting there. 12 Q And here it says -- at the top of the page, Bear with me here. 13 it's the second line down, it says: 14 he still hung out with Townsend Street. 15 did not." 16 "I asked Antunez if Antunez said he Do you see that? 17 A Yes. 18 Q And what does that indicate to you in 19 determining whether Daniel Antunez is an active 20 participant in Townsend Street today? 21 Okay. A Well, that line by itself wouldn't indicate 22 anything, because I don't know when Antunez said that. 23 I had to back up and read a little bit more. 24 Q Yeah, let's go back. 25 A Let's see here. 153 JEFF LAUNI, EXPERT Q 1 2 I think on page 0000144, the date is 11-22-07. Can you see that? 3 A Would you agree with me? Where do you see -- I see 11-20-07. 4 the assignment date. 5 date somebody -- Don't pay attention. Oh, that's That's the 6 Q So the date is "Date Prepared"? 7 A I would look at "Occurred," which is in the 8 Incident of Active Summary. 9 Q I see. Okay. That would be 11-13-07. And so on 11-13-07, flipping 10 back to 146, "I asked Antunez if he still hung out with 11 Townsend Street. 12 A 13 right? 14 then, again, he's a twin. 15 talking about here. 16 Okay. Antunez said he did not." You realize that's under David Antunez; Date of birth isn't the same as Daniel's, but So I don't know who we're Q Okay. 18 A It might. 19 or doesn't. 20 me look at the narrative for that. 17 So this might not relate to Daniel at all? I just won't be able to say it does Unless, you see something else there. Let 21 Q Okay. 22 A It could be all the way from a typo to somebody 23 else. I don't know. 24 Q So you don't know whether this -- 25 A It's not Sergio, you know. So I'm going to 154 JEFF LAUNI, EXPERT 1 assume it's Daniel, but it says David. 2 Q Why do you know it's not Sergio? 3 A Well, I think that Sergio and David are a 4 little different. Daniel and David at least sound -- 5 you know, they both start with a "D". 6 mean? You know what I It might be a typo. 7 Q Oh, but that's what it's based on? 8 A Yes. 9 Q So would you consider this report as part of 10 Daniel Antunez's file in determining whether he's an 11 active participant of the gang since you're not clear 12 who the person is that it -- 13 A You know what? I'm hesitant to make any 14 determination on something I see an error in. 15 that STEP Notice that I'm not sure it may not be him. 16 It may be him, but I'm not sure. 17 testify to it. 18 Q Right. Just like I don't want to And so I'm just asking you: With the 19 information that you have, is this a report that you 20 would consider part of your determination of whether 21 Daniel Antunez is an active participant of the gang? 22 23 24 25 A As I sit here right now? Probably not. I want to know who the David is, who David really is. Q Just referring back to your declaration, the next criteria in determining active participation is an 155 JEFF LAUNI, EXPERT 1 individual's criminal gang actions. 2 page 105? 3 A We're still on 105? 4 Q Yeah. You see that on So we just did admission of gang 5 membership or active participation. 6 criteria is individual's criminal gang actions. 7 8 A And the next I'm reading to see where I wrote that, but, yes, I would agree with that. 9 Q So what are Daniel Antunez's criminal gang 10 actions that you consider to be part of your 11 determination that he's an active participant of the 12 gang? 13 14 15 16 17 18 A Nuisance activities that he's been contacted and/or arrested for in the past. Q Okay. And can you be specific about what you're talking about? A Drinking in public, blocking street, things like that. 19 Q Is there documentation that supports that? 20 A I think there is, yes. 21 Q Okay. 22 A I think I can. And can you refer to it? Let me go back here. The STEP 23 Notice served on him on 7-16-13, he was drinking in 24 public. 25 On 5-28-13 -- 156 JEFF LAUNI, EXPERT 1 Q I'm sorry. If we can go back. I apologize, 2 but just for the record, can you gave me the number of 3 the STEP Notice you just referred to? 4 A Oh, I'm sorry. 5 Q Okay. 6 A And then if you go to STEP Notice four. 7 Q Okay. 8 A He was contacted for -- over a contributing to 9 Bates stamp number four. delinquency of minor's investigation, and I believe he 10 was issued a citation. 11 be a citation. 12 13 Two. Q Let me look here. Do you know what the result was of that citation? 14 A 15 front of me. 16 Q If we can go back to number four? 17 A Yes. 18 Q What tells you it was a citation? 19 20 It appears to No. I don't have any of those adjudications in Is the citation number there? A Yes, and that's longer than the case number. 21 And it's a cite number. Although, it would be easy 22 enough to tell, I just can't do it right this second. 23 Q Okay. 24 A He was arrested under a particular case number 25 here in 2013. 157 JEFF LAUNI, EXPERT 1 Q Can you tell me what Bates number? 2 A Eight. Let me see if I have a report to go 3 with that and I can tell you what for, if you want to 4 know. 5 Q I do. 6 A Possession of meth amphetamine. 7 Q Can you tell me what Bates stamp number you're 8 9 10 talking about? A Yes. Report under 000069 is page 1 of the report I'm referring to. 11 Q Okay. 12 A He was arrested for possession of meth 13 amphetamine and possession of live ammunition and for 14 bringing a controlled substance into the jail. 15 Q Now, would you consider that a gang crime? 16 A Yes, most definitely. 17 Q And why? 18 A Possession for sales is one of the primary 19 activities of this gang, it had occurred within the 20 Townsend Street area and he was with another Townsend 21 Street Gang member when he was arrested and the other 22 gang member was also arrested. 23 24 25 Q And do you know what the result of these arrests were? A Any adjudication of anything we're discussing 158 JEFF LAUNI, EXPERT 1 2 3 4 today, I'd have to look it up. Q So you don't know whether he was charged with any type of gang activity -A 5 I don't know anything about that. Also, I might add, you know, charging and 6 prosecution isn't our arena. 7 say her arena, referring to the DA. Okay. It's your arena. 8 Q 9 gang action? 10 A Let me go back here. 11 Q What page? 12 A I'm sorry, 12. I should And what's the next action, criminal He was contacted -- I keep forgetting it. He was 13 contacted with other Townsend Street gang members in the 14 alley over narcotic activity. 15 in association at that time. He was not arrested but 16 Q And do you know what narcotic activity it was? 17 A If doesn't state on the STEP Notice, and I 18 don't see a case number associated with it. 19 look it up. 20 Q 21 22 23 Okay. So I can't Does that tell you anything; that there's no case number or citation number? A All it tells me is there is no case number. Whether a report was written or not, I don't know. 24 Q You don't know? 25 A No. 159 JEFF LAUNI, EXPERT 1 2 Q And the two members, the two other members that he was with, do you know who they were? 3 A Yes. 4 Q Who are they? 5 A On page 13, Pedro Ramirez and Jesus Delgado, 6 7 8 9 10 both documented Townsend Street gang members. Q And when you say "documented Townsend Street gang members," what do you mean? A on file. That means we have gang documentation on them They're known to us. 11 Q Okay. 12 A He was contacted -- on page 16, he was 13 contacted on 3-29-09 for drinking in public, and there 14 was a claim or a statement made there. 15 or citation number associated with this. 16 17 18 19 Q contact: A What does it mean when it says: No case number "Reasons for Same 10-33 violation"? SAMC, Santa Ana Municipal Code 10-33 is drinking in public. 20 Q So drinking in public? 21 A Yes. 22 Q And the next? 23 A Let me look here. On 11-09-07, he was 24 contacted and cited for obstructing passage, another 25 municipal code violation. He claimed to be a Townsend 160 JEFF LAUNI, EXPERT 1 Street gang member in that piece of documentation, page 2 18. 3 Q So the municipal code is blocking? 4 A Yes. It's -- what's the exact language of it? 5 Impeding pedestrian or vehicle traffic, sidewalk or 6 street. 7 8 9 10 Q And, I'm sorry, did you say that there was a report related to it? A There appears to be a report and a citation issued. 11 Q Okay. 12 A I'll have to look. 13 Q Case number 0743317. 14 A O7, Okay. 15 16 17 18 19 20 And do you have that in your packet? just confirm that. Q Okay. Case number? I don't think it's in here. Let me It's not in here. So if it's not in here, does that mean that you did not review it? A Correct. I read the STEP Notice, not the report. Q And I'm sorry if you said this before, but I 21 just want to make sure that we were talking about Bates 22 stamp number 18? 23 A Yes, correct. 24 Q And the next criminal gang action? 25 A Let me look. On number 20, page 20, 7-09-07, 161 JEFF LAUNI, EXPERT 1 he was contacted again over obstructing -- this case 2 looks like -- the sidewalk. 3 He admitted being on probation, having gang terms on his 4 probation. 5 It was -- He was with his brother. He said he was a twin from Townsend Street. 6 Q So it says loitering? 7 A Right. 8 Q And there's no citation or case number? 9 A Correct. 10 It doesn't look like he was cited or arrested. 11 Q And then the next? 12 A I'll keep looking here. 13 14 15 16 And you wanted ones just where he was arrested? Q No. I wanted to know what -- when you look at your criteria about involving criminal gang actions. A If you go to page 22, 1-22-07, contacted for 17 loitering on the sidewalk again, no case or cite number, 18 and he claimed gang membership, said that he'd been -- 19 claimed he'd been backing up Townsend Street for two 20 years at that time. 21 Q Okay. 22 A Number 24, page 24, 4-15-06, drinking in 23 public. There's no case or cite number listed. 24 Drinking in public on Townsend gang area wearing 25 Townsend gang color. 162 JEFF LAUNI, EXPERT 1 Q And what is the gang color that he's wearing? 2 A Let me look. Blue. He does not claim on this. 3 He said his brother's a gang member and he was with 4 another gang member that had Townsend gang-related 5 screen-saver on his phone apparently. 6 Q And in these STEP Notices that we're going 7 through, if there's another person indicated to be with 8 him that's indicated to be a gang member or documented 9 gang member, that that's part of the criteria you look 10 at with repeated or ongoing associations with active 11 participants? 12 A That would be something that I look at, yes. 13 Like I said, gang members hang out with gang members. 14 In this case he was, along with his brother. 15 look on page 25, it has Modesto Lopez's name on there. 16 I know him to be a Townsend Street gang member. 17 carded on there. 18 brother is not on here. If you He's He says he was with his brother. His 19 A lot of times our people and myself will fill 20 these out, and even though he's not with a gang member, 21 we'll still fill out who he was with on here. 22 this particular incident, he was with another Townsend 23 Street gang member. 24 25 Q Okay. Now, on And so if I refer you back to your declaration on 105, I think you have it open to that 163 JEFF LAUNI, EXPERT 1 page. 2 A Uh-huh. 3 Q The next criteria is by the individual's 4 repeated and ongoing associations with other active 5 participants of the street gang. 6 So in determining whether Daniel is an active 7 participant of the street gang, are the individuals that 8 he is stopped with by police that he's hanging out with, 9 do they also have to be deemed active participants of 10 the gang in order for you to -- 11 A No, just members of the gang. 12 Q Just members of the gang. So their level of 13 activity doesn't sway or isn't weighted differently for 14 you in determining whether Daniel is an active 15 participant; is that right? 16 A I would say that's correct. And if anything, 17 it would be the other way, would have a positive 18 opinion, because, you know, he could be schooling 19 younger people that aren't active participants yet and 20 haven't entered into that realm. 21 Q And how would you know that? 22 A Well, you wouldn't. I'm just saying. Without 23 me being there or knowing more, I wouldn't. 24 saying is they don't have to be active participants to 25 be listed as an associate on a STEP Notice. 164 JEFF LAUNI, EXPERT But all I'm 1 Q Okay. And just being with that person would 2 contribute to your assessment about Daniel being an 3 active participant? 4 A It would hold some weight, in my opinion, if 5 that affiliated individual listed there is also a 6 Townsend Street gang member, yes, or a gang member. 7 Townsend Street has associate gangs, too. 8 Q Okay. And what's the next -- 9 A On page 26, 4-22-05, Antunez was contacted with 10 his brother and another Townsend Street gang member at 11 805 South Townsend Street, and he was wearing gang 12 colors and he was in association, again, with other gang 13 members. 14 Q And the gang color is blue? 15 A Blue. 16 Q Is that right? 17 A Let me look. Yes. There's also a report 18 written with this. I will have to look for that report 19 and see what it is, if it's in here. 20 Q Can you see if it's in here? 21 A Sure. 22 Q And what is that? 23 A It's on page 90. 24 Q Okay. 25 that right? It is. And this is for probation violation; is 165 JEFF LAUNI, EXPERT 1 A Correct. 2 Q And this is Daniel's arrested for probation 3 violation? 4 5 A No, another gang member he was with was arrested. 6 Q Okay. And this is the report that we talked 7 about earlier when he was younger and he said that he 8 just hangs out with them; is that right? 9 92. 10 A 11 back in '05. 12 Q 13 It's on page He was definitely younger, because this was So in your experience, how long do individuals remain gang members? 14 A There is no set time. 15 Q Is there an average length of time? 16 A No. 17 I could tell you what we typically see. I don't know if it's average, though. 18 Q Okay. What do you typically see? 19 A Fourteen years old up to early to mid 20s. I 20 would say -- I might actually have something about this 21 in my expert declaration, if you want me to look. 22 a survey on ages, average ages. 23 Q And how -- 24 A It will just go back to 2013, when I wrote I did 25 this, but I can say it's still pretty accurate. 166 JEFF LAUNI, EXPERT You can keep going while I'm looking, if you 1 2 want. 3 Q Can I ask questions -- 4 A Go ahead. 5 Q So in your work as a gang unit officer and in I can talk while I'm turning pages. 6 your experience in testifying as an expert, is there any 7 other individuals who provide or who have expertise in 8 gang membership that you look to as being a person who 9 has a lot of knowledge, that you read their readings or 10 11 read their books or confer with them? A I wouldn't say books and, you know, the 12 knowledge base so much, but I do talk to other people in 13 law enforcement, particularly our own people that work 14 at Santa Ana PD. 15 they're the ones that are out there day in and day out. 16 I talk to our probation parole officers, primarily 17 probation officers. 18 now it seems like. 19 I talk to our Stop 2 guys, because Everyone on parole is on probation And I'll talk to patrol officers who work my 20 particular areas of interest or subject, because they're 21 working in that neighborhood day in and day out and they 22 develop a lot of knowledge and expertise in the resident 23 gangs, people in those gangs, different families, 24 different people. 25 Q What about anybody outside of the police 167 JEFF LAUNI, EXPERT 1 department? 2 A Not so much, because our gang problem is our 3 gang problem. 4 look at and I read a lot of things that are more 5 general, I think, to my existing knowledge base. 6 I mean, I know where you're going. I To be honest with you, the most recent things 7 I've read are not -- it's not resident information to 8 the west coast, but I know what gangs do here. 9 interested in what they do, like, on the east coast, I'm more 10 Latin Kings, 18 Street. 11 my areas of interest at present time. 12 this so long. 13 eventually, we're going to have here. 14 be above-the-bar on that so when I see it, I know what 15 I'm seeing. 16 local information, local people. 17 Problems we don't have here are I have been doing Because whatever we have elsewhere, I would like to I think I put more weight in, you know, the I don't have that chart, by the way. 18 Q Okay. No problem. 19 A I actually have it. 20 Q Okay. I just don't have it here. And it's a chart you did with respect to 21 Townsend Street in your preparation for the gang 22 injunction? 23 A I did it in preparation for the Townsend Street 24 Gang Injunction, but it's not specific to Townsend 25 Street. It's specific to our resident 99 gangs we have 168 JEFF LAUNI, EXPERT 1 in our city. 2 the age groups. 3 extremes. 4 It's an age survey. It gives, you know, It shows average and, you know, the And then I did another one where it shows our 5 active gangs related to other gangs in the county and 6 then specific to our city. 7 other one I think it was -- the first one I referenced 8 was a line graph or like a chart graph. 9 MS. HELZER: Those are pie graphs. Okay. The So, Susan, I'd like to ask 10 that we get the surveys regarding the age range that he 11 did. 12 MS. ECKERMANN: I haven't seen it. 13 it from the officer and let you know. 14 BY MS. HELZER: 15 Q And in doing that age range, what information 16 did you look at? 17 documented -- 18 A So I'll get Yes. Just the population of the Obviously, I went through crime analysis, 19 our crime analysis unit. I looked at, you know, cases 20 and information, FI Cards, STEP Notices. 21 ton of stuff. 22 looked at. I looked at a I probably can't even remember what I 23 Q Okay. 24 A And then, you know, I think I did a survey in 25 that regards to see, you know, what is the age of our 169 JEFF LAUNI, EXPERT 1 gang problem. Some of the findings are surprising, 2 interesting. 3 Q Okay. 4 A We update these things from time to time, too. Some of them we know already. 5 I haven't updated it since this, but I did update one of 6 those. 7 this project, which is stale information now, but I will 8 get it to you, if you want it. 9 Q 10 No. You know what? I updated all of them for I would. And I took you off track a little bit. 11 want to make sure we wrap up all of the crime 12 activities. 13 A Did we? 14 Q And you identified the report for us. 15 I just And we left off, I think, on 26. And so I think the next one is on 28; is that right? 16 A Yes. 17 Q And here what is -- the reason for the contact A Trespass violation. 18 19 was? And the question by the 20 officer was, "Who do you kick it with?" 21 Antunez answered, "Townsend Street gang." 22 23 24 25 Q And Daniel And then does this also indicate because he's wearing a blue shirt he's wearing gang colors? A There's no indication of that on here. I see that he was wearing a blue T-shirt, but it's not noted 170 JEFF LAUNI, EXPERT 1 as an issue on this piece of documentation. 2 it might be something I would look at. 3 here, he is in a blue shirt quite often. 4 where he's at during the contacts. 5 Street. You know, If you look back And we look at He's on Townsend 6 Q Do you know where Daniel lived? 7 A Well, Daniel moves around. The family still 8 lives at 800 South Townsend. Last I knew, he was living 9 just outside that area in a residential neighborhood. 10 Q 11 young. And it says -- it notes -- 12 A Yeah, he is and he isn't. 13 During the time of these contacts, he's quite I mean, the most recent one we have on him is July 16, 2013. 14 Q And what number are you -- 15 A Two. He gave the address of 805 South 16 Townsend, No. 1. 17 his mom, I think aunt, brothers. 18 good size family. 19 there's so many of them, but they live at that address I 20 know and they have for a while. 21 address on West California, which I haven't verified, 22 but that might have to do with his -- 23 24 25 Q I know that's where the family lives, He comes from a pretty I wouldn't even know who's all who And then he lists an So when it says "Location of Service," does that mean residence? A No. "Address" means residence. 171 JEFF LAUNI, EXPERT "Location of 1 Service" means where he was served with the form. 2 he was served with this particular form at the 3 California address, which is outside our safety zone. 4 So -- 5 Q And So the person is given a copy, like Daniel is 6 given a copy of this, but he's not given a copy of it at 7 the time that he has the contact? 8 9 A Yes, given at the time, yeah. call it "Proof of Personal Service." That's why they If you look on 10 page two -- I'm sorry. 11 that we give them. 12 "Affidavit of Proof of Personal Service." 13 actually put it in their hand. 14 15 16 Q Okay. I don't actually have the half But on the top of that it says We have to So if they're anywhere, you know, standing in front of the house somewhere -A We can stop them and serve them anywhere, but 17 we hand them their half of this, which puts them on 18 notice. 19 20 21 22 Q That's why it's Notice of Determination. So 2510 West California doesn't mean that that's where he's living? A Well, up here, where it lists address, that's what he lists as the address. 23 Q I see. 24 A I've seen two addresses at that address line. 25 I can see how the conversation went. 172 JEFF LAUNI, EXPERT Sometimes I'm 1 here, sometimes I'm there, something like that. 2 officer put, you know, both addresses there. 3 4 5 Q Okay. I understand. A We left at 28. Let me look further. Yeah, from there, it goes to FIs. 7 predate the last STEP Notice. 8 Postdate. 9 was '05. 11 Where we ended off? 6 10 I'm sorry. So the And the FIs Or, I'm sorry, predate. They're back in 2013. The last STEP Notice So I think the FIs would be a duplicate of pretty much the STEP Notice. Q Okay. So let's go back to 105 real quick and 12 see if we covered the criteria. 13 105 to your declaration. And I'm talking about 14 A Right. 15 Q So I think we've talked about his associations. 16 We talked earlier about his tattoos; that none of the 17 tattoos that he has you consider to be gang tattoos; is 18 that right? 19 A Correct. 20 Q We talked about his dress. 21 Any other nuisance or criminal activities that 22 we haven't talked about that you considered in 23 determining that he's an active participant of the gang? 24 25 A No. They would have been discovered, if I did, and they would be in here. So I would say no. 173 JEFF LAUNI, EXPERT 1 2 Q And in here is also anything outside the safety zone as well? 3 A Yes. 4 Q And the California Street address was outside 5 6 the safety zone? A 7 8 Yes. MS. HELZER: Let's go off the record real quick. 9 (Off the record at 3:06 p.m.) 10 (Back on the record at 3:09 p.m.) 11 MS. HELZER: Back on the record. 12 We're done with the deposition. There are a 13 couple of outstanding issues, I think, with respect to 14 some of the questions that you instructed him not to 15 answer. 16 anything further that we'll do with that. We'll go back and review and see if there's 17 But other than that, we've stipulated, 18 Ms. Eckermann and myself have stipulated to relieve the 19 court reporter of her duties under the Code; that the 20 deposition transcript, original, will be sent to -- 21 Would you like it sent to your office? 22 MS. ECKERMANN: 23 MS. HELZER: That would be fine. -- to the DA's office to Susan 24 Eckermann; within two weeks of receipt of the deposition 25 transcript, Detective Launi, you will have an 174 JEFF LAUNI, EXPERT 1 opportunity to review the deposition transcript and make 2 any changes that you feel were recorded inaccurately. 3 I can tell you that if you make any substantive 4 changes to it, that it may reflect on your credibility 5 at trial. 6 typos, if there's names. 7 transcript. 8 instruction. 9 So, really, it's just to see if there's any There's also a blank in the So that if you can include that jury So within two weeks you'll send the original 10 back to my office in Santa Ana with any changes that you 11 may have to the transcript or to let me know that there 12 are no changes; if we don't receive it, any word back 13 within two weeks following your receipt, we'll just 14 assume that there's no changes and it will be deemed to 15 be complete. 16 Is that okay? 17 MS. ECKERMANN: 18 MS. HELZER: 19 THE REPORTER: 20 MS. ECKERMANN: 21 THE REPORTER: 22 MS. ECKERMANN: 23 24 actually. (No audible response.) Thank you very much. So stipulated? Yes, so stipulated. Do you need a copy? Yes, we do need a copy, Thank you. (End of deposition at 3:11 p.m.) 25 175 JEFF LAUNI, EXPERT 1 2 I have read the foregoing deposition transcript and by signing hereafter, approve same. 3 4 Dated_____________________. 5 6 7 _______________________________ (Signature of Deponent) 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 176 JEFF LAUNI, EXPERT DEPOSITION CERTIFICATE STATE OF CALIFORNIA ss. COUNTY OF ORANGE I, MICHELLE hereby certify: I am a duly qualified Certified Shorthand Reporter, in the State of California, holder of Certificate Number CSR 8226 issued by the Court Reporters Board of California and which is in full force and effect. (Bus. Prof. 8016) I am.not financially interested in this action and am not a relative or employee of any attorney of the parties, or of any of the parties. (Civ. Proc. I am authorized to administer oaths or affirmations pursuant to California Code of Civil Procedure, Section 2093(b} and prior to being examined, the deponent was first placed under oath or affirmation by me. (Civ. Proc. 2025.320, I am the deposition officer that stenographically recorded the testimony in the foregoing deposition and the foregoing transcript is a true record of the testimony given. (Civ. Proc. JEFFLAUNLEXPERT 10_ have not, and shall not, offer or provide any services or products to any party's attorney or third party who is financing all or part of the action without first offering same to all parties or their attorneys attending the deposition and making same available at the same time to all parties or their attorneys. (Civ. Proc. 2025.320tb}) I shall not provide any service or product consisting of the deposition officer's notations or comments regarding the demeanor of any witness, attorney, or party present at the deposition to any party Or any party's attorney or third party who is financing all or part of the action, nor shall I collect any personal identifying information about the witness as a service or product to be provided to any party or third party who is financing all or part of the action. [Civ. Proc. Dated: October 2, 2015 178 Cnur: JEFF LAUNI. EXPERT JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG A AB (1) 119:19 abbreviated (1) 149:5 abbreviations (1) 149:5 ability (1) 83:22 able (4) 29:25;72:17; 139:16;154:18 above-the-bar (1) 168:14 Absolutely (1) 27:19 accept (2) 104:11;134:5 access (3) 72:13;73:6,13 according (1) 101:13 account (1) 85:19 accurate (4) 7:3;106:1;147:2; 166:25 action (4) 45:22;159:8,9; 161:24 Actions (6) 22:4,5;156:1,6,10; 162:15 active (195) 8:22;12:1,8,14,21; 13:15;16:16,23;17:1, 5,7,9,12,14,17,21,23, 25;18:1,10,12,15,17, 19,20;19:21,23; 20:18;21:5,23; 22:12;23:8,9,14,14, 21,24;24:19,25,25; 25:4,9;26:2,19; 27:12;29:14;30:1,11, 16;31:23,24;33:13; 41:2;42:7,23;44:23; 46:4;47:9;48:4,11; 49:4,13,20,25;50:14; 51:2;52:25;56:5,9; 57:4,10;58:15,17; 59:1,5,12;60:4,14; 63:8,16;64:8;65:14, 23;67:5;68:20;69:3; 71:3,11;73:15,25; 74:7,23;76:3,6,10, 22;77:5;78:15; 79:15;80:4,11;81:8, 12,20,25;84:5,8,14, 19,22;85:7,10,18; 86:2;87:9,18;88:23; 90:14,20;91:19; Min-U-Script® 93:3;96:16,19;97:3, 20;98:4;99:2,14,22; 100:18;102:6,18; 104:22;105:11,15; 107:4,19;108:7; 111:18;114:3; 116:11;118:14; 119:14;120:16,19, 22;121:14;122:22; 123:21;124:9,22; 125:3,15;126:15,19; 127:18;128:3;129:9; 130:2,6,7,14;131:8, 11;133:1,8;135:2,8; 136:12;138:14; 140:23;141:14; 144:2,14,15;150:16, 20;152:23;153:19; 154:8;155:11,21,25; 156:5,11;163:10; 164:4,6,9,14,19,24; 165:3;169:5;173:23 activities (19) 12:19;13:12; 20:10;26:8,8,11,12; 36:7;51:15,21; 97:24;99:17;102:13; 109:1;121:18; 156:13;158:19; 170:12;173:21 activity (32) 15:14;17:6;26:17; 27:22;32:19;34:7,7, 8;45:22;47:5;102:2, 4,10,11,11;104:12; 105:13;106:25; 107:2,9;109:24; 110:8,9;127:16,20, 21;132:5;133:7; 159:3,14,16;164:13 actually (13) 11:14;31:20;50:3; 78:23;136:15; 141:23;149:6;151:4; 166:20;168:19; 172:10,13;175:23 Adams (10) 78:20;79:1;91:4, 13;92:10;93:9,18; 94:3,24;95:8 Adams' (1) 78:20 add (6) 20:12;27:19; 74:10;105:7;120:8; 159:5 added (1) 73:6 adding (2) 31:6;73:13 addition (6) 17:11;47:15;85:6; 101:25;102:21; 127:12 additional (3) 16:1;74:12;102:24 additions (1) 137:3 address (12) 10:2;97:23;99:16; 171:15,19,21,25; 172:3,21,22,24; 174:4 addresses (6) 38:19;42:20; 97:23;99:17;172:24; 173:2 adjudication (1) 158:25 adjudications (1) 157:14 administrative (3) 46:19,20;134:23 admin-type (1) 46:21 admission (7) 14:8,14;15:15; 144:14;150:4,21; 156:4 admissions (2) 14:24;20:6 admit (1) 96:1 admits (2) 144:25;145:3 admitted (4) 138:15;144:19; 146:3;162:3 admitting (2) 141:11;147:19 advertisements (1) 117:3 affect (16) 8:12,15;119:13; 120:3,5;121:7,8; 123:20;124:1,4,8,14, 22;125:2,11;126:14 Affidavit (1) 172:12 affiliated (2) 115:6;165:5 affiliation (1) 146:5 afield (1) 41:25 afterwards (2) 85:17,18 again (54) 18:2;20:22,23; 22:17;31:20;38:13; 41:10;45:15;47:10; 48:12,16;53:2; 62:25;63:21;66:4; 68:24;70:6;71:13, 16;78:3,4;82:17; 85:3;86:6;87:13; 89:18,23;90:1;91:4, 5,11,14,16;92:10,14; 93:18;94:3,8,14,15, 24;107:15;114:21; 119:7;131:8,16; 134:21;149:8; 152:14;153:7; 154:14;162:1,17; 165:12 against (6) 36:10;50:24; 131:5,17;135:18; 136:3 age (6) 51:11;169:1,2,10, 15,25 ages (2) 166:22,22 ago (15) 11:10;39:20; 48:25;67:11,24,25; 68:3,6,13,14;98:8; 117:11;137:22; 139:1,1 agree (4) 85:4,4;154:2; 156:8 ahead (6) 54:19;98:17; 123:16;146:8;148:5; 167:4 aisle (1) 72:16 alcohol (1) 8:14 allegations (1) 113:22 alleged (4) 14:4;135:2,4,8 allegedly (1) 138:11 alley (3) 39:21;108:25; 159:14 allied (1) 78:25 allies (1) 35:15 allover (3) 77:2;79:2;129:2 allow (1) 8:1 allowed (3) 14:1;42:1;130:12 allows (1) 88:20 almost (2) 48:25;132:21 along (4) 52:16;121:9; 152:3;163:14 Although (5) 58:8;59:20;86:4; Barkley Court Reporters 109:2;157:21 always (9) 22:17,17,18; 25:21;34:13,25; 35:14;57:18;130:19 ammunition (1) 158:13 among (2) 40:2;107:10 amongst (1) 146:18 amount (13) 12:18;13:8,9,10; 21:8;23:14;32:6; 121:13;133:12,16, 22,25;134:8 amphetamine (2) 158:6,13 A-m-t (1) 13:9 Ana (15) 5:1,18;28:20,25; 41:3,6;86:12;101:5; 115:23;129:1; 130:25;143:21; 160:18;167:14; 175:10 analysis (4) 38:4;143:10; 169:18,19 and/or (1) 156:14 answered (3) 8:2;123:9;170:21 anticipate (2) 6:13;12:12 anticipated (1) 57:22 anticipating (1) 11:23 anticipation (2) 13:5;55:17 anti-gang (4) 81:22;83:8;84:17, 18 Anti-injunction (1) 83:2 Antunez (138) 5:12;10:11,20; 11:21;12:6,8;30:15; 38:23;42:4,6,11,22; 44:22;45:2;46:4,25; 47:7;48:4,11,15,21; 49:4,11,18,20;50:8, 14;51:1;53:5,9,18; 54:7,22;56:4,9;57:3, 10,17;58:7,14,25; 59:5,11;60:4,14; 61:12;62:23;63:3,8; 64:8;65:14,23; 68:20;69:3;71:3,11; 72:21;74:22;77:5, 22;78:14;80:4;81:8, (1) AB - Antunez JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 20;86:2;88:12,19,22; 90:13,20;92:4,11; 93:3,9,19;94:4;97:3, 20;98:3;99:1;100:1, 6,18;101:2,14;102:5, 18;103:3;104:12,22; 105:14,23;106:8,11, 16,18,24;107:18; 108:12;109:17; 110:22;111:15,21; 113:12;115:2; 116:10;118:10; 120:2;122:22; 123:19;124:7,21,25; 125:3,14;126:13; 128:16;134:18; 137:20;139:23; 142:3;144:19;146:2, 10,15;147:15,17; 149:13;153:13,14, 19,22;154:10,11,12; 155:21;165:9; 170:21 A-n-t-u-n-e-z (1) 10:11 Antunez's (30) 12:1;55:16;59:13; 60:1;61:3,6,8,17,23; 62:2,6,7;64:25;65:3, 8;66:12;67:16,21; 68:7;77:18,25;79:5, 20;86:9;87:15;88:2; 109:13;111:12; 155:10;156:9 anymore (2) 23:25,25 apart (1) 95:5 apologize (3) 71:24;133:4;157:1 Apparently (3) 134:1,5;163:5 appear (1) 57:24 appeared (1) 88:11 appears (8) 71:13;82:9,12,17; 90:2;148:21;157:10; 161:9 applicable (1) 78:7 applies (1) 153:6 apply (1) 21:14 approach (3) 39:25;44:6;45:12 appropriate (3) 29:11;107:8; 122:16 approximately (3) 67:23,23;115:18 Min-U-Script® April (1) 92:24 area (7) 32:20;35:21,23; 82:23;158:20; 162:24;171:9 areas (5) 11:25;12:3;36:12; 167:20;168:11 arena (3) 159:6,6,7 arm (2) 110:25;111:1 Armando (3) 40:24;50:16,19 Arny (3) 71:18;73:24;74:1 around (8) 36:11;73:17; 85:23;92:24;95:15; 100:16;102:12; 171:7 array (1) 52:22 arrest (2) 22:6;26:14 arrested (19) 24:6;25:18,19; 35:2,7;38:6;106:13; 108:13;151:20; 156:14;157:24; 158:12,21,22; 159:14;162:10,13; 166:2,5 arrests (1) 158:24 articles (3) 21:1;37:12;52:9 aside (1) 11:1 aspect (2) 78:25;104:19 aspects (2) 38:21;126:24 ass (1) 57:18 assemble (1) 11:7 assessing (3) 15:1,6;26:16 assessment (1) 165:2 assigned (2) 11:6;46:17 assignment (4) 11:5,9,18;154:4 assignments (1) 46:18 assist (2) 12:25;28:16 assisted (3) 16:15;28:19;98:3 assisting (3) 29:6,8,10 associate (6) 151:8,10,12; 153:5;164:25;165:7 associated (8) 17:4;41:9;76:22; 82:4;99:17;151:20; 159:18;160:15 associates (3) 42:19;91:22;151:6 associating (5) 75:4;102:12; 125:24;136:3,8 association (12) 13:25;88:21;92:1, 7;94:3;135:9,10; 150:23,25;153:3; 159:15;165:12 associations (5) 111:22;112:11; 163:10;164:4; 173:15 assume (10) 7:6;74:13;83:25; 84:16;95:21;105:2; 112:17;113:15; 155:1;175:14 assumed (1) 101:6 assuming (2) 130:19;147:6 assumption (5) 61:7,9,22;62:1; 63:5 attach (2) 55:2;96:22 attached (5) 46:14;56:23; 80:24;96:25;98:20 attained (1) 36:8 attention (6) 15:9,17;20:7,7; 97:25;154:4 attire (1) 113:16 Attorney (1) 113:22 Attorney's (6) 8:25;11:3;27:17; 53:12;54:17;130:20 attribute (2) 102:4;127:1 attributed (2) 91:22;92:3 attributing (1) 91:24 audible (3) 111:25;120:25; 175:17 aunt (1) 171:17 available (3) 24:12;125:9,9 average (4) 166:15,17,22; 169:2 aware (4) 101:15;102:17; 110:21;111:5 away (2) 92:9;110:8 ax (1) 85:2 27:7 base (6) 23:23;92:25;97:6, 19;167:12;168:5 baseball (2) 66:4;93:13 based (13) 25:7;26:20;62:1; 85:17;112:13,19; 140:7;141:24; 142:25;149:14; 152:25;153:1;155:7 baseline (1) B 115:5 basic (1) back (82) 69:10 12:23;14:22;16:3, basically (10) 4,5,19;17:9,17; 12:17;14:6;21:8; 19:21;33:7;35:24; 29:6;32:5;35:9; 37:22;48:25;50:9; 39:24;44:16;51:7; 53:22;56:17,18; 77:14 63:25;64:18;70:2,6, basics (1) 8;80:24;83:3;87:4; 17:22 89:16,17;96:12,13; 98:6,14,15,22;99:3; basis (16) 19:11,17,18; 100:2,22;104:5,7,11, 21:18;25:2;27:23; 16,17,24;105:7,8; 32:7;33:11,13;61:9; 111:7;114:7;115:4; 66:14;69:9;109:20; 116:18,19;122:3; 112:1,20;126:3 125:2;132:22,24; Bates (11) 136:16;137:12,13, 54:18;105:24; 14;143:2;148:7; 106:4;142:19; 151:1,17,25;152:25; 145:24;148:6;149:2; 153:23,24;154:10; 157:7;158:1,7; 155:24;156:22; 161:21 157:1,16;159:10; Bear (2) 163:24;166:11,24; 115:11;153:11 171:2;173:8,11; become (2) 174:10,11,15; 51:10;150:16 175:10,12 becomes (1) background (26) 72:24 10:8,20;12:5;23:3; 29:6;31:20;32:6,6,9, beginning (2) 100:10;148:21 11;33:1;47:17;48:5; behalf (3) 62:8;85:15;97:7,9, 61:7;63:5;130:20 15,18;99:8,9,12,25; belief (2) 101:25;109:8; 109:17,20 119:11 Belinda (1) backgrounded (1) 5:11 31:21 Bell (1) backgrounds (1) 96:1 97:13 belong (1) backing (1) 37:8 162:19 beneath (1) bad (2) 70:16 69:8;146:11 best (9) baggy (1) 7:18;8:9;47:25; 117:14 50:23;52:3;78:8; Baker (3) 112:5;129:14;149:8 54:2,2;83:12 better (6) banging (9) 20:17;35:4,5; 51:5,6;52:5,10,18, 45:19;46:18;139:16 20;54:9;83:5,6 beyond (6) bar (1) Barkley Court Reporters (2) A-n-t-u-n-e-z - beyond JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 12:17;13:7,17; 16:8;104:8;133:3 big (1) 86:21 binder (3) 54:21,25;105:23 binders (3) 10:15,17;50:6 birth (1) 154:13 bit (10) 17:9;18:16;23:10; 37:10;39:6;45:25; 46:2;133:20;153:23; 170:10 blank (2) 136:21;175:6 blanket (3) 14:19;70:18,20 block (2) 72:23;73:1 Blocking (3) 37:1;156:17;161:3 blue (17) 59:14,15,22;60:2, 17;63:21,22;64:2; 70:6;114:10,25; 163:2;165:14,15; 170:23,25;171:3 Bogus (1) 142:4 bold (1) 37:4 bolstered (1) 85:18 book (4) 50:3;86:25;108:1; 109:8 books (11) 21:1,7,9,10,14,17; 37:12,20;52:9; 167:10,11 Boston (1) 93:13 both (6) 76:22;140:12; 146:25;155:5;160:6; 173:2 bottom (10) 25:12;70:12; 82:16;90:10,11; 92:15;143:23;144:5; 145:6;146:4 box (1) 44:21 boy (2) 59:7;61:5 boys (2) 63:15;64:3 boy's (1) 62:19 brag (1) 51:21 Min-U-Script® Brandi (11) 78:20,20;79:1; 91:4,13;92:9;93:9, 18;94:3,24;95:8 brazen (2) 37:4,6 break (7) 7:25;8:1,4;10:24; 56:12,19,21 breaks (1) 7:24 breezeways (1) 35:17 brew (1) 94:12 brief (1) 56:12 bringing (1) 158:14 brother (15) 39:14;40:5,24; 142:5,11,22,25,25; 143:6,14;162:2; 163:14,17,18;165:10 brothers (8) 40:18;50:16,19; 135:1,13,24;136:3; 171:17 brother's (1) 163:3 brought (2) 15:16;136:17 bubble (1) 113:3 bulk (9) 13:20,22;14:3,22; 15:1,6,21;133:6; 149:3 bumping (1) 94:5 bunch (3) 51:23;149:25; 153:8 buyer (1) 110:2 C Calbert (3) 28:23;29:12;32:5 C-a-l-b-e-r-t (1) 28:23 Calbert's (1) 29:4 California (6) 5:1;130:21; 171:21;172:3,19; 174:4 call (3) 5:25;142:4;172:9 Calle (3) 66:18,21;89:23 C-a-l-l-e (1) 66:19 called (1) 144:1 calling (1) 95:23 came (6) 64:10,19;65:5; 77:11;84:16;85:12 can (121) 5:25;7:2,4,19,24; 8:3;10:1,16;13:3; 14:13;16:3,15,19; 17:1;19:19;20:15, 23;22:11,24;23:1,10, 17;26:8;32:25; 33:10,18,21;34:19, 20;37:5,20,21;38:11, 25;40:6;41:20; 42:15;44:6,16; 45:12;51:16,24;55:7, 10;57:2,15;58:1,10; 63:19;65:21;66:1; 67:12,20;68:9,11; 71:21;72:23;73:1,2; 74:9;81:1,2,3,15; 83:13,15;85:3; 86:25;90:21;91:22; 92:6;95:12;98:9,12; 103:14,14;104:3; 105:18,20;108:1; 113:25;120:23; 121:1;122:13,21; 123:12;125:19; 129:14;131:20; 132:13;133:19; 138:6;140:1;142:16; 143:8;145:3,10,13; 146:1,7;147:7; 153:10;154:2; 156:15,21,22;157:1, 2,16;158:1,3,7; 165:20;166:25; 167:1,3,4;172:16,25; 175:3,7 cap (1) 93:13 capture (2) 6:9;7:11 capturing (1) 43:9 Carachure (2) 71:18;73:25 Card (25) 42:13,14,17;43:1, 2,4,9,14,22,24;44:1, 7;45:15,15;138:25; 139:3;145:16,18,20; 151:16,18,22,23,24; 152:2 carded (1) 163:17 Cards (14) 42:8,10,22,24; 44:12;103:1,1; 105:21;138:22,23; 140:25;151:14; 152:6;169:20 cars (1) 36:12 case (19) 5:13;9:1,21;11:4; 90:16;118:19; 157:20,24;159:18, 21,22;160:14; 161:12,13;162:1,8, 17,23;163:14 caseloads (1) 33:7 cases (3) 27:25;51:8;169:19 Casper (5) 75:21;76:9,21; 77:1;90:3 Casper's (1) 90:2 catch (1) 135:20 categories (1) 99:20 caught (2) 46:21;117:5 cause (6) 43:15,18,19,20; 44:4;121:2 caused (1) 121:3 center (1) 88:10 certain (14) 14:1;15:3;17:24; 23:14;26:7;34:7; 55:10;73:14,16; 102:12;105:4; 121:11;124:17; 127:14 certainly (1) 127:10 certified (1) 143:13 Cesar (1) 76:2 challenges (1) 51:19 chance (1) 55:18 change (4) 26:9;81:6,10; 125:14 changed (2) 122:7;123:6 changes (6) 137:3;175:2,4,10, 12,14 charged (1) 159:2 charges (1) Barkley Court Reporters 130:15 charging (1) 159:5 chart (3) 168:17,20;169:8 chased (1) 39:24 cheat-sheet (1) 100:13 check (14) 16:9;40:15,17; 97:7,9,15,18;99:8,9, 13,25;101:25;143:3, 17 checks (4) 31:20;32:9,11; 33:2 child (1) 63:20 children (4) 125:13;126:14; 127:7;128:1 chronological (1) 101:10 Chugging (1) 94:4 Cincinnati (1) 89:24 Cinco (1) 93:19 circle (1) 82:15 circumstances (8) 26:24;43:1;53:1; 60:13;126:18;127:3; 128:2,5 citation (9) 157:10,11,13,18, 19;159:21;160:15; 161:9;162:8 cite (3) 157:21;162:17,23 cited (2) 160:24;162:9 Cities (5) 66:4;79:14; 114:14;115:1; 118:20 city (4) 129:2,7;169:1,6 civilian (3) 28:20,24;29:2 claim (21) 18:14;118:22; 129:4,7;139:8,9; 140:3,11;141:5; 149:14;150:3,4,24; 151:2,9,11;153:3,7, 9;160:14;163:2 claimed (6) 13:25;147:11; 149:9;160:25; 162:18,19 (3) big - claimed JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG claiming (5) 140:18,20,22,22; 151:4 claims (1) 139:14 clarify (5) 12:11;28:3;39:6; 59:24;145:14 class (1) 29:1 classes (1) 52:11 clear (5) 26:2;73:20;84:25; 91:18;155:11 clearer (1) 133:20 clerical-type (1) 29:7 click (1) 74:11 client (1) 41:24 client's (2) 131:8,11 clothes (1) 113:18 clothing (9) 42:19;114:8,9,23; 115:6;116:25; 117:13,14,24 Coast (3) 21:13;168:8,9 code (5) 152:18;160:18,25; 161:3;174:19 color (9) 59:16;60:17;64:2; 70:6,7;114:10; 162:25;163:1; 165:14 Colors (7) 63:18;116:21; 117:2;118:12;150:2; 165:12;170:23 column (1) 79:14 coming (5) 21:4;95:4;132:22; 151:2;153:2 comitting (5) 22:7;36:1;38:5; 128:10;136:5 commit (1) 141:8 committed (1) 50:4 committing (5) 26:10;35:21;36:6, 16;37:14 common (4) 54:3;69:4;82:7; 94:18 Min-U-Script® communicating (3) 90:21;91:5;93:9 compare (1) 139:14 compared (1) 35:7 compiled (1) 41:8 complaining (1) 118:2 complaint (1) 86:20 complete (4) 6:14,16;43:21; 175:15 completed (3) 11:18;44:1,8 completely (1) 100:2 completeness (2) 44:17,20 completing (4) 43:4;44:11;45:13, 14 completion (1) 43:2 compliance (2) 40:15,16 complies (1) 98:11 computer (1) 83:16 concept (2) 52:9;146:16 concepts (1) 18:7 concerned (2) 24:14;132:13 conclude (1) 130:7 concluded (1) 30:15 conclusion (5) 98:4;105:4; 109:12;141:21,22 conclusions (4) 27:10,12;29:20; 49:25 Conduct (1) 146:5 confer (1) 167:10 confirm (1) 161:15 confirms (1) 87:23 confused (1) 143:7 conglomeration (1) 102:7 conjunction (3) 59:21;145:21; 151:19 connecting (1) 81:24 connection (1) 62:21 conquests (1) 51:21 consecutively (1) 54:18 consensual (2) 44:2,4 conservative (1) 129:21 consider (50) 19:2;22:19;23:20; 24:18,24;26:1;30:1; 37:5;49:21,24;50:15, 25;53:3;57:9;65:13; 73:17,20,24;76:2,5, 9;83:6;84:5,7,21; 85:7,9;102:1; 104:23;105:14; 106:15;107:17; 111:14;118:13; 122:2;126:21; 127:10,12;128:11; 135:16,25;147:8,13; 148:10,19;155:9,20; 156:10;158:15; 173:17 consideration (9) 14:25;15:20; 50:18;51:4;64:8; 128:15,23,25;129:6 considered (20) 17:21;30:10;33:1, 7,16,22;38:9,11,15, 17;48:6;63:7;85:20; 99:14,21;102:17; 105:10;106:14; 129:5;173:22 considering (14) 20:17;41:1;42:6, 22;44:10,22;46:4; 47:8;48:3;49:4,13; 50:12,13;63:16 consistent (2) 118:13,15 consistently (1) 35:18 constantly (1) 129:24 constraints (1) 38:20 consult (1) 76:20 consulted (1) 33:4 contact (34) 8:19;22:6;24:22; 32:16,17,17;33:12; 38:1;39:22;40:5,10, 14;43:10,13,16,24; 44:2,5;97:25;101:1, 14;105:22;107:1; 109:9,13;112:6,10; 113:8;118:7;126:3; 128:9;160:17; 170:17;172:7 contacted (12) 33:5;97:24; 156:13;157:8; 159:10,13;160:12, 13,24;162:1,16; 165:9 contacting (3) 20:21;23:17,25 contacts (17) 18:24;20:2,3,10; 25:12;32:14,23; 106:25;107:3,6; 112:17;127:21; 133:17;134:25; 149:16;171:4,10 contained (2) 36:21;56:1 context (2) 18:6;114:22 continue (3) 112:23;113:7; 115:13 continues (1) 112:17 continuing (1) 66:3 contribute (1) 165:2 contributing (2) 92:1;157:8 control (2) 72:20;73:12 controlled (1) 158:14 conversation (3) 48:3;134:15; 172:25 conversations (18) 9:21;14:4,18;15:4; 19:6;29:12,17;46:3; 47:7;48:8,9,10;49:3, 6,11;110:13;112:15; 113:6 converse (1) 19:9 conversed (1) 29:17 cool (1) 116:22 copied (1) 36:22 copies (1) 96:15 copy (11) 64:16;69:8;96:17, 18;143:11;146:11; 172:5,6,6;175:21,22 core (2) Barkley Court Reporters 80:9;129:4 corner (3) 73:5;87:10;118:5 correctly (1) 20:20 correlation (2) 78:25;92:10 counter (1) 27:18 county (2) 129:7;169:5 couple (7) 11:22;33:24,25; 37:24;66:23;75:13; 174:13 course (4) 26:21;106:1; 117:12;119:8 court (15) 6:7,17,20;7:11; 15:12;34:20;100:12, 14;129:20,24,24; 130:17;134:1; 137:16;174:19 court's (1) 104:10 courtyards (1) 35:16 covered (1) 173:12 Cowboy (1) 89:25 Cowboys (9) 63:20,24,25; 68:25;69:25;70:3; 114:12,25;118:19 create (1) 85:22 creation (1) 28:12 credibility (2) 131:14;175:4 crime (16) 22:7;25:19,23,24; 26:13,17,18;27:1,2, 3;121:4;128:10; 158:15;169:18,19; 170:11 crimes (13) 25:20;26:1,7,11; 32:24;35:21;36:1,6, 6,17;37:15;38:6; 141:8 criminal (14) 12:15,19;13:12; 36:9;102:10,11,14; 156:1,6,9;159:8; 161:24;162:15; 173:21 Criminals (3) 81:5,14;119:23 criteria (21) 20:17,19;21:4,24; (4) claiming - criteria JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 22:14;26:19,23; 49:4,10,13,18,20; 27:7;34:3;38:8,15; 50:7,14;51:1;53:5,9, 18;54:7;56:4;57:3, 101:23;113:23; 127:4;144:13; 10;58:14;59:4,11,13; 60:14;61:3,5,8,12, 155:25;156:6; 17,23;62:2,6,7,23; 162:15;163:9;164:3; 173:12 63:3,7;64:8,25;65:3, 8,14,22;66:12;67:5, crossed (2) 15,21;68:7,20;69:3, 82:15;139:10 16;71:3,11;72:20; CSI (1) 143:13 73:6,12;74:6,22; CT (6) 77:5,18,22,24;78:14; 79:5,15,20;80:4; 66:3,14;74:25; 75:18;79:14;87:13 81:7,20;83:19; curfew (1) 85:10;86:2,9;87:15; 150:1 88:2,11,19,22;89:7; current (4) 90:13,19;91:19,20, 22;92:4,4;93:3,9; 101:12;120:21; 97:2;99:1;100:1,5, 128:16;151:17 currently (14) 18;101:2,14;102:5, 18;103:3;104:21; 33:3;102:6,18; 104:22;105:11,15; 105:13;106:8,18,23; 107:18;110:21; 107:19;111:19; 111:12,15,18,21; 114:3;116:11; 112:4;113:12;114:2; 123:20;125:15; 116:10;118:10; 134:17;152:23 119:2;122:22;123:7, custody (2) 19;124:7,21,25; 107:7,11 125:3;126:13; cut (7) 134:17;139:23; 30:21;31:18; 142:22;143:2; 33:20,23;35:1; 144:18;146:2,22,24; 37:22;106:10 147:4,14;149:13; cutting (2) 152:18,23;153:19; 37:23;38:9 154:16;155:1,4,10, cuz (1) 21;156:9;164:6,14; 92:19 165:2;170:20;171:6, cyber (1) 7;172:5 52:12 Daniel's (18) cycle (3) 40:5,7,21;63:16; 23:12,13;25:3 72:5;73:10,15;77:9, D 11;80:11,17;81:12; 82:20;89:5;135:1; 142:25;154:13; DA (11) 166:2 9:7,8;53:23;54:1; Danny (7) 93:20,20;94:5,6; 57:17;58:7,25; 95:14;145:24;159:7 60:1,4;79:13;91:14 daily (5) dark (3) 32:7;33:11,13; 59:19,22;60:3 38:1;126:3 DA's (4) Dallas (10) 36:23;83:11; 63:20,24,25; 96:11;174:23 68:25;69:25;70:3; 89:24,25;114:12,25 date (27) 11:15;57:25;58:2, Dallas' (1) 4,6,7,12,16,20;70:8, 70:7 12,16;79:24;86:19, Daniel (169) 20;88:4;89:7,8; 5:12;10:11,20; 108:16;151:24; 11:21;12:1;30:15; 152:2;154:1,4,5,6,6, 38:23;39:2,8;40:19; 13 41:1;42:4,6,11,22; 44:22;45:2;46:4,24; dated (2) 143:21;150:7 47:7;48:3,10,15,21; Min-U-Script® dates (12) 42:19;57:24;58:1, 22,23;70:11,23;78:5, 6;139:7,11;151:15 David (6) 154:12;155:1,3,4, 23,23 day (10) 51:11;60:22,22; 88:13,14;124:18; 167:15,15,21,21 days (5) 125:8,8,11,12,13 de (1) 93:20 deal (4) 31:1,15;110:3; 139:3 dealing (2) 108:24;109:25 dealt (1) 119:21 decide (1) 32:11 decided (1) 107:4 deciding (1) 126:19 decision-making (1) 29:16 decisions (2) 29:9;130:16 declaration (17) 10:7,18;29:24; 36:21;113:20,21; 114:20;115:16,18, 23;143:18,20,24; 155:24;163:25; 166:21;173:13 dedicated (1) 133:7 deemed (3) 132:24;164:9; 175:14 define (1) 17:12 defines (1) 96:16 defining (3) 16:16;17:14;96:19 definitely (3) 79:2;158:16; 166:10 definition (5) 12:14,16;17:9; 52:24;132:25 delete (1) 84:6 Delgado (1) 160:5 delinquency (1) 157:9 delve (1) 121:5 denied (1) 139:24 denying (1) 141:12 Department (13) 5:19;28:21,25; 29:2;41:3,6;43:6; 86:12;101:5;115:24; 131:1;143:21;168:1 depend (3) 25:22,22,23 depending (2) 17:3;23:24 depo (1) 131:11 deposition (25) 6:2;8:18;9:4,13; 10:4,13,22;31:5; 55:4,14,25;96:23; 98:18,25;101:24; 118:2;122:17,19; 135:17;136:22; 174:12,20,24;175:1, 24 depositions (1) 129:20 depth (1) 100:3 der (1) 57:18 describe (3) 13:21;42:15;45:5 description (1) 14:19 designated (1) 8:25 Details (2) 41:3,7 detain (3) 43:19,20;44:4 detainment (1) 45:21 detective (22) 5:21,23;16:5,6; 27:21;54:20;56:19, 25;90:9;96:14,17; 97:2;98:16;110:14, 18;111:7;115:23; 116:20;137:14; 143:20;146:1; 174:25 detectives (2) 27:16,24 Detective's (1) 122:23 determination (21) 11:7;14:2;19:22; 21:22;27:7,21;28:4; 30:22;44:24;45:1,4, 5;83:5;136:14; 138:13;141:25; 145:15;155:14,20; Barkley Court Reporters 156:11;172:18 determinations (4) 29:13;42:1;85:16; 107:14 determine (10) 12:21;13:15; 31:18;41:18;47:5; 126:18;127:24; 133:23;136:11; 144:13 determined (3) 14:4;30:10;147:19 determining (30) 14:23;16:12;21:4; 29:10;49:20;51:1; 58:25;60:13;63:7; 65:13;81:7;84:22; 85:10;91:19;99:14, 21;102:18;105:10, 15;107:18;127:17; 128:16;134:7; 152:22;153:19; 155:10,25;164:6,14; 173:23 detriment (1) 107:12 develop (1) 167:22 devoted (4) 12:18;13:11; 133:12,16 devoting (1) 133:24 difference (7) 16:22,25;135:9; 138:1;140:20;142:7; 151:7 different (15) 15:24;21:12; 45:21;57:15;72:3,4; 76:18;106:12;107:3; 127:15;138:23; 141:7;155:4;167:23, 24 differently (1) 164:13 dime (1) 121:23 dire (1) 143:13 direct (6) 20:1;21:9;33:8; 53:19;78:24;92:10 disappear (1) 23:16 disappears (1) 24:3 discovered (6) 86:11;108:2; 124:7;126:13; 140:16;173:24 discovery (2) 36:23;105:8 (5) crossed - discovery JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG discuss (1) 18:6 discussed (2) 29:19;96:20 discussing (2) 13:24;158:25 dismay (1) 36:2 display (1) 51:17 disputing (1) 8:22 disrespecting (2) 57:12,13 disrespects (1) 51:18 distinction (2) 117:23;140:24 distinguish (4) 54:8,12;101:20; 141:10 District (7) 8:25;11:3;27:17; 53:12;54:17;113:22; 130:20 document (28) 42:18;54:15,16, 19;55:3,7,9,12,20, 22;56:1,8,20;57:1,6; 60:12;61:15,15,16; 62:10,24;96:23; 107:21;109:6; 142:16;143:4; 145:23;146:2 documentation (35) 11:7;12:5;17:13; 36:22;47:18;48:5; 50:2;100:25;102:8; 104:8,16,23;108:3; 114:5;116:14; 118:12;121:9; 133:17;139:5,14,18, 20,25;141:3,23; 142:10,14,15,21; 151:17;153:1; 156:19;160:9;161:1; 171:1 documented (9) 15:9,17;20:8;27:6; 104:12;160:6,7; 163:8;169:17 documents (6) 10:3,6,12;100:17; 107:16;144:25 dog (1) 95:15 done (9) 11:24;43:6; 119:11;132:21; 151:1,18;152:3,3; 174:12 dope (4) 36:9;108:25; Min-U-Script® 110:2,3 dormant (1) 23:15 doubt (4) 12:9;33:15;109:1, 3 down (40) 6:8;27:8;28:1; 31:11,19;32:2,8,10; 33:1;34:15;35:10; 38:10;39:24;47:17; 66:17;67:18;71:18; 72:24;74:24;75:12, 20;78:17,22;79:13; 88:10;89:16;92:15, 18;93:22;94:4,11,19; 95:13;101:4;110:3; 118:5;121:9;146:22; 152:12;153:13 dramatically (1) 26:9 drawn (1) 15:9 dress (4) 113:24,24;114:22; 173:20 dressed (4) 117:19,20,21; 118:5 dresses (2) 113:14;114:2 drew (2) 45:22;97:25 drinking (10) 36:10,10;94:11; 156:17,23;160:13, 19,20;162:22,24 drive-through (1) 95:25 drug (1) 121:12 drugs (5) 109:18,25;121:13, 25,25 due (2) 38:20;135:10 duly (1) 5:5 duplicate (1) 173:9 during (11) 40:15;56:19; 97:24;101:17;109:9; 118:1,7;123:10; 149:25;171:4,10 duties (4) 15:4;29:7;46:20; 174:19 dynamics (1) 21:2 E earlier (9) 5:11;23:4;96:20; 101:24;114:9;122:4; 127:15;166:7; 173:16 early (8) 97:19;119:9,13,17, 23;120:6;135:17; 166:19 easier (1) 101:4 easily (1) 140:11 East (2) 21:13;168:9 easy (1) 157:21 Eckermann (30) 9:9,12,16,18,22, 23;41:23;55:15; 84:23;122:9,11,14, 15,18,22;123:8,16, 22;124:3;131:7,10, 19,22;169:12; 174:18,22,24; 175:17,20,22 education (4) 18:21;19:10,16; 37:12 effect (2) 6:23;47:11 effects (1) 132:15 efficiency (2) 31:10,13 efficient (1) 31:8 eight (2) 68:14;158:2 either (5) 27:14;83:12; 114:5;134:2;140:11 elbows (1) 117:15 eliminate (4) 31:25;32:2;35:5; 83:23 eliminated (3) 33:9;38:21;83:23 elimination (2) 34:11,22 else (52) 9:10;15:20;18:25; 19:14,16;20:14; 26:14;27:13;31:18; 32:25;33:16;37:18; 40:21;53:8,17;54:4, 12;58:24;60:22; 63:6;65:12;67:1,4; 71:2,15;74:5;75:7; 77:4;80:15,21;81:4, 11;87:14;88:15; 91:6;92:12;93:2,10; 94:1,10,25;95:1; 96:5;97:19;114:16; 124:19;127:12; 130:18;135:21; 145:3;154:19,23 else's (2) 72:18;89:18 elsewhere (1) 168:12 employed (1) 126:3 employee (1) 28:24 employees (1) 126:9 employment (2) 127:6,25 end (4) 107:11;141:17; 144:11;175:24 ended (1) 173:4 ends (2) 41:18;144:11 enforce (1) 136:3 enforcement (21) 18:24;20:13; 28:12,17;29:5,9,21; 30:12;32:14,15; 33:21;46:9,24;48:2; 85:22;106:20;122:3, 7;123:7;132:11; 167:13 enhancements (1) 28:1 enjoin (2) 11:21;107:8 enjoined (8) 8:21;38:12;47:3, 15;82:1,7;85:20; 89:3 enjoining (2) 29:11;30:24 enjoinment (1) 85:21 enough (5) 24:17;95:25; 96:15;132:9;157:22 entered (1) 164:20 entire (2) 78:7;118:3 entitled (5) 7:18,20;115:22; 124:2;131:11 entry (4) 60:10;70:24; 92:16;141:16 equate (1) 13:22 era (1) 51:5 Barkley Court Reporters errata (1) 137:2 error (1) 155:14 Escobosa (1) 5:12 established (2) 41:24;127:3 estimate (8) 7:18,19,21;67:12, 20;100:9;129:14; 149:8 evaluating (1) 81:24 even (11) 6:13,21;18:1; 45:16;110:4;120:10, 11;129:6;163:20; 169:21;171:18 eventually (3) 30:10;38:14; 168:13 everybody (6) 17:24;84:18; 91:24;97:13;125:8, 18 everyone (5) 18:17;19:21;23:9; 31:21;167:17 everyone's (1) 17:23 evidence (12) 22:11;26:2;58:17; 81:6;84:9,10;105:1, 3;107:18;109:2; 114:1;123:23 exact (1) 161:4 exactly (3) 46:8;67:10;133:5 EXAMINATION (1) 5:7 example (8) 21:12;24:15;34:6, 12;127:16;138:24; 147:9;150:18 examples (3) 22:23;23:18;147:7 exception (1) 132:21 exceptions (1) 18:13 Excuse (3) 37:22;44:10;105:1 exhaust (1) 23:1 exhibit (31) 55:3;56:21,22; 57:1;96:23,24;98:18, 19;99:5;100:4,8; 101:9;102:15;103:5, 16;104:5,6,7,14; 105:7;108:5,16; (6) discuss - exhibit JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 111:8;119:2;132:24; 133:11;136:11; 137:15;144:24; 145:4,6 exist (4) 103:3,19;117:18, 18 existing (1) 168:5 exists (1) 139:5 experience (23) 13:24;18:21; 19:10,17;20:21;21:9, 16;25:7;26:21; 36:24,24;37:16; 94:20;104:10;110:5; 112:13;118:24; 132:14;134:4,14; 147:4;166:12;167:6 expert (17) 9:1,20;10:7,18; 11:4;28:1;36:21; 113:20;114:19; 115:16,22;123:24; 129:8;130:12; 143:20;166:21; 167:6 expertise (3) 143:12;167:7,22 experts (1) 27:22 explain (7) 23:10;34:19; 41:20;46:14;81:23; 104:3,4 explanation (1) 35:8 extent (3) 80:15;87:23; 117:18 extremes (1) 169:3 F Facebook (13) 55:23;64:20; 71:25;72:5,7,12; 79:6,20;80:18; 82:20;83:21;90:19; 91:21 fact (13) 17:2;38:17;69:19; 80:12;84:4;85:1,5; 120:7,13;123:19; 130:14;138:11; 140:4 factor (8) 22:10;34:2;38:14; 84:21;116:22; 117:25;127:16,22 factors (11) Min-U-Script® 20:17,19;21:4,24; 22:14;38:8;101:23; 126:17;127:4,15; 128:1 facts (3) 25:24;26:25;42:25 fair (3) 92:23;93:1;96:2 fairly (1) 147:2 fall (1) 151:3 false (1) 89:17 familiarize (1) 55:16 families (1) 167:23 family (16) 39:1,12;40:7,22; 50:24;93:20;95:21; 125:12;135:7,10,18; 136:1,8;171:7,16,18 far (10) 8:6;24:13;25:13; 37:19;41:25;110:8; 130:13;132:12; 150:21;151:1 father's (1) 138:5 feed (1) 19:10 feel (1) 175:2 fellow (2) 27:16;112:18 fence (1) 151:3 few (7) 24:4,17,17;37:25; 38:20,21;56:19 FI (18) 45:7,14,15;103:1; 105:21;138:22,23, 25;139:3;140:25; 151:14,15,18,23,24; 152:2,5;169:20 Field (8) 42:8,10,21,24; 44:11;45:6;103:1; 145:20 fiercely (1) 80:13 Fifty (1) 129:13 figure (1) 139:16 figures (1) 129:21 file (5) 42:25;55:16; 102:8;155:10; 160:10 Filed (13) 42:13;43:1,2,4,9, 14,21;44:1,7;86:20; 130:15;145:15,18 fill (7) 44:18,21;45:16,21, 23;163:19,21 filled (3) 44:16;145:21; 149:8 filling (2) 45:25;139:17 fills (1) 50:3 financially (2) 127:6,25 find (8) 27:5;38:18;59:3; 115:11,12;121:3; 136:24;142:16 findings (1) 170:1 fine (3) 101:18;153:5; 174:22 finite (1) 24:1 firme (1) 93:19 First (28) 5:16;18:19;21:6; 30:21,23;40:1; 42:25;50:13;54:23; 57:2,6;75:11;77:23; 86:16,17,19,22,24; 97:10;101:12; 104:14;111:8; 120:17;122:5;132:8; 135:12;137:19; 169:7 FIs (3) 173:6,6,9 FI's (1) 151:18 fits (1) 12:16 five (3) 117:11;118:1; 139:1 FK (2) 94:6;95:14 FKN (1) 95:13 f-k-n (1) 57:18 flagged (1) 92:15 fled (2) 39:23;141:18 flip (3) 12:20;18:14;126:1 flipped (1) 12:22 flipping (2) 64:18;154:9 float (1) 17:6 flooded (1) 119:20 flowing (1) 100:15 focus (1) 35:5 focused (3) 34:4,5;38:4 focusing (2) 31:9;48:7 follow (1) 58:7 following (1) 175:13 follows (1) 5:5 follow-up (1) 122:24 food (1) 35:16 force (1) 6:22 forefront (1) 24:2 forgetting (1) 159:12 forgo (1) 138:6 form (7) 15:14;25:10;45:7; 59:21;100:7;172:1,2 formal (1) 120:14 formed (1) 116:11 forming (2) 102:5;104:21 forms (4) 49:15,17;66:24; 69:12 formulating (1) 60:6 forth (1) 125:21 found (3) 53:25;89:18; 140:17 four (4) 57:15;157:6,7,16 Fourteen (1) 166:19 fourth (3) 79:13;152:12,15 free (4) 37:2;134:10,18,20 frequency (2) 107:1,2 fresh (2) 101:7;131:16 Barkley Court Reporters friend (4) 72:6,10;74:10; 88:19 friended (2) 72:8,17 friending (3) 73:18,21,24 friends (11) 72:6,15,15,21; 73:11,13;92:7; 112:16,22;113:7,8 front (21) 6:23;10:15,16,17, 25;50:6,8;54:21; 63:21;76:19;87:15, 19;103:13;124:20; 137:17;142:17; 146:4;148:7;149:25; 157:15;172:15 Fuck (4) 92:18,20;94:6,12 fucken (1) 92:18 fuckers (1) 95:23 fucking (2) 57:19;95:20 full (2) 132:13,16 full-time (8) 123:20;124:8,21, 25;126:4,8;127:6,25 fun (1) 95:16 further (9) 75:8;77:3;94:11; 96:6;121:2;143:3, 17;173:5;174:16 G Gabriella (1) 111:1 gage (8) 12:21;13:15; 21:15;133:15,25; 134:3,14;136:11 Gallegos (2) 79:13,15 Gang (385) 8:20;10:8,8,19; 11:8;12:5,6,8,15; 13:11,23,25;14:4,6, 9,14,16,19,21,24; 15:2,13,14,19,22; 16:12,12,17,22,23; 17:1,2,4,4,6,7,17,19, 25,25;18:1,9,12; 19:4;20:9,24;21:2,3, 17,23;22:7,18;23:12, 13,14;24:6,8,12; 25:3,14;26:7,7,12, 17;27:22;28:1,13; (7) exist - Gang JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 29:24;30:6,20;32:14, 15,18,19,20;33:6; 34:6,14;35:25;36:4, 8,13,15;37:4,14; 41:2,3,6,12,13,15; 42:7;45:7;46:2,5,9, 13,22,24;47:9,12; 48:2;49:14,17;50:1, 2,14;51:7,12,17,19; 52:23;54:11;56:6, 10;57:4,19;58:15,18; 59:1,12,16,21;60:14; 62:8;63:8,17,25; 64:1;66:5,15,17,23; 67:2;69:3,4,8,10,12, 13,21;70:3,5;71:13, 20;73:15,17,18,18, 21;74:1,1;75:1,6,8, 15;76:23;78:24; 79:3;80:8,13;82:1,3, 3,5,8,16;84:6;85:11; 86:3,6,16,17;87:9; 88:23;90:15;91:5,12, 15,20,25,25;92:2,3; 93:24;94:3,16,18; 95:10,14,19;97:3; 98:5;99:3,15;102:2, 4,7,10;104:8,9,12, 16;105:8,13;106:12; 107:4;108:13;109:1, 24;110:6,6,9,15; 111:15,19,23; 112:12,14,15,15,16, 18,21,22,24;113:2, 15;114:6,9,9,23; 115:6;116:2,10,21, 21;117:2,3,12,13,16, 20,23;118:6,12,12, 14,16;119:14,24; 120:19;124:13; 125:15;126:2,4,5,7; 127:16,18,19; 128:20,25;129:1,3,4; 130:2,6,14;131:3,5, 12,17;132:2,5,6,23; 133:7,7,13;134:11, 12,15,15,19;135:2; 137:21;138:4,5,6,15, 19,20;139:11,11; 140:14,17,17,18,19, 20,22,23;141:6,8; 142:2;144:2,6,15,19, 25;145:3;146:3,9,16, 17,18,19;147:12,19; 150:2,11,21;151:4,5; 152:19,24;155:11, 21;156:1,4,6,9,12; 158:15,19,21,22; 159:3,9,13;160:6,8, 9;161:1,24;162:3,15, 18,24,25;163:1,3,4,8, 9,13,13,16,20,23; 164:5,7,10,11,12; Min-U-Script® 165:6,6,10,11,12,14; 166:4,13;167:5,8; 168:2,3,21,24;170:1, 21,23;173:17,23 gang-banging (1) 88:12 gang-related (4) 32:17,23;135:10; 163:4 gangs (24) 17:23;20:9;21:12, 13;23:12,18;26:7,9; 41:10,10;69:6;70:2; 118:17;121:18,19; 129:2,7;165:7; 167:23,23;168:8,25; 169:5,5 gang's (4) 12:19;57:14; 118:21;146:20 gang-specific (2) 22:20;45:6 gangster (3) 116:24;117:6,10 gave (14) 24:15;54:24;55:3, 7;64:16;65:5;73:6; 78:2,4,7;105:8; 108:9;157:2;171:15 general (9) 23:19;26:7;82:6; 95:21;105:22; 109:24;110:5; 112:21;168:5 generally (12) 24:7;42:16;43:12; 44:14;45:20;48:18; 104:11;106:9;107:5; 110:4;115:4;133:17 generate (1) 134:24 generated (1) 69:13 generic (2) 93:23;117:7 gentleman (1) 76:18 gestures (1) 34:19 gets (1) 6:18 Gilbert (5) 75:2,5,18;76:5,6 Gilbert's (1) 75:4 given (9) 11:5,9;17:2,19; 130:17;172:5,6,6,8 gives (20) 19:11;57:3;59:11; 63:10,15;65:22; 67:4;68:20;71:2,11; 74:6;77:4;78:14; 80:3,10;81:11,20; 84:14;87:8;169:1 giving (5) 12:25;21:19; 73:13;123:24,25 goes (18) 15:20;35:24;60:9; 64:7;70:2,6;90:24; 104:5,7,8,16,17,23; 105:7,8;130:17; 151:25;173:6 gonna (1) 77:16 Good (10) 5:9,10;38:19; 51:25;52:1;81:15; 82:4;128:6;150:17; 171:18 govern (1) 44:5 graffiti (4) 36:11;69:11;83:2; 121:21 granted (1) 122:19 graph (2) 169:8,8 graphs (1) 169:6 great (1) 132:15 grew (1) 138:8 grind (1) 85:3 ground (1) 6:4 group (3) 39:23;71:14; 107:10 groups (3) 36:5;110:4;169:2 guarantee (1) 117:15 guess (6) 7:16;15:25;24:8; 37:10;50:23;83:14 gun (3) 146:16,17,18 guy (8) 35:3,3;108:24; 113:18;118:4; 124:18;140:2,5 guys (4) 35:14;47:24; 77:15;167:14 guy's (1) 139:18 H Ha (7) 92:19;95:17,18,18, 22,22,22 Habing (1) 93:19 haha (1) 95:15 half (10) 17:3,3,20,20;18:9, 9,11;116:4;172:10, 17 halfway (3) 75:20;78:17;94:4 hand (4) 34:19;54:15; 172:13,17 handed (1) 56:20 handing (2) 54:16;96:17 handle (2) 31:1;119:24 handwriting (1) 111:9 handwritten (3) 132:25;146:6; 149:18 handwrote (1) 104:1 hang (7) 36:14;53:22; 73:17;93:11;125:19; 152:19;163:13 hanging (26) 34:14,25;35:6,11, 14,15,16,17,20,22; 36:5,11,16;37:7,14; 38:2,5;102:12; 106:11;125:13,24; 133:7;134:18; 135:14;139:10; 164:8 hangs (1) 166:8 happened (1) 26:25 happy (1) 82:8 hard (4) 58:8;82:18;89:4; 146:14 Hardcore (6) 71:20;74:1;75:1,5; 78:24;117:16 hat (2) 79:14,14 hate (1) 125:5 hats (1) 66:16 head (2) 7:10,10 heard (2) 52:13,18 hearing (4) Barkley Court Reporters 12:2;52:14;94:12; 122:19 heart (1) 80:8 heavily (6) 22:11;64:2;66:5; 108:6;127:17,22 help (10) 6:17;13:13;15:5; 17:14;29:20;74:9; 103:14;107:16; 116:1;137:15 helped (3) 17:11;47:8;90:9 helpful (5) 59:4;131:6,18; 132:2,17 helping (3) 16:16;29:4;32:11 helps (2) 25:10;37:13 HELZER (47) 5:8,12;9:20,25; 42:3;50:5,11;56:15, 18,24;84:25;85:8; 90:9;96:8,13,22; 97:1;98:12,15,21; 111:6;116:16,19; 122:13,15,21,24; 123:3,5,11,18,24; 124:5;131:9,14,20, 24;137:9,13;144:1,4; 169:9,14;174:7,11, 23;175:18 hereto (3) 56:23;96:25;98:20 hesitant (5) 25:21;70:25;81:3; 125:17;155:13 hidden (1) 146:19 hiding (1) 57:18 high (2) 117:14,22 higher (1) 107:11 hindered (1) 132:12 history (3) 71:21;118:22; 141:4 hit (1) 46:20 hits (2) 89:13,15 hold (4) 50:23;94:25; 135:18;165:4 home (1) 40:15 homies (8) 93:20,23;94:5,7,9, (8) gang-banging - homies JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 12,14,15 honest (5) 114:20;140:12; 143:5,14;168:6 honestly (1) 80:19 honesty (1) 82:17 hood (1) 79:2 Hopefully (1) 87:2 hour (2) 125:1,1 hours (3) 8:12,14;124:18 house (2) 95:11;172:15 hundred (2) 129:13,18 hung (2) 153:14;154:10 hypothetical (1) 35:8 I identifiable (1) 117:13 identification (3) 56:23;96:25;98:20 identified (1) 170:14 identifiers (5) 66:6;114:18; 115:7,8;118:18 identifies (2) 64:1;66:5 identify (3) 29:25;114:19; 141:3 identifying (4) 29:23;55:9;75:4, 22 illegal (1) 135:25 immediate (1) 135:7 immediately (1) 74:17 impacted (1) 129:2 Impeding (1) 161:5 important (5) 6:10;7:9;22:1,3; 43:23 improper (2) 123:15;131:24 inaccurately (1) 175:2 inactive (11) 19:23;20:18;21:5, Min-U-Script® 24;23:21,24;24:13, 19,25;25:4;29:14 Inactivity (1) 24:7 inappropriate (1) 136:5 incarcerated (1) 33:4 incident (11) 26:25;27:5; 107:21;108:8,11; 110:11,14,19;121:5; 154:8;163:22 Incidents (4) 15:24;108:8,21,22 include (8) 19:4,6;51:18; 98:18;102:10,13; 151:15;175:7 included (5) 106:4;107:25; 122:6;146:23; 147:23 includes (1) 105:21 including (1) 99:25 inclusion (1) 8:23 inconsistency (3) 138:22;139:2,4 incorrect (1) 139:20 independent (2) 101:20;114:24 in-depth (1) 100:21 indicate (11) 59:15;80:22;85:2; 87:17,19;101:19; 111:17;120:14; 153:18,21;170:22 indicated (16) 56:8;58:17;62:13; 68:8;73:4;76:15; 100:5;103:4,18; 108:15;118:11; 119:1;144:22;145:4; 163:7,8 indicates (10) 60:25;71:10;74:5, 22;84:7;86:1;88:8; 93:2;142:22;146:2 Indicating (2) 90:5;108:7 indication (10) 57:3;59:11;60:3; 62:18;63:16;73:25; 90:13;116:9;144:18; 170:24 indicator (4) 53:3;73:16;85:6; 118:8 indicators (4) 102:1;116:2; 117:2;135:23 indicia (8) 69:12;114:6,10, 23;116:2,10;118:12; 146:5 individual (42) 10:9,10;14:8,18, 20;15:6,21;17:6; 22:9,17,21;23:20; 24:2;26:10;27:23, 23;28:20;29:18; 32:18;34:12;36:2; 41:12;43:10,13,16; 44:6;45:22;54:10; 72:11,11;93:24; 129:9;130:1,5,16; 133:18,18;134:9,10; 138:23;144:6;165:5 individualized (1) 83:17 individuals (50) 11:22;14:10,11,13, 14,24;15:15;17:4; 20:6,21;23:18;25:3; 29:7,18,25;30:1,5,6, 9,11,16,19;33:2; 34:8,13;35:18;39:23, 25;41:9,10;42:18; 49:22;51:15;52:23; 72:4;75:21;85:16; 107:3;116:20; 117:19,21;129:3; 132:1;138:8;140:13; 141:11,18;164:7; 166:12;167:7 individual's (8) 20:13;113:24; 128:4;141:4;144:14; 156:1,6;164:3 inference (2) 59:22,25 influence (1) 138:12 inform (2) 24:24;114:3 informal (6) 104:15;119:2; 120:8,10,11,13 informalities (1) 6:22 information (65) 9:19;16:7;36:21; 43:9;47:6;48:23; 51:9;57:9;58:25; 59:4;61:14,15;62:9; 63:10;64:7;65:13, 22;67:1,5;68:20; 71:3,11;73:14;74:6, 22;77:5;78:14;80:4, 10;81:12,20;84:5,7, 14;86:5;87:8;88:22; 98:3;99:1,13,20,25; 102:16,17,21,24; 103:15,18;111:11; 120:4,21;123:25; 124:15,17;127:9; 137:5;142:14; 150:19;152:4; 155:19;168:7,16; 169:15,20;170:7 informs (3) 18:22;19:17;57:9 infractions (1) 32:24 initial (1) 38:16 initially (3) 11:6;22:25;85:20 Injunction (29) 8:20;10:8,19;11:8; 28:13;61:19;81:22; 82:2,8,16;83:8; 84:17,19;85:3;86:6, 16,18;104:9;131:5, 12,17;132:2,9,13,14; 136:3,7;168:22,24 injunctions (3) 31:7;36:8;132:7 input (1) 47:4 insinuating (1) 95:19 instances (1) 109:5 instruct (2) 9:23;131:21 instructed (2) 123:14;174:14 instruction (10) 10:1;16:11;17:11; 122:16;133:10; 134:2;136:15,18,25; 175:8 instructions (3) 16:9,14;136:16 intention (1) 30:23 interact (2) 24:12;112:17 interacting (1) 24:5 interactions (4) 49:22,24;50:15,19 interest (2) 167:20;168:11 interested (1) 168:9 interesting (1) 170:2 internet (2) 83:9,10 interpret (2) 13:19;88:14 interpretation (2) Barkley Court Reporters 81:6;133:9 interpreted (1) 86:5 interrupt (2) 34:17;103:10 intersection (2) 80:6,16 Interview (19) 42:8,10,13,21,24; 43:1,2,4,9,14,21; 44:1,7,12;45:6; 103:1;145:16,18,20 interviews (1) 112:14 intimidating (1) 37:6 into (22) 14:25;15:20;16:6; 19:10;21:18;50:18; 61:19;64:7;72:8,10, 14,17;85:19;121:5; 126:11;137:21,24; 138:6,12,24;158:14; 164:20 investigate (2) 11:6;26:13 investigating (1) 58:14 investigation (9) 53:6,8,17;54:6; 56:3;60:25;61:19; 150:1;157:9 investigations (2) 32:23;52:12 investigative (2) 29:2;51:10 Investigator (3) 53:16,23;54:1 involved (15) 15:14,18;20:9; 25:24;26:15;27:4; 32:18;51:14;97:24; 99:18;105:14;109:4, 18;121:5,6 involvement (3) 12:6;26:18;109:13 involves (2) 24:7;45:20 involving (1) 162:15 irrelevant (1) 128:23 issue (6) 51:18;120:20; 129:9;130:5;131:10; 171:1 issued (2) 157:10;161:10 issues (1) 174:13 issuing (2) 146:6;149:15 item (1) (9) honest - item JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG kid (1) 59:13 kids (2) J 125:21;133:22 killed (2) jail (1) 33:24;37:25 158:14 kind (32) jams (1) 14:19;27:1,2,3,6; 94:5 29:9,17;35:8,24; January (5) 41:25;45:11,21; 85:23;97:11,12, 52:9;58:8;70:17; 16;122:4 72:19;90:24;94:18; JEFF (4) 95:21;96:14;98:24; 5:4,16;115:23; 100:13,14;117:7,7; 143:20 119:19;121:6; J-e-f-f (1) 124:15;125:24; 5:16 136:4;138:8;146:20 jersey (1) kinds (1) 63:20 141:13 Jesus (1) Kings (1) 160:5 168:10 job (12) Kira (2) 46:20;124:15,16, 54:2;83:12 21,25;125:1,2;126:6; K-i-r-a (1) 131:6,18;132:2; 54:2 134:23 knee-socks (1) jobs (1) 117:14 124:13 knew (9) judge (1) 31:22,22,24;32:7; 6:23 38:19;72:14,14; Julio (2) 142:11;171:8 74:25;76:2 knowing (3) July (2) 66:18;117:19; 101:16;171:13 164:23 jump (1) knowledge (17) 137:25 21:9,15;53:19; jumped (6) 67:2;78:8;82:7; 138:17,25;139:1; 110:5,6;112:5; 146:10;147:15; 113:13;119:5; 148:23 139:23;146:24; jumping (1) 167:9,12,22;168:5 138:2 known (3) jumps (1) 72:11;138:9; 95:2 160:10 June (5) knows (3) 58:9,11,19,19; 125:18;140:5; 143:22 146:15 jury (7) 6:24;16:9,11,14; L 17:11;136:24;175:7 150:8 K keep (6) 100:13;136:8; 152:7;159:12; 162:12;167:1 Kevin (2) 53:16;83:12 kick (5) 139:8;150:14,22, 22;170:20 kicking (1) 150:10 Min-U-Script® la (2) 95:15,17 label (1) 118:6 laboriously (1) 36:22 lack (4) 20:16;32:14; 45:19;46:18 laid (1) 86:4 Lame (1) 57:18 language (2) 14:2;161:4 large (3) 117:18;126:1,2 larger (1) 106:21 Last (32) 5:17;8:11,14;9:14; 22:21;67:15,20;68:4, 13;74:3;75:23,25; 90:7;91:14;95:17; 96:6,7;98:2,25; 99:24;101:1,14; 128:12;132:10; 143:1;146:9;147:12; 148:22;149:17; 171:8;173:7,8 later (2) 10:2;139:9 latest (2) 51:20,21 Latin (1) 168:10 latter (1) 11:13 LAUNI (20) 5:4,16,18,23;16:7; 54:20;56:19,25; 90:9;96:14,17;97:2; 98:16;111:7;115:23; 116:20;137:14; 143:20;146:1; 174:25 L-a-u-n-i (1) 5:17 Launi's (1) 16:5 law (8) 18:23;20:13; 32:14,15;36:10; 134:6;136:5;167:13 lazy (1) 74:20 Le (1) 38:18 leads (1) 19:17 learn (1) 52:4 learned (2) 49:10;119:12 learning (1) 72:2 least (7) 33:18;54:5;66:23; 118:1;123:9;148:21; 155:4 leave (3) 37:9;78:10;136:21 Lee (1) 78:20 left (12) 11:20;27:20;28:4; 71:13;75:11;78:11; 87:10;89:23;95:6; 110:25;170:12; 173:5 left-hand (4) 55:8;73:4;76:16; 90:10 legal (7) 12:16,21;13:12, 15;29:9;136:11; 141:15 length (1) 166:15 less (6) 17:3,20;18:9; 76:17;129:18;132:5 lesser (1) 46:17 level (8) 43:15,18;46:13; 77:1;106:25;107:2; 121:11;164:12 levels (5) 16:13;31:23; 41:22;47:5;107:9 lie (1) 140:13 life (3) 90:24;91:1;126:24 lifestyle (7) 14:7,9,14,16,20, 25;15:22 likes (1) 140:5 limit (1) 104:9 limiting (2) 105:1,3 line (16) 23:23;24:1;25:12; 43:23;52:16;57:22; 71:17;95:25;101:18; 144:5;150:15;153:5, 13,21;169:8;172:24 list (32) 20:4;28:12,17; 29:5,21;30:12; 33:21;34:15,16,18, 18;35:10;38:9,16; 41:4,7,8,14,18,25; 42:4;51:25;52:1; 85:22;106:19,20,21; 122:3,7;123:7; 126:8;149:18 listed (4) 52:22;162:23; 164:25;165:5 Listo (1) 78:18 lists (4) 34:21;171:20; 172:21,22 literature (1) Barkley Court Reporters 52:8 little (26) 5:11;17:9;18:16; 20:1;23:10;37:10; 39:6;45:25;46:2; 59:7;61:5;62:19; 63:14;64:3;71:25; 74:20;76:16;82:18; 93:23;109:1;133:20; 137:2;139:16; 153:23;155:4; 170:10 live (9) 32:21;113:3; 128:20,21;129:4; 134:11;138:7; 158:13;171:19 lived (4) 14:6,9,16;171:6 lives (2) 171:8,16 living (5) 14:24;15:22; 128:14;171:8; 172:20 local (2) 168:16,16 Location (2) 171:23,25 locations (2) 38:20;42:20 loco (1) 118:5 log (1) 129:21 logical (2) 112:16;113:7 logically (1) 13:6 logo (1) 66:12 loitering (2) 162:6,17 long (8) 33:4;85:12; 117:22;124:16; 131:3;132:9;166:12; 168:12 longer (3) 73:2;128:9;157:20 look (83) 10:24;15:8,9,24; 24:22;26:13,20,23; 27:4;50:2;56:11; 59:19;71:15;73:16; 75:8;76:14;77:3; 78:16;86:25;91:11, 13;92:14;96:6; 105:25;108:4,5,9; 109:7;114:8,21; 116:14;118:3,4,7,8, 24,25;121:2;122:1; 126:11,22;128:4; (10) jail - look JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 135:20;139:5,6,7,11, 13,25;142:8,9,24; 143:8;147:19; 148:14;150:19,25; 151:24;154:7,20; 157:10;159:1,19; 160:23;161:12,25; 162:9,14;163:2,9,12, 15;165:17,18; 166:21;167:8;168:4; 169:16;171:2,2,3; 172:9;173:5 looked (19) 33:3,7;34:24;35:1; 38:15;47:16;68:3,4, 7;81:2;99:1,24; 100:24;106:6,11; 107:9;169:19,20,22 looking (25) 53:24;54:21; 58:13;59:25;60:9, 12;73:3;75:17; 76:21;83:18;89:3; 93:11;94:2,25; 101:19;107:11; 115:16,17;128:2; 142:23;143:4; 145:23;149:22; 162:12;167:1 lookouts (1) 110:1 looks (7) 58:21;63:14; 80:24;82:12;101:10; 143:6;162:2 Lopez's (1) 163:15 lose (1) 87:4 lost (1) 135:12 lot (29) 21:7,9,10;27:20; 31:22;47:24;48:23; 51:9;58:1;63:5; 64:15;77:3,15; 89:14;114:18; 116:25;117:17; 124:13;128:20,25; 129:2;140:9;141:8; 151:18;153:4; 163:19;167:9,22; 168:4 lots (1) 127:7 lower (2) 68:24;87:10 low-level (2) 120:18;129:6 lying (2) 139:18,21 Min-U-Script® M M3 (1) 152:18 mad (1) 92:19 mad-doggers (2) 59:17,18 maintained (1) 146:19 makes (2) 82:10;133:8 making (9) 19:11;21:22;29:9, 13;33:22;34:19; 95:16;106:9;118:3 Male (1) 69:19 mall (1) 117:16 manner (3) 113:23,24;114:22 many (11) 14:18;31:1,1,6; 45:15;51:8;129:12, 22,23;130:6;171:19 marathon (1) 7:24 March (6) 96:3;97:12,16; 103:22;119:3; 145:10 mark (6) 10:1,1;56:21; 122:21;123:1; 131:25 marked (7) 56:22;57:1;92:14; 95:4;96:24;98:19; 119:2 may (49) 18:1;23:13,13,14; 24:2;25:25;26:6; 27:18;31:21;32:20, 21;34:24;36:7,7,8; 38:21;48:12;53:23, 24,24;60:6;61:7; 64:15;85:18;89:9; 93:23;100:23; 103:10;105:7;107:5; 111:4;115:9;116:13; 120:9;121:6;123:25, 25;134:5,5,11; 141:11,18;143:7; 145:8,21;155:15,16; 175:4,11 maybe (22) 17:3;22:8,20,20; 24:3;34:4;35:3; 46:14;60:23;83:25; 100:9;103:11,14; 104:3;107:6;133:18; 135:12;138:4,7; 140:12;146:13,14 Mayo (1) 93:20 mean (44) 13:17;20:2;22:5; 23:11;24:10;25:17; 28:4,7;31:3,14; 35:12;51:6,13; 59:18;60:8;68:10; 69:20;74:10;75:24; 80:15;81:9;85:13; 86:18;95:18;100:7; 105:18;113:4,18; 119:23;120:19; 126:4,5;136:13; 137:24;140:9;149:4; 155:6;160:8,16; 161:16;168:3; 171:12,24;172:19 Meaning (2) 31:15;65:10 means (6) 137:25;138:20; 139:9;160:9;171:25; 172:1 meant (1) 101:6 media (9) 50:25;51:9;52:24; 53:6,9,18;54:7,8,13 medication (1) 8:11 Medrano (2) 74:25;76:2 meet (1) 52:24 meeting (2) 39:8,11 member (46) 17:1;19:23;20:24; 71:20;74:2;75:1,6,8, 15;78:24;79:3;82:3; 91:13;108:13; 117:16,23;118:6; 135:7;138:5,16,20; 139:11;140:17; 144:19;146:3,9; 147:12;150:2;151:5, 7,9;153:5;158:21,22; 161:1;163:3,4,8,9, 16,20,23;165:6,6,10; 166:4 members (86) 13:23;14:5,6,21; 15:13;18:1,10;19:4, 4;22:18;23:12; 29:24;30:7,20; 32:19;34:14;35:25; 36:5,14,16;37:5,14; 39:1,11;40:7;41:9; 46:9;47:13;66:17, 23;69:12,13;71:14; 73:17,18,18;90:16; 91:5,15,25;92:3,3; 106:12;111:23; 112:12,14,15,15,16, 18,21,22,24;113:2; 117:13,20;118:16; 119:24;124:13; 126:3,4,5,8;128:20; 129:1;134:12,13,15, 16,19;138:19; 140:19;141:8; 146:15;152:19; 159:13;160:1,1,6,8; 163:13,13;164:11, 12;165:13;166:13 membership (25) 13:25;15:2,19; 16:12,12,13,22; 17:17;21:2,3; 135:11;139:24; 140:18,21,22;141:6; 144:15,25;145:4; 147:20;153:3,7; 156:5;162:18;167:8 memorized (1) 136:20 memory (3) 23:2;50:4,13 mentality (2) 69:8,10 mentioned (12) 23:4,8;36:1;37:19, 24;98:16;99:12; 106:9;109:16;112:3; 113:23;132:22 met (12) 5:11;38:24;39:1, 14,17;40:8,9,21,24; 61:3;112:9;113:12 meth (2) 158:6,12 microscope (2) 34:4,6 mid (1) 166:19 middle (5) 74:17,24;75:20; 78:17;79:14 Midwest (1) 21:13 might (49) 15:8;19:1,1;20:12, 22;22:19;34:15; 35:1;38:5,17;41:5; 44:17;48:22;51:22; 52:6;60:22;64:17; 68:14;75:7;81:14; 83:25;84:2;85:7; 100:14;101:19; 106:6;109:6;120:8, 17;121:2,7,8,16,17; 124:17;126:21; 128:6,24;135:20; Barkley Court Reporters 139:6,7;149:4; 154:16,18;155:6; 159:5;166:20;171:2, 22 million (1) 119:18 mind (5) 16:24;107:22; 109:2,3;131:16 mine (1) 145:5 mine's (1) 152:17 minimum (4) 24:21,23;45:11; 151:6 minor (2) 36:7,13 minor's (1) 157:9 minute (3) 78:16;108:9; 115:12 missing (1) 114:17 misspoke (1) 100:23 misstates (1) 84:23 mix (2) 35:1,12 mixing (1) 34:14 mode (1) 60:7 Modesto (1) 163:15 mom (2) 40:9;171:17 moment (3) 15:24;33:10;71:22 moments (1) 56:20 momentum (1) 87:4 moniker (1) 142:5 monikers (1) 51:20 Monta (1) 80:7 months (17) 24:4,17,17,23; 67:13,13,24,25;68:3, 6,13,14,15;98:8; 131:2;139:8,9 more (90) 11:23;13:19,22; 14:3,22;15:1;18:11, 12;20:1;21:15,25; 22:3,7,11;23:10; 25:9;27:25;28:11; 29:10;30:5,20;31:7, (11) looked - more JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 17,24;33:13;34:4,5, 7;36:5;37:5,11;38:4, 12;43:8;45:6,7,24, 25;46:2,9,18,23; 63:19;66:1;67:13; 72:10,14;76:14; 81:23;93:24;102:21; 105:18;106:9;107:5, 6;108:6,20,22;109:6; 110:4;118:17;120:3, 5;124:15;126:22,22, 23;127:4,11;130:3,4; 131:4;132:22; 135:23;139:13; 142:24;149:15,19; 150:16,22,24;151:9, 11,17;152:1;153:23; 164:23;168:4,8,15 morning (3) 5:9,10;6:6 most (13) 7:3;8:9;30:1,11; 43:12,23;47:2; 89:15;101:12; 107:17;158:16; 168:6;171:12 motherfuckers (1) 92:20 move (3) 28:10;74:9;96:11 moved (1) 23:21 moves (1) 171:7 much (13) 25:11;50:18,21; 60:19,20;72:20; 76:20;86:5;117:8; 167:12;168:2; 173:10;175:18 multipage (1) 54:16 Municipal (3) 160:18,25;161:3 murder (1) 40:2 music (3) 94:12,15,16 must (2) 95:1;110:12 myself (4) 27:3;32:5;163:19; 174:18 N name (20) 5:15,16,16,17; 12:17;13:8,18;16:8; 39:14;62:17,19; 74:3;75:23,25; 89:18;90:7;133:4; 142:25;143:1; Min-U-Script® 163:15 names (3) 72:4;89:17;175:6 narcotic (6) 110:7,8;121:19, 22;159:14,16 narcotics (1) 108:14 narrative (1) 154:20 narrow (2) 30:19;34:8 narrowed (3) 31:11;101:4; 106:12 narrowing (1) 32:10 Nathan (1) 110:25 nd (3) 94:5,11;95:13 near (3) 32:7;33:11,13 nearby (1) 118:22 necessarily (5) 57:24;133:23; 151:2;152:1;153:6 need (9) 7:25;101:17; 107:15;116:6;120:4; 124:15;145:1; 175:21,22 needed (1) 60:23 needs (2) 6:9;43:16 neighborhood (19) 25:14;34:1,2;37:6; 38:1;66:18;67:3; 80:9,9,14;107:13; 125:24;128:21; 129:5;132:15; 134:11;138:7; 167:21;171:9 neighborhoods (1) 132:6 net (8) 51:5,6;52:4,9,20; 54:9;83:5,6 networking (4) 58:3;77:2;90:15; 106:6 New (6) 11:15,16;22:20; 51:5;52:2,9 next (49) 35:1;59:3,6;63:10, 12;65:19;68:17; 71:6;74:14;78:9; 79:10,11;80:1,2; 81:17,18;84:11; 85:24,25;87:6;88:6; 89:20;90:23;91:8; 92:8,13;93:6,17; 94:23;95:3;101:18; 133:11;141:16; 142:1;148:13,25; 149:1,10;150:6,7; 155:25;156:5;159:8; 160:22;161:24; 162:11;164:3;165:8; 170:15 nexus (1) 92:6 nine (1) 131:2 Nita (2) 78:24,25 Nobody (1) 113:2 nod (1) 7:10 nominal (1) 13:19 nonactive (1) 18:20 noncontact (1) 24:24 noncriminal (1) 102:14 none (1) 173:16 non-gang (1) 19:4 notation (1) 55:8 note (10) 13:7;55:15;73:8, 19;96:15;98:7,9; 99:4,4;143:17 noted (2) 69:25;170:25 notes (34) 10:21;12:23;16:6, 15;45:18;98:17,18; 100:5,6,11,13,16; 101:9,13,17,20; 102:15,22;103:5,17, 17,18,24,25;107:15, 16;108:4;119:1; 132:25;136:10; 137:15;141:17; 144:24;171:11 Notice (35) 45:4,5,9,13,20,24; 103:8,21;145:11,13, 14,15,19,20,22,22; 146:21;148:17; 150:20;151:19,20; 152:2,3;155:15; 156:23;157:3,6; 159:17;161:18; 164:25;172:18,18; 173:7,8,10 Notices (15) 44:24;45:1; 102:25;104:20; 105:21;138:21,24; 139:3;140:24;145:7; 147:18,23;148:2; 163:6;169:20 November (1) 58:21 nuisance (3) 36:7;156:13; 173:21 number (45) 8:21;18:2;20:1,10; 31:8;32:1,2,8,20,22; 42:18;110:8;120:18; 121:25;129:3; 135:22;136:18,24; 142:19;146:12; 150:8;157:2,7,16,19, 20,21,24;158:1,7; 159:18,21,21,22; 160:14,15;161:12, 13,22,25;162:8,17, 22,23;171:14 numbered (1) 115:15 numbers (4) 37:5;55:11; 105:24;106:4 numerous (1) 112:14 nuts (1) 37:8 O O7 (1) 161:14 oath (3) 6:20,21,22 object (7) 41:23;122:11; 123:8,22;131:7,19, 20 Objection (3) 9:18;42:2;122:16 observation (2) 19:1;35:22 observations (13) 15:3,4,5,16;20:2,3, 11,22;25:7;26:21; 36:24;37:17;149:15 observed (3) 22:18;24:5,16 obstructing (2) 160:24;162:1 obtain (2) 14:17;109:13 obtained (1) 152:5 obviously (7) 56:11;64:16;81:2; 88:19;107:11; Barkley Court Reporters 108:24;169:18 OC (1) 111:3 occur (1) 27:2 occurred (5) 89:19;108:11; 120:1;154:7;158:19 off (36) 55:11;56:15,16; 64:10,12;77:8,11; 78:10,11;83:9,10,15; 84:16;85:4;96:9; 98:12,13;116:16,17; 119:12,21;125:8,8, 11,12,13;137:10,11; 141:1;143:11;151:3; 170:10,12;173:4; 174:7,9 offending (2) 25:13,16 offense (3) 6:1;120:17,18 offenses (3) 121:20,20,22 offensive (1) 72:24 offering (2) 12:1,7 Office (14) 8:25;11:3;27:17; 36:23;53:13;54:18; 83:11;96:11;112:7; 130:20;136:16; 174:21,23;175:10 officer (20) 5:19;18:23;20:7; 26:22;28:5,8;43:16, 21;44:6,19;45:12; 48:15;49:3;95:10; 146:7,22;167:5; 169:13;170:20; 173:2 officers (11) 19:7,13;44:11; 47:19;48:2,9,13; 49:2;167:16,17,19 officer's (3) 139:17;147:4; 149:15 officers's (1) 146:24 often (5) 36:5;51:19;70:3; 138:20;171:3 old (2) 72:1;166:19 older (2) 63:22;138:4 one (88) 6:10;10:18,19; 11:21;15:14;22:4; 23:13;26:10,11; (12) morning - one JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 30:15;31:10,10,25; 34:24;35:6;37:1,3; 40:18;44:16;45:18, 23;46:8,23;50:6; 53:3;57:16,17;60:10, 10;65:10;66:2,5; 70:23;71:18;74:24; 78:16;82:3,24; 84:21;91:14;92:15, 17;94:23;95:2,9; 96:22;101:23;102:1, 9;106:10,14;107:23, 24,24;108:25;110:8, 12;113:9,23;118:8; 121:7,8,14;135:23; 136:6;138:25,25; 139:14;141:18; 144:13;147:1;148:3, 13,25;149:1,10,13, 17;150:4,6,7;158:18; 169:4,7,7;170:5,15; 171:13 ones (4) 22:3;149:21; 162:12;167:15 one's (12) 12:21;13:20,22; 14:3,23;24:7,10; 27:22;37:8;50:24; 117:4;135:18 ongoing (5) 111:22;112:11; 132:12;163:10; 164:4 online (3) 51:8,12;52:23 only (17) 6:10;7:25;12:17; 13:8,18;14:20;16:8; 20:12;38:11;66:2; 86:7;92:18;104:5,7; 122:23;133:4;142:7 open (3) 10:16;132:6; 163:25 opened (2) 50:7;54:22 opine (1) 82:10 opined (1) 30:16 opinion (65) 12:1,7;15:13; 17:23;18:22;19:11, 18;21:18;25:2,6,10; 36:18;37:13;43:23; 59:4,21;60:10;65:4; 66:15;69:9;73:10; 81:10;84:10;85:18; 97:2,6,20;102:5; 104:21;111:18,21, 24;112:2,10,19,21; 114:3;116:11; Min-U-Script® 118:11;119:13; 120:3,5;121:7,8; 122:6,23;123:6,20, 25;124:1,8,14,22; 125:2,14;126:14; 136:4,8;140:4,6; 141:15;149:4;153:1; 164:18;165:4 opinions (1) 27:15 opportunity (1) 175:1 opposed (8) 34:18;54:24; 106:20;120:14; 140:22;141:4; 142:22;147:4 opposition (1) 86:6 order (6) 43:16,21;95:25; 101:10;120:5; 164:10 original (4) 78:3;98:22; 174:20;175:9 originally (3) 16:10;30:9;38:12 others (7) 22:1,3,12;82:25; 83:1;111:4;127:4 otherwise (1) 7:20 out (85) 13:4;17:6;22:17, 19;23:17;24:5;32:7; 33:25;34:13,14,25, 25;35:2,6,6,11,14,14, 15,16,17,20,22;36:5, 14,16;37:7,14,25; 38:2,5;43:15;44:16, 18,21;45:16,18,21, 23,25;46:22;47:12, 12;51:9;69:7;81:1, 15;86:4;95:2; 106:11;107:9; 108:24;110:2; 114:19;117:6; 119:25;121:3; 125:13,20,24;132:5; 133:7;134:10,18,19, 22;135:14;139:10, 16,18;140:11,17; 145:21;149:8; 152:19;153:14; 154:10;163:13,20, 21;164:8;166:8; 167:15,15,21 out-and-out (1) 36:9 outside (12) 61:15,16;62:9; 103:16;128:14,21; 129:7;167:25;171:9; 172:3;174:1,4 outstanding (1) 174:13 outwardly (2) 135:25;149:14 over (21) 11:10;12:22; 26:21;36:22;61:11, 12;62:7;73:13; 107:22;121:19; 122:7;125:23;128:5; 129:15,16,23;131:1; 150:15;157:8; 159:14;162:1 overage (1) 119:20 overall (1) 131:15 overtime (1) 139:5 own (8) 14:14;15:17; 20:13;21:15;26:21; 36:23;144:14; 167:13 P package (3) 78:2,7;118:4 packet (8) 54:24;65:5;83:18; 86:21;95:6;132:23; 142:17;161:11 pad (1) 95:14 page (163) 6:5;54:23;55:9; 57:2,5,6;58:24;59:3, 6,11;60:24;63:10,12; 64:10,13,23,25;65:3, 5,8,12,19,22,24;66:2, 8,12;67:4,9,16,21; 68:2,7,10,17,19,24; 69:18,23;70:12,15, 21,21;71:2,6,23; 72:5,7,8,10,12,14,17, 18,18,25;73:6,13; 74:5,14,21;76:16; 77:4,8,21;78:9,13; 79:3,6,10,11,18,21; 80:1,2,3,6,12,18,23; 81:11,17,18,19,24; 82:20;83:21,22;84:1, 11,13,16;85:2,24,25; 86:1,4,5,9;87:6,11, 16,19,20,24;88:2,6,8, 10,11,15,17;89:2,4,6, 20;90:1,10,19;91:8, 21;92:8,13;93:2,6, 17;95:3;96:5,6,7,23; 104:14;108:15; 111:7,8;115:14,16, 20;116:4;143:19,23; 144:1;146:4;149:12, 23;152:10;153:12; 154:1;156:2;158:9; 159:11;160:5,12; 161:1,25;162:16,22; 163:15;164:1;165:9, 23;166:8;172:10 pages (15) 55:5,10,23,25; 56:3;58:23;70:11, 23;75:13;89:15; 95:6;115:18;140:7; 145:24;167:4 painted (2) 82:9,10 paired (1) 47:17 paper (3) 12:23;62:19;96:18 paperwork (1) 28:14 paragraph (3) 144:11;152:12,15 paraphernalia (2) 51:17;70:4 parenthesis (1) 142:4 paring (2) 35:9;47:20 park (1) 118:22 parole (5) 19:13;33:5; 119:18;167:16,17 parsing (1) 33:1 part (22) 11:13;32:12; 47:19;48:17;51:4; 60:12;68:24;70:3; 97:10;122:5;126:17; 133:11;134:2; 135:12;140:13; 142:2;145:24; 148:18;155:9,20; 156:10;163:9 participant (123) 12:8,15;17:10; 21:23;24:19,19; 26:19;27:12;29:14; 30:17;33:14;41:2; 42:7,23;44:23;46:5; 47:9;48:4,11;49:5, 14,21;50:1,14;51:2; 56:5,9;57:4,10; 58:15,18;59:1,5,12; 60:4,14;63:8,17; 65:14,23;67:6; 68:21;69:3;71:4,12; 73:15,25;74:7,23; 76:3,7,10;77:6; Barkley Court Reporters 78:15;79:16;80:4, 11;81:8,13,21;84:8, 14,19;85:10;86:2; 87:9,18;88:23;90:14, 20;91:20;93:3;97:3; 98:4;99:2,22; 100:18;102:6,19; 104:22;105:11,16; 107:19;108:7; 111:19;114:4; 116:12;118:14; 119:14;120:16,19, 22;121:15;123:21; 124:9,23;125:3,15; 126:15,19;127:18; 128:3,17;129:10; 130:2,6,8,14;133:8; 135:8;138:14; 141:14;144:2; 150:21;152:23; 153:20;155:11,21; 156:11;164:7,15; 165:3;173:23 participants (13) 17:21;18:2,10; 25:9;26:3;107:4; 135:2;144:7;163:11; 164:5,9,19,24 participate (1) 28:12 participating (5) 12:18;13:11; 126:24;133:12,24 participation (37) 8:23;12:2,21; 13:16;16:16,23;17:7, 12,15,18;18:20; 22:12;23:9;31:23; 52:25;64:9;76:22; 81:25;84:5,22;85:7, 19;96:16,19;97:20; 99:15;122:23;131:8, 12;133:1;136:12; 140:23;141:2; 144:14,15;155:25; 156:5 particular (20) 10:8;11:14;18:5; 21:25;25:20;26:16; 36:17;57:25;58:20; 82:24;92:16;109:25; 110:6;117:3;122:19; 146:25;157:24; 163:22;167:20; 172:2 particularly (1) 167:13 parts (1) 148:14 pass (2) 73:8;150:15 passage (2) 37:2;160:24 (13) ones - passage JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG passed (2) 75:13;117:7 passes (1) 23:20 passive (5) 12:17;13:8,17; 16:8;133:4 past (9) 13:23;15:10,17; 20:8;80:20;116:23; 117:8,9;156:14 patrol (1) 167:19 pattern (1) 66:3 pay (1) 154:4 PD (1) 167:14 pedestrian (1) 161:5 Pedro (1) 160:5 peer (1) 27:14 pelaron (2) 95:17,22 people (71) 8:21;13:24;14:15; 15:10;18:14;19:2,3, 9,12;20:8,24;30:24; 31:5,6,7,16,19,19,22; 32:2,6,10;33:6,14, 17,17,20,21,23,23, 24,25;37:24,25; 38:20,22;39:3;46:17, 23;47:2;48:22; 72:21;73:14;83:20; 97:23;99:17;102:12; 107:6,12;119:17,21, 22;121:25;125:18; 129:6;130:20; 134:24,25;139:15; 140:10,18;150:14; 153:7,8;163:19; 164:19;167:12,13, 23,24;168:16 people's (1) 116:25 per (1) 34:21 perceived (1) 116:21 percentage (4) 126:2,2,7,25 perfectly (1) 143:5 period (5) 23:16;24:3;34:1; 128:5,7 permission (1) 74:12 pero (2) Min-U-Script® 95:15,17 person (13) 6:11;19:23;28:22; 32:12,13;58:13; 130:14;139:21; 155:12;163:7;165:1; 167:8;172:5 personal (9) 121:12,13,23,24; 125:9,19,19;172:9, 12 personally (5) 27:24;38:23; 71:21;113:13; 135:16 person's (1) 26:18 pertaining (1) 8:20 pertinent (1) 71:22 phone (1) 163:5 photo (10) 57:13;64:12,14,16, 18;66:9;68:22; 71:13;75:2;78:20 photograph (21) 50:7;59:10;60:1; 61:23,23;62:15,22; 63:6,14,15;64:19,25; 65:3,7,9,10,17; 79:13;85:9;87:12; 88:11 photographs (11) 62:2,5,13;71:17; 72:4,16;78:17,21,22; 83:19;87:10 photos (7) 51:14;62:24; 64:10,15;70:18; 74:24;89:23 photo's (1) 75:12 picture (20) 15:25;59:7;60:10, 16,21,25;63:22;64:4; 65:24;66:2,3;69:7; 80:15;84:4;87:15,17, 22;90:11,11;139:17 pictures (5) 61:10,17;72:18; 83:18;90:12 picture's (1) 87:20 pie (1) 169:6 piece (12) 12:22;62:18; 100:24;102:9; 105:20;107:17; 121:8;139:14; 142:15;153:1;161:1; 171:1 pieces (1) 121:9 pile (1) 33:14 piled (1) 77:19 pissed (1) 92:18 pistos (1) 94:5 place (2) 40:1;79:2 places (1) 35:20 plain (1) 145:5 play (1) 138:19 playing (1) 141:1 please (11) 5:14;7:2;16:3; 23:5;78:16;104:4; 122:21;123:1; 131:25;143:12; 152:14 plural (2) 14:10,13 pm (11) 5:2;96:12;98:13, 14;116:17,18; 137:11,12;174:9,10; 175:24 PO (2) 95:13,19 pocket-size (1) 42:17 point (7) 7:3;35:4;57:2; 118:3;128:23; 150:15;151:3 Police (48) 5:18;8:19;18:23; 19:7;20:1,2,10; 26:22;28:4,8,20,25; 29:2;33:12;41:3,6; 43:15;44:6;45:12; 86:12;92:21;95:16; 97:25,25;101:1,5,14; 102:25;103:3,7; 105:21;106:25; 107:1,3;109:14; 110:10;111:13; 112:7,10;115:24; 128:9;130:25; 143:21;145:8; 146:21,23;164:8; 167:25 policies (6) 41:17,21;43:3,5,6; 44:5 policy (1) 27:8 population (1) 169:16 portion (1) 55:16 posed (1) 125:16 posing (1) 71:14 position (3) 29:3;69:12;134:23 positive (3) 126:24;132:15; 164:17 possession (9) 108:13;114:6,23; 121:12,23;158:6,12, 13,18 possibility (2) 120:2;143:3 Possibly (15) 15:23;19:12;20:1, 13;21:13;27:16; 48:1,8;49:2;63:21; 67:13;70:11;102:25, 25;125:16 post (24) 51:14,17,20; 52:24;54:8,9,13,13; 57:21;58:16,20; 72:18;74:25;77:15; 83:5,6,6;84:2,6; 91:12;93:22;94:7; 95:9,13 Postdate (1) 173:8 posted (12) 57:25;70:14,25; 83:19,20,24;89:7; 90:17;92:4,16,24; 96:2 posting (4) 72:5,25;89:8;91:4 postings (1) 50:25 posts (3) 57:15;91:20;92:2 potential (6) 18:2;20:24;85:6; 100:12;117:4; 140:16 potentially (3) 15:11;84:10; 125:23 practicality (2) 31:17;38:14 predate (2) 173:7,7 prefer (1) 122:14 premise (1) 40:13 preparation (9) Barkley Court Reporters 9:3;10:3,13,21; 55:24;97:8;100:12; 168:21,23 prepare (1) 10:21 Prepared (1) 154:6 preparing (1) 100:16 present (6) 18:15;22:18; 24:11;35:23;109:9; 168:11 presenting (1) 105:4 presumably (1) 43:10 pretty (18) 15:11;25:11; 51:25;61:8;77:1,19, 20;78:23;81:15; 116:15;140:1,11; 143:8;147:24; 150:17;166:25; 171:17;173:10 previous (1) 83:4 previously (1) 145:25 Primarily (5) 32:22;64:2;75:18; 121:21;167:16 primary (12) 8:19;26:8,8,10,12, 17;57:14;107:21; 108:25;110:8; 121:18;158:18 print (1) 64:12 printed (5) 64:14,15,15; 70:21;77:8 prior (10) 12:5;34:11;40:14; 55:14,24;68:4;70:2; 88:11;104:13; 132:14 prison (1) 33:25 privileged (2) 9:19,22 Probably (56) 11:10;18:11; 21:21;22:13,24; 24:13;27:6,25; 29:16;30:8;32:1; 33:9;34:3,9;35:6; 38:12;42:9;47:3,22, 24,25;48:16,17;49:9; 51:22;52:13,16;53:2, 13;58:22;61:16; 66:10;81:10;85:23; 93:1;98:1,6;99:3,23; (14) passed - Probably JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 108:11;110:15; 112:1;116:14; 117:11;130:15,22; 131:4;136:2;148:15, 24;149:7;150:17; 152:3,25;155:22; 169:21 probation (31) 19:13;33:5;40:15, 16;48:12,14;49:3; 95:10;104:15,19; 119:3,6,8,13,18; 120:8,9,10,12,14,14, 20;121:3,12;162:3,4; 165:24;166:2; 167:16,17,17 problem (9) 34:2;77:14;136:9; 137:4;142:7;168:2,3, 18;170:1 Problems (1) 168:10 procedures (3) 41:17,21;43:3 proceed (1) 6:6 proceedings (1) 96:11 process (15) 8:21;11:22;29:23; 31:2;34:12,22; 47:20;48:18;81:24; 91:19,23;97:8; 123:10;130:11,13 processes (2) 31:6;132:12 proclaim (1) 140:6 produced (2) 54:17;145:25 prohibitions (1) 136:7 project (3) 11:14;61:20;170:7 promise (1) 132:21 pronounced (1) 74:3 proof (4) 76:21;113:1; 172:9,12 Prop (1) 119:19 properties (1) 37:7 prosecution (1) 159:6 prospective (1) 110:2 protected (1) 80:14 proud (5) 80:13;140:2,2,5,12 Min-U-Script® provide (3) 8:8;120:20;167:7 providing (1) 137:16 provisions (1) 132:1 public (8) 36:10;156:17,24; 160:13,19,20; 162:23,24 pull (2) 45:18;83:15 pulling (1) 29:6 purposes (7) 45:16;70:19;78:1; 93:15;97:8;104:9; 129:19 put (14) 6:21;29:5;30:12; 31:4;34:7,15;70:25; 72:18;106:19; 107:22;142:6; 168:15;172:13; 173:2 puto (1) 57:20 p-u-t-o (1) 57:20 Putos (3) 95:15,18,22 puts (1) 172:17 putting (1) 28:16 Q quantities (1) 110:1 quarter (1) 132:10 queries (2) 89:14,15 query (1) 101:7 quick (6) 116:15;143:8; 148:1,4;173:11; 174:8 quicker (1) 103:15 quickly (1) 6:4 quit (2) 126:5;129:22 quite (6) 51:19;68:11,16; 138:19;171:3,10 quotations (2) 148:21,22 68:12;80:19;106:18; 140:1 receipt (2) 174:24;175:13 ramifications (1) receive (2) 12:16 44:15;175:12 Ramirez (1) received (2) 160:5 47:6;89:15 ran (6) receives (1) 97:7,18;99:8,12; 44:19 100:2;117:12 recent (3) range (2) 152:1;168:6; 169:10,15 171:13 rank (1) Recess (1) 5:21 96:10 rat (1) recognize (1) 79:2 55:20 rather (1) recollection (22) 26:9 48:20;64:24;65:2, reaching (4) 7;66:11;77:17,24; 29:20;49:25;98:4; 78:8;79:5,20,23; 109:12 82:19;86:8;88:1; read (22) 89:1;101:21;103:2; 13:14;16:6;21:7,9, 110:17;114:7,25; 10,13,17;57:16;58:5; 116:1;147:24 82:18;84:1;110:10; record (41) 111:12;144:10; 5:15;6:18;7:12,14; 146:7,14;153:23; 16:6;34:20;39:6; 161:18;167:9,10; 50:5;54:16;56:15,16, 168:4,7 17,18;96:9,12,13; reading (3) 98:12,13,14,15; 12:23;52:8;156:7 101:19;111:6; readings (1) 115:17,22;116:16, 167:9 17,18,19;128:4; ready (1) 137:10,11,12,13; 115:13 146:6,7;147:2; real (5) 157:2;174:7,9,10,11 6:4;27:7;148:4; recorded (1) 173:11;174:7 175:2 realize (2) records (1) 117:16;154:12 111:13 really (9) red (1) 6:10;26:20;59:20; 55:8 69:7;128:18;140:15, redacted (1) 18;155:23;175:5 152:17 realm (1) redaction (1) 164:20 152:17 reason (12) reducing (1) 8:8;39:22;43:24; 33:16 45:25;47:4;55:2; 86:7;113:20;120:24; Reece (1) 83:12 130:9,10;170:17 refer (14) reasonable (1) 5:23;43:5;79:1; 83:25 100:13;101:17; reasons (7) 103:11;107:15,16; 17:5;18:3;31:11; 115:9;143:19;145:1; 45:16;119:18; 152:10;156:21; 120:18;160:16 163:24 recall (22) reference (18) 16:13;30:3;34:10; 54:24;57:2;58:11; 35:9;38:25;39:4,8, 66:4,15;68:15,22,25; 11,17;40:6,23;47:6, 69:1;73:21;75:3; 10;48:14;49:10; 78:18;82:13,14; 52:8,14;62:12; R Barkley Court Reporters 91:1;92:21;94:18; 118:21 referenced (4) 93:25;103:17,21; 169:7 references (4) 54:11;61:10; 88:12;93:19 referencing (3) 50:6;55:5;57:25 referred (6) 20:5;21:3;45:8; 76:6;143:19;157:3 referring (21) 16:5;20:5;32:3; 33:12;55:10;57:16; 58:4,6;70:15;95:12; 98:10;99:5;100:4; 104:17;111:7; 113:15;137:22; 144:23;155:24; 158:10;159:7 reflect (1) 175:4 refresh (3) 98:24;114:7;116:1 regalia (1) 63:25 regard (7) 11:23;38:22;49:7; 52:17;53:9,20; 124:17 regarded (1) 115:5 regarding (12) 21:2;44:20;46:24; 48:10,15;53:17; 100:1,5;105:23; 110:14;111:12; 169:10 regards (3) 53:4;127:15; 169:25 registration (2) 49:15,17 regular (3) 54:8,13;83:5 relate (3) 43:4;114:19; 154:16 related (7) 32:14,15;69:21; 99:1;100:17;161:8; 169:5 relates (1) 41:14 relating (7) 42:11;45:2;49:18; 61:12;98:3;103:3; 115:2 relatives (1) 138:4 released (3) (15) probation - released JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 119:22,25;120:6 Relevance (2) 9:18;122:15 relevant (11) 58:16;87:22,23; 90:19;105:15; 122:12,18;131:8,9, 13,15 relieve (1) 174:18 remain (1) 166:13 remember (18) 40:10,18;46:8; 47:1;52:6;64:17; 65:9;67:17;68:10; 77:14;89:5;93:12, 14;107:25;114:20; 140:1;142:23; 169:21 removal (2) 24:8,10 render (2) 100:14;153:1 rendering (2) 130:11;153:2 re-offending (1) 128:10 repeated (4) 111:22;112:11; 163:10;164:4 repeating (1) 27:3 repercussions (2) 117:4;140:16 rephrase (3) 7:2;124:5,5 report (20) 45:6;103:7; 109:14,22,23; 110:10;151:20; 155:9,19;158:2,9,10; 159:23;161:8,9,19; 165:17,18;166:6; 170:14 reporter (11) 6:7,17,20;7:11; 34:20;123:2,4; 136:21;174:19; 175:19,21 reports (4) 102:25;103:3; 105:21;145:9 represent (1) 5:12 representative (1) 53:12 represents (4) 65:25;66:18,20; 88:13 requested (1) 137:5 requirements (1) Min-U-Script® 45:11 requires (1) 45:25 re-read (3) 30:3;100:3;109:22 research (1) 93:15 researching (1) 62:7 residence (2) 171:24,25 resident (3) 167:22;168:7,25 residential (3) 97:22;99:16;171:9 residents (1) 37:7 resource (1) 51:10 respect (24) 18:4;21:19;25:6,8; 29:14;53:5;54:7,21; 56:4;58:16;66:14; 69:14;96:16;106:8, 15;107:18;110:11; 111:18;114:23; 116:9;117:24; 118:10;168:20; 174:13 response (3) 111:25;120:25; 175:17 responses (1) 152:5 result (3) 56:3;157:12; 158:23 results (5) 43:14;44:7;89:14; 97:7;132:10 retaliations (1) 51:21 reveal (1) 102:1 reverse (1) 101:10 review (17) 10:3,6;41:3;42:8, 21;44:23;49:14; 54:19;55:15;56:20; 100:17,21;140:7; 148:1;161:17; 174:15;175:1 reviewed (4) 10:12;17:14; 42:11;98:2 reviewing (2) 32:9;55:24 rhetoric (1) 84:17 Rhino (2) 143:1;148:20 Rhino' (1) 142:4 Right (67) 13:7;23:7;30:2,7, 13,17;33:19;38:2; 39:9;48:23;50:3; 57:13;58:4;60:15; 61:24;62:3,14; 68:23;70:24;73:7, 22;74:2;76:23;84:8; 88:18;90:8;91:17; 92:2,9;96:7,8;99:18; 100:22;101:3,15; 102:2;103:12; 105:24;106:13; 107:20;109:3;111:1, 2;112:5;119:10; 135:3,5,19;136:23; 139:21;140:8;143:5, 10;144:16,20; 154:13;155:18,22; 157:22;162:7; 164:15;165:16,25; 166:8;170:15; 173:14,18 right-corner (1) 90:11 right-hand (1) 76:18 rights (1) 138:6 ripped (1) 92:19 rituals (1) 138:6 rival (1) 57:14 rivals (2) 51:19,22 road (2) 72:24;121:10 Robert (16) 75:8,12;76:15,17, 20;88:17,21;89:2; 90:1,16,18,18;91:16, 22;92:2,15 Robert's (3) 89:6;91:21;92:4 role (1) 29:4 Roman (9) 75:8,12;76:15,17, 21;88:21;90:16; 92:2,16 Roman's (6) 88:17;89:2;90:1, 18,18;91:16 room (5) 6:8,10,22;13:5; 117:15 row (4) 75:11,20;78:17,21 rub (1) 117:15 screen (1) 66:8 screen-saver (1) 163:5 se (3) 34:21;95:15,17 second (6) 74:24;93:11; 108:15;142:2; 153:13;157:22 secondarily (1) 75:9 secondary (1) 89:17 secondly (1) 132:11 second-to-the-top (1) S 91:12 secreted (1) safety (6) 146:19 37:5;128:15,21; section (2) 172:3;174:1,5 137:20;142:1 sale (2) seeing (15) 109:18;121:25 23:24;24:24;65:7, sales (4) 9;66:11;77:14,17,24; 108:14;110:7; 79:5,20;82:19;86:8; 121:24;158:18 88:1;89:1;168:15 SAMC (1) seem (3) 160:18 76:16;117:7; same (19) 140:10 6:5,16,22;35:18; seemingly (1) 45:14;55:5,11; 126:24 64:15;71:17;77:15, 15;78:21;79:4,19,22; seems (1) 167:18 136:2;145:16; seldom (1) 154:13;160:17 53:3 SANDERSON (1) Self-admitted (2) 143:25 146:9;147:12 Santa (17) self-serving (1) 5:1,18;28:20,25; 60:7 41:3,6;78:24,25; 86:12;101:5;115:23; semantics (1) 138:19 129:1;130:25; send (1) 143:21;160:18; 175:9 167:14;175:10 sense (2) Santana (1) 8:2;82:7 91:11 sent (2) save (1) 174:20,21 116:7 sentence (2) savvy (1) 142:2;148:22 71:24 September (7) saw (2) 5:1;9:15;11:11,11; 62:12;89:5 67:21;108:12; saying (10) 109:10 15:25;18:13;21:6; 90:25;106:7;120:1; Sergio (7) 39:15;40:5;50:16, 146:22;151:6; 20;154:25;155:2,3 164:22,24 serious (1) scenarios (1) 109:7 22:16 serve (2) school (1) 38:19;172:16 138:8 served (4) schooling (1) 86:20;156:23; 164:18 Ruiz (1) 53:16 R-u-i-z (1) 53:16 rules (1) 6:5 run (8) 27:10,12,15;97:9, 14,15;99:9;119:7 running (2) 97:13;101:7 runs (1) 110:1 ruthless (1) 57:19 Barkley Court Reporters (16) Relevance - served JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 172:1,2 service (10) 38:21;86:16,17,19, 22,24;171:23;172:1, 9,12 set (4) 10:25;26:19,23; 166:14 seven (1) 117:11 several (2) 58:23;98:8 shake (1) 7:10 shall (1) 32:13 shared (1) 146:18 sheet (5) 98:7,9;99:4,5; 108:23 shell (1) 57:18 Sheryl (2) 28:23;32:5 S-h-e-r-y-l (1) 28:23 shift (2) 117:9,10 shin (1) 111:2 shirt (7) 59:14,15,23; 63:22;92:19;170:23; 171:3 shirts (1) 66:16 shock (1) 36:2 shocking (1) 15:11 shorts (1) 117:22 shot (1) 66:8 show (2) 90:21;92:6 showing (1) 146:5 shows (3) 26:18;169:2,4 shy (1) 51:8 siblings (1) 138:4 sic (2) 67:22;68:23 side (12) 12:20;18:14;55:8; 57:13,19;74:10; 76:16,18;90:10; 126:1;148:9;151:3 sidewalk (3) Min-U-Script® 161:5;162:2,17 sidewalks (1) 37:2 sightings (1) 20:2 sign (1) 80:25 significance (2) 93:12,14 significant (10) 12:18;13:8; 107:17;128:8; 133:12,15,22,25; 134:8;138:18 significantly (1) 32:8 Similar (4) 45:7;121:9;152:4, 5 simplest (1) 31:4 single (2) 52:24;66:9 sit (4) 76:23;101:15; 119:10;155:22 site (6) 77:9,11,18,25; 92:3,5 sites (1) 77:16 sitting (3) 33:19;101:3;109:2 situation (7) 21:11;22:10;24:1; 25:23,24;26:14;27:5 situations (3) 18:3;22:16;24:18 six (12) 24:22;67:13,13,23, 25;68:3,6,12,15; 139:8,9;142:20 Sixteen (1) 115:21 size (2) 17:4;171:18 slightly (1) 31:22 slowly (1) 51:16 small (2) 121:13;128:25 smaller (2) 31:8;110:1 smoking (1) 36:9 social (12) 50:25;51:9;52:24; 53:6,8,18;54:7,8,13; 58:2;77:2;106:6 socks (1) 117:22 sold (1) 116:24 sole (1) 131:10 somebody (25) 22:6,8;24:16; 31:24,25;34:25; 35:7;45:12;50:24; 72:10,13,18;73:5; 74:12;82:7;83:11, 25;84:2;89:18; 110:1;119:8;127:18; 139:7;154:5,22 somebody's (1) 72:25 someone (10) 20:18;21:5,23; 24:16,18;27:1,13,14; 133:24;149:5 someone's (5) 18:20;126:19; 128:3;133:6,21 someplace (1) 82:9 sometime (3) 67:11;86:15;97:14 sometimes (9) 26:9;36:2;45:8,18; 51:20;136:9;151:19; 172:25;173:1 somewhere (3) 52:16;72:24; 172:15 son (13) 59:13;60:1;61:3,6, 8,18,23;62:2,6,13, 13;63:3;111:1 son's (1) 62:17 sorry (28) 12:10;27:2;34:17; 43:25;46:15;60:8; 74:18,20;75:20; 79:9;88:25;90:4; 121:1;122:10; 128:13;133:19; 140:21;143:15; 144:23;145:14; 157:1,4;159:12; 161:7,20;172:10; 173:3,7 sort (3) 41:24;73:21;121:4 sound (1) 155:4 source (1) 35:4 sources (1) 37:19 South (6) 39:21;80:7; 108:14;165:11; 171:8,15 span (1) 133:21 Spanish (1) 95:24 speak (2) 46:7;95:24 speaking (2) 51:16;121:21 specific (38) 21:10;26:6;34:10; 37:11;43:8;45:7,24; 46:2;48:20;63:19; 64:24;65:2,7;66:1, 11;77:17,24;79:5,19, 23;82:19;86:8;88:1; 89:1;103:2;105:19; 109:23;110:17; 112:20;117:1,2; 118:17;129:25; 132:8;156:15; 168:24,25;169:6 specifically (19) 9:8;27:8,11;28:11; 35:13;39:1;47:1; 49:6;52:14;60:16; 62:12;70:5;92:1,16; 106:19,23;115:3; 127:11;132:23 specifics (1) 47:10 spell (1) 5:14 spelling (1) 54:3 spending (2) 15:6,21 spiel (1) 95:16 spoke (4) 22:21;46:23; 48:14;134:12 spoken (1) 48:12 sports (1) 63:25 square (1) 90:11 stairwells (1) 35:17 stale (1) 170:7 stamp (6) 106:4;148:6; 149:2;157:7;158:7; 161:22 stamped (3) 54:18;105:24; 145:24 standard (1) 136:14 standing (2) 108:24;172:15 star (4) 69:25;87:3;89:24, Barkley Court Reporters 25 start (7) 31:8;67:19;68:6; 94:6;96:14;152:14; 155:5 started (4) 11:14;31:8;35:9; 47:17 starting (2) 144:5;151:22 state (4) 5:14;130:21; 141:17;159:17 stated (5) 19:25;137:21; 138:11,23;142:3 statement (15) 36:2,15;69:4; 70:18,20;138:16; 146:5,6;147:13; 148:9,11;149:3,14; 150:9;160:14 statements (15) 14:17;15:12,18; 19:2;20:8,13,22,23; 25:7;97:22;99:16; 133:18;139:2,15; 141:2 stats (1) 132:10 status (3) 23:13,21;25:3 STEP (43) 45:9,13,20,24; 102:25;103:8,21; 104:20;105:21; 115:4;138:21,23; 139:3;140:24;145:7, 10,13,14,19,20,21, 22;146:21;147:18, 23;148:17;150:20; 151:19,20;152:1,3; 155:15;156:22; 157:3,6;159:17; 161:18;163:6; 164:25;169:20; 173:7,8,10 stereotypes (2) 117:14,17 stereotypical (1) 117:22 still (22) 8:2;26:2;35:6; 75:17;92:20;119:5, 23;122:13;125:22, 23;126:22;127:13; 148:16;151:1,7; 153:2,14;154:10; 156:3;163:21; 166:25;171:7 stipulated (4) 174:17,18;175:19, 20 (17) service - stipulated JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG stoned (1) 94:11 Stop (17) 46:9,10,12,15,15, 16,17,19,24;47:19; 48:2,9;49:2;80:25; 118:6;167:14; 172:16 S-t-o-p (1) 46:11 Stopp (6) 68:23;69:2,17; 71:14;73:4,20 stopped (1) 164:8 stores (1) 116:25 straightforward (1) 140:2 Street (175) 8:20;10:7,19; 12:15;18:5,8,9,15; 19:24;21:19;22:19; 24:5;26:6;27:11,13; 28:11,13;29:15,24; 30:2,11,17;33:6; 34:13;35:13,15,18, 21;39:21;41:2,15; 42:7;44:23;46:5,13, 21;48:4;49:5,14,21; 51:2;56:5,10;57:4, 11,14;58:15;59:1,16; 60:5;63:24;64:1; 65:15,23;66:5,15,17, 23;67:2,6;68:21; 69:14;70:5;71:20; 74:7,23;75:1,3,5,6, 16,22;76:3,7,10,23; 79:1,16;80:5,8,13, 14;81:21;82:5,23; 84:15,19;86:3; 87:18;90:14,20; 91:12,20;93:4;97:3, 21;98:5;99:3,15; 100:19;102:6,19; 104:23;105:16; 107:19;108:8,14; 111:19,23;112:12, 18;114:4,24;115:6; 116:3,12;118:21; 120:16,22;121:15; 123:21;124:9,23; 125:4;126:7,15,20; 128:14,17;131:6,18; 134:10,18,23; 137:21;138:12,14, 15,24;139:24;144:2, 6;148:23;150:2,11; 151:5;152:19; 153:14,20;154:11; 156:17;158:20,21; 159:13;160:6,7; 161:1,6;162:4,19; Min-U-Script® 163:16,23;164:5,7; 165:6,7,10,11; 168:10,21,23,25; 170:21;171:5;174:4 streets (1) 37:2 Strike (3) 44:10;77:22; 128:13 Strippers (1) 69:20 strongly (2) 47:10,14 structure (6) 17:2,20,25;23:13; 24:8;25:15 structures (1) 21:17 studied (3) 17:13;21:3;100:3 stuff (11) 51:7,12;52:23; 71:25;76:14;77:3, 19;85:17;104:20; 106:6;169:21 stupendous (1) 132:10 style (5) 116:24,24;117:6, 10;118:9 styles (1) 116:21 subculture (1) 94:19 subject (3) 15:12;132:1; 167:20 submitted (2) 28:13;113:21 subpoena (1) 130:24 substance (1) 158:14 substantive (1) 175:3 sudden (1) 23:15 suggesting (1) 114:2 summarized (2) 102:22;103:4 summary (4) 102:16;137:20; 144:23;154:8 summer (3) 100:10,10,17 sunglasses (8) 59:8,19,22;60:2,3, 18,20,23 sunny (1) 60:22 supervise (1) 27:15 supervised (1) 120:11 supervision (1) 33:8 supervisions (1) 119:22 supervisor (1) 27:14 supervisors (1) 33:5 support (3) 37:13;105:4; 113:21 supporting (3) 125:12;127:6,25 supports (3) 36:18;126:13; 156:19 suppression (2) 46:13,22 sure (38) 6:17;7:13;13:4; 16:4,20;23:6;40:13; 53:13;55:4;57:23; 61:8,21;63:1;70:9; 74:11,13;76:17,24, 25;77:1,19,20;89:4; 106:17;108:10; 115:10;117:3; 129:22;135:12; 137:1;147:6,24; 148:5;155:15,16; 161:21;165:21; 170:11 surprising (1) 170:1 survey (3) 166:22;169:1,24 surveys (1) 169:10 Susan (3) 9:9;169:9;174:23 suspect (4) 40:2;47:11,14; 66:9 sway (1) 164:13 swing (2) 132:13,16 sworn (1) 5:5 synonymous (1) 52:20 system (3) 19:12;119:25; 120:12 systems (1) 119:20 T T' (1) 92:20 Taco (1) 96:1 talk (23) 6:11;9:3,6,12,16; 15:10;18:4,16; 27:11;28:11;39:3; 47:24;51:20;112:23; 113:5;115:5;118:6; 132:22;167:4,12,14, 16,19 talked (10) 87:21;110:18; 114:9;133:3;135:1; 166:6;173:15,16,20, 22 talking (23) 13:23;14:17,20; 17:22;18:19;32:23; 37:23;43:5;45:17; 47:19;48:1,1;49:6; 95:9;101:24;121:22; 135:13;150:13; 154:15;156:16; 158:8;161:21; 173:12 Target (6) 41:4,7,9,14,25; 42:4 targeted (3) 41:11,12,13 tattoo (7) 22:20;62:15,16,22, 23;63:4;143:1 tattoos (9) 110:21,24;111:12, 14,15,17;173:16,17, 17 TC (3) 66:12;68:2,7 Td (1) 87:13 T'd (3) 78:18;88:13,13 team (4) 46:9,13,24;48:2 techie (1) 71:25 Telesforo (1) 111:2 T-e-l-e-s-f-o-r-o (1) 111:2 telling (3) 14:15;22:8;139:19 tells (3) 147:3;157:18; 159:22 ten (1) 68:14 tend (2) 118:17;129:20 term (9) 20:17;46:19;52:4, 13,14,18;93:23; Barkley Court Reporters 95:22;141:15 terminated (2) 119:17;120:6 termination (1) 119:9 terminology (1) 135:4 terms (1) 162:3 testified (11) 5:5;17:19;25:8; 84:24;122:4;127:14; 129:8,24;130:5,19; 134:12 testify (4) 17:19;27:22; 130:23;155:17 testifying (4) 6:23;18:22;21:8; 167:6 testimony (19) 7:3;8:9,12,15; 18:8;23:5,5;25:6; 28:1;59:24;61:22; 70:2;100:12,14; 129:20;130:1,12,17; 137:16 theoretically (1) 72:7 thereabouts (1) 11:10 therefore (1) 26:17 thinking (2) 62:14;145:9 third (2) 93:22;95:13 Thirty-two (1) 37:16 though (9) 6:21;18:1;58:1; 69:18;82:5;139:13; 143:8;163:20; 166:17 thought (5) 31:7;71:15;81:23; 91:23;94:24 three (11) 39:20;70:11,23; 104:7,11;105:7; 114:16;137:22; 138:25;146:9; 147:12 three-quarters (1) 75:11 three-year (1) 104:8 threshold (1) 139:10 throw (2) 20:22;51:9 Thug (2) 90:24;91:1 (18) stoned - Thug JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG thumbprint (3) 142:8,9;143:10 thumbprints (1) 143:9 Thursday (1) 9:14 thus (1) 92:7 ties (1) 116:21 timeframe (5) 23:19;97:14; 100:9;105:5,9 timeframes (4) 29:19;78:3,3; 89:19 times (14) 17:24;42:19; 118:1;123:9;129:12, 23,24;130:3,4,6; 151:18;152:1;153:4; 163:19 today (32) 7:3;8:9,12,15,18; 9:4;10:4;18:22; 19:11,18;21:8; 55:25;96:20;97:4, 21;98:5;99:3,15,22; 101:24;108:8; 117:20;118:2; 119:14;120:16; 121:15;124:10; 125:4;143:4;153:2, 20;159:1 together (9) 15:13,18;20:9; 28:16;29:5;35:25; 37:4;134:13;135:21 told (7) 14:1,6;47:11,14; 53:23;112:14;113:2 ton (2) 119:21;169:21 took (4) 56:19;67:18; 100:5;170:10 tool (2) 51:10;132:20 top (11) 39:2;58:6;68:22; 71:13;72:16;73:4; 90:10;107:22;144:1; 153:12;172:11 totality (8) 26:24;52:25;53:2; 60:13;108:2;126:18; 127:2;128:2 towards (2) 92:15,21 town (1) 57:19 Townero (8) 75:2,18,21,24; Min-U-Script® 76:5,6,9;90:3 Townsend (179) 8:20;10:7,19;18:5, 8,9,15;19:23;21:19; 26:6;27:11,13;28:11, 13;29:15,23;30:2,11, 17;33:6;35:13,21; 39:21;41:2,15;42:7; 44:23;46:5;48:4; 49:5,14,21;51:2; 56:5,10;57:4,10,14, 19;58:15;59:1,16; 60:4;63:24;64:1; 65:14,23;66:5,15,17, 19,21,22;67:2,6; 68:21;69:14;70:5; 71:20;74:7,23;75:1, 3,4,6,15,22;76:3,7, 10,23;78:19;79:1,16; 80:5,7,7,8,13;81:21; 82:5,13,14,17,23; 84:15,19;86:3; 87:18;88:14;89:24; 90:14,20;91:12,20; 93:4,14;97:3,21; 98:5;99:2,15; 100:19;102:6,19; 104:22;105:16; 107:19;108:7,14; 111:19,22;112:11, 18;114:4,24;115:6; 116:2,12;118:21; 120:16,22;121:15; 123:21;124:9,23; 125:4;126:7,15,20; 128:14,17;131:6,17; 132:8;137:21; 138:12,14,15,24; 139:24;142:3;144:2, 6;146:15;148:20,23; 150:2,2,11;151:5; 152:18;153:14,20; 154:11;158:20,20; 159:13;160:6,7,25; 162:4,19,24,25; 163:4,16,22;165:6,7, 10,11;168:21,23,24; 170:21;171:4,8,16 track (2) 100:15;170:10 traffic (1) 161:5 train (1) 17:8 trained (1) 44:11 training (5) 44:14,19;52:11; 110:5;112:13 transcript (8) 55:4;96:23; 136:22;174:20,25; 175:1,7,11 travel (3) 15:3;125:1;127:7 trespass (2) 150:8;170:19 Trespassing (3) 37:1,7;150:1 trial (1) 175:5 trucks (1) 35:16 trusted (1) 138:9 truth (1) 139:19 truthful (1) 8:9 trying (14) 7:13;23:1;38:10; 63:1;73:8;83:3; 84:25;91:18;93:12; 95:14;116:6;127:24; 141:10;142:23 T-shirt (2) 60:2;170:25 Tuesday (1) 5:1 turn (3) 27:25;143:18; 145:10 turned (1) 36:22 turning (1) 167:4 turtle (1) 57:19 Turtles (1) 57:18 twin (11) 39:2,14;40:5;66:3; 79:14;114:14,25; 118:20;148:22; 154:14;162:4 twins (1) 142:7 two (26) 39:20;48:25; 63:14,22;70:11; 73:3;78:22;95:6; 110:4;123:9;125:1, 2;126:14;127:6; 135:1;141:7;157:4; 160:1,1;162:19; 171:15;172:10,24; 174:24;175:9,13 two-page (2) 108:23;109:6 type (5) 32:18;45:21; 47:16;83:2;159:3 typed (6) 60:10;98:7,17; 99:4;108:23;137:15 types (2) 19:9;119:22 typically (7) 117:1;138:3,4; 139:13;147:1; 166:16,18 typing (1) 29:8 typo (2) 154:22;155:6 typos (1) 175:6 U Uber (1) 91:11 ultimate (1) 33:21 ultimately (2) 43:14;44:7 unaware (1) 111:4 under (17) 6:20,21;33:8;34:3; 58:20;70:24;75:2; 89:8,17,17;128:5; 137:19;146:4; 154:12;157:24; 158:9;174:19 underage (1) 36:10 underneath (1) 58:5 understands (1) 146:16 Understood (3) 6:25;7:6;17:18 unethical (1) 131:25 unfortunately (1) 129:1 uninformed (1) 72:1 unit (6) 95:10,19;110:15; 131:3;167:5;169:19 units (2) 95:14,14 unless (7) 41:23;70:23;72:8, 14;118:6;136:5; 154:19 up (37) 21:4;41:18;46:21; 52:6;53:22;63:25; 64:23;71:1;77:19; 78:18,18;84:25; 87:13;88:13,13; 89:16,17;94:19,19; 98:7,17;99:4;100:7, 8,11;121:24;137:15; 138:8;151:2;153:2, 23;159:1,19;162:19; Barkley Court Reporters 166:19;170:11; 172:21 update (2) 170:4,5 updated (2) 170:5,6 upper (1) 89:23 use (20) 14:2;19:1;42:17; 44:17;45:15;51:19; 55:10;70:3;121:13, 24,25;134:3,3,7; 141:11,13,14; 146:20;150:22; 151:8 used (2) 118:8;129:21 useless (1) 120:10 uses (1) 93:24 using (5) 21:24;68:15; 121:12;142:25; 145:16 uss (2) 95:15,20 usually (9) 36:1,15,16;37:14; 109:25;121:4; 139:15,16;140:1 V vacuum (1) 113:3 vandalism (2) 121:20,21 vandalizing (1) 36:12 variance (1) 78:4 various (6) 35:20;51:15,15; 66:16;97:8;119:22 vato (1) 118:5 vehicle (1) 161:5 vehicles (1) 42:19 verbalize (1) 7:9 verbally (1) 34:20 verbatim (15) 146:22;147:2,3,8, 10,13,16;148:10,15, 18,19,24;149:4,7; 150:9 verbiage (1) 57:12 (19) thumbprint - verbiage JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG verified (1) 171:21 verify (1) 96:18 versa (1) 88:20 versus (2) 17:17;54:9 vertical (1) 71:17 vice (1) 88:20 victims (1) 45:16 Villa (1) 91:14 violating (1) 136:6 violation (7) 136:5;150:8; 160:17,25;165:24; 166:3;170:19 visible (2) 25:14;132:6 Vista (1) 80:7 voir (1) 143:13 wear (2) 116:21;118:17 wearing (18) 32:21;59:7,14; 60:2,2;64:11;66:23, 25;114:6;116:10; 118:12;150:2; 162:24;163:1; 165:11;170:23,23,25 wears (2) 113:18,19 web (8) 52:18;66:8;67:8, 16,21;68:7;69:23; 70:21 web-banging (1) 54:13 website (9) 64:20;67:8;68:2,8; 83:20;90:18,18; 91:16,21 websites (4) 51:1;53:6,9,18 weeks (3) 174:24;175:9,13 weigh (15) 21:25;22:11; 26:24;34:6;108:6, 20;117:24;121:14; 127:3,9,22,25;128:1, W 22,24 weighed (3) wait (1) 27:22;28:7;127:17 87:3 weighing (1) Waiting (1) 108:22 94:5 weight (8) walk (2) 22:7;34:7;81:6; 137:24;138:3 126:23;127:5,14; walked (4) 165:4;168:15 137:21;138:12,17, weighted (1) 24 164:13 walking (2) weren't (3) 138:1,20 31:23;34:21;38:1 wall (3) west (4) 82:9,11,22 39:20;168:8; watching (1) 171:21;172:19 40:3 what's (22) way (30) 54:25;82:14; 21:25;31:4;43:6; 84:11;85:24;87:6; 58:2,22;70:10; 88:6;89:20;90:23; 75:12;92:20;93:22; 94:23;100:4;102:21; 96:4;103:4;104:24; 103:16;130:10; 113:9;114:2;117:20; 138:1;144:22;145:4; 119:24;120:15; 146:17;148:25; 121:7,14,24;125:16; 150:6;159:8;161:4; 130:16;133:5;147:5, 165:8 6;148:24;149:6; Whenever (2) 154:22;164:17; 68:4;134:9 168:17 Whereas (1) ways (3) 34:11 19:25;35:10; Whereupon (3) 107:13 56:22;96:24;98:19 weapons (1) whole (5) 51:18 Min-U-Script® 15:25;30:3;52:22; 78:2;100:21 who's (5) 22:17;107:9,9; 118:4;171:18 whose (1) 39:14 wid (3) 94:5;95:15,20 willingness (1) 27:21 within (14) 17:7,25;23:13; 24:22,23;25:3,14,14; 61:14;129:3;158:19; 174:24;175:9,13 without (8) 42:2;76:19,21; 90:25;101:6;128:9; 152:3;164:22 witness (13) 9:1,20;11:4;50:5, 10;54:16;85:1; 98:11;122:10; 123:17;129:8; 131:14;144:3 wondering (2) 37:11;103:15 word (4) 13:13;82:16; 141:14;175:12 wording (2) 141:11,13 words (3) 26:25;44:17;141:1 work (9) 11:23;27:25; 46:21;72:3;127:8; 133:22;167:5,13,19 worked (7) 110:15;121:19; 124:7,18,21,25; 130:25 working (4) 55:11;125:21; 134:22;167:21 works (3) 58:3;69:19;123:19 worn (1) 117:2 worst (4) 31:9,9;41:11,11 wrap (1) 170:11 write (5) 45:19;51:16; 100:8,11;136:25 writing (5) 13:14;16:15; 69:12;145:5;146:22 writings (3) 17:13;21:2;96:19 written (15) 12:23;16:6;27:8; 43:15;82:22;96:15; 103:16;144:24; 147:5,7;148:24; 149:6,20;159:23; 165:18 wrong (3) 23:5;63:1;99:7 wrote (8) 13:4;16:7;69:16; 100:7;102:15; 136:10;156:7; 166:24 X Xerox (1) 143:11 Y year (5) 11:10;24:23;89:9, 10;97:10 Years (24) 11:15,16;37:16; 39:20;48:25;104:7, 11;105:7;116:23; 117:9,11;121:19; 131:1,2,4;137:22; 138:9;139:1,1; 146:10;147:11,13; 162:20;166:19 young (2) 116:25;171:11 younger (5) 40:24;151:1; 164:19;166:7,10 Z zero (2) 70:10;130:9 zeros (1) 149:25 zone (5) 128:15,21;172:3; 174:2,5 Zuniga (2) 110:14,18 0 0000144 (1) 154:1 0000146 (1) 153:10 000016 (1) 145:24 000018 (2) 148:6,16 000022 (1) 149:2 Barkley Court Reporters 000024 (1) 149:12 000026 (1) 149:24 000028 (1) 150:8 000030 (1) 151:22 000069 (1) 158:9 000092 (1) 152:10 000108 (2) 54:18;58:24 00143 (1) 54:19 05 (5) 105:8;145:9; 152:25;166:11; 173:9 0743317 (1) 161:13 09 (2) 103:22;145:10 1 1 (11) 46:15,16,17;56:21, 22;57:1;105:24; 106:4;140:7;158:9; 171:16 1:26 (1) 116:17 1:32 (1) 116:18 1:59 (1) 137:11 10:45 (1) 56:16 10:59 (1) 56:17 10-33 (2) 160:17,18 104 (3) 143:19,23;144:5 105 (6) 144:11;156:2,3; 163:25;173:11,13 10-7-05 (1) 150:7 108 (1) 57:5 109 (1) 119:19 10th (1) 9:15 11:56 (1) 96:10 110 (3) 59:6;64:19,25 11-09-07 (2) 148:3;160:23 (20) verified - 11-09-07 JEFF LAUNI, EXPERT September 15, 2015 THE PEOPLE OF THE STATE OF CALIFORNIA v. TOWNSEND STREET CRIMINAL STREET GANG 111 (5) 63:11,11;65:3,10, 12 11-13-07 (2) 154:8,9 11-20-07 (1) 154:3 11-22-07 (1) 154:1 113 (4) 65:20,21;68:2,8 115 (2) 68:18;70:15 117 (5) 71:7,8,10;77:21,25 118 (2) 74:15;78:11 1-18-13 (1) 151:25 119 (1) 78:12 12 (2) 119:3;159:12 12:48 (1) 96:12 12:52 (1) 98:13 12:57 (1) 98:14 120 (1) 79:11 121 (1) 80:2 122 (1) 81:18 1-22-07 (2) 149:1;162:16 12-27804 (1) 108:18 123 (1) 84:12 124 (1) 85:25 125 (2) 87:7,8 127 (1) 88:7 129 (1) 89:21 12th (1) 92:24 13 (1) 160:5 130 (1) 90:24 131 (1) 91:9 135 (1) 92:9 136 (1) 92:14 138 (1) 93:7 Min-U-Script® 139 (1) 93:18 140 (1) 94:3 141 (1) 94:24 142 (3) 95:4,7,8 143 (2) 95:7;96:7 145 (1) 115:18 146 (2) 153:10;154:10 15 (3) 5:1;94:6;146:11 16 (4) 101:16;115:16; 160:12;171:13 17th (1) 89:9 18 (6) 148:7,8,9;161:2, 22;168:10 19 (4) 108:12;109:10; 148:7,8 193 (4) 105:24;106:4; 140:7;145:24 2 2 (16) 46:9,10,12,15,19, 24;47:19;48:2,9; 49:2;96:23,24; 132:24;133:11; 136:11;167:14 2:11 (1) 137:12 20 (5) 146:13,14;148:17; 161:25,25 200 (11) 30:6,20,24;31:5, 15,19;32:10;33:2,17; 47:20;106:20 2004 (1) 143:22 2005 (2) 104:16,24 2012 (8) 58:9,10,20,21; 92:24;96:3;108:12; 109:10 2013 (16) 11:13;85:23; 97:10,11,16,19; 99:10,13;100:22; 101:16;122:4,5; 157:25;166:24; 171:13;173:8 2014 (6) 11:12,15,16; 67:22;70:16;89:11 2015 (4) 5:1;11:11;100:10, 17 2016 (1) 119:3 20s (1) 166:19 22 (1) 162:16 24 (5) 8:11,14;124:18; 162:22,22 240 (1) 106:10 25 (3) 121:19;131:4; 163:15 2510 (1) 172:19 26 (3) 149:23;165:9; 170:12 27 (1) 144:5 28 (3) 150:8;170:15; 173:5 29 (16) 30:10,12,16;33:21, 23;34:8;37:23;38:9, 12;47:21;96:3; 103:22;106:10; 126:8;131:1;145:10 2nd (3) 58:9,10,19 2Pac (1) 91:1 3 3 (21) 98:18,19;99:5; 100:4,8;101:9; 102:15;103:5,16; 104:6,7,14;105:7; 108:5,16;111:8; 119:2;137:15; 144:24;145:4,6 3:06 (1) 174:9 3:09 (1) 174:10 3:11 (2) 5:2;175:24 30 (2) 131:2;146:14 300 (1) 129:23 3-12-16 (1) 104:15 3-29-09 (2) 103:8;160:13 3rd (1) 58:21 9-2-08 (1) 110:25 99 (1) 168:25 4 40 (21) 29:25;30:5,9,11, 21;31:11,19;32:10, 12,13;33:2,17,20,23; 34:8;37:23;38:9; 47:20,21;106:10,20 4-15-06 (2) 149:11;162:22 4-22-05 (2) 149:22;165:9 47 (1) 119:19 4th (1) 143:22 5 50 (5) 129:15,16,23; 130:3,4 5-23-13 (1) 142:1 5-28-13 (2) 141:17;156:25 7 7-09-07 (1) 161:25 7-1 (1) 70:16 7-16-13 (2) 137:19;156:23 7-9-07 (1) 148:17 8 8 (1) 147:11 800 (3) 39:21;80:7;171:8 805 (3) 108:14;165:11; 171:15 9 9:26 (1) 5:2 90 (1) 165:23 9-19-12 (1) 108:16 92 (1) 166:9 Barkley Court Reporters (21) 111 - 99