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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 1 Safety Zone (paragraphs 21 to 77h); (D) the NSO gang’s activities, culture, and values 2 (paragraphs 78 to 91); (E) the NSO’s qualification as a criminal street gang (paragraphs 3 92 to 95); (F) the identification of specific gang members (paragraphs 96 to 109m); and 4 (G) my conclusions in support of injunctive relief against the NSO criminal street gang and 5 all of its members (paragraphs 110 to 111). 6 A. SPECIAL EXPERIENCE, EDUCATION, AND EXPERTISE REGARDING 7 CRIMINAL STREET GANGS AND GANG MEMBERS 8 1. I am a sworn California Law Enforcement officer employed by the Oakland 9 Police Department. I make this declaration in support of the People’s request for a gang 10 injunction and other relief against the North Side Oakland (NSO) criminal street gang 11 within a proposed Safety Zone, located in the City of Oakland. 12 2. In this Declaration, except where I state something to be based on my 13 personal observations, I am stating my opinion as a gang expert, or am referring to 14 information that I used to form my opinions. The information I used to form my opinions on 15 the NSO criminal street gang includes discussions with other law enforcement officers 16 including other gang experts, conversations I have had with members, associates, and 17 affiliates of the NSO criminal street gang, conversations I have had with non-gang 18 members who live and work in the community, and my review of police records, internet 19 materials, music, documentaries, and a review of criminal records of gang members. 20 3. I am currently employed as a police officer with the Oakland Police 21 Department. I have been so employed as a peace officer since November 17, 2006. My 22 current assignment is as a Problem Solving Officer for Area 1, District 2, which covers the 23 physical area of the proposed Safety Zone. 24 4. I have a Bachelor of Arts degree in Economics from California State 25 University, Fresno, California. 26 5. For the opinions about NSO that I discuss in this declaration, I have also - 2 - EXPERT DECLARATION OF OPD OFFICER PATRICK GERRANS ISO RELIEF AGAINST NORTH SIDE OAKLAND STREET GANG 1 drawn on my personal experience as a police officer performing gang and controlled 2 substance enforcement especially working as a Problem Solving Officer in North Oakland. 3 Many of the assignments I had at OPD have directly involved investigating the North Side 4 Oakland gangs and gang members and their criminal activity. 5 6. My work investigating gangs involves gathering intelligence on criminal street 6 gangs, including the number and names of gang members, gang trends, the gang’s 7 method of operation, gang terminology, and the gang’s turf, rivalries, alliances, tattoos, 8 graffiti, and clothing. I have had numerous direct contacts with gang members and their 9 rivals through traffic stops, pedestrian stops, consensual encounters, preliminary 10 investigations and follow up investigations involving gang members as victims or suspects, 11 and through parole and probation compliance investigations. I have spoken directly with 12 gang members almost every day I have been on duty investigating gang crimes and 13 activities. I have participated in over 50 investigations involving gang members. 14 7. As an officer familiar with the NSO and gang investigations, I have taught 15 OPD officers assigned to patrol in North Oakland, OPD specialized units, and OPD 16 Criminal Investigations Division commanders and staff on the NSO gang and gang culture. 17 I have also trained officers from the Berkeley Police Department on awareness and 18 identification of the NSO gang and gang culture. 19 8. My duties include identifying and photographing active gang members and 20 graffiti, tracking gang members and their activities, working with area detectives in solving 21 gang related crimes and conducting preliminary investigations concerning gang related 22 crimes, specifically tracking gang related robberies and controlled substance activities. I 23 obtain information about the NSO criminal street gang and its activities by conducting 24 custodial and non-custodial interviews with gang members, associates, and affiliates, rival 25 gang members, members of the community, other OPD officers, other law enforcement 26 representatives, and by reviewing crime reports involving gang-related and gang-involved - 3 - EXPERT DECLARATION OF OPD OFFICER PATRICK GERRANS ISO RELIEF AGAINST NORTH SIDE OAKLAND STREET GANG 1 incidents such as robbery trends that are gang related. I also obtain information about the 2 NSO gang and its activities from evidence obtained during search warrant services, 3 probation and parole searches, and searches for gang-related documentation on the 4 internet. 5 9. I have received approximately 83 hours of training in relation to investigating 6 crimes, including interviewing and interrogation techniques. While in the Special 7 Resources Division, I have been assigned nine criminal cases to investigate as the lead 8 investigator. 9 10. I have received training about criminal street gangs from other Law 10 Enforcement agencies, including gang identification and documentation and training in 11 identifying gangs in general, specifically black gangs, social networking websites 12 connection with gang activity, gathering documentation to create files on individual gang 13 members to document their criminal activities and verifying the existence of a gang. 14 11. I received training related testifying as a gang expert in Court and internet- 15 based databases and networking sites from the San Francisco Police Department Gang 16 Task Force. 17 12. I received 40 hours of training from the California Gang Investigations 18 Association (CGIA) at the annual gang conference from July 21, 2009 to July 24, 2009. 19 13. I received 16 hours of training on the topic of Criminal Street Gangs 20 presented by Multi-jurisdictional Counter drug Task Force from Moses Robinson, 21 Rochester Police Department and the New York City Schools Police Department. 22 14. I have received training as a police officer relating to the investigation and 23 identification of gangs and narcotics trafficking and ongoing training from my supervisor, 24 Sgt. Bernard Ortiz and 12 hours of training on narcotics and street drugs at the police 25 academy. 26 15. I received approximately 92 hours of training in the detection, recognition - 4 - EXPERT DECLARATION OF OPD OFFICER PATRICK GERRANS ISO RELIEF AGAINST NORTH SIDE OAKLAND STREET GANG 1 and investigation of narcotics and controlled substances. My training included knowledge 2 of controlled substances that are commonly abused on the streets of Oakland. I learned 3 to recognize the substances, common packaging for transportation, paraphernalia used to 4 ingest narcotics, and drug symptoms. I have spoken to over 500 persons who use and 5 sell narcotics and other controlled substances. I have been involved the investigation of 6 over 500 incidents relating to narcotics activity, possession and possession for sale of 7 narcotics, sales of narcotics and other controlled substances and possession of stolen 8 property. I am familiar with the appearance, packaging, use and sales methods of 9 narcotics and other controlled substances. My narcotics training and experience helped 10 me better understand criminal street gangs and gang members because the illegal sale of 11 controlled substances is a source of money and primary activity for the NSO Gang, and is 12 the cause of crimes committed to maintain the ability to continue drug sales, such as 13 murders,shootings, loitering, graffiti, assaults, and robberies. 14 16. I have read publications about criminal street gangs such as “Gangs, Stories 15 of Life and Death from the Street” by Sean Donahue and “Gangsters – Fifty Years of 16 Madness, Drugs and Death on the Streets of America” by Lewis Yablonsky. 17 17. In addition to the formal instruction I have received, I have also learned a lot 18 about the NSO street gangs and gang members from senior OPD officers in informal 19 settings, such as while on patrol. Both my formal and informal training help me better 20 understand criminal street gangs and gang members. 21 B. THE PROPOSED SAFETY ZONE AND ITS SIGNIFICANCE 22 18. The proposed Safety Zone is described as follows: 23 Starting at 37th Street and Martin Luther King, Jr. Way, then west on 37th 24 Street until Adeline Street; then north on Adeline Street until 53rd Street; 25 then west on 53rd Street until Boyer Street; then north along Boyer Street 26 and along the northerly line as it continues along Vallejo Street until 66th - 5 - EXPERT DECLARATION OF OPD OFFICER PATRICK GERRANS ISO RELIEF AGAINST NORTH SIDE OAKLAND STREET GANG 1 Street; then east on 66th Street until Herzog Street; then south on Herzog 2 Street until Alcatraz Street; then east on Alcatraz Street until Market 3 Street; then southeast on Market Street until 61st Street; then east on 61st 4 Street until Dover Street; then north on Dover Street until Fairview Street; 5 then east on Fairview Street and along the easterly line as it continues 6 along 66th Street until Telegraph Avenue; then south on Telegraph Avenue 7 until 60th Street; then east on 60th Street until Canning Street; then south 8 on Canning Street until 58th Street; then west on 58th Street until 9 Telegraph Avenue; then south on Telegraph Avenue until 49th Street; then 10 west on 49th Street until Shattuck Avenue; then north on Shattuck Avenue 11 until 52nd Street; then west on 52nd Street until Martin Luther King, Jr. Way; 12 then south on Martin Luther King, Jr. Way until the starting point at 37th 13 Street, and extending 100 yards to the outside of each of those boundary 14 streets. I am informed that a copy of a map illustrating the proposed 15 Safety Zone is attached as Exhibit A to the Declaration of Ofc.
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