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July 22, 2016

Hand Delivcrv

Amarillo Police Department
Chief of Police Ed Drain
200 SE 3rd Avenue
Amarillo, Texas 79101

RE: Complaint of Police Abuse
Dear Chief Drain:

The purpose of this letter is to make a formal complaint about APD homicide detectives
and/or officers involved in the recent investigation of the drowning death of 7-year-old California
resident, Alexis Wartena. I am representing her parents and they have requested that I contact you
regarding the conduct of APD officers. 

Based on our preliminary investigation, it appears that APD detectives and officers suffered
from tunnel vision and violated my clients Fourth Amendment right to be free from
unconstitutional searches and seizures, as well as unlawful detention.

First, according to my clients, your of?cers and detectives ignored their request that they
be allowed to continue their independent search efforts for their daughter. Instead, they were
separated and interrogated for six hours. We now know that sometime during this six hours, their
daughter struggled to survive in the pond just a few feet from the hotel room where their
interrogations took place.

Secondly, during the police interrogations, the mother was repeatedly tortured emotionally
by your officer?s accusations of murdering her daughter. We now know, her daughter was not
murdered and in fact died accidently.

Third. your of?cers threatened and intimidated my clients with criminal prosecutions and
loss ofcustody of their children unless they submitted hair, ?ngerprint and blood samples.

MAILING ADDRESS: 801 S. Fillmore, Suite 460 AMARIIJO, TEXAS 79101
(806) 374-4024 Fax (806) 352-0073

Amarillo Police Department
July 22, 2016
Page 2

 

Fourth, all of their personal belongings were seized, probably without a warrant, and
de?nitely without probable cause or consent. They were left with nothing. No toiletries. No
phones. No clothes. 

Fifth, your officers acted as catalyst for CPS to take my clients four other children from
them by making false accusatory statements of neglect.

By the time your officers came back to continue their torturous interrogation ofthese grief
stricken parents, I agreed to represent them. I instructed your officers that their ghoulish terror
tactics were over and they were ordered to return all of my client?s belongings immediately. They
partially complied with my request and returned only some of their personal property.

It is my opinion that APD officers violated my clients? Constitutional rights by using
unreasonable, excessive and unprecedented intimidation tactics and force and unlawfully detained
them.

On behalf of the parents, please accept this as their formal complaint and request for an
internal investigation of the referenced officers? and/or detectives? conduct.

Sincerely,


44. 

Jesse Quackenbush

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