36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside :2995 Hwy 111, Ste. 101 India, California MICHAEL A. HESTRIN FILED DiStriCt Attorney Superior Court of California County of Riverside county 0f RiverS'de 2126/2015 82995 Hwy 111, Ste. 101 agarcia1 Indio, California 92201 By Fax Telephone (760) 863?82 1 6 Kirsten Seebart, Deputy District Attorney State Bar No. 209690; kseebart@rivcoda.org SUPERIOR COURT OF CALIFORNIA COUNTY OF RIVERSIDE (Indio) PSC 1 60091 7 THE PEOPLE OF THE STATE OF CALIFORNIA, Case No. ex rel. MICHAEL HESTRIN as the District Attorney SUPPLEMENTAL for the County of Riverside, DECLARATION OF DEPUTY CLAUDIA HERRERA IN SUPPORT Plaintiff, 0F EX PARTE APPLICATION FOR AN ORDER TO SHOW CAUSE RE: PRELIMINARY INJUNCTION VARRIO COACHELLA RIFA CRIMINAL STREET GANG, an unincorporated association, Assigned for all purposes to the 3M Honorable Defendant. I, Claudia Herrera declare: 1. I am the School Resource Of?cer (SRO) for Coachella Valley High School I have been assigned to this position since March 2012. DECLARATION OF DEPUTY CLAUDIA HERRERA IN SUPPORT OF EX PARTE APPLICATION FOR AN ORDER TO SHOW CAUSE RE: PRELIMINARY INJUNCTION 000738 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside 82995 Hwy [11, Ste. Indie, California brie?ngs that suspects I would later contact had a gang background or prior law enforcement 2. I am, and have been, a sworn full-time peace of?cer in the State of California for 9.5 years and have been employed with the Riverside County Sheriff?s Department since November 2005. 3. Prior to my assignment as an SRO, I was assigned to the Indio Jail for a year. I spent three years working patrol operations where I was assigned as Field Training Of?cer (FTO). I was assigned to the La Quinta Special Enforcement Team for 2.5 years. 4. During my tenure assigned to patrol and serving as an FTO, I worked the Eastern Riverside County Regions of Salton Sea, Thermal, Mecca, Coachella, and the City of La Quinta. I was routinely assigned patrol in the City of Coachella. During my time on Coachella patrol, I became familiar with the VCR, or Vanio Coachella Rifa, criminal street gang and several of its subsets, including Avenue 52, Avenue 53, CTL, and the 50 Boys via patrol brie?ngs, crime analysis bolo ?iers, graf?ti throughout the city, and search warrant brie?ngs. Prior to being assigned to CVHS as the SRO, Ihandled numerous calls and criminal investigations related to criminal?street gang activity in the Coachella area. During those calls, I contacted VCR gang members and associates while assisting on a homicide investigation involving a deceased male juvenile on a bicycle near Boys and Girls Club. I have contacted gang members while conducting pedestrian checks, during traf?c stops, at loud music/party calls and while assisting special teams on executing search warrants. Some of the gang members self-admitted their gang membership. Some gang members were identi?able by tattoos. I have been informed on many occasions during search warrant contacts. 5. In addition to my experience in the ?eld, I have also received education and training related to criminal street gang activity in the Coachella Valley from deputies and supervisors more knowledgeable than myself. I learned about gangs in the police academy, the 40-hour School Resource Of?cer Class, in patrol brie?ngs, from crime analysis bolos, and from my training of?cers, senior deputies and patrol supervisors. While working as a deputy on the La Quinta Special Enforcement Team, the team assisted the City of Coachella on several occasions in arrest warrant Sweep Operations. I learned about and came in contact with gang members gang activity in the city at that time as well. 6. Over the past three years, I have been responsible for the safety and law enforcement component on the campus of CVHS. During this time, I have witnessed enough aggregate activity leading to my opinion of active gang-related activity on campus. This includes, but is not limited to, the information outlined below. DECLARATION OF DEPUTY CLAUDIA HERRERA IN SUPPORT OF EX PARTE APPLICATION FOR AN ORDER TO SHOW CAUSE RE: PRELIMINARY INJUNCTION 000739 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside 82995 Hwy Ill, Ste. lndio, California 10] 7. CVHS is physically located at 83800 Airport Blvd., Thermal, California, in the County of Riverside. CVHS is geographically isolated from parks and commercial areas. It is situated in and surrounded by an agricultural/industrial zone. Because of this geographical situation, CVHS students come from several different areas and neighborhoods. The majority reside in the City of Coachella. Some live in the surrounding Thermal area and a few come from Indio. Although most students are from the City of Coachella, a different neighborhood means a different gang af?liation. I have contacted and interviewed students responsible for tagging the campus with ?53? and along with their gang moniker. One student self-admitted to being a member of CTL, or ?Coachella Tiny Locos.? CVHS students associate and co-exist despite any gang differences while on-campus. They will also band together in opposition of anythin related to Indio or Indio-based gangs. CVHS and Indio High School students have been rivals for decades. In addition, Coachella gangs and Indio gangs are also long-standing rivals. 8. Every year, CVHS and Indio High School compete against each other in a football game. This is commonly referred to as the ?Bell Game.? Because of the intense rivalry between Indio and CVHS, this yearly football game between the two schools requires additional resources to keep the event safe. Both Coachella Valley Uni?ed School District and Desert Sands Uni?ed School District participate in additional security planning and staf?ng. I have received intelligence from various sources of potential gang ?ghts and planned shootings at football games. When this kind of intelligence is received, the Riverside County Sheriff?s Department is required to staff extra sworn deputies. My duties and responsibilities include coordinating the extra law enforcement staf?ng with the Indie Police Department for that speci?c football game. No other football game at Coachella Valley High School requires as much extra security as the Bell Game. 9. Since my assignment began at CVHS in 2012, I have seen school property spray-painted with gang graf?ti on numerous occasions. I have repeatedly seen the numbers ?5 2? or ?53? tagged at the school along with individual gang monikers. Crucial resources such as staff time, school district funds, and Riverside County Sheriff?s criminal investigation resources must be used to identify and prosecute vandals. I have contacted and interviewed CVHS students who have admitted they are responsible for the gang graf?ti and vandalism of school property on multiple occasions. 10. Since 2012, I have had the opportunity to observe the social media pages of CVHS students on countless occasions. I have observed CVHS students throwing up gang hand signs speci?c to VCR and its subsets. I have seen students use the hand-number combinations of ?52? and ?53? as well as and DECLARATION OF DEPUTY CLAUDIA HERRERA IN SUPPORT OF EX PARTE APPLICATION FOR AN ORDER TO SHOW CAUSE RE: PRELIMINARY INJUNCTION 000740 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside 82995 Hwy Ill, Ste. 10] India, California 11. As part of my duties at CVHS, I have investigated ?ghts on campus that have ranged from mutual assaults to two or three-against one physical assaults. I have investigated ?ghts involving student-suspects identifying themselves with ?Coachella? as they confront new students from Indio. I speci?cally investigated an assault on a new student who identi?ed himself from ?Penn West? in Indio. On one occasion, dean of students was threatened by a student and member, stating they were going to come after him. 12. I have investigated ?ghts involving male students that display criminal sophistication. I have seen a group of males students try to out number other students in confrontations and ?ghts to establish physical authority, gain superiority and/or intimidate others, as is a common gang behavior. During criminal investigations, identifying their gang af?liation or alliances has been dif?cult because involved students will routinely tell me they will not ?snitch? on others and have been taught to disassociate themselves from identi?ed gangs and to refuse to provide law enforcement with assistance of information of any kind. 13. Daily social interaction is important to CVHS students. A unique characteristic of CVHS is that the high school and its property is their ?zone? - where students interact and socialize. Again, geographically, the high school is situated on Airport Blvd. between Van Buren and Calhoun Street in Thermal. The nearest fast food restaurant, gas station, and] or park is over two miles away. Most CVHS students are given rides or bussed to school. They do not leave campus because there is nowhere for them to loiter nearby. Students who have admitted to criminal activity occurring away from campus have also told me they will be respectful on campus speci?cally to avoid suspension by the school district. The students do not want to impede their ability to meet on campus to socialize by being suspended from school. This has created some intelligence-gathering dif?culties as the involved ?52? ?5 3? students will not wear identi?able gang-related attire and will not congregate or provide outward clues to their gang af?liation. Again, this displays a level of sophistication that does not occur at other high schools. During my time as an SRO, I have taken several classes on school violence. I also communicate with other SROs at other schools. I know that many other high schools with gang problems are still dealing with gang-related attire, as well as graf?ti and assaults on a regular basis. When I compare CVHS to other high schools, I believe that there is a strong gang presence and undercurrent at play but that it is more cleverly disguised than in other schools with similar gang problems. DECLARATION OF DEPUTY CLAUDIA HERRERA IN SUPPORT OF EX PARTE APPLICATION FOR AN ORDER TO SHOW CAUSE RE: PRELIMINARY INJUNCTION 000741 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside 82995 Hwy 111, Ste. lndio, California l4. enforcement efforts to eliminate all gang activity and to ensure the educational missions of the I believe that there is a need for further gang-related intelligence gathering and additional school district and the overall safety and welfare of CVHS is preserved for all students and staff. I declare under penalty of perjury under the laws of the State of California that the following is true and correct. Dated: limit/L Hiram: a Deputy Claudia Herrera DECLARANT DECLARATION OF DEPUTY CLAUDIA HERRERA IN SUPPORT OF EX PARTE APPLICATION FOR AN ORDER TO SHOW CAUSE RE: PRELIMINARY INJUNCTION 000742