1 XAVIER BECERRA, State Bar No. 118517 Attorney General of California 2 TAMAR PACHTER, State Bar No. 146083 Supervising Deputy Attorney General 3 ALEXANDRA ROBERT GORDON, State Bar No. 207650 JOHN D. ECHEVERRIA, State Bar No. 268843 4 Deputy Attorneys General 455 Golden Gate Avenue, Suite 11000 5 San Francisco, CA 94102-7004 Telephone: (415) 703-5509 6 Fax: (415) 703-5480 E-mail: [email protected] 7 Attorneys for Defendants 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 12 13 WILLIAM WIESE, et al., 2:17-cv-00903-WBS-KJN 14 Plaintiff, EXHIBITS 29 THROUGH 34 TO THE DECLARATION OF ALEXANDRA 15 v. ROBERT GORDON IN SUPPORT OF PLAINTIFF’S MOTION FOR 16 TEMPORARY RESTRAINING ORDER XAVIER BECERRA, et al., AND PRELIMINARY INJUNCTION 17 Defendant. Date: June 16, 2017 18 Time: 10:00 a.m. Courtroom: 5 19 Judge: The Honorable William B. Shubb Action Filed: April 28, 2017 20 21 22 23 24 25 26 27 28 Decl. of Alexandra Robert Gordon (2:17-cv-00903-WBS-KJN) Exhibit 29 Gordon Declaration 00856 Mass Shootings at Virginia Tech April 16, 2007 Report of the Review Panel Presented to Governor Kaine Commonwealth of Virginia AUGUST 2007 Gordon Declaration 00857 Chapter III TIMELINE OF EVENTS he following timeline provides an overview of family. He has serious health problems from Tthe events leading up to the tragedy on April 9 months to 3 years old, is frail, and after 16, and then the actions taken on April 16. The unpleasant medical procedures does not time scale switches from years to months to days want to be touched. and even to minutes as appropriate. This infor- 1992 Cho’s family emigrates to Mary- mation is a reference source to use as one reads land when he is 8 years old. the chapters. 1993 The Cho family moves to Fairfax The information here was drawn from numerous County, Virginia, when he is 9 years old. interviews and written sources. The Cho family They work long hours in a dry-cleaning and Seung Hui Cho’s school administrators, business. counselors, teachers, and medical and school records are the prime sources for his history 1997 Seung Hui in the 6th grade con- prior to attending Virginia Tech. tinues to be very withdrawn. Teachers meet with his parents about this behavior. In the Information obtained on his university years summer before he enters 7th grade, he before the shootings came from interviews with begins receiving counseling at the Center for faculty, counselors, administrators, police, Multi-cultural Human Services to address courts, psychological evaluators, suitemates, and his shy, introverted others. The panel also had access to many uni- nature, which is diagnosed as “selective versity, medical, and court records and to e-mails mutism.” Parents try to socialize him more and other written materials involving Cho. by encouraging extracurricular activities The timeline for the events of April 16 relied pri- and friends, but he stays withdrawn. marily on state and campus police reports and 1999 During the 8th grade, suicidal interviews, supplemented by interviews with and homicidal ideations are identified by survivors, university officials, emergency medical Cho’s middle school teachers in his writing. responders, hospitals and others. It is connected to the Columbine shootings The information on the aftermath drew on medi- this year. (He references Columbine in cal examiner records, interviews with families, school writings.) The school requests that and other sources. his parents ask a counselor to intervene, which leads to a psychiatric evaluation at Each aspect of the timeline is discussed further the Multicultural Center for Human Ser- in the following chapters, with an evaluation as vices. He is prescribed antidepressant medi- well as narration of events. cation. He responds well and is taken off the medication approximately one year later. PRE-INCIDENTS: CHO’S HISTORY 2000–2003 (High School) 1986–2000 Fall 2000 Cho starts Westfield High School 1984 Seung Hui Cho is born to a in Fairfax County as a sophomore, after at- family living in a small two-room apartment tending another high school at Centreville in Seoul, South Korea. He is an inordinately for a year. After review by the “local screen- shy, quiet child, but no problem to his ing committee,” he is enrolled in an 21 Gordon Declaration 00858 CHAPTER III. TIMELINE OF EVENTS Individual Educational Program (IEP) to 2005 (Virginia Tech) deal with his shyness and lack of respon- siveness in a classroom setting. Therapy Spring 2005 Cho requests a change of major to continues with the Multicultural Center for English. The idea for a book sent to a New Human Services through his junior year. He York publishing house is rejected. This has no behavior problems, keeps his ap- seems to depress him, according to his fam- pointments, and makes no threats. He gets ily. He still sees no counselor at school or good grades and adjusts reasonably to the home, and exhibits no behavioral problems school environment. Both the guidance other than his quietness. office in school and the therapist feel he was Fall 2005 Cho starts junior year and moves successful. back into the dorms. Serious problems begin June 2003 Cho graduates from Westfield to surface. His sister notes that he is writing High School with a 3.5 GPA in the Honors less at home, is less enthusiastic, and won- Program. He decides to attend Virginia Tech ders if the publisher’s rejection letter curbed against the advice of his parents and coun- his enthusiasm for writing and reversed his selors, who think that it is too large a school improving attitude. At school, Cho is taken for him and that he will not receive ade- to some parties by his suitemates at the quate individual attention. He is given the start of the fall semester. He stabs at the name of a contact at the high school if he carpet in a girl’s room with a knife in the needs help in college, but never avails him- presence of his suitemates. self of it. Professor Nikki Giovanni, Cho’s poetry pro- fessor, is concerned about violence in his 2003–2004 (Virginia Tech) writing. She also asks him to stop taking pictures of classmates from a camera held August 2003 Cho enters Virginia Tech as a under the desk. She offers to get him into business information systems major. Little another class and writes a letter to English attention is drawn to him during his fresh- Department Chair Lucinda Roy to create a man year. He has a difficult time with his record that could lead to removing Cho from roommate over neatness issues and changes her class. rooms. His parents make weekly trips to visit him. His grades are good. He does not Dr. Roy removes Cho from Professor see a counselor at school or home. He is Giovanni’s class and tutors him one-on-one excited about college. with assistance from Professor Frederick D’Aguiar. When Cho refuses to go to coun- Fall 2004 Cho begins his sophomore year. seling, Dr. Roy notifies the Division of Cho moves off campus to room with a senior Student Affairs, the Cook Counseling who is rarely at home. Cho complains of Center, the Schiffert Health Center, the mites in the apartment, but doctors tell him Virginia Tech police, and the College of it is acne and prescribe minocycline. He Liberal Arts and Human Sciences. Cho’s becomes interested in writing and decides to problems are discussed with the university’s switch his major to English beginning his Care Team that reviews students with junior year. He submits the paperwork late problems. that sophomore year. His sister notes a growing passion for writing over the sum- November 27 A female resident of WAJ files a mer break, though he is secretive about its report with the Virginia Tech Police content. Cho submits a book idea to a pub- Department (VTPD) indicating that Cho lishing house. had made “annoying” contact with her on the Internet, by phone, and in person. The 22 Gordon Declaration 00859 CHAPTER III. TIMELINE OF EVENTS VTPD interviews Cho, but the female stu- Before 11 a.m. A staff psychiatrist at Carilion dent declines to press charges. The investi- evaluates Cho, concludes he is not a danger gating officer refers Cho to the school’s dis- to himself or others, and recommends outpa- ciplinary system, the Office of Judicial tient counseling. He gathers no collateral in- Affairs. formation. November 30 Cho calls Cook Counseling Cen- 11-11:30 a.m. Special Justice Paul M. Barnett ter and is triaged (i.e., given a preliminary conducts Cho’s commitment hearing and screening) by phone at following his interac- rules in accordance with the independent tion with VTPD police. evaluator, but orders follow-up treatment as an outpatient. Cho then makes and keeps December 6 E-mails among resident advisors an appointment with the campus Cook (RAs) reflect complaints by a female resi- Counseling Center. dent in Cochrane residence hall regarding instant messages (IMs) from Cho sent under Noon The staff psychiatrist dictates in various strange aliases. E-mails also report his evaluation summary that “there is no that he went in disguise to a female stu- indication of psychosis, delusions, suicidal or dent’s room (the event of November 27). homicidal ideation.” The psychiatrist finds that “his insight and judgment are nor- December 12 A female student from Campbell mal.…Followup and aftercare to be Hall files a report with the VTPD complain- arranged with the counseling center at ing of “disturbing” IMs from Cho.