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THE LATEST
COMPLAINTS & JURY DEMAND
WILSON v. LAFAYETTE, CITY OF et al,
07-cv-02248
EXCESSIVE FORCE,
(USE OF FORCE & EXCESSIVE USE OF FORCE BY OFFICER WITH ELECTRO MUSCULAR DISRUPTION TECHNOLOGY DEVICE, (TASER))
WRONGFUL DEATH, PRODUCT LIABILITY
& PERSONAL INJURY CLAIMS
42 USC 1983
TIME LINE
2009 - July
PreTrial Conference pending Judge's Rulings on Motions for Summary Judgment and results of defendant's anticipated appeal.
June
Pretrial Conference Pending
May
Replies and Rulings on Motions
Counsel bounces massive files back and forth.
April
Linked University of Colorado Boulder, thru 97 CV 239, and Auraria Campus Police for the traffic case under Kratzer, on Ryan's birthday in 1998 for historical reference of Malicious Prosecution against Mom, and existing claim of Familiar Relationship.
March -
Defendant's object to any and all evidence against them, filing Motion's to Strike Wilson's Expert Witness, Deposition testimony and Exhibits attached to Responses to Summary Judgment, including their own Internal Affairs Interviews. Granted, this implies that the truth, as supported with evidence, is unconstitutional.
February -
27th: Seven Motions in Response to Defendants filed with court,
- Three Responses to Summary Judgment
- Three Responses in objection to defendents Motions
to exclude Wilson's Expert Witnesses- One Motion to Seal to comply with Rules of Civil ProcedureWilson's objection to Taser's Motion to delay PreTrial Conference was Denied. Now, the scheduled Pretrial Conference must be re set.
Motion for an Extension of Time, to respond to Defendants Motion's for Summary Judgment, was Granted.
Pretrial Conference Set.
January -
This is exhaustive... Mom filed Motion for an Extension in Time to respond to Defendants Latest Motions.
Erik Ziporin, lead counsel for defendants and designated attorney on assignment for the City of Lafayette & Chief Schultz, withdrew and Magistrate Judge Mix terminates Patrick Edward Rogers from case.
Preparing responses - three separate, one for each Motion filed by Defendants for Summary Judgment
Preparing Response to Taser's attempt to exclude Wilson's Experts.
Former Lafayette residents, witnesses to the Lafayette Police Officer, identified as John Harris, as the individual in an official capacity, a traffic cop, not part of the Boulder County Drug Task Force sting operations, or an informant for the department, spoke privately with Mom about mutual concerns, claiming Harris provided police protection for dealers in exchange for cocaine, accepting bribs in 2006, nothing short of Impersonating an Officer.
2008
December: Trial Prep Continues . . .
November:
Still Deposing Expert Witnesses -
Cardiologist: Wilson's witness deposed out-of-state by Taser
(1) Smaller measure of vein in heart does not indicate defect.
(2) Ryan's heart functioned properly, without incident, and
within normal limits for almost 23 years.
(3) Heart responded correctly to Taser application.
Defendants - Insurer declines Wilson's offer to settle.
October: Federal Judge Edward Nottingham Resigns under pressure
10-21-2008; Law Blog
September: Scheduling Settlement Conference.
August: Scheduling Expert depositions.
Murphy assigned as Judge to Adams County Court.
Mom's Law Firm, Pervis Gray & Murphy move from their downtown Boulder offices to new location.
Still messin' with me...
On August 4th of this year, the driver of an older model, restored, Burgundy colored, Chevy Pick-up Truck, flashed the high beams repeatedly while following within inches of my vehicle in Louisville, Colorado, at about 6:30 pm. Perhaps this guy is related to WMA driving a black truck/suv, CO plates, 547NAT, who flashed the high beams into my windshild while on-site, and on duty, as security officer in Las Vegas, NV at 4:20 am on the morning Ryan was killed.
Kratzer Family Historian Observes : Ryan Wilson case
Marina Data Solutions: Hank Kratzer, Managing Director
Mom's first cousin assists Los Angeles Police Department. "With the LAPD TEAMS II Development Bureau, Hank has worked with LAPD and LA City employees to implement an ad-hoc Cognos environment focusing on the Use of Force System (UOFS), Complaint Management System (CMS), and Risk Management Information System (RMIS). "
July: Review, Summary Judgments anticipated, Preparing responses to Summary Judgments
DEPOSITIONS SCHEDULEDJune: Forensic Pathologist for Arapahoe/Boulder County Coroners, Boulder County Drug Task Force Officers, Kurtz, VescoMay: Mom, Dad, and Lafayette Police Chief Chie Paul Schultz.April: Rick Smith, CEO, TASER Intn'l; Harris, Lafayette PD; and, Lanphere, Louisville PDMarch: Emerson, Lafayette PD; and Adair, the Civilian Ride-Along02/25: Scheduling Depositions01/24: Legal Interpretation of Findings & Developing Strategies01/22: New experation date for Discovery.
01/07: Unopposed Motion for an Extension in Time for submittal of Plaintiff's Response to Request for Disclosure of documents, Discovery filed.
01/07: Responses to Interrogatories and discovery due .
2007
Questions, questions, questions... Five sets of interrogatories and discovery to ask and answer keeps us busy, along with production of documents during this Holiday Season when we would much rather be relaxing with our son.
Mom's Settlement Conference vacated due to consolidation.
Mom & Dad join forces, consolidate cases.
Response to Defendant's Motion to Dismiss, Disclosures and Scheduling Order filed on time with approval.
Boulder's Judge Sanstead Denied the Probate Motion for Reconsideration.
10-19: Motion for Reconsideration file in Probate matter
10-15: Michael J. Thomson Entry of Appearance
10-12: Magistrate Judge Mix Granted Mom's Motion for Extension in Time to Respond to Motion to Dismiss, but Denied the rest.
Depositions to be administered in her Court Room.
10-12: Mom signed with Mike Thomson, Esq., of Purvis, Gray & Murphy, LLP, A Boulder Law Firm specializing in Governmental Liability, Personal Injury, Constitutional Law and Civil Rights.
10-11: First Court Appearance, Mom Entered Motion for Extension in Time to Respond to Defendant's Motion to Dismiss and all other Matters
10-04: Scheduling Order filed
09-24: Court Ordered Reponse to Motion to be file by 10-24.
09-24: Responses filed, along with defendant's Motion to Dismiss citing among other defenses, the GIA as an excuse to kill Ryan.
09-20: Parties met for teleconference re: Setting of Scheduling Order, Order due in Court October 4th, First appearance in Court October 11th.
09-07: Court Order Granting Extension of Time for Responses
09-07: Defendant Harris, Motions for an Extention of Time in which to respond to Complaint delivered on August 20th.
09-06: Informed of Order referring case to US District Court Magistrate, from the Honorable Edward W. Nottingham pursuant to 28 U.S.C. Section636(1)(A) and D.C. Colo.LCiv 72.1
09-05: Informed of change in Defendant's representatives who are requesting an extension of time in which to respond to the Complaint & Jury Demand.
08-23: Return of Service lodged with Court.
08-20: Denver Boulder Couriers delivered Summons, Complaint and Jury Demand for the city of Lafayette, Lafayette Police Department, Chief Paul Schultz and Officer John Harris upon the Secretary, Julie Robbins, for Bill Hayashi, Esq., of Windholz & Associates, the law firm under contract for the city of Lafayette.
08-17: Cover Sheet and Summons filed with Court
08-08: Unable to blog on to respond to local, Daily Camera News paper, established alternate log-on, mom@rhythmforcedmelody.com
08-07: Sgt Palmer informs Wendy that previous records relating to alleged traffic offences on 08 April 96 were unavailable as are any details regarding the CO plate, 547NAT, without violating dept policy.
08-06: Mom initiates rhythmforcedmelody, Ryan's former email address. The website is intended to provide informational support for interested parties, links to www.ryanmichaelwilson.com
08-02: Mom files claims in Boulder District Court
08-01: Father's attorney files claims in Boulder District Court
07-23: Uncle Eli establishes ryanmichaelwilson.com
07-19: Lafayette Police Department releases Internal Investigation
06-19: OSO, Public Records Request to BL County Drug Task Force
06-14: WKW, Public Records Request to Louisville PD
06-07: OSO, Public Records Request to Boulder County Sheriff
06-04: OSO, Public Records Request to Louisville PD
05-25: WKW, Public Records Request to Louisville PD
05-21: WKW, Public Records Request to Louisville PD
01-31: Notice of Intent(NOI), pursuant to CRS 24-10-109, sent
2006
10-16: Received Copy of Boulder District Attorney's decision
09-25: Certificate of Death stamped for distribution
09-22: Arapahoe County Coroner amends autopsy report
09-20: Lafayette News publishes article saying Boulder County Coroner, Tom Faure, determined the number one cause in the death of Ryan Wilson, as application of Taser.
09-19: Boulder Coroner, Faure, writes cause of death is undetermined. Ryan did not die of natural causes nor was his death an accident.
09-14: Toxicology Report is Negative for any trace of drugs or alcohol in Ryan's blood or urine. Arapahoe County Coroner amends autopsy report
08-16: Lafayette News: Lt Steve Pentup, Boulder County Drug Task Force cannot confirm allegation of Chief Schultz that Ryan admitted to growing marijuana plants from seeds.
08-08: Boulder County Paramedics Service Invoice arrives in the amount of $2,159.00
08-07: Ryan's Grandfather, PLK, shows his mother, Wendy, a death certificate with the name, Wendy Kratzer printed on it.
08-06: Pete Lilly, BL Coroner's office:
1) Confirms storage of the body of my son.2) Ryan was subject of DEA Sting Operation3) Ryan ran from a marijuana grow4) Lafayette Police Officer shot Ryan with a Taser5) Ryan immediately fell, convulsed and died6) He,(Lilly) found a small folding knife in the front pocket of the pants Ryan wore.7) Ryan's heart was sent to the East coast for an examination 8) No organs were harvested for donation9) Autopsy scheduled for Monday, August 8th.08-05: Donor Alliance Records/Clinical Summary:
1) CPA S/P Tazing by police, down time approx 60 min2) EMS-No rhythm in field,3) pronounced dead in ER08-04: Exempla Good Samaritan Hospital Report: Dr. James Rook
Time 2355: Ryan's body released to Pete Lilly
2345: Lilly dates Post Mortem Checklist as 8/3/062240: Lilly accepts case, assumes custody of Ryan's body, dates report 8/3/062225: Lilly, BL Coroner's office, arrives at hospital08-04: 2142: Email from Ryan, rhythmforcedmelody, arrives
2130: Pete Lilly reports an August 3, 2006 contact call2050: Hospital reports contacting Pete Lilly, coroner's office 2005: DT Robert Howard, BL Drug Task Force, takes charge of Ryan's body and belongings. Howard dates report 8/3/06 and inventoried Ryan's personal property as follows: clothing, scissors, bottle caps, and shoes.
1942: Ryan, in full cardiac arrest, arrives at the hospital1905: Lafayette Officer Harris shoots and kills Ryan 08-04: 1552: Ryan sends email to me, accepts invitation to join me
1435: Louisville PD/BL Cnty Drug Task Force Officials confer via email, Subject: Marijuana Grow0420: WMA driving black truck/suv, CO plates, 547NAT, flashes high beams into my windshild while on-site,
and on duty, as security officer in Las Vegas, NV.
08-03: BL Cnty Drug Task Force spokesman, Lt Steve Prentup
acknowledges awareness of resident complaint of marijuana grow operation. Eleven benign seedlings growing on private property 1300: Louisville Police Officer Gordanier informs Dt Kurtz of outdoor Marijuana cultivation activities. Agency detectives: Vesco and Kurtz establish an undercover sting operation.Wearing street cloths, neither Officer identified themselves or commanded Ryan when he was within range to hear them.07-29: 18:56:59: PST, hell of a summer arrives in my inbox
12:56:59: PST or 11:57MST(1157): Ryan sends Email Subject: hell of a summer1235: Louisville PD confer online, thru email. Subject: Extra Patrol
