Breonna Taylor Lawsuit - Motion To Compel

Filed 20-CI-002694 06/09/2020 David L.
Nicholson, Jefferson Circuit Clerk
ELECTRONICALLY FILED
NO. 20-CI-002694 JEFFERSON CIRCUIT COURT

DIVISION NINE (9)
HON. JUDITH MCDONALD-BURKMAN
TAMIKA PALMER, PLAINTIFF

as Administratrix of the ESTATE OF
BREONNA TAYLOR
v. NOTICE-MOTION-ORDER
BRETT HANKISON, et al. DEFENDANTS
*** *** *** *** *** ***
PLEASE TAKE NOTICE that the undersigned, on the 15th day of June, 2020 at 1:45
p.m., in the courtroom of the above Court (telephonically), will make the Motion and tender the
Order set out below. The conference call number is 1-774-220-4000 and the ID number is 595-
4356.
MOTION FOR INJUNCTIVE RELIEF AND TO COMPEL PRODUCTION OF

DEVICES AND CLOUD DATA FOR FORENSIC EXTRACTION AND INSPECTION
Comes the Plaintiff, through counsel, and hereby respectfully requests for the Court to
order that:
1. The Defendants, Brett Hankison, Myles Cosgrove and Jonathan Mattingly be enjoined
from usage or destruction of all cell phones, body cameras, MDT’s, arbitrator units, tablets,
and computers which were in their possession at any time from March 12, 2020 to present.
2. These officers preserve and produce these devices for storage by a neutral custodian.
3. These devices be available for inspection, imaging, logical extraction and physical
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extraction by experts, specifically including data recovery experts, within 7 days from the
entry of the proposed Order.
4. Neutral experts be appointed to perform inspection, imaging, logical extraction, and
Filed 20-CI-002694 06/09/2020 David L. Nicholson, Jefferson Circuit Clerk

physical extraction, as well as copying of cloud data from these devices.
5. Neutral experts adhere to the proposed protocol for identifying relevant documents,
recorded media, data, and communications.
6. A protective order be entered regarding the production and dissemination of all identified
relevant documents, recorded media, data, and communications.
I. INTRODUCTION
The Court is likely familiar by now with this case, which involves the tragic death of
Breonna Taylor. The criminal investigation into this case remains ongoing. The Plaintiff has not
been made aware of the actions associated with the investigation and what, specifically, has and
has not been done. Shortly following Breonna’s death, undersigned counsel sent a preservation
demand to LMPD identifying several items to be maintained and produced. See Exhibit A. This
demand encompassed the information and devices sought herein.
Since day one, LMPD has portrayed a narrative of the events which is inconsistent with
that which has been identified by the Plaintiff throughout the course of the investigation.
Meanwhile, information on the officers’ devices, which is critical towards ascertaining the truth,
has not been disclosed or produced. This information is necessary to identify the true facts leading
up to Breonna’s death, as well as what took place shortly thereafter for the officers to cover up the
truth. Without the requested relief, essential information will be lost and unrecoverable.
II. FACTS ACCORDING TO LMPD
Shortly following Breonna’s death, LMPD identified the following narrative:
1. That on March 13, 2020 several officers within LMPD’s criminal interdiction unit executed
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a search warrant upon Breonna Taylor’s home.
2. That the criminal interdiction unit was composed of a combination of narcotics officers
Filed 20-CI-002694 06/09/2020 2 David L. Nicholson, Jefferson Circuit Clerk

and officers from the ninth mobile division.
3. That LMPD officers, in procuring the search warrant for Breonna’s home, relied upon
surveillance and information from the U.S. Postal Inspector that Breonna was receiving
suspicious packages from a local drug dealer, visiting the drug dealer at him home, and
participating in a drug ring. See Search Warrant Affidavit, Exhibit B.
4. That these officers, on March 13, 2020, knocked on Breonna’s door, announced themselves
and waited more than a minute for compliance.
5. That the officers, after three attempts using a ram, breached the front door of Breonna’s
home and were immediately met by gunfire.
6. That Defendant Mattingly was shot, sustaining a severe and life-threatening wound to his
femoral artery. He went to the ground, scooted backwards out of the home, got to his feet,
backed out of the entry way, and stumbled to the ground after falling over officer Campbell,
who himself had gone to the ground. Mattingly then holstered his firearm.
7. That the Defendant officers returned gunfire.
8. That Breonna Taylor was killed.
9. That specifically, per a whiteboard produced by Tom Wine to the public, the following
officers were assigned to execute the warrant at Breonna’s home:
a. The Defendants
b. Josh Doerr
c. Michael Campbell
d. Michael King
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e. Tony James
f. Hankison’s drug dog, Franklin

10. That Hankison left the scene of the shooting and went directly to the hospital check on
Mattingly and then went directly to the Public Integrity Unit office without any interim
stops or detours.
11. That there was no body camera footage of the events.
12. That none of the criminal interdiction unit members were issued body cameras.
III. FACTS IDENTIFIED WITHIN THE COURSE OF PLAINTIFF’S

INVESTIGATION
1. That the former ninth mobile officers within the criminal interdiction unit were assigned
body cameras well prior to March 12, 2020. This is confirmed both by footage of these
officers from other cases and through citations identifying the usage of WVS (body
cameras).
2. That multiple narcotics officers, including Hankison, were assigned body cameras well
prior to March 12, 2020. This is confirmed by Hankison’s own body camera footage on
former cases and by several citations confirming the presence of WVS (body camera) worn
during the execution of search warrants by narcotics detectives.
3. That LMPD never confirmed with the local U.S. Postal Inspector that Breonna Taylor was
receiving suspicious packages. In fact, a third-party agency was specifically advised by the
U.S. Postal Inspector that Breonna was not receiving suspicious packages.
4. That in February of 2020, LMPD officer Wes Barton impounded Jamarcus Glover’s
vehicle and confiscated a bank statement from the vehicle.
5. That within the week leading up to March 13, 2020, LMPD officers attempted to search
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and confiscate drug related items from Jamarcus Glover at his home at 2605 West
Muhammad Ali.
6. That the officers struck out on this search, prompting Glover to taunt them on social media

for coming out empty.
7. That on March 12, 2020, LMPD officer Josh Jaynes sought and obtained five no-knock
warrants on Jamarcus Glover and others. Four of the warrants identified the same six
individual targets. They were for the homes at 2424 Elliott, 2425 Elliott, 2426 Elliott and
2605 West Muhammad Ali. The fifth warrant was for Breonna’s home at 3003 Springfield,
Apartment 4. The warrant identified her name, as well as Jamarcus Glover and Adrian
Walker. These were the only five no knock warrants obtained by LMPD to this date in all
of 2020. Breonna was not listed as a target on the LMPD whiteboards identifying by the
warrants.
8. That Breonna has no criminal history whatsoever, let alone charges or convictions for
drugs.
9. A judge’s signature is on each of the identified March 12, 2020 warrants. Notably, the
Judge listed her Division within her signature on every single other previously warrant she
executed over the prior five months, but did not do so on the Springfield warrant.
10. That, despite the warrants being obtained before 1 pm on March 12, 2020, LMPD did not
execute the warrants until after midnight.
11. That the following officers were assigned on a whiteboard to serve the Springfield warrant:
a. John Mattingly
b. Mike Campbell
c. Mike Nobles
d. Joshua Doerr
e. Tony James
f. Mike King
g. Myles Cosgrove
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h. Brett Hankison/Franklin (K9 dog)
12. That the following officers were assigned to the Elliott and Muhammad Ali warrants:
a. Goodlett

b. Sgt. Meany
c. Barton
d. Weyer
e. Flynn
f. Priel
g. Haywood
h. Benzing
i. Sgt. Phan
j. Sgt. Neal
k. Beckham
l. Evans
m. Pawul
n. Winstead
o. Gibson
p. Daughtery
q. McCauley
r. Haywood
s. Neese
t. Kiper
u. Mattiche
v. Troutman
13. The following officers are listed on the warrant execution form, but were not assigned on
the whiteboard:
a. Vidourek
b. Jaynes
c. Settle
d. Doerr (listed for Springfield on the whiteboard)
14. That the warrant whiteboard lists the Springfield address as 3007 Springfield. Multiple
officers and dispatchers continue to identify the address as 3007 Springfield even after the
shooting.
15. That at 11:12 pm on March 12, 2020, LMPD Sergeant Kyle Meany (who was not assigned
to Springfield on the whiteboard) requested that an ambulance prepare for the execution of
the Springfield warrant and stage closely nearby. The ambulance staged at 11:17 pm, only
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to be cancelled and depart from the scene at 11:39 pm.
16. LMPD officers’ report executing the warrant at 2424 Elliott and detaining Glover and

others at 12:40 am.
17. That shortly thereafter, LMPD officers attempted to execute the Springfield warrant. These
officers were in plain clothes and were required to have a patrol officer present in order to
flash blue lights upon entry into the home. LMPD has not identified this officer, who would
have been required to have body camera activated.
18. That the apartment complex in which Breonna’s home was located does have security
cameras, but LMPD has not produced footage from them to date.
19. LMPD officers did not announce their presence prior to entering Breonna’s home. More
than a dozen neighbors have confirmed the same.
20. Present for the breach and entry were, at a minimum, were the Defendants officers, as well
as officers Michael Campbell, Tony James and Mike King. Lieutenant Shawn Hoover was
also present according to Mattingly, but he is not identified anywhere on the warrant
assignments.
21. Mattingly states that he was assigned the initial entry into the home. In this situation,
protocol would have been for Mattingly to use a ballistic shield to enter. This shield, if
used, should have covered his chest down below to a portion of his legs extending below
his wallet and pockets. LMPD has not indicated whether this was used and, if not, why not.
22. Breonna and Kenny yelled multiple times for the individuals banging on the door to
identify themselves. The officers did not announce themselves, their police affiliation, or
their purpose prior to making entry.
23. That a reasonable individual would be able to hear these screams from outside the
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apartment, as confirmed at multiple other apartments within the building.
24. As the door was slamming open from the hinges, Kenny Walker fired a warning shot

towards the ground. His intention was to scare off the intruder. Defendant Mattingly
suffered a gunshot wound to his thigh which, per Tom Wine, went through Mattingly’s
wallet in his front pocket. Mattingly claims he then went to the ground, scooted out of the
apartment, dropped his gun, picked it up, got to his feet and then fell to the ground over
Officer Campbell before holstering his firearm. Despite the unexpected jerking and falling
backwards to the ground, Mattingly claims that his Glock did not discharge as a result.
Mattingly claims he fired six shots total into Breonna’s home; 4 from inside the home and
2 more after exiting the home.
25. That Defendant Hankison fired more than 20 shots, the majority of which were fired blindly
from outside the home through windows which were covered by shades and blinds.
26. That at 12:43 am, the shooting is reported to LMPD dispatch.
27. That at 12:44 am, patrol officer Randall Richardson reports being on the scene. His body
camera has not been produced.
28. That at 12:46 am Kenny Walker calls 911; he confirms in the audio that he does not know
who broke into the home and killed Breonna.
29. That following the shooting, officers (one of whom is believed to be Hankison) reported to
dispatch that Kenny Walker was “bunkered up” inside the home with an assault rifle.
Walker did not have an assault rifle.
30. That following the initial flurry of gunshots, witnesses state that an officer (presumably
Hankison) yelled “reload” and then proceeded to fire more into Breonna’s home. Several
of Hankison’s rounds went into an adjacent apartment in which a pregnant mother and five-
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year-old son were located.
31. That at 12:46 am officer Ed Johnson arrives on scene. His body camera has not been

produced.
32. That at 12:51, officer Steven Gida arrives on scene. He is a neighbor of Hankison, and he
also appears to leave the scene without announcing his whereabouts. He does not return
until shortly before 2 am.
33. That at 12:52, Sergeant Brent Jones arrives on scene. He departs the scene at 1:10 am and
does not return until close to 2:30 am. His body camera has not been produced.
34. That the SWAT team arrives around 1 am. This unit is equipped with body cameras. This
camera footage has not been preserved.
35. That shortly after 1 am, officer Jonathan Harris arrives on scene. He then leaves the scene
shortly before 2:30 am and proceeds to Elliott. Nothing has been produced to explain this
odd sequence. No body camera has been produced.
36. That the major of Hankison’s unit at this time was Kimberly Burbrink. Prior to becoming
a ranking officer, Burbrink was Hankison’s longtime partner. She was also Hankison’s
neighbor at the time and had been for nearly two decades. Her whereabouts and actions on
the morning in question are unknown.
37. That the lieutenant of Hankison’s unit at this time was Shawn Hoover. He was also part of
the team which rammed Breonna’s door. Prior to becoming a ranking officer, Hoover
worked side by side with Hankison and Burbrink. No documentation has been produced to
explain why a lieutenant was at Breonna’s home and why his identity was not disclosed on
the whiteboard or CAD log.
38. That dozens of officers dispatched to Springfield prior to 1 am do not report being on scene
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for more than an hour; in many cases it is 2-5 hours before arrival with no indication of
what they are doing in the meantime.

39. That more than 120 officers were ultimately dispatched to Springfield. Other than those
with SWAT, the vast majority of the officers do not appear on scene until after 1:20 am.
From the undersigned counsel’s experience in officer shooting cases, this figure is
incredibly high.
40. That no body camera has been produced from any officers.
41. That following the shooting, Breonna’s mother was advised at the scene by LMPD that
Breonna was at the hospital.
42. That after spending multiple hours at the hospital only to be told that Breonna was not
there, Breonna’s mother returned to Springfield. She remained there for several additional
hours before being told that Breonna was inside the home.
43. That Hankison was assigned a body camera. In fact, the undersigned is in possession of his
body camera footage from another incident.
44. The criminal interdiction officers were wearing body cameras at the execution of the
warrant at 2424 Elliott.
45. The following the shooting, LMPD officer Kelly Hanna Goodlett advised those present at
2424 Elliott to turn off their body cameras.
46. That following the shooting, multiple officers who were previously at Springfield left the
scene and went to Elliott.
47. The following the shooting, Hankison left the scene of Springfield and could not be located
by LMPD. Nothing has been produced to date establishing his whereabouts.
48. The following the shooting, Officer Barton sought a warrant for the same bank records
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which he already confiscated from Glover.
49. That the bank records show multiple payments from Glover to Breonna made via Zelle.

These payments were for 1) Glover’s phone bill, which had been in Breonna’s name since
the two dated previously and 2) shoes which Breonna had shipped to her home for Glover.
50. That these bank records, rather than any U.S. Postal Service records, identify Glover’s
address at Springfield; this was likely the basis relied upon by Barton and Jaynes in
identifying the Springfield address in seeking the warrant. Barton’s efforts to obtain the
records (which he already had obtained) post-shooting were a deceptive effort try and show
a further connection between Glover and Taylor when, in fact, they were the original basis
for the connection.
51. That LMPD’s sixth and last no-knock warrant obtained this year also related to Jamarcus
Glover.
52. There are legitimate concerns regarding LMPD’s propensity to cover up incriminating
evidence implicating criminal conduct of Hankison. Over the past week, several women
have come forward with allegations of sexual assault against Hankison. Multiple women
have insisted that they filed citizen complaints against Hankison with LMPD, yet
Hankison’s personnel file lacks these complaints and no actions were taken against him.
53. As it stands currently, the phones and devices of the Defendant officers have not been
produced. Confirmation has not been provided that they were preserved and placed in the
hands of a custodian.
IV. STANDARDS FOR RELIEF
Per CR 65.04, a temporary injunction may be granted if the “movant's rights are being or
will be violated by an adverse party and the movant will suffer immediate and irreparable injury,
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loss, or damage.” CR 65.04. The granting of a temporary injunction is within the sound discretion
of the trial court. Maupin v. Stansbury, 575 S.W.2d 695, 697-98 (Ky. App. 1978). A Court should

grant a temporary injunction if the movant shows irreparable injury and a weighing of the equities
favor injunctive relief. Id. As the movant, the Plaintiff concedes that she carries the burden of
showing these elements. CR 65.04(1); Maupin, 575 S.W.2d at 698. At a minimum, the rule
contemplates that a mere allegation that irreparable injury will result is insufficient. Rather, “(t)he
complaining party must allege and prove facts from which the court can reasonably infer such
would be the result.” Id. at 698-99. In a departure from federal jurisprudence, in Kentucky a
movant is not required to show a substantial probability of success on the merits. Id.
V. ARGUMENT: FURTHER USAGE OF THE DEVICES WILL CAUSE

IMMEDIATE AND IRREPARABLE INJURY, LOSS OR DAMAGE
The continued usage of the identified devices will violate the Plaintiff’s rights. The
information contained within devices is subject to destruction, whether intentional or not, for a
plethora of reasons. Communications, recordings, data files, and other critical information are
subject to retention schedules, deletion, modification, and destruction. This is not speculative; it
happens and all forensic experts in this field confirm the same. Given that three months have
elapsed since the shooting, it is imperative that the devices be placed in the hands of a custodian
and that they be copied/imaged/extracted immediately. The annoyance is minimal; the Defendants
may either get new phones or they may have their devices returned once the extraction process is
completed. Meanwhile, if this relief is denied, the harm associated with the loss of critical
communications and data is substantial. As alluded to previously, the facts as set forth by LMPD
and the Defendants differ entirely from those identified in the Plaintiff’s investigation. The
information on these devices will reconcile these discrepancies, especially as it relates to the
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locations of the officers, the information giving rise to the officers’ presence at Breonna’s home,
the identify of those who actually went to Breonna’s home, the events giving rise to the entry and

shooting, and the actions of the officers thereafter. As data and information within the devices
continues to be lost with time, there is an immediate impairment of the Plaintiffs’ rights.
VI. NEUTRAL IMAGING/EXTRACTION/COPYING OF THE DEVICES WILL

NOT BE BURDENSOME OR PREJUDICIAL
A balancing of the various equities involved in this action heavily weighs in favor of the
issuance of a temporary injunction. The relative benefits and detriments should be weighed, which
entails a consideration of whether the public interest will be harmed by the issuance of the
injunction, whether the Defendants will be harmed or whether its effect will merely be to maintain
the status quo. Maupin, 575 S.W.2d at 698 (citing Kentucky High School Athletic Ass’n v. Hopkins,
552 S.W.2d 685 (Ky. App. 1977)).
The Plaintiff will bear the cost of this process. The Plaintiff has proposed a protocol to
assure that, while efforts are made at complete restoration and imaging, only the restored
information which is relevant and non-privileged would be produced to Plaintiff’s counsel. The
devices will be returned from the neutral custodian as soon as the data is obtained.
PROPOSED PROTOCOL
1. The Court appoints a neutral custodian to take immediate possession of the cell phones,
body cameras, MDT’s, arbitrator units, tablets, and computers which were in any of the
Defendants’ possession at any time from March 12, 2020 to present.
2. The Court appoints a neutral expert to perform a logical, physical, and manual extraction
and examination of the Defendants’ cellular telephones which were in their possession at
any time from March 12, 2020 to present, as well as the corresponding cloud accounts for
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each.
3. The Court appoints a neutral expert to image/copy the body cameras, MDT’s, arbitrator
units, tablets, and computers in the Defendants’ possession at any time from March 12,

2020 to present.
4. Plaintiff shall cover the complete costs associated with the work performed by the
custodians and neutral expert(s).
5. All parties to this action, their attorneys, and their own forensic experts, if applicable, may
be present during the extractions/imaging/copying.
6. The devices shall be returned to the Defendants’ counsel following the completion of the
extractions/imaging/copying.
7. Only counsel for the Defendants, along with their own designated forensic expert, if
applicable, shall be provided with copies of the extractions/imaging/copying.
8. Once the extractions/imaging/copying is done, the forensic analysis shall identify the
following:
a. Text messages and other instant messaging
b. Emails
c. Social media usage and social media messaging.
d. Call history
e. Location data
f. App usage and data
g. Deleted communication.
h. Voicemails
i. Photographs and recorded media (including video and audio)
j. Any other forms of communications

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9. The neutral shall prepare a report identifying all methodologies used and results of the
analysis (including any non-recoverable information). In addition to the report, the neutral

shall submit to counsel for Defendants complete copies of all recovered text messages,
voicemails, emails, pictures, videos, app data and other communications from the cellular
phones and cloud accounts. These items shall be produced with bates labeling for
identification.
10. Within 24 hours of receiving the report and copies of received information, defense counsel
shall notify counsel for Plaintiffs that the same has been received.
11. Upon receipt of the report and information, counsel for Defendants shall have seven (7)
days review the report and information and lodge claims for privilege and objections with
the Court or otherwise to Plaintiff’s counsel in relation to matters on the report and within
the other received information.
12. On or before the expiration of the 7-day review period, Defendants’ counsel shall produce
a complete copy of the report and the information received, with redactions in identifiable
black markings and labeled “REDACTED” to counsel for Plaintiff.
13. Counsel for Defendants shall prepare and produce to Plaintiff’s counsel a privilege log
designating the contents of the report and additional information which they claim are
subject to privilege and objections.
14. If, after good faith measures are made, the parties cannot agree upon a resolution to disputes
over claims for items designated as privileged or subject to objections, the parties shall
only then request that the Court the review the materials as part of an in-camera review.
15. If an in-camera review is necessary, the forensic expert shall provide the Court with the
report and the bates labeled production so that the Court may be able to efficiently identify
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the items subject to dispute.
VII. CONCLUSION
The Court should grant a temporary injunction to enjoin the Defendants from continuing

to use and/or retain the cell phones, tablets, body cameras, MDT’s and computers, which have
been in their possession at any time from March 12, 2020 to present. Temporary injunctive relief
is necessary pending the extraction/copying/imaging of the devices. The Plaintiff has demonstrated
that she will suffer immediate and irreparable injury and that the balancing of equities greatly
weighs in favor of temporary injunctive relief. The Plaintiff has no adequate remedy at law if this
critical evidence is lost or destroyed. The relief the Plaintiff requests is the only means to mitigate
the irreparable harm that would be caused by the continued usage of the devices.
Respectfully submitted,
SAM AGUIAR INJURY LAWYERS, PLLC
/s/ Sam Aguiar

Sam Aguiar
Lonita Baker
1201 Story Avenue, Suite 301
Louisville, KY 40206
Telephone: (502) 400-6969
Facsimile: (502) 491-946
sam@kylawoffice.com
lonita@kylawoffice.com
Counsel for Plaintiff
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CERTIFICATE OF SERVICE
I hereby certify that the foregoing was electronically filed with the Jefferson Circuit Court
and a true and accurate copy was served via electronica mail and/or U.S. First-Class Mail, postage
prepaid, on the 9th day of June, 2020 upon the following:
Peter F. Ervin
Kristie Walker
Assistant Jefferson County Attorney
531 Court Place, Suite 900
Louisville, KY 40202
Peter.ervin@louisvilleky.gov
Kristie.walker@louisvilleky.gov
Counsel for Defendants
/s/ Sam Aguiar

Counsel for Plaintiff
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Breonna Taylor Lawsuit - Motion To Compel

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Filed 20-CI-002694 06/09/2020 David L.

Nicholson, Jefferson Circuit Clerk

NO. 20-CI-002694 JEFFERSON CIRCUIT COURT

TAMIKA PALMER, PLAINTIFF

BRETT HANKISON, et al. DEFENDANTS

*** *** *** *** *** ***

MOTION FOR INJUNCTIVE RELIEF AND TO COMPEL PRODUCTION OF

entry of the proposed Order.

4. Neutral experts be appointed to perform inspection, imaging, logical extraction, and

Filed 20-CI-002694 06/09/2020 David L. Nicholson, Jefferson Circuit Clerk

physical extraction, as well as copying of cloud data from these devices.

recorded media, data, and communications.

relevant documents, recorded media, data, and communications.

demand encompassed the information and devices sought herein.

II. FACTS ACCORDING TO LMPD

Shortly following Breonna’s death, LMPD identified the following narrative:

a search warrant upon Breonna Taylor’s home.

Filed 20-CI-002694 06/09/2020 2 David L. Nicholson, Jefferson Circuit Clerk

and officers from the ninth mobile division.

participating in a drug ring. See Search Warrant Affidavit, Exhibit B.

and waited more than a minute for compliance.

home and were immediately met by gunfire.

7. That the Defendant officers returned gunfire.

8. That Breonna Taylor was killed.

officers were assigned to execute the warrant at Breonna’s home:

f. Hankison’s drug dog, Franklin

Filed 20-CI-002694 06/09/2020 3 David L. Nicholson, Jefferson Circuit Clerk

11. That there was no body camera footage of the events.

III. FACTS IDENTIFIED WITHIN THE COURSE OF PLAINTIFF’S

during the execution of search warrants by narcotics detectives.

vehicle and confiscated a bank statement from the vehicle.

Filed 20-CI-002694 06/09/2020 4 David L. Nicholson, Jefferson Circuit Clerk

for coming out empty.

execute the warrants until after midnight.

h. Brett Hankison/Franklin (K9 dog)

Filed 20-CI-002694 06/09/2020 5 David L. Nicholson, Jefferson Circuit Clerk

to be cancelled and depart from the scene at 11:39 pm.

Filed 20-CI-002694 06/09/2020 6 David L. Nicholson, Jefferson Circuit Clerk

others at 12:40 am.

have been required to have body camera activated.

than a dozen neighbors have confirmed the same.

their purpose prior to making entry.

apartment, as confirmed at multiple other apartments within the building.

Filed 20-CI-002694 06/09/2020 7 David L. Nicholson, Jefferson Circuit Clerk

2 more after exiting the home.

26. That at 12:43 am, the shooting is reported to LMPD dispatch.

camera has not been produced.

who broke into the home and killed Breonna.

Walker did not have an assault rifle.

year-old son were located.

Filed 20-CI-002694 06/09/2020 8 David L. Nicholson, Jefferson Circuit Clerk

until shortly before 2 am.

camera footage has not been preserved.

odd sequence. No body camera has been produced.

the morning in question are unknown.

the whiteboard or CAD log.

what they are doing in the meantime.

Filed 20-CI-002694 06/09/2020 9 David L. Nicholson, Jefferson Circuit Clerk

Breonna was at the hospital.

body camera footage from another incident.

warrant at 2424 Elliott.

2424 Elliott to turn off their body cameras.

scene and went to Elliott.

* * * * * *