The Honorable Mariano C. Spearman Date of Hearing: December 9, 2016, 9:00 am. SUPERIOR COURT OF THE ST ATE OF WASHINGTON FOR KING. COUNTY AMY individually, DIANA NEFF, individually, and LOU CABALLERO, individually, NO. 15?2-09687?7 SEA DECLARATION OF KATIE LARSON IN SUPPORT OF RESPONSE TO MOTION FOR SUMMARY JUDGMENT Plaintiffs, v. KING COUNTY, a political subdivision of Washington State Defendant. KATIE LARSON declares and states as folEows: My name is Katie Larson; I am over the age of 18 and competent to testify to the matters herein. I. I have worked as a deputy with the King County Sheriff?s Of?ce for 32 plus years. I hold the rank of Sergeant. I tested and promoted to, the rank of Sergeantin 2003. My current assignment is Chief of the Woodi-nville Police Department. The City of Woodinville is a "contract city" with the KCSO. I have held this position since November 2014. la. I have held the following positions within the KCSO. I was hired by the King County Sheriff?s Of?ce in March of 1984. I was ?rst assigned to our SW Precinct area (White Center, Burien, SeaTac) as a reactive patrol of?cer. While at the SW Precinct I also worked as a Field Training Of?cer and for two years as the Crime Analysis Of?cer. lb. For approximately 9 years I was assigned to the King County Sheriff?s Of?ce Drug Enforcement Unit. The focus of this Unit was to investigate mid to upper level narcotics traf?ckers. I was also responsible for implementing the Drug Abatement Program for the CONNELLY LAW OFFICES, PLLC 230] North 30'? Street Tacoma, WA 98403 (253) 593-5100 Phone - [7.53) 593-0380 Fax DECLARATION OF KATIE LARSON - I Sheriff?s Office. 1c. From i999?2001 I was assigned to the King County Sheriff?s Of?ce Background Investigations Unit. I was responsible for conducting background investigations for those applying for Deputy Sheriff, professional staff, and all volunteers/reserve positions for the King County Sheriff?s Of?ce. Id. In 2001, I was asked to be a member of the Green River Homicides investigation. I was responsible for handling any and all media associated with the investigation. In addition, I was also assigned speci?c cases for investigation and was assigned as one of the primary detectives responsible for the investigation as it pertained speci?cally to the suspect in this case. I also acted at the family liaison to the victim families. 1e. 1 was promoted to the rank of Sergeant in December of 2003 and was assigned to Precinct 5 which is the contract city of Shoreline. Initially, I was assigned to reactive patrol for approximately two years. From October 2005 until January of 2009 was assigned as the Administrative Sergeant for the City of Shoreline and then from January 2009 until November of 20l3 1 was the Criminal Investigations Sergeant. If. From November 2013 until November 2014 I was assigned as an investigator in the Internal Investigations Unit of the King County Sheriff?s Of?ce. lg. I am currently assigned to the Woodinville Police Department as the Chief of Police. KCSO Background unit: 2. From 1999-2001 I worked as a detective in the KCSO "Background unit." In that capacity I was responsible for conducting background investigations into prospective candidates to become Deputies and/or civilian employees/volunteers for KCSO. 1 am familiar with the Backgrounding Unit Standard Operating Procedures (SOP). In brief, the backgrounding process for a prospective employee involves, in all cases, the following: Truthful completion of the KCSO application and any/all documents associated with the background process as set forth in the Backgrounding Unit SOP (2.1.3) Ail applicants are required to pass a polygraph given by polygraph examiner who is a graduate of an accredited polygraph school (RCW 43.101095). 2a. I am familiar with the process that Chief of Staff Barringer completed prior to attending the Washington State Criminal Justice Training Academy and I can state that I am unaware of anyone else on the King County Sheriff?s Office who has been afforded the same opportunity. To the best of my knowledge the SOP in regards to the background process was not followed regarding Mr. Barringer. Shoreline Police Department under Major Ledford: 3. I have worked under the commands of Chief Denise Pentony, Chief Tony Burtt, Chief Dan Pingrey and Chief Sean Ledford while at Shoreline. I noticed a number of concerning behaviors associated with Chief Ledford. I did note at the time that the Chief did CONNELLY LAW OFFICES, PLLC 2301 North 30'? Street Tacoma, WA 98403 (153) 593-51 00 Phone - (253) seamen Fax DECLARATION OF KATIE LARSON - 2 not seem to have a great deal of interaction with the women at the Precinct. In contrast, I did see him often ?chatting it up" with the male of?cers. The Chiefs prior to Ledford (Pentony, Burtt and Pingrey) treated women as equals and with respect. That was not the case with Chief Sean Ledford. Based Upon my personal observations, Ledford treated women differently than men and ultimately created a hostile workplace forcing tenured women from their positions. 4. When Chief Ledford took over the command of Shoreline, I noticed almost immediately that he went out of his way to NOT have interactions with women in the precinct. I observed that the following occurred under Ledford's command of the Shoreiine Precinct. 4a. It has been my experience that when a new Chief arrived it was common practice to reach out to the deputies, sergeants etc. and introduce themselves. Typically, the Chief met with the Sergeants in charge of the patrol division and specialty units to learn about what each Unit was doing, and to develop a rapport with staff. Chief Ledford was at our Pct. for approximately 3 weeks and walked by my of?ce numerous times without engaging me in any way. Initially, I gave him the bene?t of the doubt, but over time I observed and experienced that Ledford treated women differently than men. 4b. I took the initiative and introduced myself to Ledford and informed him of what I did at Shoreline. For the most part, during my tenure at Shoreiine under Ledford, we had little interaction unless it was initiated by me. 5. While at Shoreline PD, while Ledford was Chief, I observed that Ledford took action to force out of Shoreline tenured females who held positions of authority at the police department. The foliowing are my personal observations: 5a. Ledford lied to me on multiple occasions. 5b. Ledford informed me that he wanted to move a highly regarded male sergeant (over the age of 50) from his administrative sergeant position. I objected to the move, and told Ledford as much. Sgt. Sowers was only a few years away from retirement, and over the age of 50. So. A few months later, Ledford stated that Sgt. Sowers was moving from his administrative Sergeant position on a temporary basis to ?ll in for a colleague who was out on a medical leave. Ledford asked me to temporarily take over the job functions of the administrative sergeant to assist. I agreed, taking Ledford at his word. [quickly realized that Ledford had not been honest with me, and he had no intention of returning Sgt. Sowers to his administrative sergeant position. Ledf'ord forced Sergeant Sowers out of the administrative sergeant position, and forced him into a patrol sergeant position. 5d. Ledford lied to me when he said that I would only need to take over the administrative sergeant responsibilities temporarily. Ledford saddled me with the work of two people: the administrative sergeant responsibilities AND my responsibilities as Detective Sergeant of the Criminal Investigations Division. LedfOrd never removed these responsibilities from my plate. CONNELLY LAW OFFICES, PLLC 2301 North 30?1 Street Tacoma, WA 98403 (253) 593-5100 Phone - (253) 593-0380 Fax DECLARATION OF KATIE LARSON - 3 was shocked by the blatant falsehoods that Ledford told me. I was further shocked by how he mistreated sergeant Sowers, who was highly regarded and had performed the administrative sergeant position so well. 5f. Ledford never removed the Administrative Sergeant responsibilities from my plate. When the new captain came on, I remained saddled with the work of two people (my job, and that of the Administrative Sergeant position). Ledford was retaliating against me for speaking out in opposition to the move of Sowers. 5g. After I was ?ned out of Shoreline, I was replaced by a male: Bruce Bartlett. To the best of my knowledge, Bartlett was not required to perform thejob of CID Sergeant AND Administrative Sergeant. Ledford was overworking me to force me out of Shoreline. Ledford?s mistreatment of Deputy Leona Obstler: 6. Deputy Leona Obstier worked as the storefront deputy at Shoreline. The storefront deputy is a position that Leona held for approximately years. In that capacity, she led a team of volunteers and is an outstanding representative of the Sheriff?s office. She works hard and I observed that she took great pride at being the storefront deputy. I base these statements on my personal observations of Leona, and my conversations with her. 621. When Ledford took over as Chief of Shoreline he regularly criticized and in my opinion looked for problems with Leone?s work product. 6b. In 2013, Leona was waging a battle against cancer. She was still wearing a wig because of her cancer treatments. 60. The Storefront position was held by two deputies, Leona and one other deputy. When Ledford took over as Chief of Shoreline, he removed one of the Storefront deputy positions, leaving Leona to do the work of two people. Leona while still waging her battle with cancer was now doing the work of two people. 6d. In July 18th, 2013, I met with Chief Ledfor?d and Captain Strathy in the Chiefs of?ce. Chief Ledford reported to me that he had heard feedback from the City of Shoreline, and allegedly the City of Shoreline staff wanted him to get rid of Leona. i confronted the Chief, and asked him for Speci?c examples of how Leona?s work was not up to standard. Chief Ledford failed to give speci?c exampies, butjust repeated what he had ?heard? from ?other? people. I informed him that Leona was overworked and that she was doing thejob of two people. 6e. At one point during this conversation, Captain Strathy commented that he was at an event where Leona was presenting. He said that it appeared that "she was flying by the seat of her pants, that her hair was askew and I don't think this is how we want to present" or words to that effect. 6f. Chief Ledford added that he had ?heard? that perhaps Leona was going to put in for a transfer and in fact he had already made a call to the Kenmore Police Department but was unable to confirm. CONNELLY LAW OFFICES, PLLC 2301 North 301" Street Tacoma, WA 98403 (253) 593-5100 Phone - {253) 593-0380 Fax DECLARATION OF KATIE LARSON - 4 that point, it was apparent to me that Chief Ledford wanted Leona out of her position. It was not lost on me that Leona was a woman, who held an important position in Shoreline. It was also not lost on me that Ledford was unable to give concrete examples of Leone?s alleged de?ciencies, and that it appeared to me that he wanted to get rid of Leona because she was a woman. 6h. I told him that 1 would have nothing to do with moving her out of her position, unless he could prove it was done for just cause. Over the course of the next few months Chief Ledford took numerous steps to force Leona from her position. 6i. At one point, the Chief told me that he wanted Leona returned to patrol in August of 2013 because we were Shorthanded. This sounded to me eerily similar to the way that Ledford forced Sgt. Sewers (male over 50) out of his administrative sergeant position. 6j. Ledford?s proposal to move Leona to patrol to ?ll in a temporary need, would have saddled me with Leona?sjob, in addition to the two I was performing at the time. Most significantly to me though was the fact it appeared that Ledford was trying to force Leona out of the storefront position. 1 stated a myriad of reasons why Ledford?s proposal of moving Leona to patrol was unworkable. I even offered to send some of my detectives to ?ll in on patrol. At the time I was convinced that if Leona had returned to patrol for even a month she would never have returned to the storefront position thus accomplishing the Chiefs goal of forcing her out. 6k. While assigned to the Storefront, Leona worked a 4/ 10 schedule. Chief Ledford approached me and told me that he wanted Leona to change to a 5/2 schedule to be more "available" to citizens. Beyond being more "available" to citizens he could not articulate why he wanted the change. I told him that I had no doubt that Leona would see this as punitive and the effect would be she would be forced to leave the position. All of the patroi deputies were on a 4/10 schedule and it is a very coveted schedule. Ledford refused to back down. It was clear to me that Ledford was focused on forcing Leona out of the storefront position. 61. Ledford?s change of Leona?s schedule had the effect of forcing her to patrol. Ledford selected a male deputy to replace Leona. The male selected to replace Leona is currently working a 4/10 schedule and misses an additional day each week for TAC 30 training. 7. noted additional instances where women were treated differently than men by Chief Ledford. 7a. While Iwas still assigned as the supervisor of the Community Storefront and after Ledford forced Leona back to patrol; Ledford excluded me from the selection process for the new storefront deputy. It was my responsibility to supervise the storefront unit. This was the ?rst time in my career that a supervisor was 100% excluded from the decision making process for a vacancy in their Unit. The deputy chosen to replace Leona was a male. CONNELLY LAW OFFICES, PLLC 2301 North Street Tacoma, WA 98403 (253) 593-5100 Phone - (53) 5930380 Fax DECLARATION OF KATIE LARSON - 5 7b. When Sgt. Sowers was forced out of the administrative sergeant position by Ledford, I took over virtually all of his responsibilities. After I was forced out of Shoreline by Ledford, the individual selected to replace me as the Sergeant of CID was a male. To the best of my knowledge the male Sergeant who replaced me did not have to maintain this workload. 7c. I had numerous conversations with Chief Ledford regarding our community volunteers at Shoreline PD. The majority of our volunteers are senior citizens and many are women. It was his opinion that our volunteers didn?t do much and that it wasjust a "coffee clatch" and he thought we "coddled" the volunteers. I informed him that our volunteer program was very robust and that many of our volunteers had been with the city since its incorporation. I went On to tell him that our volunteers ran the majority of our crime prevention programs to include but not limited to: Victim call backs our goal was to reach out either via telephone, e?mail or mailing regarding their crime and to provide relevant crime prevention infonnation Court call back program volunteers reach out to those subpoenaed to court and remind them of their court date. 1 do not recall the exact amount of money this saved the city but it was substantial. Ledford?s remarks about our volunteers, who are comprised of senior citizens and women, were derogatory, disrespectful, unprofessional and uncalled for. 7d. In August of 20 I 3, I was working at the city?s largest community event, Celebrate Shoreline. The Shoreline Police tent was staffed by me, Leona, and some of our- volunteers. I watched as Chief Ledford walked past our tent (he was wearing his uniform) he did not even acknowledge Leona, mine or the volunteers presence. He walked over to a bunch of male deputies assigned to the beer garden and talked and hung out with them. This was typical of Ledford, to ignore women and seek out male deputies to talk to and engage with. 7e. Reflecting back to my time in Shoreline under the leadership of Chief Ledford, rarely did I see him actively engaging with women. Rather, saw him engage with the men in the Pct. He often walked past my of?ce which is almost directly next door to the roll call room and spoke with the deputies, more often than not, male deputies. 7f. On July Chief Ledford and Captain Strathy asked to speak with me. When I went into the meeting I did not have any intent of leaving my position. At the end of a long meeting it was clear to me that regardless of what I said or did Chief Ledford and I would never be on the same page regarding our treatment of staff and that I would be looking for a new position. I also had concerns his lack of honesty. 7g. I left the of?ce and left for a planned 3 week vacation. After I left the Chief and Captain told my Unit that I would be leaving. Detective Diana Magan, a female was the senior detective in my Unit and was in the of?ce that day. All my detectives with the exception of Diana Megan, were called into/e-mailed by the Chief or Captain and told that I would be leaving the Precinct. CONNELLY LAW OFFICES, PLLC 2301 orth 30* Street Tacoma, WA 98403 (?253) 593-5100 Phone - (253) 593-0330 Fax DECLARATION OF KATIE LARSON - 6 Ledford?s mistreatment of Sergeant Diana eff. 8. To the best of my knowledge Sgt. Neff had a much better relationship with the Chief and Captain than I did. I know that the Captain was often behind on paperwork etc., but Sgt. Neff typically stepped up and either did it for him or found him for necessary signatures etc. I also observed and had numerous conversations with Sgt. Neff regarding Chief Ledford. Mostly that he rarely sought us out or engaged in conversation. Typically, we had to initiate any contact with Chief Ledford. 8a. When I left the Precinct on July 301?1 for vacation 1 was visibly upset. This is not the norm for me and after I left] called Sgt. Neff and told her what had happened. She told me to take my vacation and to use the time to reassess. my desire to ieave the Pet. 8b. During the month of Au gust while on vacation I received a number of calls from Sgt. Neff. She said that neither the Chief nor Captain would interact with her at all. i remember speaking with Sgt. Neff and apoicgizing for their behavior. I assumed they were ?freezing? her out based upon our friendship and thinking that she was being punished for my issues with Chief Ledford. 8c. Sgt. Neff asked to meet with Chief Deputy Kirkpatrick and brought along her notes concerning her treatment at the hands of Ledford and Strathy. As mentioned above, the Chief Deputy states that she was there at Sheriff Urquhart?s direction and that neither Ledford or Strathy would be moved, no investigation, and that if wanted to stay we would have to ?gure it out or leave. Sgt. Neff was very frustrated and tried more than once to bring up her concerns but to no avail. 8d. During the course of the EEO investigation, Sgt. Mullin asked that to preserve the integrity of the investigation that Sgt. Neff and have no contact. I know that this was especiaily dif?cuit on Sgt. Neff. She does not have any close family left and I know that the fashion in which she was forced out of Shoreline was humiliating and she felt very isolated. 8e. Captain Strathy told Sgt. Neff to have her of?ce cleaned out over the course of a weekend. Again, this is unheard of. Typically, we work as a team and work together to arrange transfers in a way that will work well for everyone, but not for Sgt. Neff. I came in on a weekend day, in the pouring rain and together we moved all of her furniture to include a desk, ?le cabinets etc., into her vehicle. Deputies were sitting in the role call room. One of the detectives in the SET Unit, Sgt. Neff?s Unit was sitting in the role call room. As we were moving the bulky furniture, no one not even her detective, a man who had worked with her for years said a word or offered to help. What had they been told by Chief Ledford and Captain Strathy? 8f. I was floored. What was going on? Now, reading the statements and declarations of those involved in this investigation and speci?cally Chief Ledford and Captain Strathy it is clear that they were punishing Sgt. Neff and making her life at the Precinct untenable thus forcing her out of a position that she had earned and loved. CONNELLY LAW OFFICES, PLLC 2301 North 30'? Street Tacoma, WA 93403 (253) 5936100 Phone - (153) 593-0380 Fax DECLARATION OF KATIE LARSON - 7 Protected activity: Complaints to Chief Deputy Kirkpatrick: 9. Protected activity: Complaints to Chief Deputy Kirkpatrick I met with Chief Deputy Kirkpatrick, Chief Pingrey and Sergeant Neff to discuss our concerns regarding Chief Ledford, and about what was happening at the Precinct. The Chief Deputy stated that she had also invited Chief Pingrey to the meeting. Both Sergeant Neff and I had brought our notes detailing speci?c incidents of concern we had with actions taken by Chief Ledford and Captain Strathy. 9.3. Before we could go into any detail, Chief Deputy told us that she was here representing Sheriff Urquhart. It was clear to me by this statement that she had communicated our concerns to the Sheriff, and that she was speaking on the Sherist behalf. She told Sgt. Neff and me in no uncertain terms that neither Chief Ledford nor Captain Strathy would be moved, that Sgt. Neff and I had to ?gure out how to get along at the precinct or find a new home. Several times Sgt. Neff attempted to bring up her concerns and was shut down by the Chief Deputy saying that she had already heard numerous stories about what was going on in Shoreline. Additionally. the Chief Deputy said that if "we couldn't act on board then we needed to ?nd a new home" and that the Sheriff supported this. At this point, I saw no point in continuing. Our concerns were summarily dismissed and I heard the orders loud and clear. Our concerns were not going to be heard and there woold not be an investigation. My immediate reaction was that Sgt. Neff and were being forced out of Shoreline, and that Ledford and Strathy were untouchable. it was startling to me that the Chief Deputy did not even want to listen to me and Sgt. Neff, and that she refused to take our documentation. 9c. I had every intention of ?nishing my career at Shoreline. For the past ten years I had given 100% of my efforts to the city and to improving the police department and our relationship with the community. I have always received positive evaluations and have never received or been the subject of a complaint, citizen or otherwise. 9d. 1 had worked for 4 different Chiefs, and at least 6 different Captains. Ail of whom, had their own ideas and facilitated change, I was able to work collaboratiVely with all them with the exception of Chief Ledford. 9e. There is no doubt in my mind that Chief Ledford has not been honest in his dealings with Deputy Obstler, Sergeant Neff or me. His dishonesty put into play a course of action that forced all of us from our positions. In further review, Isee a common theme in his dealings with all ofus. We are all women. Forced out of Shoreline: 10. In August of 2013, I was on vacation most of the month. I recall receiving numerous phone calls from Sgt. Neff in which she told me she was being ?frozen out by the Major and Captain?. I believed at that time that they had ?painted us with the same brush? and assumed that my issues were hers as well. 1 truly believed at that time that she was being ?punished? for being supportive of me. Sgt. Neff was NOT involved in any way with my concerns regarding the storefronts or any changes being made by the city. Sgt. Neff called me often over the course of the next few months, very upset. LAW OFFICES, PLLC 2301 North 30?" Street Tacoma, WA 98403 (253) 593-5100 Phone - (253) 593-0330 Fax DECLARATION OF KATIE LARSON - 3 idea why Chief Ledford or Captain Strathy were ?freezing? her out and excluding her from decisions regarding her Unit. I remember feeling responsible. Regardless of my issues with the Chief and Captain, Sgt. Neff maintained a good working relationship with them and tried to maintain a neutral position. We had several things in common: we are both women, we are friends, and we were in tenured Sergeant Positions at Shoreline. 11. After I returned from my August 2013 vacation, and after the conversation that Sgt. Neff and I had with Chief Deputy Kirkpatrick, I recall being present at a Shoreiine staff meeting. Sgt. Neff was not present. That same August, Deputy Mitch Wright, had been arrested by Federal Agencies for engaging in criminal acts. During this staff meeting it was announced by Captain Strathy that Sgt. Neff was leaving the precinct. I was shocked because Sgt. Neff was not there and also because Sgt. didn't have was processing this, Captain Strathy and Ledford announced that I was leaving and that I was being replaced by a male, Bruce Bartlett. This had to be one of the most humiliating days of my career. I was sitting in a room with my peers, I did not have another position at that point, and they had already chosen and were announcing my replacement. I had had more than one conversation with Chief Ledford asking him to refrain from telling people I was leaving. I did NOT have ajob to go to. I had been told by numerous staff from the City that the City Manager was sending out noti?cations that Sgt. Neff and I were both ?leaving to go to other positions?. At the time, neither one of us had other positions. This information was provided to thecity by Chief Ledford. The Chief was also directing staff both within the Sheriff?s Of?ce and the City to contact our replacements concerning business associated with our Units. Basically, taking away our authority to run our Units. 123. Prior to this meeting, and after the meeting with Chief Deputy Kirkpatrick where Sgt. Neff and I were told that our concerns and complaints about mistreatment by Ledford of women didn?t matter, I told Ledford that 1 could no longer work for him. I had sincere issues with his lack of honesty but I had also asked him on more than one occasion to refrain from telling everyone I was leaving because at that point I did not have another job and frankly did not know when I would find anotherjob. On more than one occasion a?er assuring me that he would refrain from telling staff that I was leaving until I found a new position, I was called or sent information to the contrary by city staff. 12b. It was shortly after this meeting that I calied the Chief Deputy and requested an immediate transfer out of the Shoreline Police Department. 1 was in a lose lose scenario. Chief Ledford had excluded me from meetings concerning my Unit; he was providing misinformation to the city and City Manager concerning me leaving for a new position. Chief Ledford provided false information to the City Manager/staff regarding my work performance. Based upon these dishonest representations the City came to inaccurate conclusions concerning my work performance. This is exactly what happened to Sgt. Neff and Deputy Obstler. Within a matter of a week or two I was transferred to CONNELLY LAW OFFICES, PLLC 2301 North 30?? Street Tacoma, WA 98403 (253) 593-5100 Phone - (7.53) 593-0380 Fax DECLARATION OF KATIE LARSON - 9 Experience as a Detective Sergeant in 1111: l3. I was assigned to to be one of Detective Sergeants. At the time [was first assigned to in 2013, the Commander was Captain DJ Nesel. Myjob at was to investigate complaints lodged againstemployees in a fair and objective manner, and to turn that investigation over to my chain of command for review, and the determination of what discipline if any would be imposed. 13a. During this time period I worked under Captain DJ Nesel, and his successor, Captain Jesse Anderson. My colleagues in IIU included: Sergeant Mike Mullinax, Sergeant Francis Carlson, and others. l4. After left Shoreline was assigned to the King County Sheriff?s Of?ce lntemal Investigations Unit. One of my cases involved a deputy of the name of Brian Barnes. Initially, this was an EEO investigation and I worked alongside an attorney hired by King County to conduct this investigation. This was a long and involved investigation and we conducted a minimum of 15 plus interviews. Me. At one point in the investigation, 1 was looking into what I initially thought may be an issue concerning ?shift adjusting" by Deputy Barnes. I had just received a document from our Finance Unit and on the face of it; it appeared that Deputy Barnes regularly adjusted his shift to accommodate working overtimejobs. Sheriff Urqohart was in the of?ce and inquired as to the status of the investigation. i told him what I thou and went back to work. I believe within a short period of time, less than 24 hours, the Sheriff changed Deputy Barnes hours. At, that time Deputy Barnes was working a 4/ i 0 schedule at the storefront in Skyway. The Sheriff toid Deputy Barnes and the media that he did this to ensure better ?coverage? at the storefront. 14b. As i continued this investigation came to the conclusion that Deputy Barnes did in fact ?flex? his hours. . on his furlough days. Additionally, Deputy Barnes volunteered to be a School Resource Of?ce in a White Center High School. With the Sergeant?s permission he adjusted his schedule on the days he worked there. Again, typically on his furlough days. The Department Manual also states that the Store Front does work a ?flex? schedule. 140. [did not ?nd any abuse of the schedule by Deputy Barnes. I was very concerned that the Sheriff made this decision based upon ?emotion? rather than fact and frankly based upon my investigation Deputy Barnes was very available to the citizens of the community in which he served and in this specific area I did not find any violations. 14d. As i continued on in this case, Sheriff Urquhart and or Chief of Staff Chris Barringer would often come into the office and inquire as to the status of the investigation or offer insight or direction. Both knew Deputy Barnes and had a friendship with him outside of the workplace. Me. At one point, Sheriff Urquhart and Chief of Staff Barringer became the ?subject? of an investigation based upon a I approached Captain Anderson and expressed my concerns that to maintain the integrity of my investigation both the Sheriff and CONNELLY LAW OFFICES, PLLC 2301 North 30th Street Tacoma, WA 93403 (253) 593-5100 Phone - (2531 593-0380 Fax DECLARATION OF KATIE LARSON - lO Chief of Staff should refrain from any involvement in this investigation. 14f. Captain Anderson left the of?ce and a short time later the Sheriff came into the of?ce. He stood directly next to my desk; arms folded and stared at me. I remember that I had my ear phones on so I took them off and asked if I could help him with something. He said, ?No, I?m just standing here not talking to yOu? or words to that effect. It was ciear to me that the Sheriff was trying to intimidate me. 14g. Captain Anderson returned and I told him what happened. He said that after our conversation he went into the Sheriff?s of?ce and asked him to refrain from discussing the Barnes investigation with me in order to protect the integrity of the investigation. 14h. At this point, I asked the Captain if he minded if I spoke with the Sheriff about what had just happened. I have no idea why the Sheriff felt the need to come into the of?ce and do what he did to me. I went to the Sheriff?s office and I walked into his of?ce. I asked him what ?that was all about?. Mi. I told him that was trying to protect the integrity of my investigation, that ultimately he would be making the final decision in this case and as such I thought it important that he remain as impartial as possible and that I was following the manual or words to that effect. Sheriff Urquhart: The rules don?t apply to me. I4j. The Sheriff'told me that as an elected of?cial the manual did not apply to him. That he could not he held accountable unless he committed a crime. That the oniy people who could hold him accountable were his constituents and that would be by not electing him in the next election. 14k. He told me that it ?wasn?t my job to protect him.? I told him it was more than just him. Itold him that he was ?the? Sheriff and as such he represented all of the men and women on the King County Sheriff?s Of?ce and I thought it was important that everything we do should be above reproach. He finished the conversation by statjga words to the effect that he could do whatever he wanted. I told him I understood and left his of?ce. I told Captain Anderson what the Sheriff told me and asked that he be present when I conducted the Sheriff 3 interview. I learn that the Sheriff ?led a complaint with IIU to investigate Sgt. Neff. 15. While working in Sgt. Mullinax told me about the investigation he was conducting based upon a complaint iodged by the Sheriff against Sgt. Neff and alleged irregularities in the bookkeeping practices at the Shoreline SET Unit. Sgt. Mullinax told me he would be serving me with an A-150. When he told me the accusations against Sgt. Neff I was livid and immediately said that this was retaliation against Sgt. Neff for ?ling her EEO complaint against Ledford. 15a. Numerous things bothered me about this IIU complaint lodged by the Sheriff against Sgt. Neff. First, I was the one who encouraged Sgt. Neff to ?le the EEO complaint. She truly felt she had been discriminated against and forced CONNELLY LAW OFFICES, PLLC 2301 North 30*Street Tacoma, WA 93403 (253) 593-5100 Phone - (153) 593-0380 Fax DECLARATION OF KATIE LARSON - position she loved. I thought it important that she follow the Department policy. She ?led her complaint and now she was the subject ofa ?major? IIU investigation. 15b. It was patently obvious to me that the IIU complaint against Sgt. Neff by the Sheri? was retaliation. The claims were ridiculous. I know for a fact that when Sgt. Neff took over the SET Unit in Shoreline she speci?cally asked me about the book keeping process. I told her that I had never been responsible for the books while assigned to the KCSO Drug Enforcement Unit. She told me that it appeared that the prior Sgt. in charge of the SET Unit had ?rounded up? the ?gures when doing the books and she was concerned about this. I know that Sgt. Neff went to the city and asked the ?nance department for a quarterly audit. I remember seeing Monica and Henry Yeh from the city in the police department conducting the audit of her books. To the best of my knowledge she never failed an audit. She was very proud of this accomplishment. Nor were any of the accusations of a criminal nature or even necessarily violations of the Department Manuai. At best, the violations could be considered a perfomiance issue. But again, many of the concerns raised could have been resolved with a phone call, not a full blown IIU investigation. Additionally, I was told that at some point, Chief Deputy Pugel sent an e-mail to Sgt. Neff after her IIU interview that he was ?rescinding? the complaint. This is unheard of. Typically, a complaint is closed with a ?nding. I.e. unfounded, exonerated, sustained etc., to put Sgt. Neff through the stress of this investigation and then ?rescind? it was egregious and retaliatory. 15c. I told Sgt. Mullinax that was amazed that the Sheriff ?led this IIU complaint against Sgt. Neff, because if Ledford had any questions about SET bookkeeping practices why not just call Sgt. Neff directly? In my experience, if a Sgt. has questions or concerns regarding a new assignment, typically you call 0r reach out to the prior Sgt. and ask questions. Sgt. Bartlett my replacement reached out to me numerous times for clari?cation/direction. 15d. When Sgt. Mullinax interviewed me, based upon the questions asked, it was very clear to me that the entire ?complaint? could have and should have been cleared up with a phone call to Sgt. Neff, and if not Sgt. Neff call the city and interview the folks responsible for the SET Units ?nances. To my knowledge, to this day, that has never been done. It was even clearer to me after my IIU interview on the subject that the Sheriff was retaliating against Sgt. Neff for ?ling an EEO complaint. 16. During this same time frame, Sgt. Neff was ordered by the Sheriff to be interviewed by the FBI regarding former KCSO Deputy Mitch Wright. Wright had been assigned to a DEA Task Force and was arrested for stealing drugs from the Task Force. Following his arrest he made false accusations, telling the DEA that Sgt. Neff ?dug up drugs from his yard? and stole them. 16a. This was a ludicrous claim. I know that Wright had interviewed on two separate occasions for a detective position in Sgt. Neft?s Unit. She did not select him on either occasion and I know he did not accept the decision well. 16b. Detective Wright had a signi?cant drug addiction and to think that Sgt. Neff would be sulking around his yard in the dead of night, with a shovel digging for drugs he buried ?somewhere? was ridiculous. CONNELLY LAW OFFICES, PLLC 2301 North 30?? Street Tacoma, WA 98403 (1513) 593?5100 Phone - (253) 5930380 Fax DECLARATION OF KATIE LARSON - l2 belief based upon my experiences, and observations that it was the intention of the Sheriff to punish Sgt. Neff for ?ling her EEO complaint. I have been told that the Sheriff is a personal friend of Chief Ledford and in my opinion this in?uenced subsequent investigations. 18. Earlier this year, I had a conversation with Detective Mullinax. In short, I told him that after reviewing the statements from the EEO investigation Chief Ledford had been dishonest with IIU. I told him that based in part on the statements it was clear to me that Chief Ledford had been dishonest in numerous instances and I would be ?ling an llU complaint against the Chief for dishonesty. He told me that during the course of the EEO investigation he had developed concerns regarding Chief Ledford?s honesty, which he brought to the attention of Captain Nesel. 1821. Apparently, the Captain brought the concerns forward and was advised by Sheriff? Urquhart that Chief Ledford would NOT be investigated. Case closed. Sgt. Muilinax stated that because he had already brought his concerns forward the 180 day clock had begun and expired therefore my compiaint would not be investigated. Work history with Urquhart; Urquhart?s disparaging remarks about women: 19. While I was assigned to the Green River Homicides Investigation I was contacted by then Sheriff Dave Reichert. He told me that he needed to replace his current Media Relations Of?cer and asked if I would take the position. I told him that I was truly invested in my position at the GRTF and declined. We looked through a list of deputies looking for a suitable replacement. I remember a conversation I had with Sheriff Reichert in which he told me that he was going to bring back John Urquhart. He said something to the effect that he could kill two birds with one stone or words to that effect by bringing John back. Reichert stated that John, who was a probationary Sergeant assigned to Pet. 4 at that time, had gotten into some trouble and he needed to move him. Additionally, he said that John knew how was comfortable with him in that position or words to that effect. 20. I remember a conversation with then Sgt. Urquhart regarding the discipline he had received as a result of the investigation at Pet. 4. Urquhart was upset about the discipline and told me that he had been ordered go through some type of ?harassment? training regarding women. He stated that he was required to go to some counselor who was a woman and he said when he got there the woman was ?laying or sitting on a couch and that she was a fat slob? or words to that effect. Urquhart said he was not going to go back. Urquhart aiso told me that if he went back to patrol and supervised women he was going to be put on quarterly evaluations, and he told me he ?was never going to do that.? 21. I also recall that Urquhart spoke in a disparaging manner about Sue Rahr. Urquhart told me that he was upset because he thought they were ?friends? and used to go out after work with others in the office for drinks. It is my recollection that Sue Rahr was either the investigator assigned to investigate the hostile work environment complaints, against Urquhart, or was somehow responsible for recommending the discipline in that matter. I remember that during this conversation, Urquhart appeared angry with Rahr, and referred to her as a ?bitch.? I remember at the time CONNELLY LAW OFFICES, PLLC 2301 North 30"1'Street Tacoma, WA 98403 (253) 593-5100 Phone - (153) 593-0380 Fax DECLARATION OF KATIE LARSON - 13 menan (onethinking that Urquhart was incredibly unprofessional and not appreciating his remarks about Sue Rahr, as a deputy and as a woman and also that because he was very obviously resistant to 'the training it would have no effect. 22. In my current capacity, each month I attend a meeting of the Eastside Police Chiefs. I attended a meeting in 2014 at the Washington State Patrol Of?ce in Believue. The participants at this meeting were the police chiefs from agencies located in the Eastside of King County to include the Washington State Patrol, approximately 14-15 Chiefs and representatives from the FBI. At one point in front of all participants, Sheri?' Urquhart made a comment about an article that had come out in the paper regarding Sgt. Neff's lawsuit. He said to the group something to the e??ect of ?I?m sure you?ve all seen the article in the paper about that frivolous lawsuit and I?m here to say that [will not pay one penny to those women in Shoreline like I had to pay to those women in and then he looked at Chief Ledford and said something like ?isn?t that right Shawn? and Chief Ledford kind of chuckled and agreed. 23. I was absolutely ?oored. I was one of ?those women at Shoreline.? The Sheri? was referring to a pending lav'vsuit involving serious accusations of discrimination and retaliation, and he was making a joke of it. He was also referring to women in a disparaging way. I didn?t leave because I wanted to. I left because] was forced out. At the time, I remember making contact with another contract city chief, who looked at me in amazement. When we were walking out the contract city Chief expressed to me total and complete amazement that the Sheriff would make Such a comment. Review of Sheriff's deposition and Captain Anderson's depositions re: Rape allegation against Sheriff: 24. I have brie?y reviewed Sheri?' Urquhart?s deposition and Captain Anderson?s depositions. Specifically, regarding an allegation of rape by Sheri?? Urquhart of a woman. I have worked in IIU, and I am familiar with the policies and procedures of EU . This is an allegation that per KCSO policies and procedures is required to be investigated by IIU. 25. When I read the deposition testimony of Captain Anderson, where he was ordered 155' ?the the rape allegation against him, I was reminded of the Sheriffs remarks to me while I worked in EU, when he said ?the rules don?t apply to me.? I was disturbed by the fact that the Sheriff refuses to be held accountable to the same rules as all other members of the department. Based upon my experience in IIU, it is clear to me that this rape allegation against the Sheriff should be investigated and documented. I DECLARE UNDER PENALTY OF PERJURY OF THE LAWS OF THE. STATE OF WASHINGTON THAT THE FOREGOING IS AND CORRECT. Signed this day of November, 2016, at Seattle, Washington. By @152 KATIE LARSON CONNELLY LAW OFFICES, PLLC 2301 North 30'1?Street Tacoma, WA 98411! DECLARATION OF KATIE LARSON - 14