Officer Kristofer Aho

October 24, 2018

Case No.:  OU18-1445

Q = James Riley   

A = Officer Kristofer Aho

Q.        I am James Riley of the Washington State Patrol.  The date is October 24, 2018, and it is 1:05 p.m.  The OPS case number is OU18-1445.  I am interviewing Officer Kristofer Aho.  This purpose — this interview is for the purpose of discussing administrative allegations lodged against an employee.  This interview is taking place at the Washington State Patrol office in Hoquiam.  Also present during this interview is Detective Sergeant Ethan Wynecoop.  Detective Sergeant Wynecoop, do you understand this interview is being recorded?

                        SERGEANT WYNECOOP:  I do, and Wynecoop is W-y-n-e-c-o-o-p.

Q.        And Officer Aho, do you understand this interview is being recorded?

A.         I do.  Officer Aho.  Aho — A-h-o — I’ve been with Shoalwater for six and a half years, so —

Q.         Okay, could you please state your full name, first and last, and spell your first name?

A.         Yes, uh, Kristofer Aho.  K-r-i-s-t-o-f-e-r.  

Q.        Okay.

A.         And last name, A-h-o.    

Q.        Thank you.  Do you understand this interview is being recorded?

A.         I do.

Q.        Thank you.  As a member and/or employee of Shoalwater Bay Tribe, you are required to full cooperate with this investigation, to answer all questions asked of you truthfully and completely.  Failure to follow this directive shall be considered insubordination and may result in discipline up to and including termination.  Do you understand? 

A.         I do.

Q.        Thank you.  During the interview, do you want us to call you Officer Aho, Kris, Kristofer.  What works best?

A.         Uh, Kristof, Kristofer, Officer Aho, Aho.  Anything like that is fine, yeah.

Q.        Okay, all right, so Kristof, how long have you been employed by the Shoalwater Bay Tribal Police Department?

A.           Uh, I’ve been employed with them since June 11, 2012, so about six and a half years now.  

Q.         And what’s your current assignment?

A.         Uh, I’m a patrol officer.  

Q.        And how long have you worked as a patrol officer?

A.         Uh, for the whole six and a half years.

Q.         Could you briefly describe your job responsibilities?

A.         Uh, I run traffic, uh — investigate if we have, you know, burglaries, things like that, uh — cover all day to day.  I’m usually a solo officer, uh — responding to calls, making contacts with the public, uh — we provide security for the bank runs for the casino.  Things like that. 

Q.         Who’s your current supervisor?

A.         Uh, currently I’ve been instructed that it’s Robin Souvenir.  Uh, our chief.

Q.         Okay, and prior to the chief being your supervisor, who was your supervisor before that?

A.         Before that, it was Lieutenant Padgett.  Uh, Matthew Padgett.

Q.         And during what timeframe was Lieutenant Matt Padgett your supervisor?

A.         Uh, he’s been my supervisor for — since I started.  He was a sergeant since I began, and about a month ago I received an email — about a month ago I received an email from Chief Souvenir stating that he would be our immediate supervisor as of that moment, and to direct any questions to him.

Q.        Could you describe your relationship with Lieutenant Padgett both personally and professionally as you may have them?

A.         Yeah, uh — he’s been my sergeant and — or first my sergeant, and then my lieutenant, uh — for — since I worked with Shoalwater Bay.  Uh, I’ve only known him since I worked there.  Uh, we definitely have ups and downs.  He’s very much — you know, there’s some days when we get along great and — you know, I feel like anything I ask would, you know, be no problem at all, and other days when I feel like if I asked for a box of tissues, he would tell me that I had screwed up on a case, so —

Q.        So, do you have just a — do you consider your relationship simply professional or also do you have a personal relationship?  Do you do stuff outside of work?  Hang out?

A.         Uh, we’ve never hung out outside of work.  We do talk on the phone sometimes about, oh, what’s going on — we’re both big Disney people so whenever he goes to Disneyland we always talk about that, or we’ll talk outside of work, but we’ve never hung out outside of — at the department or at Shoalwater, so —

Q.        Can you please describe the work environment, uh, at the office?  Most specifically the interaction between the officers in your own words?  How would you describe that?

A.         Uh, yeah, uh — currently we — we have five, uh, people that work there, uh — Chief Souvenir, Padgett, myself, uh — Chris Boggs — or Officer Chris Boggs and Officer Sarah Boggs, and, uh — it’s — we definitely have good days, we have bad days.  Currently for me it’s — everything’s been good since before I left for paternity leave.  I just got back, I was gone for the entire month of September, so that was — I mean it’s the best way to work there is, but since I’ve gotten back, I personally have had no problems with anyone.  Uh, in the past, I have had issues with feeling bullied by Lieutenant Padgett.  And at different points during my career, there have been different incidents, uh — we — I feel like with everyone there’s days I like them better than I do other days.  I feel like Lieutenant Padgett — it’s a heavier swing.  When he’s upset with you, you know it, and so — but everyone else, we — there are things we definitely don’t agree on and we don’t hang out outside of work, but I can work with anyone in the department.  And make it work.

Q.        So specific to your relationship with Lieutenant Padgett, I think you mentioned you worked with him, uh, except most recently over the last month, for about six and a half years.  Him being your sergeant and lieutenant.  Uh, has your relationship with lieutenant and/or potentially then Sergeant Padgett, has that changed overtime and if so, how?

A.         It’s — it wouldn’t — uh, we’ve been — we’ve become, uh — I feel like we’re — we talk more.  We’re definitely, you know — we’re a little bit closer than we were when I started, but there were definitely times when I feel like he’s, you know — he’s pissed and, you know, he’s going to take it out on me.  I said before that he feels like he has favorites and so at times I feel like I’m the favorite and I can do just about anything, you know — anything I ask, if I say hey, you know, I want to take six weeks off, he’d be like oh, yeah, we can make that happen.  We’ll flip this around and then you only have to use that much vacation and we can make it work best we can and other days I’ll say, you know, hey, I need a sick day, my son is sick and he’ll tell me well you have to come in and cover.  

Q.       Do you believe that the favorites as you described them —

A.         Yes.

Q.        — uh, change?

A.            Yes.  Uh, when I first started, uh — it was myself, Officer James Wells, who’s currently with Montesano Police Department, and Officer Dan Matthews, who’s with the Westport Police Department, and Dan and I started within a week of each other, and James or Jimmy, uh, had been on for about a year and a half before that, and Jimmy was definitely the favorite at that point, uh — and throughout his time until he left — I started in June and Jimmy left in, I believe, December of that year, and then while Dan and I were at the academy, we hired Officer Lucas Stiegel (ph) — or currently Sergeant Stiegel with the — uh, with South Bend Police Department, uh, and Lucas came in — Lucas and Matt are friends, as far as I know, outside of work, and he was definitely the favorite, and then Officer Matthews was let go not that long after we can back.  Well, no, we came back, it was about — I forget how long it was.  After he got let go, we hired Officer Chris Boggs — let’s see, was that — no, Officer — it was — Lucas left, then we hired Chris, and while Chris was at the academy, Dan was let go, then while Chris was still at the academy, we hired Sarah, and during that time, I’ve seen when Sarah’s been the favorite, I’ve seen when Chris has been the favorite, and I’ve seen when I have been the favorite.  Uh, when it was down to just me and Robin and Matt, I was decidedly the favorite, and it didn’t matter what I did, they were going to make sure they did everything they could to help me and I was — I was well loved at that point, and there’ve been other times when I’ve really just been horrible, uh — I considered leaving at one point.  I actually interviewed with, uh — the state parks and, uh — during that time, it was — I felt not wanted at all.  I felt like I was being pushed out the door.  Uh, at different points, I’ve been told by Lieutenant Padgett that, you know, if we ever tried to leave, he would bury our career, and he said it to me, he said it to other officers, and he generally would say it and then say oh, you know, I was just joking and never gave the impression that he was joking.  And then other times he would say it and then it’d be brought up later and he’d say oh, I was just joking when I said that, which —

Q.        So do you — do you — when you’re talking about this favorite — is it specific to Lieutenant Padgett or does it involve — I mean, is — when you’re saying I’m the favorite, are you — are you —

A.         Yes.

Q.        — thinking in your mind, I’m Lieutenant Padgett’s favorite?  Or are you thinking of the lieutenant and the chief?

A.         I think the lieutenant much more so.  I think the chief is, uh — you know, he likes all of us, you know.  We have days where we get along better than others, but I don’t — I don’t ever feel like — I have felt like a few times — where felt like chief just didn’t want me there, but I feel like Lieutenant Padgett really has favorites.

Q.        Is it fair to say that the chief has acted in your time there relatively consistently with how you respond to —

A. Generally.  Uh, I feel like there are some people in our department that feel like you know, he’s really come after them at different points.  I’m — I do fairly well at — he and I get along well, so I know — I’ve heard other people say they felt like he was coming after them for different things, so —

Q.        Okay, so the — uh, the information that we have is that you provided a letter to the, uh — to your HR.  Is that accurate?

A.     Yes, that’s correct.

Q. So what I have is a letter that appears to be written by you.  Uh, could you take a look at that and see if that’s the letter that you provided to HR?

A. Yes.  Yeah, that’s my letter.  Yeah.

Q.        Thank you.  Could you do me a favor?  With that being your letter, could you just initial and date at the bottom of that for me, please?

A.         Yep.

Q.        Thank you very much. 

A.         Yeah.

Q.        All right, so I’m going to talk to you about a number of incidents, uh —

A.         Okay.

Q.         — as we go through this and get your — get your, uh, recollection, knowledge, and insight.

A.         Okay.

Q.        So, the information that I have is Lieutenant Padgett has referred to a nurse who worked at the Willapa Harbor Hospital as a fucking cunt.

A.         Yeah.

Q.        Uh, do — do you know about that?  If so, please explain.

A.         Uh, I know he’s used that term at different times.  I can’t say specifically — I — I know I’ve heard it and I’ve been there when he’s said it, but I’ve gotten accustomed to it and for the most part tune it out so I don’t pay attention to what he’s talking to — I know he’s mentioned a few different females, I’d say.

Q.        So do you — specific — specific to the nurse at Willapa Harbor Hospital, do you recall specifically the lieutenant calling her a fucking cunt?

A.        I don’t remember that incident specifically.

Q.        In responding, you had mentioned a couple of things of note.  One, hey, I’ve become so accustomed to it.  Why do you say that?

A.   Uh, I feel like if he’s —

Q.        He being who?

A.         Uh, Lieutenant Padgett.  If Lieutenant Padgett feels strongly about something, he’s never afraid to say his opinion.  He is very honest about what he thinks about everyone and anyone and at different points, he’s referred to different members of the tribe and different people in conversation as a cunt.

Q.        Can you provide some specific examples to your recollection of who he would have called — referred to as a cunt?

A.         Uh, I believe — I remember one time when we were talking and we were speaking about, uh, [Name taken out] (ph), who’s —

Q.         Who’s that?

A.         Uh, [Name taken out].  She works for the tribe.  She’s the special projects manager.

Q.        [Name taken out]?

A.         Yeah, and he said something — or [Name taken out] had — let’s see, what was — what was it about?  I believe they were repaving, we were doing new — they were doing drainage ditches near our department, towards the entrance, and [name taken out], you know, came over and talked to me and said hey, you know, can you guys make sure not to drive on this part of the pavement because it still needs to drive, we don’t want it to crack, and I said yeah, sure, and when I told Lieutenant Padgett, he said oh, you know, she’s a cunt.

Q.         Can you — uh, on that one instance, who was present when that happened?

A.         I believe myself and Lieutenant Padgett. 

Q.        And can you describe, uh, the lieutenant’s tone of voice and demeanor?  I mean, was he joking, was he angry, frustrated, whatever?  How did it come across to you?

A.          Uh, it seemed more frustrated — or just annoyed with her for asking us not to do something.  

Q.        Is the way that the lieutenant made that statement, uh, calling [Name taken out] a cunt in whatever context he did — what that derogatory in your opinion?

A.         Yes.

Q.        Do you believe that this action or statement by Lieutenant Padgett was threatening, bullying, or harassing?

A.         Uh, not to me personally for that — for that specific statement.  No.  I — for me, I mean, I was witness to it and it makes me uncomfortable that, you know — to use that — that’s one of the terms that you just don’t use in my opinion.  That — and so for him to say it and — it just didn’t seem like — you know, she was asking us not to drive on something, and I can’t remember specifically if there was anything else to it, but it just felt like it was really jumping up the — you know — you know, oh, she asked us not to drive on this, like — you can say oh, man, you know, why is she complaining about that?  But — so — to use that term is overkill, I think.

Q.        So I had a couple of things and I was on one — which is a follow up of using the word.  Can you think of any specific instance where Lieutenant Padgett has used the word cunt individually or in a phrase, and applied it to anyone in an instance and if so, please provide that.

A.         Yeah.  Yeah, I can’t say for certain of other times.  I — I can remember him saying it at other times and referring to different individuals, but I can’t say a specific — or one specific incident so —

Q.        And so the number two on my follow up questions to your original statement is you had said it happens so many times I just tune it out.

A.         Yeah.

Q.         Can you explain that?  

A.         Yeah, uh —

Q.        So many times — how long and what environments and who’s present?  How do you get immune to something like that?

A.         Yeah, uh — generally if he’s going to say something like that, it will be when it’s just —

Q.        He being who?

A.         Uh, Lieutenant Padgett.  When Lieutenant Padgett is going to say something — if he’s going to speak in a derogatory term about someone, he’ll generally do it in the office, uh — with just officers around.  Uh — I can’t say that I’ve heard him say that around the public, uh — but yeah, in the office, or possibly if we’re roadsiding and it’s just the two of us, he might say it.  

Q.        And when you describe officers, does that include the chief?

A.         Uh, I can’t say with 100% certainly whether he said it in front of chief.

Q.        Okay, the information we have is Lieutenant Padgett made lewd comments about [name taken out] when she was being measured for a uniform.

A.         Yes.

Q.         Do you know anything about that?

A.         Yeah, I —

Q.    Please explain.  

A.         While I was in there — we were all in the — all in the officer’s room —

Q.        All — all of us? 

A.         Uh, the whole department, so myself, Lieutenant Padgett, Chief Souvenir, uh, Officer Sarah Boggs and Officer Chris Boggs, and [name taken out] as well.  Who was currently ride along — she was interested in trying to become reserve, and [name taken out] was wearing jeans and — which were very tight fitting jeans, uh — and Lieutenant Padgett made comments about, uh, the jeans and if she’d be able to, I believe, fit into a uniform or if the jeans were painted on or — comments about, you know, her pants and Savanna Walker is — you know, she’s a young, fit girl and is — yeah, she — yeah, is — I don’t know — I don’t know how to say this.  Uh, she’s — she’s an attractive girl and she’s got a large hindquarters so it is very much noticeable if she’s wearing tight jeans.

Q.        Uh, in what tone did the lieutenant make those statements?  And if you can specifically provide some clarity on what he said to the best —

A.         Yes.  Uh, to the best of my knowledge, it was, you know, about her getting fitted for the pants.  I don’t remember the specific comment.  Uh, it was — I believe he meant it to be joking around when he was saying it, uh — it was inappropriate.  I think.  That’s — you know, she was trying to come on as a reserve and it was, you know — making any kind of comments like that, I’m — [name taken out] rode with me quite a few times and I really was always — you know, and I told her many times, you know, I want thank you to feel comfortable.  If I say anything that makes you feel uncomfortable, please let me know or, you know, tell someone else.  I don’t want you to feel uncomfortable in this car.  This is — you know, I said I’m an officer, and there are times when I will say stupid things and I said if I do, please call me on it immediately.

Q.         And when did this incident happen?

A.         That would have been — let’s see, before we got our vests — uh — I gave [name taken out] a ride last — that was —

Q.         You can just give an estimate to us.

A.         Yeah, at least six months ago, so — whenever — before we got our new TAC (ph) vests and uniforms now, so — it would have been — let’s see, it would have been before — before September of 2017.  

Q.        Okay.

A. So — Q. Thank you.

A.         I know that much.

Q.         How did Savanna respond?

A.         Uh, she seemed to mostly brush it off.  Uh, didn’t really have much of a response to it that I can remember.

Q.        You don’t recall if she said anything verbally?

A.         I don’t, and —

Q.         Her physical body language indicated what to you?

A.         I don’t think she was super comfortable with it, but — that’s my opinion and yeah, I’m — I don’t know how she felt, uh — she didn’t say anything about it to me afterwards, and so I didn’t want to bring it up and make her feel uncomfortable.

Q.        Fair enough.  The information that we have is Lieutenant Padgett stated Savanna doesn’t have to wear business casual because she looks hot in stretch pants.

A.    Yeah, that sounds about right.

Q.         Please explain that.

A.         Uh, yeah, she was wearing, uh — I believe tight jeans and —

Q.         She being?

A.         Savanna Walker.

Q.        Okay.

A.         Yeah, I believe she was wearing tight jeans when she came in and had been contacted earlier in the day, saying hey, we’re doing fittings for uniforms, can you come in at this time to our officer’s meeting so you can get fitted, and the rest of us were all in uniform, and so — yeah.  That sounds about right, what he would have said so —

Q.         Who — to your recollection, when the lieutenant made that statement, who was present?

A.         I believe, uh — myself, Lieutenant Padgett, Chief Souvenir, Officer Chris Boggs and Officer Sarah Boggs, and [name taken out] as well.

Q.         Did anyone do anything or say anything?

A.         I don’t believe so.

Q.         Thank you.  The information that we have is Lieutenant Padgett —

A.         Oh, and also, uh — the — I forget his name, but whoever was doing the fittings for us for Bratwear (ph), I believe.  

Q. Thank you.  The information that we have is Lieutenant Padgett ridiculed and laughed at officers during interview training which he had prepared for you?

A. That’s correct.

Q.         Please explain that.

A.         Uh, we had talked to them about —

Q.        We?

A.         Because — uh, myself, Sarah Boggs and Chris Boggs talked to Chief Souvenir and Lieutenant Padgett about possibly doing some interview training because we’re a very small department, we don’t spend a lot of time doing, you know, very in depth interviews.  Most of our interviews are witnesses and things like that, and so doing an interview with a suspect is not something we’re getting a lot of experience with, so we had asked about possibly doing some more interview training.  We felt like that would help us, and they agreed and, uh, Lieutenant Padgett and Chief Souvenir agreed they could help us do that, and we went — during an officer’s meeting, into the tribal center, and they set up and gave us some scenarios —

Q.        They?

A.         Uh, Lieutenant Padgett and Chief Souvenir, and Lieutenant Padgett was going to act as our suspect during, uh, our practice interviews.  And so he would sit across and then give us a quick rundown and we would interview him and he would dodge the questions and, you know, be a less than cooperative suspect, and I would first, uh — after I got done, I — you know, asked some questions, he kept denying things, and — you know, giving a — uh, more of a hostile witness — or hostile suspect to deal with that, you know, he wouldn’t — wouldn’t answer questions and wouldn’t — you know, was not being helpful and finally I said okay, I’m done, and he said oh, don’t you want to ask anything else?  And I said no, I’m done and I — I turned and moved back to my chair and finished my interview, uh — and then —

Q.    What was your demeanor like then when you were done?

A.         I was upset.

Q.         Angry, frustrated, upset?

A.         Yeah, I was — I was upset, uh — I went over and, uh — just sat and I said I’m done and — you know, he said oh, don’t you want to ask some more — nope — nope I’m good, and I — I was not professional at that point, I don’t think.  I think I was being an asshole right back, because I was pissed off and so I went over and sat down in my chair and I said I was done.  And Lieutenant Padgett laughed about that, and then he said oh, who’s next, and I forget if Chris or Sarah went next, but one of them went and we went through it and it was the same type of thing for him — you know, that he was not going to give any information.  Well, sorry, before we — before the next person went, Chief Souvenir asked us if there anything that we felt went well, anything that we felt we could have improved upon and asked the group if they had anything they noticed and, uh — Sarah and Chris and I all tried to say oh, you know, I saw this, this was good or — you know, uh — and Lieutenant Padgett pointed out our mistakes, and I honestly don’t remember what he pointed out about me doing wrong — I was very frustrated, I was checked out and done.  I got to a point where I was tired of him doing that kind of crap and so then we went on and Sarah or Chris went and we did it and when we got done, Lieutenant Padgett was laughing about how, you know, none of us could get him to admit to what he had done and, you know, what was going on and all of us you know, had failed at —

Q.            How did that make you feel?

A.         Oh, it made me feel horrible.  Uh, horrible and angry.  It made me mad, because we were doing a practice scenario and your plan was you’re going to be a suspect that’s not going to give up any information.  And that’s great, you know, if you’re — if it’s a practice scenario and you don’t want to give up information, you don’t have to.  You — we aren’t learning anything from that and this is after we had all gone to the read training and so we were trying to do that, and Lieutenant Padgett thinks of himself of being one of the greatest interviewers of all time and —

Q.      Why — why do you say that?

A.         Oh, because he’s told me, so — uh — but he really prides himself — and I have seen him do interviews that I do feel like he gets more information — he’s got more experience doing it and really has an interest in asking questions and trying to figure those things out, but the way he goes about it is to ridicule you for oh, you should have asked this or you should have asked that.

Q.         Do you feel ridiculed?

A.         Yes.

Q.        Do you —

A.         I felt like, uh — myself, Chris, and Sarah were all as a group being put down that, you know, we had a lot to work on.

Q.        Do you believe these actions and statements by Lieutenant Padgett as you have described were threatening, bullying, or harassing?

A.           I feel like it was bullying.

Q.         How so?

A.         Uh, just to go into a training situation with a plan that you’re going to train us by not providing us any information, and I feel like if you’re in a training situation where you’re practicing interviews, you want to show the person you’re training how to succeed and I felt like this was set up on being trained on how he was better at hiding things than we were at
asking questions.  

Q.        Thank you.  The information that we have is Lieutenant Padgett talks about his testicles, referring to them as big, hairy balls.

A.         Yes.

Q.         Please explain.

A.         Uh, on multiple occasions, he’s referred to his own genitals as big, hairy balls, and you know, he’s got such big balls and that’s why he’s in charge.

Q.        Uh, can you provide a specific example of, you know — when he made those statements, who was present, what the context was?

A.         Uh — yeah, I wouldn’t be able to provide a specific — I — I’m — Q.    How many times do you think he’s referred to “his big, hairy balls”?

A.         Uh, I would say at least 50 times over the course of my career.

Q.        And is it in the context of — these are in my words, me, James —

A.         Mmm-hmm. 

Q.        — hey, I’ve got the balls to handle this job, or is it — is it in a sexual context, let’s say, like — I have — my balls are big and hairy, or is it both?

A.         I believe more than anything it’s in the context of you know, I can do this job, this is why I’m in charge.  That’s what impression I’ve gotten from it, so —

Q.        Do you believe this — these statements made by Lieutenant Padgett are threatening, bullying, or harassing?

A.         Uh, I feel like the way that he — he makes statements like that that you know — he likes to put other people down and say, you know, that dad will come and fix it and he’ll refer to himself as dad, Lieutenant Padgett will, and that dad needs to step in and fix this problem because you screwed up.

Q.        So, to clarify, he’s, like, referring to himself as dad in third person —

A.         Yes. 

Q.         And telling you about how “dad” is going to come fix it?

A.         Yes.

Q.        But he’s talking about himself?

A.         Yes.  Yeah.

Q.        The information that we have is Lieutenant Padgett has stated comments such as if you apply for another job, that tells me you’re unhappy here and you will be done.

A. Yes.

Q.        Please explain that comment or any comments to that nature which —

A.         Okay, yeah —

Q.         — you’ve already talked a little bit about during the interview.

A.         Yeah, uh — he’s at multiple times during my career told us — uh, myself — I believe he’s said it to Sarah Boggs, I believe he’s said it Chris Boggs, I know he’s said it to Dan Matthews.  I don’t know that he ever said it to Lucas or Jimmy, but I think to the rest of us he’s said it — if you’re applying for another job, you are done here and he’ll make sure to get rid of you, and he’s also told us — and I know specifically with myself and Officer Matthews first that if we ever applied somewhere else, immediately following Jimmy, uh — Jimmy Wells left our department and took a job with Jefferson County and right after Jimmy left he told us in an officer’s meeting — was it in an officer’s meeting?  It was either in an officer’s meeting or it was just him and Dan and myself.  I can’t know for certain who was there, uh — Chief Souvenir may have been there.  I’m not 100% on that.  But multiple times told us that if we ever applies somewhere else, he would bury our law enforcement career and we would never get a job anywhere.

Q.         What, uh — how did you interpret that statement?

A.         Oh, I interpreted it as a threat, that if I tried to go somewhere else, that he was going to do what he could to keep me from getting another job and get me fired.  

Q.         Is it your belief that he had some ability to potentially do some of that?

A.         Uh, as a new officer, I was under the belief that if I tried to go somewhere else in Pacific County, that he knew enough people in Pacific County that he would say things about us as an officer that — to try and hold us from getting a job.

Q.        Uh, please describe his tone of voice and demeanor when he stated — made those statements.

A.         Uh, it was very threatening, uh —

Q. Consistently threatening when he made it?

A.         Consistently — at — different — at sometimes, he would make the statement to us and pretend like it was a joke and it would come out threatening and he’d say oh, I’m just joking.  But other times —

Q.         Was it your belief that during those times that you’re describing it was a joke?

A.         No.

Q.        What did you believe?

A. I believe that he was threatening us and tried to cover it up and had said it and then thought well, I probably shouldn’t say that so I’ll tell them it was a joke.

Q.        The information we have is Lieutenant Padgett stated I know the benefits of working four 10s and you guys are not worthy.

A.         Uh, yeah, that was in an officer’s meeting.

Q.         Okay, what did he say?  Give some context to it if you could.

A.        So, uh — there was Chief Souvenir, Lieutenant Padgett, and myself.  Sarah Boggs and Chris Boggs were all in a meeting and we had asked — currently myself, Sarah, and Chris all work five eights, and Robin and Matt both worked four 10s, and we had asked about switching our schedule to four 10s, and, uh — and we’d gone through this before, uh — actually at one point, when Officer Matthews — Dan Matthews and Lucas Stiegel were working for our department, uh, we had sked about going to four 10s and Lucas went to four 10s with Sunday, Monday, Tuesday off, and Dan went to four 10s with Tuesday, Wednesday, Thursday off, and I stayed on five eights, and I was told I’d have weekends off, and I had Friday, Saturday off, and I told them you know, Friday, Saturday is not the weekend, and I was left on five eights, so — and then I was told that just the way it works out with five people, we can’t have four 10s, we won’t have the coverage, uh — it was brought up — it’s been brought up a couple times at different points — we’ve said hey, you know, we’d like to look into having four 10s, and at this officer’s meeting where this statement was made, uh — Lieutenant Padgett — or, I believe it was Sarah or Chris had said you know, we — could we look into us having four 10s and — or, you know, why do you guys have four 10s and we don’t?  And Lieutenant Padgett said, you know — yeah, I know — or, no, sorry, hold on.  Okay.  Because it was stated that — by one of the patrol officers, myself, Sarah, or Chris, that you know, four 10s were — has been proven to be better for officers.  It’s — you get more time off, you’re — you know, it’s easier to — when you take a vacation, you get an extra day, it’s nicer for us and Lieutenant Padgett had said that no, we’re not going to four 10s and he knew that four 10s were better, that’s why he’s on four 10s.

Q.         How did you — how did he make the statement?  What tone of voice and what —

A.         Uh, as though he was speaking down to us.  That we were — as though we weren’t, you know, smart enough to figure out that, you know, yeah, we wanted to have four 10s and he was telling us yeah, it is better.  You can’t have it.

Q.        And did you take this statement made by Lieutenant Padgett as threatening, bullying, or harassing? 

A. Oh, I felt like it was bullying.  It was — it felt like he was in a position of power and he was telling us, yeah, this was better, you can’t have it, because I don’t want you to.

Q.        Thank you.

A.         And he — his explanation was that we don’t have enough officers to have a four 10s schedule and that our, uh, coverage would be lacking if we had a four 10 schedule for everyone.  

Q.        The information that we have is Lieutenant Padgett stated this is an at will position.  You can be fired for the color of your eyes.

A.         Yes.

Q.         Please explain what he said, uh, and where you were at, who was present.

A.         I believe that was myself, Sara Boggs and Lieutenant Padgett, and I believe we were in his office, and I don’t remember the context of why it came up, but I do remember him saying — uh, and I don’t know specifically about the color of your eyes, but I know before he has said to me that this is an at will position and you can be fired at any time, for any reason.

Q.             In what context is that statement made?

A.         Uh, it feels like a threat to me.  That — and a lot of the times, that will follow up — or be in the same context of a conversation about if you try to leave, I will bury your career.

Q.        And do you believe those statements made by lieutenant — Lieutenant Padgett are threatening, bullying, or harassing?

A.         Uh, yeah, I believe it’s threatening, and bullying and — yeah, it’s — I mean, yeah, probably harassment too.  I mean, I don’t feel like it’s as much harassment, I just felt like it’s more a threat from a bully that, you know — I’m in a position of power and you are underneath of me. I can do what I want.  

Q.        Thank you.  The information that we have is Lieutenant Padgett stated I’m constantly receiving complaints about you all day and night.  You’re lucky I’m such a great guy and you still have a job.

A.         Yes.

Q.         Please explain that. 

A.         Uh, I’ve gotten that one multiple times since I’ve started.

Q.        That one being —

A.         Uh, that same statement of him receiving complaints 24 hours a day, uh — and how 24 hours a day he’s answering emails, he’s answering calls about the complaints of the officers and everything we’re doing wrong and it’s all thanks to him that we don’t have to deal with it.  He’s told me multiple times how lucky I am that I’m not a supervisor because I don’t have to deal with all of these calls, because people are calling him 24 hours a day to complain about what the officers are doing.

Q.        Do you believe those statements — particularly the first half, that people are calling him consistently throughout the day and/or night to be true?

A.         No.  No, I —

Q.        Has the lieutenant ever addressed any complaint of a citizen he was called about while he was off duty?

A.         No.  No, he’s — he’s told us that but then, you know, I’ve asked before you know, is there something I’m doing wrong and I’ve been told you just keep doing your job, I’ll take care of it.

Q.        What’s your belief on — uh, as you stated, you don’t believe that that’s statement accurate, that the lieutenant actually isn’t receiving complaints, so why do you think he’s making those statements to you?

A.         I think it’s a bullying tactic.  I think he wants to keep us constantly thinking that the tribe doesn’t want us there, that he is the only thing that protects us, and so just a — you know, he wants to be in a position where we have to have him, because without him, we’re toast.  

Q.        The information we have is Lieutenant Padgett stated I don’t have to do police work, I’m a professional police officer with all the calls I’ve handled.

A.         Yes.

Q.         Please explain.

A.         Uh, I believe he told us that in —

Q.         Us being?

A.         Uh, myself, Chris Boggs and Sarah Boggs, I believe, were all there for that one.  Uh, he may have said that — I — he said a similar statement — I believe he told Officer Matthews and I that once we’ve handled the amount of cases that he has — you know, then we don’t need to worry about getting cases.  Uh — I —

Q.           How did you perceive that?

A.         Uh, as a bullying thing.  That — it was 100% that he’s putting himself so above us, because he believes that he’s done so much over the course of his career that there’s no way that he could be asked to do anything and that comment is usually following someone bringing up the fact that — I believe currently, at this point, for 2018, Lieutenant Padgett has eight cases for the year.  So — he has less than our chief, he has, you know, a 10th of — less than — I think I’m the lowest of the patrol officers, and I think I have over 100 cases this year, pretty sure, and —

Q.        And the cases — what, in summary —

A.         Uh, that would be traffic stop, citizen assist, burglary, any call that we respond to.

Q.           So, any kind of reactive or proactive traffic law enforcement function is considered a case?

A.         Yes.  Yes, so anything where you’re, uh — calling dispatch to let them know you’re going to be out dealing with something and yeah, so he’s told us that multiple times, that he doesn’t need to do cases, he spends 75% of his time supervising and 25% of his time working on the road and he works a shift where, generally, on Saturdays, he and I work most of our shift together when he was there, and — but other than that, during the week, he doesn’t work a shift with any of us.  Actually, on Tuesdays, as well, he works — on Tuesdays, during the day, would be, uh — he would work in the mornings, uh — Chief Souvenir would also work in the mornings and then I’d come in sometimes in the morning, sometimes an early swing shift, so those were — Saturdays and Tuesdays were the only days I worked with Lieutenant Padgett.

Q.        The information we have is Lieutenant Padgett stated Sarah’s, Chris’s and your trucks will be the same.  Mine will be top notch because I’m a lieutenant.

A.         Yeah.

Q.         Please explain.

A.         I, uh — we have —

Q.         We being?

A.         Uh, the Shoalwater Bay Police Department has received — I’m trying to remember that.

Q.        I know.

A.         Yeah, I appreciate it.

Q.        That’s what I’m here for.

A.         Yeah, uh, the Shoalwater Bay Police Department, we received a grant I believe in 2017 to get new patrol vehicles and we got two new F150s, and Chris and Sarah got those first two trucks.  They were driving Chargers.  2009 Chargers that were not doing well, uh — you know, we referred to — or I referred to one of the cars as Frankenstein because it has a new motor because the other one blew up.  They were all at, I think, 120,000 plus miles which — when you’re going a mile and a half is a lot of miles so — but they were in bad condition and I know State Patrol has much more (inaudible – 00:41:56) but for our department, that’s a huge amount of miles.  Uh, I currently have the highest mileage care.  I’m waiting for my new truck.  Uh — it was delivered, I believe, the 2nd week — around the 16th, 17th of August, and I was told that it would be done before I got back from paternity — paternity leave when my son was born.  I went out — my wife went to the hospital on the 31st of August, and I was told — talked to Lieutenant Padgett a little bit after I got home from the — after we were home from the hospital, a few days after, he called to congratulate me on my son being born, and so early September — he called to say oh, yeah, your truck’s going to be done, it’s going to look awesome.  And you know, it’ll be ready when you come back.  And I came back on, I believe, October 2, and on the 29th of September, I think it was, or the Friday before I came back, I went to range because we had range and I talked to chief and said hey, I can come for range.  I’m coming back in three days.  My wife will be okay for four hours for me to be gone.  Said okay, and I had asked him — you know, my truck was done and he told me it was not done at this time due to — this investigation was getting started, so I said okay, and he said that it would be done soon so it’s — you know, October 24, and I’m still currently driving my Tahoe, so — which is fine, I mean, I turn the key and it starts up, but it has — you know, it has battery issues, the battery will die if you don’t run it enough, uh — Lieutenant Padgett actually provided — it was his Tahoe before I had it, because my Tahoe during the summer — the air conditioning broke in it, so then he switched me Tahoes because he was working on the new trucks, and so I have his old Tahoe, which — when I got it, I had — the airbag light says it needs to be services, which I brought up at the time and that was in August and so I’m waiting for that to get done any time and I was told, you know, the new truck will be here and I said that’s fine, you know, I understand it’s — it’s on its way out, I understand not throwing a bunch of money into the car, but I wanted an air conditioner — was my big thing.  I said, you know, it’s 90 degrees outside and I have no air conditioning, so —

Q.        So how — how did you take the statement of Sarah and Chris’s and your trucks will be the same, mine will be top notch because I’m a lieutenant?

A.         Uh, it — it was just frustrating.  It just felt like, you know, you’re talking down to someone that — and I wasn’t surprised at all by the statement.  I talked to Lieutenant Padgett about the differences between his truck and ours, and he was telling me that it’s a different package than ours, because he needed the towing package.  Which — I don’t know what for.  I’ve never seen him tow anything in the whole time that I’ve been there.  Uh, we got an F250 diesel so we can tow our range trailer, which also — our chief will tow our motorcycle in, uh — oh, yeah, Lieutenant Padgett told me that, you know, that my truck was going to be awesome and all this and he said — but you know, it’ll be a little bit different than mine.  I said okay, and I said you know, if I can turn the key and it starts up and when I hit the lights, they turn on and the radio works, and it stops when I hit the brakes, that’s what I care about.  I said I’m excited about a new car as much as anybody because it’s a new car and my Tahoe seat is starting to wear down.  It’s had a cop butt in it for, you know — well, it’s 2012, so it’s been running the reservation for years, so —

Q.        The information we have is Lieutenant Padgett stated you’re lucky I discipline you like this.  In the woods, I would have pissed on your head.

A.         Yes.  Uh —

Q. Please explain.

A.         Uh, Lieutenant Padgett has multiple times talked about how before he was a police officer, when he was first out of — or he had gone to college for a couple years and then came back and worked for — I believe Weyerhaeuser, in the woods, and he said that his old boss, when he was mad at you, he wouldn’t yell at you, he’d just piss on your head.  While you were eating lunch, and they’re lucky that’s not the discipline that he does.

Q.          How did you take that statement?

A.         Uh — I was — I’m — uh — just confused by — I don’t know — I mean, I felt like it was —

Q.    Do you take it as threatening, controlling —

A.         Yes.

Q.        — funny?

A.         I think, uh — controlling, yeah.  The — you know, we’re so lucky that, you know, we have someone like him that will just yell at you or have you write a memo because you did something wrong, or make you correct something 50 times, rather than peeing on your head, and I thought you know, if you pee on my head, then I — I’m done.  I’m not — not going to work in a place where that’s okay.  That’s not — you know, that’s not an okay way to discipline someone.  Like — how that’s even, you know, thought of as being, you know, oh, you’re lucky because this isn’t how I do it.  Like, yeah, no one does that.  

Q.        The information we have is Lieutenant Padgett stated never talk to department business — anyone outside of the department, or your worst nightmare will come true.

A.         Yes.  Uh —

Q. Please explain.

A.         So, that occurred, uh — myself and Officer Sarah Boggs were in the office after an officer’s meeting where we had talked about, uh, the possibility of going to a four 10s schedule, and we had the mock four 10s schedule that we were working on up on my computer, and deputy Jessie Eastham (ph) had come to the office and he knocked, he came in — he asked when he walked in what that was, and I told him oh, you know, we’re looking at a four 10s schedule and we’re going to try to pitch it to Robin and Matt and I believe he asked me if I thought it would go, and I said I don’t think they’ll go for it, but it’s at least worth a shot, and then the next day we were told that if —

Q.        By who?

A.         Uh, Lieutenant Padgett.  That if we spoke about department business and — at that point, four 10s were completely eliminated from being a possibility because we were talking with them to an outside — or with another agency.

Q.        So, just to make sure I’m understanding it, it’s your opinion that the reason that the four 10s were eliminated is because of this discussion with the deputy?

A.         Yes, because we told the deputy that we were presenting a four 10s schedule to Lieutenant Padgett.  I think the real reason that we weren’t given it is because he just wanted a reason to not give us four 10s, and felt like he was justified in how we talked about department business with someone else, and I told him at the time, you know — I — you know, I told him we were looking at four 10s.  I said I didn’t know that was a secret.  

Q.        The information that we have is Lieutenant Padgett has stated you’re all morons.  

A.         Yes.

Q.        To officers?

A.         Yes, uh, he’s said that to, I believe, myself, uh, Chris, Sarah, Dan —

Q.      All at once, or —

A.         Uh, at different times.  Dan was never there when Sarah was there.  So, but — at different times —

Q.         How many times have you heard him say — can you give a specific example?

A.         Uh — let’s see.  Uh — (inaudible – 00:49:39) I can’t give a specific example.  I —

Q.         Okay, provide the context and what you can, then.

A.         Yeah, uh — at different times, uh — we were, you know, working on a case and you know, Officer Matthews, I know, had — he needed some extra training and was not learning well from the way Lieutenant Padgett and Chief Souvenir were going about trying to train him and he did something wrong with the case, and Lieutenant Padgett told him, you know, you’re a moron, you know — I have to come and fix this.

Q.        In what — what con- — what — what tone of voice is this —

A. Uh, it was —

Q.         Being Lieutenant Padgett’s —

A.         — uh, a harassment type of — you know, you’re not good enough to do this.  Uh, at different times, he’s told us when there have been myself, Chris, and Sarah around that we’re morons because we couldn’t figure out, you know, how to deal with a case, or we, you know, didn’t do something right, and so you’re a moron.

Q.        How many times do you think that you’ve heard Lieutenant Padgett refer to yourself or other officers or people as morons over the course of your career?

A.      Oh, uh, a lot.  I honestly don’t have a number.

Q.         Can put a, uh — like a number range on that?

A.         Yeah, probably at least 100 times that he’s called different people morons.  

Q.        The information that we have is that Lieutenant Padgett stated Chris can’t go on light duty because only the command staff can have light duty.  Chris is too stupid to ever be on light duty.

A.         Yes.  Uh — that was — I believe that was me and Sarah and Matt — were in the room.  I believe.  Uh — Chris, uh — injured himself, he was at home, uh — walking down his stairs, I believe, and he slipped and fell and broke his back and he went to the doctor afterwards and he was out for 12 weeks and at one point had asked about coming back on light duty and when he asked about it, he was told no and then later on, talking about the incident, Lieutenant Padgett stated that, you know, Chris couldn’t have light duty because that was just for, uh, administration, because Lieutenant Padgett had just recently come back from being on light duty because he — let’s see.  I think it was he had had hernia surgery, which he said happened while he was on duty, but it was months after the incident happened that he was suddenly in so much pain that he needed hernia surgery.  So he had — he claims, like, in November he had pushed a car that was stuck on the side of the road — helped pushed it off to the — back onto the roadway, and then in, like March, he said that, you know, he needed to go get surgery for a hernia.  And then when he came back, he came on light duty, and so he —

Q.        Would he —

A.         — was in the office but not doing anything.

Q.        Just to clarify, when he made that statement about Officer Chris Boggs — Officer Chris Boggs was not present?

A.         I don’t believe so.  But yeah, I don’t think Chris was there when he said it, but he might have been — I — I thought it was me and Sarah and Matt when he said that.

Q. The information that we have is Lieutenant Padgett has stated to Officer Sarah Boggs your husband is hung like a donkey.

A. Yes.  Yes, he has.

Q.         Please explain.  

A.         Uh —

Q.        In what context?  How does that even —

A.         Uh — I believe it’s supposed to be in a joking context, and almost as a compliment to Arley (ph).  Arley works for Raymond Police Department.  Uh — and we all know Arley and we all like Arley.

Q.        And Arley is?

A.         Uh, Sarah’s husband.

Q.         Okay.  How many times do you believe he’s said that?  

A.         Uh, probably at least five that I’ve heard.

Q.        And is it — is it oddly like a term of endearment about Arley?

A.         Yes.  Yeah.

Q.         I mean, how — or how do you get to that point where you’re making that statement, uh —

A.         I’m not 100% — I — yeah, it seems as though he’s saying it as a compliment to Arley and I think in his mind it may be a compliment to Sarah that Arley is — hey, you know, I think — trying to compliment — we all like Arley and, you know, Arley’s been a cop for years, so I think it’s supposed to be a compliment to him.

Q.        How did Officer Sarah Boggs respond at the time when she was present when the statement was made?

A.         Oh, she looked frustrated when he said it, and — for the most part, I think just kind of blew it off and left the room.

Q.        The information that we have is Lieutenant Padgett has stated I never give above an 85% on an evaluation because none of you will ever deserve it.

A.         Uh, yeah, I think he’s told me that it was above a 90.  But yeah, he’s told me that no one can ever get 100% on an evaluation, and I’ve brought up, you know, uh — being on time, and I said you know, I’ve never been late and you know, I’m always here.  Well, you know that’s a 90, because you could be better, and I said okay, and so — but he’s said that to other people as well, that yeah, he won’t give — won’t give a high mark on an evaluation, so —

Q.         And how does the lieutenant’s opinion on that make you feel?

A.         It makes me feel bitter.  That you know — it’s an evaluation and that I know that my score is never going to be as high as it really should be by what he’s telling me that, yeah, you know, there’s — you know, you’re doing everything right on this, but that’s not 100%.  You know, you could do better.  100% is going above and beyond.  And so —

Q.        The information that we have is on July 4 of 2017, Lieutenant Padgett handcuffed then reserve — Raymond reserve police officer Rikki Coma to the coat closet rod.  Were you present?

A.         I believe I was, yes.

Q.        Okay, please explain.

A.         Uh, we were in, I believe it was myself, Lieutenant Padgett, Officer Rikki Coma, Officer Eric Fuller, they — Officer Chris Boggs was there.  I’m not sure if Sarah Boggs was there.  I don’t think Sarah was there yet, uh — but we were in, everyone was talking in Lieutenant Padgett’s office, and he had a — had a, uh — the rod in — behind his door there’s a rod for — to hang, and it’s a removable one, and he — I believe in a joking manner — handcuffed Officer Coma to the thing and then tossed a handcuff key at her feet and then laughed about it, because Officer Coma didn’t realize that she could just lift it up and take it off and she did not have a second handcuff key, and he said that was why he was teaching her a lesson, that she needed to have more than one handcuff key.

Q.        So the information we — that we have is Lieutenant Padgett was laughing and called in other officers to see Officer —

A.      Uh, yes, he called —

Q.        — Coma —

A.         — Officer Chris Boggs to come in and see Officer Coma.

Q.        You had mentioned that it was in a joking manner from the lieutenant’s perspective?

A.         Yes.

Q.         How did Officer Coma take it in your opinion?

A.         I felt like I personally — and I felt like Officer Coma felt — I — to me it seemed like she was embarrassed and felt uncomfortable with it.  From my perspective, that you know, he was the lieutenant and she was currently in reserve from Raymond and she was hired to come up and work and I don’t think she felt like she — I don’t think she would have felt like she could say anything.  I didn’t feel like I could say anything, so — but I was an employed officer by Shoalwater Bay, so —

Q.         And the information that we have — the information that we have is that the lieutenant had thrown the handcuff key on the floor, stated it was training, and then left his office.  Is that accurate?

A. I believe so.  Yes.

Q.        Do you believe this action and the statements made by Lieutenant Padgett to be threatening, bullying, or harassing?

A.         Oh, I think it was definitely bullying.  

Q.        The information that we have is on July 4, 2017, Lieutenant Padgett asked Officer Coma if her boyfriend’s dick was large.

A.         Yes.  I beli- —

Q.        Do you have — and if you don’t have any recollection — any recollection of this then —

A.         I don’t — yeah, I don’t have — I — I can’t say that I can remember exactly when it happened, so —

Q.        Okay, and that goes for all of these.  The information that we have is on July 4, 2017, Lieutenant Padgett continued his — his statements and asked if he gave it to her good.  Do you have any —

A.         Yes, I remember him saying that to her.  I believe —

Q.         Okay, him and — lose the him and lose the her and what did he say?

A.         Lieutenant Padgett.  Uh, yeah, I believe Lieutenant Padgett asked Rikki if her boyfriend was giving it to her good, and I believe that was either in his office or it was over — uh, we were walking around as a — all the officers walked around as a group, uh — and I believe that could have been out by, uh — we parked the global command center next to the Chevron station in Tokeland and I believe we were outside of the Chevron, talking as a group when he said that.

Q.        So what, uh, was the lieutenant’s tone of voice and what was his demeanor like when he asked that question?

A.           Uh, he was — I believe he was joking around, thinking that he was funny saying that to her.

Q.        And how did Officer Coma respond?

A.         Uh, she didn’t say anything and looked embarrassed.

Q.        What — and — and in what context — what’s the conversation like to get to the point where the lieutenant’s asking reserve officer — you know —

A.         Yeah, I —

Q.         — if he gave it to her good?

A.         I don’t know what conversation leads to that.  The information that we have is during this same conversation — we’ll call it — Lieutenant Padgett asked Officer Coma if she was a come dumpster. Yes.

Q.         Please explain.

A.         Uh, we were talking in a group and I believe in the same — after asking if her — if Officer Coma’s boyfriend was giving it to her good, Lieutenant Padgett asked if she was a come dumpster.

Q.        What — two questions, what does a come dumpster mean to you and in what context do you believe the lieutenant was using that — that terminology in?

A.         Uh, I believe the context that I’d take from it is that, you know, uh — essentially that she’s having many, you know, guys coming on her or in her, and I believe that’s the context that he was saying when he said it.  Or that he was inferring.

Q.    How did Officer Coma respond?

A.         She looked embarrassed, uh — and I believe walked away after that, or started to and I — yeah, I think she walked away.  I think I walked away after that.

Q.        Do you believe this incident we have just been speaking about involving Lieutenant Padgett and Officer Come to be threatening, bullying, or harassing?  

A.             I think it was harassing and bullying, yes.

Q.        Several times during this interview, we’ve discussed the use of the word cunt.  In your opinion, as the use of the word cunt become normally or seemingly acceptable in your work environment?

A.         Yes, I do believe it’s become —

Q.        By everyone?

A.         Not by everyone.

Q.        By who?

A.         I believe Lieutenant Padgett uses it as though it’s the word hello.  At times.  It’s nothing more than that.  Yeah.  And not that — I should rephrase that.  I don’t feel like he says it as much as you would say the word hello, but I feel like it’s essentially the same level of reaction from him.

Q.        So, in comparing it to the word hello, are you indicating that he just uses it in — in a normal sentence, or does he use it in a phrase when he’s happy or does he use it in a phrase when he’s talking derogatory and negative about someone?

A.         Uh, as a derogatory comment, so — yeah, that’s a better way of phrasing it, yeah.   During this interview, we’ve discussed the terminology come dumpster.  Has the use of this terminology become normal or seemingly acceptable in your work environment? I don’t believe so.  I believe it was — the only time I can remember it specifically being used is that one incident with Officer Coma and yeah.  I feel like Lieutenant Padgett said it in a derogatory fashion, but I don’t feel like it was you know — he was saying something that was outlandish to him.

Q.        Several times during this interview we’ve discussed conversation, questions, and comments referring to the size or description of male genitalia.  Have this topic of discussion become normal or seemingly acceptable in your work environment?

A.        Yes, it’s —

Q.         By who and how so?

A.         Well, I believe Lieutenant Padgett — I’m probably guilty of it as well, I’ve probably done it as well, uh — I think yeah — it’s — it — the way that it’s used, it’s — you know, Lieutenant Padgett jokes around a lot, saying those kinds of things, and I’ve probably said it as well, and so I need to be better about doing that.  

Q.        Does the culture at work encourage or discourage the use of derogatory language like we’ve discussed today? 

A.         Uh, I believe — I wnd necessarily say it encourages it — but especially in Lieutenant Padgett’s case, I feel like there’s no deterrent to it.  It’s — I believe he says whatever he feels like saying.

Q.         Why do you feel like there’s no deterrent for him to say it?

A.         I feel like no one’s ever told him no, that you shouldn’t say these things, or — Q.    Are you talking up his chain of command, down his chain of command, or both?

A.         Uh, I think both.  Uh, I think there’s been an incident, and I don’t know if they talked to you guys about this, but that — he had a text message series with Sheriff Johnson (ph) — Lieutenant Padgett had a series of text messages with Sheriff Johnson and he showed me the text message —

Q.        He being? 

A.         Uh, Lieutenant Padgett showed me the series of text messages, and I can’t specifically remember what all of it said, but I know in the end he said that Sheriff Johnson is a liar and if he did not come out and admit to what he was lying about, that Lieutenant Padgett would expose him and Lieutenant Padgett stated that Sheriff Johnson needed to go and seek immediate mental health because he was unfit to hold his position.  
The information we have discussed today spans over a period of several years. 

Q. you, six and a half years.  Given the severity of which you have talked about today, why did you wait until September to provide the letter to HR?

A.         I — when I first started and — and up until I knew that someone else was going to do it, I didn’t feel comfortable doing it because I figured I’d get let go, and —

Q.   Someone else like as in —

A.         If another officer was willing to come out and do it as well, then I was going to be willing to speak, but I didn’t feel like if a single officer went and made a complaint, that it would go to HR, HR would then speak to our chief, and then Lieutenant Padgett would try to find ways to get you fired.

Q.         So is it fair to say you felt like if you did it alone you’d lose your job?

A.         Yes.

Q.        So, the information that I have is that at some point in time in your career, you have approached the chief with concerns you had about Lieutenant Padgett.

A.         Yes.

Q.        If so, what were they and what was done and what was the end result of the concerns you brought forward?  

A.         Uh, I brought up with him bullying in the past.

Q.         Him being?

A.         Uh, Lieutenant Padgett bullying me in the past.

Q.        And you’re talking to the chief?

A.         To Chief Souvenir.  Uh, I brought it up with him before.  I’ve brought it up with Lieutenant Padgett before and I’ve talked to them about the fact that, you know, I feel like — I brought up that I feel like there’s always a favorite.  That there’s somebody that’s in the dog house that is going to get — you know, just dumped on, uh — I talked to them about that, uh — and I had a long conversation with both of them about it, uh, around the time that I applied with state parks and, uh — I was told that you know, uh — you know, they — we needed to have better communication, which I think was a good point, we do need better communication, but there was no reason I should feel threatened or bullied, that I was just fine being there, and that they wanted me to bet here, and I also feel like it’s gone in cycles where, you know, if we’ve had a complaint in the past, that it’s been brought up and then it’s been just swept under the rug and for a while everything’s okay and then we go back to just getting torn apart.  In the letter you provided information — much of which we’ve talked about today.  Considering the information that you wrote and all the information that we discussed today and everything else that — that you may be thinking about, uh — what do you think is an appropriate resolution for the stuff we talked about?  

A.         I would like to be able to say that, you know, hey — Lieutenant Padgett can be disciplined and you know, he can be put on suspension or something like that and the problem would be solved, but I’m very concerned that if he comes back, he will be a perfect angel for a few months and then all of a sudden we’ll start noticing people getting writeups and everything will be going wrong and I know when Dan Matthews was — he resigned, uh — he was given the option to resign or be let go, and it seemed as though he was suddenly — had been — Lieutenant Padgett had decided that Dan was going to be gone, and everything that Dan did became a write up and he was being disciplined for different things, and — I’m worried about if he comes back, that he’s going to try to come after all of us for saying anything.  I’ve heard rumors of different things that have been said, and I haven’t heard any of them personally so I don’t want to claim that any of them are true, but I’m concerned about what I’ve heard.  I’ve seen the way Lieutenant Padgett has, you know — he’ll go on Facebook or he’ll go on — I know on the Chinook Observer and make comments and he made comments about Raymond having officers — or, well, did not specifically say Raymond, but made comments about officers that were rats and how them getting let go was such a good thing and I believe inferring to Officer Muskell (ph), and Officer, uh, Jarvis (ph) from Raymond who were both let go and are both — that’s a whole other issue, but just the statements that he makes — there’s no — there’s no filter, there’s no fear of what he’s saying.  Uh, the text message chain that he showed me to Sheriff Johnson about how Sheriff Johnson needed mental help — he’s the sheriff and I was told and I can’t say this — I wasn’t there to witness this, that Sheriff Johnson contacted Chief Souvenir and asked him to have Lieutenant Padgett stop this, uh — attack, I guess, and Chief Souvenir said, uh, he’s my officer and, you know, I’ll deal with it as I see fit, and told him he has constitutional rights to say what he believes, so I don’t think — if he’s coming back, I don’t think anything will happen to him.  I think it has to come from outside of our department.  

Q.        Do you have additional information pertaining to this investigation that we have not asked you about today?

A.          Uh, I — again, this is all — you know, I’m getting it really third-hand, but I was told by Officer Sarah Boggs that she was contacted by Katherine Horne (ph), who’s the social services Officer Kristofer Aho  October 24, 2018  director for the tribe, on — I believe it was on Friday or maybe Monday — just before I came in here, and told her that at the most recent tribal council meeting, that Lieutenant Padgett and Chief Souvenir came into council and asked if they could present their side of the case and asked for the immediate dismissal of Sarah Boggs, Chris Boggs, and myself.  And I can’t confirm if that’s true or not, but that bothers me a lot.  Uh, the other one that I’ve had that Sarah told me about, that she was speaking to Lieutenant Padgett and he told her that he needed to put me back on dayshift because I had recently come in and talked to him and I was going through some personal issues, and he told her that he needed to put me back on dayshift or he was concerned that I was going to blow my brains out.

Q.        I have that information as well, I just decided to not ask you about it.  But please talk about it, since you’re aware of it.

A.         Yeah.  Yeah, uh — so, that’s what I was told, uh — I went in and talked to Lieutenant Padgett.  I was dealing with some personal issues and he asked me to come in and talk to him and I feel like he listened and we had — have some — you know, both have our own issues that we’re working through and I was —                          Code 1(e)                    

Code 1(e)

You know, I have my issues, but I talked to him about what was going on and what I was feeling, and at no point did I ever make mention of doing harm to myself or others, and then he turned around and told Sarah he was concerned that I was going to blow my brains out, which bothers the hell out of me, because if I can’t talk to you about — that I’m having an issue and you’re going to turn around and say that you’re concerned I’m going to blow my brains out —

Q.        Do you believe Officer Boggs —

A.         I do.  I — because she said it and in the context of what she said, I don’t see any reason why she would have made that up.  It doesn’t —

Q.         Why do you think Lieutenant Padgett would have made that up, then?

A.         I think because in his mind, he was justifying why he was changing me from graveyards to dayshift, and it’s well known in our department that I prefer dayshift.  I’m not hiding that at all.  I’m not going to at any point say that I would rather work nights.  I like dayshift.  I like — you know, I like talking to people, I like going around — I do our after school program, I do different things with the kids and I like getting to talk to them and having that interaction with people during the day and I do not do as well on nights.  I’ve asked before — I told them flat out I would prefer dayshift, so yeah.  

Q.        Okay.  Is there anyone else we should talk to that would have information pertaining to this investigation?

A.         Uh, I don’t believe Officer Lucas Stiegel would say anything.  I think he would keep his mouth shut, uh —

Q.         What information would he have to share?

A.         I’ve — again, I’ve heard rumors that while he was at Shoalwater that he was so frustrated with Lieutenant Padgett, who I believe at the time was Sergeant Padgett — that he was so frustrated with the way he was being treated that he was going home in tears and talking to Arley Boggs (ph) about what was going on with the situation and I’ve heard this third hand and I’ve been told that Lucas will never say anything.  Uh, I believe Officer Dan Matthews still has emails we’ve received from Lieutenant Padgett while he worked — while he was Sergeant Padgett and while Dan was there.  And I’m sure that Dan would be willing to come in and speak with you if you guys had questions about his experience, and I can provide his phone number.  If you need that.  So, he’s working for Westport right now and lives in (inaudible – 01:15:46).

Q.        Thank you.  

                        SERGEANT WYNECOOP:  Yeah.  Yeah.

Q.        Okay, we will conclude the interview.

                        SERGEANT WYNECOOP:  Can I ask a couple questions.

Q.        Oh, yeah, sorry about that.  I forgot you twice.  

A.         Man, that’s hard.

                        SERGEANT WYNECOOP:  While you’re looking for that phone number — A. Yeah.

                        SERGEANT WYNECOOP:  — uh, these comments made by Lieutenant Padgett or even Sergeant Padgett, way back — was he on duty when he made these comments?

A.         Yes.

                        SERGEANT WYNECOOP:  Was he in uniform? A. Yes.

                        SERGEANT WYNECOOP:  Was it almost always office or in public?

A.         Yes.  Uh — I would say that 90% of the comments were made in either our officer’s — or in the Shoalwater Bay Police Department, so —

                        SERGEANT WYNECOOP:  And you mentioned, uh, Savanna coming in to get measured.  Was she wearing jeans or stretch pants?

A.         I believe they were jeans, but I know she’s worn stretch pants at different times when she’s been around.

                        SERGEANT WYNECOOP:  I — I assume that’s like yoga pants?

A.         Yeah.  Yeah, the real tight fitting, like, workout type of pants.

                        SERGEANT WYNECOOP:  But you’re not sure which of the two?

A.         I can’t say for certain.

                        SERGEANT WYNECOOP:  Uh, this language that you’ve heard from your lieutenant — is this something that subordinates are allowed to use in the workplace?

A.         Uh, yeah, for the most part, I don’t think there’d be — he would have any problem with anyone else saying anything at all.

                        SERGEANT WYNECOOP:  Like big hair balls, and talking about male genitalia and —

A.         Yeah.  Yeah, that wouldn’t disturb him in the least, I don’t believe.

  SERGEANT WYNECOOP:  Okay, so you wouldn’t be disciplined if you were to say those things?

A.         I don’t believe so.

                        SERGEANT WYNECOOP:  How about the other two officers?

A.         I don’t believe they would.

                        SERGEANT WYNECOOP:  Okay, and in general with all the comments we’ve discussed and his behavior — whether it’s handcuffing the officer to the rail, or publicly talking about her boyfriend and being a come dumpster, in your opinion, as a professional, is this acceptable conduct?

A.         No.

                        SERGEANT WYNECOOP:  Okay.  

A.         No, that’s — she was a reserve and he’s the lieutenant, so — that’s — I mean, it’s not okay for an officer to say to another officer, and you know, she’d come up for, you know, two days to help us out, and that’s — to be spoken to like that by a supervisor is a lot harder than — you know, who are you going to talk to?

                         SERGEANT WYNECOOP:  And then, uh — when he was — Lieutenant Padgett was

talking to Officer Coma — this is the come dumpster conversation —

A.         Yes.  Yeah.

                        SERGEANT WYNECOOP:  Was this a dialogue or a monologue?  Was she participating in it?

A.         I believe it was more of a — a monologue than a — I — I think she was there, and deflecting questions, but I think more than anything, it was — once he starts going into — you know, he wants to get some ideas across, it turns into more monologue and everyone else is there, so —

                        SERGEANT WYNECOOP:  Okay, and then does your department or the tribe offer sexual harassment training for you guys? 

A.         I can’t say for certain.  I’ve never had to go to any, so I can’t speak to that one.

                        SERGEANT WYNECOOP:  Okay.

A.         I think that’s my truck.

                        SERGEANT WYNECOOP:  That’s all I have. A.       Yep, that’s mine.

Q.        Thank you.  You are reminded of the order given to you by the chief that you shall not discuss this investigation with anyone other than the investigators.  Do you understand?

A.         I do.

Q.         That’ll conclude the interview.  The time is 2:25 p.m. 





            I, Taylor Normington, Legal Transcriber, do hereby certify that I was authorized and did listen to the recording of the foregoing matter; and that the transcript, Pages 1 through 32, is a true and accurate record of the digital recording to the best of my ability.

            I FURTHER CERTIFY that I am not an attorney or counsel of any parties, nor a relative or employee of any attorney or counsel connected with the action, nor financially interested in the action.

            DATED this 1st day of November, 2018.


Taylor Normington, Legal Transcriber Transcription Outsourcing, LLC 1780 S. Bellaire St.

Suite 400

Denver, CO 80222

Tel:   720-287-3710 Fax: 303-952-9897