IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Civil Action No. 12-CV-02682-J LK-MJ W

J AMAL HUNTER,

Plaintiff,
v.

THE CITY AND COUNTY OF DENVER, a municipality;
DEPUTY GAYNEL RUMER, in his individual and official capacities; and
DEPUTY EDWARD KELLER, in his individual and official capacities,

Defendants.


DEFENDANT THE CITY AND COUNTY OF DENVERS SUBMISSION OF
POTENTIALLY RELEVANT DOCUMENTS RELATED TO PLAINTIFFS
MOTION FOR SANCTIONS AND EMERGENCY HEARING [ECF NO. 106]



EXHIBIT A

RESTRICTED ACCESS LEVEL 1 & CONVENTIONALLY SUBMITTED
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AFFIDAVIT OF AMOS U. PAGE
I, Amos U. Page, swear that the following is true and correct to the best ofmy knowledge
and information. I was born on July 21, 1988. 1 have not been made any promised or been
induced in any way to make this voluntary statement.
1. They call me "DC." I was a tier porter in 3A. I was in 3A for around one year. I cleaned
the pods and I was not subject to the lockdown as I was a trustee. As such, I could walk around
the pod unrestricted from around 6 in the moming, breakfast, until night lockdown.
2. In about October 2010, I caught Rumer with a thermos full of straight vodka. I emptied it
into my Folgers coffee cup when he wasn't looking. I told him "I got his vodka." He gave me a
scared look. I told him "I wasn't going to tell but 1 wanted a pack cigarettes and a lighter." The
next day, he brought me the lighter and a pack ofNewport cigarettes. After that, we were cool.
He wanted to be friendly with me as he did not want me to tell on him. He would often be drunk
around me and I would joke with him about being drunk on his shift.
3. After that, we went into business together. Rumer would bring in porno magazines and I
would sell each page for $3.00 a page. At first, he let me keep the money, and after a while 1
would buy the magazines for $10.00 using pop tokens. Inmates would pay me in pop tokens,
street to street money to my baby's mama, stamps, and different types of contraband.
4. Rumer would let me control the pod. Rumer would allow me to give other inmates
violations such as "50 punches to the chin" or "straight up two minutes" (two minutes with four
homies). This happened in the cleaning closet or the shower. If someone left without a
"pumpkin head," I would make it happen again. Rumer knew this was going on. He would
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Exhibit A
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I

Affidavit ofAmos U. Page
June 13,2013
Page 2 of5
unlock the closet or tum off the lights in a room or the bathroom. Rumer was our regular pod
officer and the vast majority ofviolations happened on his shift.
5. If Rumer didn't like an inmate, he would approach me and tell me to take care of it.
was his muscle. Rumer used us to get rid of inmates that he didn't like. Rumer would unlock
the cell of the person when everyone else was on lockdown. Since four of us in my cell were
trustees, our door would not be locked during the day. Everyone in my cell would come out, and
my little homies would take care ofthat inmate.
6. Rumer would often feed me information about other inmates. Rumer would allow me to
look on his computer. We knew who were the sex offenders. Rumer would tell us who was
snitching. When inmates owed me money and tried to kite out of 3A, Rumer would always
loudly announce that the inmate was trying to kite out. Rumer would also tell me about other
inmate's kites.
7. At first, Hunter and I were cool. I took care ofhim. He didn't belong in that pod. I
would tell Hunter ''this is not the spot for you." Hunter was scared ofme. Hunter and Rumer
hated each other because Hunter would openly make fun of him for being a drunk. I was really
disappointed when Rumer told me Hunter was talking shit about me in court.
8. One time, Rumer and I got into it over Lloyd. Rumer once told too much info to a 211
about Llyod's nv, going into too much detail about the dog collar and her being white. This put
Llyod into danger with the 211 s. I beat a 211 guy and he told me that Rumer was spreading shit
about Lloyd. I went to Rumer and told him never do that again. Rumer said sorry and he
wouldn't do that again. I had total control over Rumer.
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Exhibit A
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Affidavit ofAmos U. Page
June 13, 2013
Page 3 of5
9. We used information we learned from Rumer to get rent from other inmates. I got paid in
rent about $50.00 a week. I used the information from Rumer to get inmates to pay for
protection. If they didn't pay me protection, they would get beat up almost daily.
10. I arranged a street to street with Rumer where he received $150.00 in February 2011.
During this street to street Rumer was given weed and he brought it to the jail for me. I sold it
for $20 per Chap Stick cap.
11. We were making about 20 gallons ofhooch a week in my time in 3A. Rumer knew we
were doing this. We sold a soda bottle ofhooch for $5.00. Rumer would get $20.00 a batch.
We would make the hooch in a smallS gallon trash bag. It took me 4 days to make the hooch.
We would arrange for Rumer to shake down a cell that we knew was in the blind spots ofthe
camera and contained the hooch. Rumer would ignore the hooch and the other guards would not
shake down that cell because they only shook down a cell about every week. I never got caught
selling hooch because of Rumer.
12. I observed the burning and beating ofJamal Hunter. It happened in my cell. It was at
count time, in 103 around 3:00pm. As soon as Hunter came back from court, my homie Bananas
told me that Hunter was talking shit about me and my boys. I went to Rumer and asked what he
heard and Rumer confrrmed everything Bananas told me. Rumer went over the top about Hunter
snitching. He was clearly trying to "poor gas on a fire." I told Rumer, about 15 minutes before
this went down, that I was going to take care ofthe situation. Rumer said ok and he offered to
turn off the lights. I said ok. When the lights are on, there is a clear view into the room from the
cameras. Rumer said to make sure it happened before his shift was over. The way we were
running the pod, Rumer knew the consequences on Hunter were going to be severe.
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Exhibit A
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~
Affidavit ofAmos U. Page
June 3 ~ 2013 "-
Page 4 of5
13. Rumer usually started his count downstairs, but this time he started upstairs. Rumer
didn't like Hunter. My homie came from the upper tiers and got two big cups ofhot water. He
handed the water to me. By that time, Hunter was knocked unconscious. He had been knocked
out 4 to 5 times. Rumer did the rounds ten minutes before the count. There was blood on the
floor and on the wall. Rumer saw Hunter's blood on the floor and wall ofmy cell, looked at me,
and in a non-verbal way, told me to clean it up, and opened the cleaning closet right outside my
cell and he went on his way. Hunter's thermal shirt was full of blood and was in the trash can.
The sheriffs never took the shirt. We then ripped up the shirt and flushed it. I was surprised they
didn't take it.
14. After the Hunter situation was over, I was taken to the hold. Sgl Sich asked me what
happened but I didn't say anything. Two days later, I was interviewed by Captain Romero. I
told him that Rumer knew what was going on. I told DPD officer Medina two weeks later
everything about what happened to Hunter, my involvement, and I told him to talk to Rumer
because he knew what was going on. I told Medina, "why are you fucking with me, Rumer was
there and knew what was going on and knew what was going to happen." "Rumer turned the
lights off for me." As soon as I said that about Rumer, Medina got up and left and I never heard
anything else about that.
15. The Hunter incident could not been pulled offwithout Rumer's help, as Hunter was
screaming the entire time he was conscious.
16. I was told later, by Captain Romero, that I was found not guilty of any discipline. I
didn't have a disciplinary hearing or anything like that. I have previously been before the three
person board. This didn't happen with the Hunter incident. I was then told that there would be
no criminal charges.
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Exhibit A
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Affidavit ofAmos U. Page
June 13,2013
Page 50f5
I, Amos U. Page, declare under penalty ofperjury pursuant to 28 U.S.C. 1746 and the
laws ofthe United States of America that the preceding is true and correct, based on my
personal knowledge.
___2013.
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Exhibit A
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