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4:18-cv-00554-MGL Date Filed 04/23/19 Entry Number 112 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT


DISTRICT OF SOUTH CAROLINA
FLORENCE DIVISION

NATIONAL ASSOCIATION FOR THE Civil Action No. 4:18-cv-00554-MGL


ADVANCEMENT OF COLORED PEOPLE,
INC., et al.,

Plaintiffs, DEFENDANTS’ MOTION FOR LEAVE


TO AMEND THEIR RESPONSE TO
v. PLAINTIFFS’ SECOND MOTION FOR
PRELIMINARY INJUNCTION
CITY OF MYRTLE BEACH, et al.,

Defendants.

Defendants City of Myrtle Beach and City of Myrtle Beach Police Department

(“Defendants”) move for leave to amend their response to Plaintiffs’ second motion for

preliminary injunction. Defendants seek to amend their response by adding: two charts

representing admission rates to the Grand Strand Medical Center’s Trauma Center and the

deposition transcript of Joe Hill, Chief of Police for the Horry County Police Department. (Ex. 1,

Total Trauma Chart; Ex. 2, Motorcycle Trauma Chart, Ex. 3, Hill Depo.).

The Grand Strand Trauma Center’s admission rates were provided to Plaintiffs on March

28, 2019. These rates were put into a chart by Defendants’ expert, Kyle McLean, Ph.D. (Ex. 4,

McLean Aff.). The charts show trauma admissions for Memorial Day Weekend dramatically

decreased from 2014 to 2015, the year Defendant’s implemented the traffic management plan.

Plaintiffs took the deposition of Chief Hill on April 15, 2019. During his deposition Chief

Hill testified:

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(1) Prior to becoming the Chief of Police for the Horry County Police Department, Chief Hill

worked for the Fairfax County, Virginia Police Department for 28 years. (Ex. 3, Hill Depo., 14:14-

20)

(2) While working in Fairfax County, Chief Hill was commander in charge of civil disturbance

units and handled police presence for the International Monetary Fund conferences, four

presidential inaugurations, assisted Washington Metro, D.C. with their special events, and several

events in Fairfax County. Id. at 15:15-20.

(3) Chief Hill attended Memorial Day Weekend as a biker with the Buffalo Soldiers Motorcycle

Club from 2006 to 2012. Id. at 71:7-13.

(4) He specifically testified:

So prior to the traffic management plan, it was a free for all. And I can say that
because I was part of that as a private attendee, not as a law enforcement officer.
What I mean by that is that traffic was everywhere, bikes and cars cutting down
side streets, couldn’t get to where they wanted to be. Everybody wanted to be on
the Boulevard for the show, if you will. And because there was no traffic
management plan when I was here in 2008, no one got anywhere. It was gridlock.
Fast forward to the traffic management plan, although you have long lines to get
down the Boulevard, my opinion, my observation, it's orderly. So you get inside
the – the traffic chute or traffic management plan, and eventually, you’re going to
get down to the Boulevard to make your pass to get out of the – off the boulevard.
It will eventually happen. It may be a few hours, but it will happen.

Id. at 93:9-94:5.

Defendants believe the trauma admissions charts and Chief Hill’s testimony are

important for the Court in reaching a decision regarding Plaintiffs’ second motion for

preliminary injunction. 

RULE 11 CERTIFICATION

The undersigned as counsel for the moving party hereby certifies that prior to filing this

motion he conferred with opposing counsel, who did not consent to this motion.

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WE SO MOVE:

s/James R. Battle
Fed ID #: 10221
s/Michael W. Battle
Fed ID #: 1243
Battle Law Firm, LLC
PO Box 530  
1200 Main Street
Conway, SC 29528
(843) 248-4321 (tel)
(843) 248-4512 (fax)
jbattle@battlelawsc.com

Counselors for Defendants

April 23, 2019

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Hill, Joseph R. April 15, 2019

1
United States District Court
District of South Carolina
Florence Division
National Association for the Advancement of
Colored People, Inc., by and through its Myrtle
Beach Branch, Simuel Jones, Leslie Stevenson and
Cedric Stevenson,
plaintiffs,
v. 4:18-CV-00554-MGL
City of Myrtle Beach, a municipal corporation
within the State of South Carolina, and City of
Myrtle Beach Police Department, a department of
the City of Myrtle Beach,
defendants.

Deposition of: Joseph R. Hill

Location: 1301 Second Avenue


Conway, South Carolina
Date: Monday, April 15, 2019
Time: 9:14 a.m. - 12:02 p.m.
Court Reporter: Roger Williamson
The deposition is taken pursuant to notice and/or
agreement, in the above-entitled cause pending in
the above-named court and pursuant to the Federal
Rules of Civil Procedure.

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Hill, Joseph R. April 15, 2019

2
1 A P P E A R A N C E S
2 For the Plaintiff:
Reiman, Dane & Colfax, P.L.L.C.
3 1225 19th Street N.W., Suite 600
Washington, DC 20036
4 By: Tara Ramchandani, Esq.
tramchandani@relmanlaw.com
5

6 For the Defendant:


Battle Law Firm
7 1200 Main Street
Conway, SC 29525
8 By: Michael W. Battle, Esq
James Richard Battle, II, Esq.
9 mbattle@battlelawsc.com
jbattle@battlelawsc.com
10
For Horry County
11 Arrigo P. Carotti, Esq.
1301 Second Avenue
12 Conway, SC 29526
carottia@horrycounty.org
13

14

15

16

17

18

19

20

21

22

23

24

25

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Hill, Joseph R. April 15, 2019

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1 I N D E X
2 Examination by Ms. Ramchandani 4
3

4 E X H I B I T S
5 No. Description Page
6 Exhibit 1 5/04/2018 Email 59
7 Exhibit 2 5/19/2017 Email 66
8 Exhibit 3 9/30/2014 Email 98
9 Exhibit 4 5/18/2018 Email 116
10 Exhibit 5 5/21/2018 Email 116
11 Exhibit 6 5/23/2018 Email 120
12 Exhibit 7 5/27/2017 Email 127
13

14

15 ** Uh-huh = Affirmative
16 Huh-uh = Negative
17

18

19

20

21

22

23

24

25

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Hill, Joseph R. April 15, 2019

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1 S T I P U L A T I O N S
2 It is stipulated among Counsel that this
3 deposition is being taken pursuant to the Federal
4 Rules of Civil Procedure; and that all objections,
5 except as to the form of the question, are
6 reserved until the time of trial.
7 It is also stipulated among Counsel for the
8 respective parties and the deponent that the
9 deponent will exercise the right to read and sign
10 this transcript.
11 THEREUPON,
12 Mr. Caroti: Standard objections, and
13 we do not waive reading and signing. So we would
14 like to read and sign, please.
15 Thereupon,
16 Joseph R. Hill,
17 being first duly sworn by the Court Reporter, as
18 hereinafter certified, testified as follows:
19 E X A M I N A T I O N
20 By Ms. Ramchandani:
21 Q Good morning.
22 A Good morning.
23 Q Please state your full name for the
24 record.
25 A Joseph R. Hill.

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Hill, Joseph R. April 15, 2019

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1 Q Thank you. And your -- your address
2 for the purpose of the deposition, whether that's
3 work or --
4 A 2560 North Main Street. That's in
5 Conway, South Carolina.
6 Q Great. Thank you. And you're
7 represented by counsel today?
8 A I am.
9 Q Have you ever been deposed before?
10 A I have.
11 Q About how many times?
12 A Five.
13 Q And have those been in your
14 professional capacity or personal capacity?
15 A Four professional, one personal.
16 Q Okay. I guess what -- what types of
17 legal matters were they?
18 A Yes, legal matters.
19 Q I'm sorry. What types?
20 A Criminal and one civil.
21 Q Was the personal one civil?
22 A Yes.
23 Q And the -- what was the nature of the
24 civil?
25 A A neighbor lawsuit.

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Hill, Joseph R. April 15, 2019

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1 Q And I'm sure the answer to this is
2 yes, but have you ever testified in court before?
3 A I have.
4 Q Okay. About how many times?
5 A I don't have an exact number. I would
6 say more than 150.
7 Q Obviously, you are quite familiar with
8 this.
9 A Right.
10 Q But I just wanted to give us a few
11 ground rules to make the morning run as smoothly
12 as possible.
13 A Uh-huh.
14 Q As you know, we have a court reporter
15 here and he's taking down everything that we say,
16 so I just ask that you provide verbal responses
17 rather than gestures or uh-huh's or huh-uh's so
18 that we have as clean a record as possible.
19 A Okay.
20 Q This should, you know, be much like a
21 normal conversation. I don't anticipate us being
22 here too, too long. Certainly we'll have you out
23 of here before noon. But to make the record run
24 as smoothly as possible, I'll just ask that you
25 let me finish my questions before answering. And

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Hill, Joseph R. April 15, 2019

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1 likewise, I will let you finish your answer before
2 I ask another question.
3 A Okay.
4 Q If at any point I ask a question that
5 is unclear or confusing, which I am sure I will,
6 please just ask me to clarify. And you have to
7 ask me rather than your counsel to clarify a
8 question --
9 A Okay.
10 Q -- if you have a question. Okay? If
11 at some point while we're talking you remember
12 more about a topic that we had already covered
13 earlier in the morning, please just let me know
14 and we'll go back and we'll supplement the record.
15 My goal is just to have as clear a record and as
16 complete a record as possible.
17 A Understood.
18 Q You understand you're under oath today
19 just as if you were in court?
20 A Yes.
21 Q And at times, I'm sure your counsel
22 will object to some of my questions. Unless you
23 are directed not to answer, you should go ahead
24 and answer the question.
25 A Okay. Understood.

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Hill, Joseph R. April 15, 2019

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1 Q Okay. If you need a break at some
2 point, please just let me know. I'm happy to take
3 one. The only thing I'll ask is that if I have a
4 question pending, you just answer the question
5 before we take a break.
6 A Understood.
7 Q Is there any reason, health or
8 otherwise, you can't give clear and honest
9 testimony today?
10 A No, ma'am.
11 Q What if anything did you do to prepare
12 for today's deposition?
13 A Had a conversation with my attorney.
14 Q And was that one conversation or
15 multiple conversations?
16 A One.
17 Q And did you speak with any other
18 officials or employees from Horry County in
19 preparing for today's deposition?
20 A No, ma'am.
21 Q Did you speak with anybody, any
22 officials or employees from the City of Myrtle
23 Beach before today's deposition?
24 A No, ma'am.
25 Q Okay. Was there anybody else you

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Hill, Joseph R. April 15, 2019

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1 talked about this deposition with?
2 A No.
3 Q Did you review any documents in
4 preparation for today?
5 A Yes. One.
6 Q What document was that?
7 A It's our bike schedule.
8 Q And what do you mean when you say bike
9 schedule?
10 A It's our operation plans.
11 Q And for -- for what?
12 A Just to refresh my memory.
13 Q Oh, sorry. No. Sorry. Operation
14 plans for -- for what?
15 A Oh, I'm sorry. For the law
16 enforcement presence for our bike week month of
17 May. Yeah, it has both schedules on there.
18 Q And when you say our law enforcement
19 presence, are you referring to Horry County?
20 A Just Horry County. Yes.
21 Q And is that the Horry County Police
22 Department?
23 A That is.
24 Q Okay. It's not the sheriff?
25 A No, ma'am.

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Hill, Joseph R. April 15, 2019

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1 Q And I think you just referred to bike
2 month. You said both rallies. What were you
3 referring to there?
4 A Both the Harley Davidson and Memorial
5 Day festivals.
6 Q And do those both take place in May?
7 A Yes, they do.
8 Q And do you have separate operations
9 plans for each of those events?
10 A We do.
11 Q Was that the case when you joined the
12 Horry County Police Department?
13 A Yes, ma'am.
14 Q And have you made any substantial
15 changes to the operations plans?
16 A No, ma'am.
17 Q So it's -- you mostly maintained what
18 was already in place when you arrived?
19 A Yes.
20 Q And is that true for both -- both of
21 the rallies?
22 A That is true.
23 Q Are there any -- is there anything
24 else that happens during bike month related to
25 motorcycles or are those the two things?

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Hill, Joseph R. April 15, 2019

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1 A Just that.
2 Q Okay. So it's just those two rallies?
3 A Yes, ma'am.
4 Q You're aware that we're here today in
5 conjunction with the lawsuit of the NAACP and a
6 number of plaintiffs have filed against the City
7 of Myrtle Beach?
8 A I am.
9 Q What do you know about the lawsuit?
10 A There is some opposition from NAACP
11 about the traffic management plan.
12 Q And when you say the traffic
13 management plan, what are you referring to?
14 A The -- the loop as they call it.
15 Q What's your understanding of what the
16 complaints are about?
17 A That it is not the same level of law
18 enforcement presence for the Harley activities as
19 it is for the Memorial Day festivals.
20 Q Is there anything else that you know
21 it to be about?
22 A No, ma'am.
23 Q Are you aware that there was a
24 previous lawsuit filed by the NAACP against the
25 City of Myrtle Beach in the early 2000's?

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1 A I didn't know when, but I heard there
2 was a previous lawsuit.
3 Q And what have you heard about it?
4 A Same thing, basically.
5 Q Okay. Did you know anything about the
6 resolution of that lawsuit?
7 A No, ma'am.
8 Q And who have you heard that the
9 lawsuit -- I'm sorry, the current lawsuit is from?
10 A I couldn't tell you a person. Just
11 talked with people who were here during that time.
12 Q Have you ever spoken with any of the
13 Myrtle Beach city officials about the lawsuit?
14 A No, ma'am.
15 Q That includes, I'm sorry, anybody from
16 the Myrtle Beach Police Department about the
17 lawsuit?
18 A No, ma'am.
19 Q What about the previous lawsuit?
20 A No.
21 Q So you haven't talked to anybody from
22 the City of Myrtle Beach --
23 A No.
24 Q -- about the lawsuit? Chief, where
25 are you -- where are you from?

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1 A Originally, Cincinnati, Ohio.
2 Q And how long have you been living in
3 South Carolina?
4 A About two-and-a-half years.
5 Q Do you live in Horry County?
6 A I do.
7 Q Do you live within the -- in the
8 unincorporated areas or are you in the City of
9 Myrtle Beach?
10 A I do. Unincorporated areas.
11 Q Since you have moved here, have you
12 ever lived inside of the City of Myrtle Beach?
13 A I have.
14 Q And when was that?
15 A When I first moved here, for the first
16 six to eight months, I lived in a community called
17 The Grand Dunes.
18 Q And during that time period, were you
19 living in The Grand Dunes during a bike week?
20 A I was.
21 Q Which year?
22 A Seventeen. Yes.
23 Q So we're in 2019. Did you move here
24 in early 2017? Would that be right?
25 A Sixteen. Latter part of '16.

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1 Q Okay. And what -- what led you to
2 move to Horry County?
3 A I wanted to get out of the Washington,
4 D.C. area.
5 Q Fair enough.
6 A Yeah. You know.
7 Q How long had you been in the D.C. area
8 before that?
9 A 1984, when I was stationed there in
10 the Navy.
11 Q And if you could, just quickly run me
12 through your positions while you were -- from the
13 date forward to --
14 A Sure. Eighty-four, I was in the
15 military. And I joined the Metropolitan
16 Washington, D.C. Police Department. Served there
17 for a period of four years. 1988, I applied and
18 was accepted to the Fairfax County, Virginia
19 Police Department and finished my career there, 28
20 total years.
21 Q And what was your position when you --
22 when you left the Fairfax Police Department?
23 A Major in charge of administrative
24 support.
25 Q And what did -- what -- what does that

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1 involve?
2 A Human resources, recruiting,
3 retention, budget management, policy development.
4 Q They must have been sad to have you
5 go.
6 A They had. It was.
7 Q Because that's a lot -- a lot for
8 somebody else to take over.
9 A Yeah.
10 Q In your time at the Fairfax P.D., did
11 you -- were you ever -- did you ever have
12 responsibility for large special events?
13 A I did.
14 Q What types of events?
15 A I was commander in charge of civil
16 disturbance units, so I did the I.M.F.,
17 International Monetary Fund. I did several
18 inaugurations, several special events and
19 assistance with Washington Metro, D.C. and several
20 events that occurred in Fairfax County proper.
21 Q So the I.M.F. group would be the
22 I.M.F. conferences --
23 A Yes.
24 Q -- that took place in D.C.? Okay.
25 And then presidential inaugurations?

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1 A Yes.
2 Q How many inaugurations would you say
3 you --
4 A If I remember correctly, four. If I
5 recall correctly, it was four.
6 Q And were -- were you stationed in --
7 inside D.C. for those or was it --
8 A Yes. We were special deputized to
9 serve as D.C. law enforcement.
10 Q Well, what are the other sort of
11 largest events that you -- you worked while you
12 were in Fairfax?
13 A I'm trying to think of the name of the
14 rally. Several C.I.A. rallies, the central
15 intelligence agency in McLean. And there were a
16 few protests. I can't remember the actual name of
17 the groups, but they were protesting the banking
18 industry and they happened to pick Fairfax County
19 as their protest site.
20 Q Were you -- what were -- what were --
21 what was your role with regards to the
22 inaugurations?
23 A The inaugurations was the
24 C.V.U. commander -- element commander. So what
25 that means is you had up to 30 officers that were

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Hill, Joseph R. April 15, 2019

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1 stationed on the line to protect the parade route
2 from the -- any type of aggression from the crowd.
3 Q Were you responsible for any of the
4 planning of the traffic management for those
5 events?
6 A Yes. Well, not for traffic
7 management, no -- no, ma'am. That was all related
8 to D.C. had to have. We were just personnel
9 management.
10 Q Okay.
11 A Crowd management.
12 Q Have you ever been responsible for
13 traffic management for a large special event?
14 A Yes.
15 Q When?
16 A Fairfax Fair, which is a local fair
17 that's held in Chantilly. As a motorcycle
18 officer, our role was traffic management.
19 Q Did -- were you personally responsible
20 for the planning of how that traffic management
21 would work?
22 A I was number three in the group that
23 were planning. It was kind of a team effort.
24 Q And about how many people would come
25 to that fair --

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Hill, Joseph R. April 15, 2019

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1 A Oh, my goodness. I do not have exact
2 numbers. Largest event that occurred in Fairfax
3 County. I couldn't tell you exact numbers.
4 Q Take the kids up, I imagine --
5 A Yes, great time.
6 Q Okay. And then what -- so -- and I'm
7 sorry, you said that just wanting a change of
8 locations is what led you to apply to the Horry
9 County --
10 A I did.
11 Q -- Police Department. Yeah. Were you
12 recruited for that position?
13 A No, it was an open process. They did
14 a national search. I was one of many applicants
15 who applied.
16 Q And how would you describe your
17 position and responsibilities here in Horry
18 County?
19 A Here in Horry County? Chief of police
20 of a medium-sized agency. The agency consists of
21 about 245 sworn-in officers and about 35
22 civilians. Typical law enforcement duties, we're
23 the primary law enforcement agency in the county.
24 So you deal -- or basic mission is patrol and
25 public safety, reduction of crime and fear of

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1 crime.
2 Q And I'm thinking this is right, given
3 what we just went over, but this is your first
4 position here in Horry County?
5 A Yes.
6 Q Okay. You took over after Chief
7 Rhodes retired. Is that right?
8 A That is correct.
9 Q Was there anybody serving a term
10 between you and Chief Rhodes?
11 A There was.
12 Q Okay. Who was that?
13 A Chief -- interim Chief Kelvin Waites.
14 Q And how long -- do you know how long
15 he served as --
16 A I do not.
17 Q -- interim? And who -- do you have --
18 I assume there's some structure of reporting
19 within that Horry County Police Department?
20 A Yes.
21 Q Okay. Who -- who -- how many direct
22 reports do you have?
23 A So our chain of command is chief of
24 police. I have two deputy chiefs that report to
25 me, a host of captains, all the way down to

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1 basically, you know, officers and civilians. As
2 far as direct reports, that would be my deputy
3 chiefs.
4 Q And who are your two deputy chiefs?
5 A Lance Winburn, Major. And Major Ken
6 Davis.
7 Q And did you hire both of them?
8 A Just one. That's Major Ken Davis.
9 Q Was -- I'm sorry. Major Winburn?
10 A Yeah. Lance Winburn.
11 Q Was he -- was he here when you --
12 A Yes.
13 Q Correct? Okay. And was he serving as
14 a deputy chief at that point as well?
15 A He was.
16 Q Who was serving before Major Davis?
17 A That would be Major Maurice Jones.
18 Q With special events -- so sorry, just
19 that -- just getting back to the Fairfax Fair, was
20 the -- is that the only event in which you were
21 responsible for the planning of traffic
22 management?
23 A No, there's -- there's smaller events
24 that occurred during my command or my career as a
25 commander, so numerous, I really couldn't -- I --

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1 just a lot.
2 Q Okay.
3 A So we've had community fairs in the
4 West Greenfield districts that I commanded, the
5 Mount Vernon participation. Of course we had the
6 sniper event and there was some traffic management
7 that had to go on for that. I was a new commander
8 and was tasked with the responsibility of
9 controlling the traffic management plan for the
10 escape route -- potential escape route of the
11 snipers.
12 Q That was a stressful time, I bet.
13 A Yes, very much so.
14 Q In the traffic management plans that
15 you have planned and executed, have you ever put
16 in place a traffic loop similar to the one that is
17 in place during Memorial Day weekend?
18 A Yes.
19 Q And when have you done that?
20 A That was for the -- it's a festival at
21 a park. And I'm trying to think of the name of
22 it. And it was -- they had several music
23 festivals at -- at this park in Chantilly. And I
24 had to design a traffic management plan for safe
25 flow of traffic into the park and orderly egress

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1 from the park at the end of the event. So
2 basically, it's two-way traffic in the park. We
3 restricted it to one way so you can funnel traffic
4 in and can control it. The biggest thing for us,
5 at the end of the event, people want to get out of
6 there, so there was a excessive speed and folks
7 were walking back with their lawn chairs, so we
8 had to make sure they remained safe. So we had to
9 slow down that traffic. And the way we did that
10 is that we funneled them in a chute.
11 Q And the chute, how -- how many miles
12 did it go out?
13 A I would be guessing. I think the
14 total park loop -- again, I would be guessing --
15 at about three miles.
16 Q And the chute, was that for the people
17 that exit the event?
18 A Both into the event and exit the
19 event -- actually, I'm sorry. We sent two-way
20 traffic one way to get folks in because there were
21 multiple ways to get into the park. There were
22 actually three ways. And on the way out, we
23 restricted it down one lane.
24 Q Okay. So there was one way into the
25 park and one way to exit the park?

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1 A Yes.
2 Q To come to the event?
3 A True.
4 Q If you were exiting the park and let's
5 say you decided you wanted to come back --
6 A You could not.
7 Q -- you couldn't come back to the event
8 at all?
9 A No.
10 Q So it was a one-time entrance?
11 A Yes.
12 Q Okay. So you didn't have people who
13 were kind of repeat visitors to the area?
14 A No.
15 Q It was one time?
16 A Yeah, for that particular event.
17 Q And then --
18 A For that particular event, once you
19 were --
20 Q Yeah.
21 A -- in that event, at the end of the
22 event, when we were letting folks out, you could
23 not go back the same way you came in because we
24 restricted that. We had one lane open so officers
25 could go and check on the patrons leaving. Also,

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1 for rescue to respond into the park -- we had a
2 lot of folks -- and this is going back years;
3 we've done this every year -- that would, you
4 know, consume too much alcohol, the heat would get
5 to them, you had to have a way to get rescue into
6 those areas. So if you had to leave the park, you
7 could not come back the same way.
8 Q So not -- so not the way you -- it --
9 was there a different way to come back if you
10 wanted to come back?
11 A There was. You would have to go all
12 the way around the parkway. So across the bridge,
13 you would have to have a -- you would have to take
14 another route to get in, but basically, you would
15 be coming in at the back of the line of traffic
16 leaving out. I don't recall anyone having to do
17 that, but we had to make a way for people to get
18 back.
19 Q Okay. So it wasn't as though this was
20 a place where you would be stationed leaving and
21 coming. It was people would come to the event and
22 they would leave?
23 A Yes.
24 Q Okay. So that is -- would you say
25 that -- would you agree that that is distinct from

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1 what's happening on Ocean Boulevard during
2 Memorial Day weekend in terms of need to access
3 the area?
4 A Yeah. I don't know a lot about what
5 goes on in the City of Myrtle Beach, but I -- I
6 can only just tell you what I know about what we
7 did in Virginia.
8 Q Okay. Are you involved with the
9 planning of what happens within the City of Myrtle
10 Beach during Memorial Day weekend?
11 A What aspect?
12 Q Well, what aspects are you responsible
13 for, if any?
14 A We just hand--- Horry County Police
15 Department handles the activities that occur in
16 unincorporated areas of Horry County.
17 Q And what are -- in your experience --
18 so now you've been here for two bike weeks; is
19 that right?
20 A Yes, ma'am. This will be my third
21 coming up.
22 Q Okay. What are the activities that
23 o--- that occur in unincorporated Horry County?
24 A We have gatherings of our visitors,
25 our cyclist visitors, at a few locations in

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1 unincorporated Horry County. Of course the egress
2 into the city and just the general traffic flow of
3 visitors coming down. It's not just motorcycles.
4 There's a lot of vehicle traffic that's associated
5 with both events.
6 Q When you say egress into the city,
7 where are you referring to?
8 A 501. Parts of 22/31 that are in the
9 unincorporated areas of Horry County.
10 Q We'll come back to the bike weeks a
11 little bit more in detail in a little bit. So
12 the -- what is the overall jurisdiction of the
13 Horry County Police Department?
14 A We cover approximately 1100-plus
15 miles. And I say plus because it varies depending
16 on who you're talking to. Big county. I'm sorry.
17 Can you repeat the question again?
18 Q Jurisdiction of the --
19 A Okay.
20 Q -- Horry County Police Department.
21 A So -- I want to see if I can frame it
22 up for you. From the North Carolina line down to
23 the Georgetown County line is Horry County. As a
24 whole, our responsibility is just that -- that
25 total square -- square miles. We don't police in

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1 the city or any of the incorporated areas unless
2 there is an event or an emergency that they
3 require assistance.
4 Q And who would make that request to
5 you, if it was --
6 A It would be the chief executive
7 officer, the chief.
8 Q And so for Myrtle Beach now, that
9 would be Chief Prock?
10 A Yes.
11 Q And what is your responsibility for --
12 for fire rescue, if any?
13 A None.
14 Q And so is that handled by Horry County
15 Fire and Safety, Myrtle Beach Fire --
16 A That is correct.
17 Q So that's Chief Pate and Chief Crosby?
18 A Yes. Well, no. That would be --
19 sorry. Chief Tanner for Horry County.
20 Q Okay.
21 A And then I'm not sure who the chief is
22 down in -- I think it is Crosby down in Myrtle
23 Beach.
24 Q It -- I think -- I think it might be
25 Alvin Pate, but --

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1 A Pate. Okay. I'm sorry. Yeah.
2 Q I could be wrong about that as well.
3 A Yeah. Sure.
4 Q Okay. And then does Chief Tanner
5 handle fire and E.M.S.?
6 A He does.
7 Q Okay. Does Horry County Police
8 Department have any responsibility for E.M.S.?
9 A No.
10 Q And then what is your -- well, do --
11 do you have any overlap with the emergency
12 management department here in Horry County?
13 A No overlap in duties other than we --
14 let's see how I can phrase this. It's a
15 monitoring.
16 Q I'm sorry. It's a what?
17 A Monitoring.
18 Q Okay.
19 A Agency for special events, whether
20 it's weather related, if they are up and running,
21 special events.
22 Q And so you may work together and -- in
23 policing those special events?
24 A Sure. We -- we share information.
25 Basically, it's an information dissemination unit

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1 for us.
2 Q Do you regularly staff any Horry
3 County Police Department officials or employees in
4 the E.O.C.?
5 A We did at one time when I first got
6 here. We had not done that in the last two and we
7 don't plan to do it for this -- I'm sorry, the
8 last -- yeah, last one. We don't plan to do it
9 for this one.
10 Q Okay. So are you -- are you referring
11 specifically to E.O.C. for bike week?
12 A Yes.
13 Q Okay. E.O.C. is sometimes operational
14 during other times of the year as well. Right?
15 A It is. During weather events, and we
16 do staff an E.O.C. function, emergency support
17 function.
18 Q So just so I'm understanding, the
19 previous two years, have you staffed the
20 E.O.C. during Memorial Day weekend bike fest?
21 A No, not last year. We did not. The
22 year prior, '17, we did.
23 Q And why would you not staff last year?
24 A You would have to ask Director
25 Webster. I don't know the exact reason for that.

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1 Q Oh, so that wasn't your decision?
2 A No.
3 Q Would you have wanted somebody there,
4 or did you not feel it necessary?
5 A I didn't feel the need after being
6 here, observing the activities, that we needed to
7 have somebody there.
8 Q Who do you report to as chief?
9 A My direct boss is Mr. Joe Huffman.
10 He's the assistant county administrator for public
11 safety.
12 Q And do you have any report or
13 responsibilities to the Horry County Council?
14 A Other than reporting out on a regular
15 basis at the public safety committee meetings,
16 that's it.
17 Q How often do those public safety
18 committee meetings happen?
19 A Once a month.
20 Q And you've attend those, have you not?
21 A Yes, ma'am. Or someone, one of my
22 designees.
23 Q What other agencies attend the public
24 safety committee meeting?
25 A Police, fire, sheriff, E M.D.,

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1 emergency management, 911.
2 Q What is the jurisdiction of the
3 sheriff's department?
4 A Sheriff's department handles court
5 security, confinement, civil process.
6 Q And then for the Horry County roads --
7 well, how many Horry County roads are there that
8 aren't state roads?
9 A I have no idea.
10 Q Okay. And are you -- is it your
11 responsibility as Horry County Police Department
12 to police those roads?
13 A That's a complicated question -- or a
14 response. So South Carolina Highway Patrol has
15 jurisdiction as well as Horry County Police in
16 unincorporated Horry County. They are the primary
17 traffic accident responders for Horry County. And
18 that goes back to an agreement long before I got
19 here. Of course if officers witness traffic
20 violations on unincorporated roads, we will take
21 action.
22 Q But you are not the primary line of
23 defense on the roads?
24 A We are in that the South Carolina
25 Highway Patrol works wrecks. As far as criminal

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1 interdictions, we're primary, as in most
2 jurisdictions across the country. Highway
3 Patrol's primary focus is traffic safety and
4 accident reconstruction.
5 Q Outside of the public safety
6 committee, are there other regular meetings that
7 you attend outside of the Horry County Police
8 Department?
9 A Yes. County council happens twice a
10 month.
11 Q Any other?
12 A Not regularly outside of Horry County,
13 no.
14 Q Is there any multi-jurisdictional
15 committees or --
16 A There is --
17 Q -- working groups that --
18 A There is --
19 Q -- you're a part of?
20 A -- a task force meeting that's held
21 for the bike weeks. And there is a chief's
22 meeting that's held monthly, and that includes all
23 the chiefs from all of the unincorporated and
24 incorporated areas to include the sheriffs from
25 Georgetown County and Horry County along with our

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1 federal partners.
2 Q And would it also include the City of
3 Myrtle Beach --
4 A Yes.
5 Q -- North Myrtle Beach --
6 A Yeah, all law enforcement, yeah,
7 that's in the county, unincorporated and
8 incorporated Horry County. And Georgetown County.
9 Q And who -- who hosts those meetings?
10 A It's -- it rotates. And the chair of
11 that meeting is Sheriff Philip Thompson.
12 Q Is he Horry County sheriff?
13 A Sheriff.
14 Q And how often do you have those -- I'm
15 sorry, are those monthly?
16 A Once a month.
17 Q Okay. Who sets the agenda for those
18 meetings?
19 A That would be the sheriff and a -- oh,
20 gosh. There's a volunteer from the solicitor's
21 office that actually is the secretary. I can't
22 think of her name right now.
23 Q Do you ever set agenda items?
24 A I do.
25 Q Have you ever set agenda items for

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1 anything related to the bike weeks?
2 A I have not.
3 Q Is any planning for the -- and I'm
4 sorry. When I -- when I say bike weeks, just so
5 we're clear on the record, I'm referring to the
6 bike weeks that happen in the month of May, so
7 it's Harley Davidson rally and Memorial Day
8 weekend rally?
9 A Sure.
10 Q Do you -- are you familiar that --
11 that Memorial Day weekend bike rally is something
12 that's called black bike week?
13 A I am.
14 Q Is that a term you had heard before
15 coming to Horry County?
16 A I have.
17 Q And so if we're referring to -- I'm
18 sorry. And it's also referred to as the Atlantic
19 Beach Motorcycle Festival?
20 A Yes.
21 Q So we're talking about the same -- a
22 bike rally that happens over Memorial Day weekend
23 here in the Grand Strand area?
24 A Yes, ma'am.
25 Q I just wanted to make sure we're

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1 talking about the same thing --
2 A Sure.
3 Q -- as we're -- as -- as we're going
4 forward. Does any planning for the bike weeks
5 happen during those chiefs meetings?
6 A No.
7 Q And you said that there's a task force
8 meeting that's held for the bike weeks. Are you
9 referring to the bike fest task force?
10 A Yes.
11 Q And do you attend those meetings?
12 A I do. Or someone who I designate to
13 attend in my absence.
14 Q And how many of those meetings take
15 place over the course of a year?
16 A Two.
17 Q And as I understand it, there -- or
18 there's the full task force meetings and then
19 there -- there's the law enforcement subcommittee?
20 A Yes.
21 Q Do you attend both of those?
22 A I do not.
23 Q Okay. So which one do you attend?
24 A Depending on my schedule, I'll try to
25 drop in as -- as much as I possibly can. But when

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1 it comes to the actual planning for this schedule,
2 one of my schedulers, that's Captain Stan
3 Strickland, will attend in my absence and will
4 brief me and the two deputy chiefs if there's any
5 changes, significant issues we have to be
6 concerned about.
7 Q And so is it usually Captain
8 Strickland who is -- who is attending the law
9 enforcement subcommittee meetings?
10 A Yes.
11 Q Do you know how many of those occur?
12 A I do not.
13 Q And is that -- have you -- have you
14 attended any of the law enforcement subcommittee
15 meetings in your time as chief?
16 A I have.
17 Q About how many would you say you've
18 attended?
19 A About two.
20 Q Do you remember what years those were?
21 A When I first got here, that was '17.
22 And then another meeting -- there may have been
23 two in '17. Could have been one in '18. I don't
24 recall.
25 Q And who runs those law enforcement

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1 subcommittee meetings?
2 A That would be -- well, that's a good
3 question. I don't recall. I know the task force
4 is run by Director Webster. I'm not sure who runs
5 the law enforcement -- I'm not sure. I don't want
6 to guess. I'm not sure.
7 Q But it is not somebody from the Horry
8 County Police Department who runs it?
9 A No.
10 Q Do you know who takes principal
11 responsibility for organizing the agenda for that
12 subcommittee?
13 A Again, I'm -- I would take a guess. I
14 believe, if I remember correctly, it's going to be
15 the City of Myrtle Beach and Joy Crosby was one of
16 the ones that coordinated the meeting when I first
17 arrived in Horry County.
18 Q And was that true for all of the law
19 enforcement subcommittee meetings that you
20 attended?
21 A I -- I don't recall.
22 Q But it was not anybody from the Horry
23 County Police Department that ever --
24 A No.
25 Q -- served that role?

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1 A No.
2 Court Reporter: I'm sorry, what did
3 you say again?
4 Ms. Ramchandani: It was never anybody
5 from the Horry County Police Department that ever
6 served that role.
7 By Ms. Ramchandani:
8 Q Do you know of any events that
9 circulated from those meetings?
10 A I don't recall seeing any minutes from
11 the subcommittee. No, ma'am.
12 Q Do you ever attend coastal alliance
13 meetings?
14 A I do not.
15 Q I want to just talk a little bit about
16 any data collection and supporting data that the
17 Horry County Police Department does. So are there
18 any regular reports that you have run for the --
19 for the department?
20 A Run -- yes, ma'am.
21 Q And what regular reports are those?
22 A Crime stats, officer performance
23 reports. Gosh, there's so many. Financial
24 reports, audits, internal affairs. I mean,
25 there's a long list. What -- what are you looking

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1 for in particular, ma'am?
2 Q Well, it's -- I'm -- I'm most curious
3 about any sort of data analysis that you do.
4 So --
5 A It -- I mean --
6 Q -- is there any report that you do
7 of -- and you mentioned crime stats. What -- what
8 crime stats are you --
9 A Okay.
10 Q -- collecting?
11 A So we have in place a comp stat,
12 computerized stat. It's a report out for the
13 performance of a particular precinct. And it
14 was -- any crime that I want to see or one of the
15 deputy chiefs wants to see, particularly, it's
16 your part one violent crimes, your robberies, your
17 C.S.C.'s, your stolen vehicles, nuisance crimes
18 like your auto theft break-ins, assault and drug
19 cases.
20 Q And are those crimes all taking place
21 in Horry County?
22 A Unincorporated areas of Horry County
23 are what we're responsible for.
24 Q Okay.
25 A It's a performance management report

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1 out.
2 Q And so when you say performance
3 management, what -- what do you mean?
4 A So I hold my captains who are in
5 charge of precincts accountable for crimes that
6 occur in their precincts. And more importantly,
7 what actions are they taking to reduce the crime
8 and fear of crime.
9 Q How do you figure out what they are
10 doing to reduce crime and fear of crime?
11 A So for the crime reporting, you run
12 the stats for the areas they are responsible in
13 and we look for ebbs and flows, if there's
14 increases in particular crime areas or decreases.
15 If there are increases, what are your plans to
16 decrease those crimes? If there's a series of
17 burglaries, are you engaged in investigations?
18 Are there suspect information? Are there
19 additional patrols? That's how we manage to keep
20 our community safe.
21 Q And so are you ever looking at crimes
22 taking place within the City of Myrtle Beach?
23 A No, ma'am.
24 Q And how often are you getting these
25 reports?

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1 A I get them daily.
2 Q And do you do any sort of overall
3 compilation or analysis in a sort of -- over a
4 time period?
5 A We do. It's -- it's our crime stat
6 meetings. We hold a leadership meeting every
7 Tuesday from 9:00 to whatever. And that's where
8 we go over urgent issues in the county,
9 directives, planning, goals and objectives. And
10 that's when each commander will report out on
11 incidents that are happening in their precincts.
12 Q Have you noticed any seasonal swings
13 to number of crimes happening?
14 A Yes.
15 Q And what -- what -- what do you see?
16 A Typically, we see the winter time's a
17 bit of a slow down across the board of all part
18 one crimes. We see an increase because of the
19 number of visitors we have coming to Horry County
20 or coming through Horry County to get to Myrtle
21 Beach. You typically see an increase in assaults,
22 drug arrests, vehicle break-ins and traffic
23 citations that are issued.
24 Q Are traffic citations included in that
25 part one crimes?

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1 A No.
2 Q Do you do a separate analysis of
3 traffic citations?
4 A I only do that for our traffic
5 enforcement unit, which is our motorcycle unit.
6 Again, that's a performance management review.
7 Not so much how many tickets they are writing, but
8 their number of contacts they are making. I don't
9 mandate actual tickets. I mandate contacts for
10 education purposes, for visibility purposes.
11 Q So would -- so are contacts counted by
12 the number of stops?
13 A Yes.
14 Q Okay. And how often do you get those
15 reports?
16 A I get them daily.
17 Q And how often do you do a compilation,
18 looking at --
19 A Quarterly.
20 Q -- number of --
21 A Or as needed. And when I say as
22 needed, in particular, if we have a citizen
23 complaint about a particular speeding in
24 communities, we look at those stats.
25 Q And again, is that -- is that traffic

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1 enforcement happening outside the City of Myrtle
2 Beach?
3 A Yes, this is all unincorporated Horry
4 County.
5 Q And so -- I'm sorry, we were talking
6 about seasonal swing. So you see an increase in
7 both traffic enforcement and the part one crimes
8 in the warmer weather?
9 A Typically, yes, ma'am.
10 Q Have you done any graphing or charting
11 of that increase?
12 A Not as it relates to special events.
13 We did do a graph for C.S.C., sexual assaults. It
14 was more curiosity of my part to determine if
15 there was an increase during our special events
16 during the summer. We have multiple special
17 events. A lot of it occurs in the City of Myrtle
18 Beach, but folks stay in Horry County and then
19 they drive into Myrtle Beach. And we did not -- I
20 did not find a significant increase or an increase
21 or a pattern.
22 Q When did you -- when did you run that?
23 A That was a year and a half ago.
24 Q And have you -- have you run it again
25 since?

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1 A I have not.
2 Q And that is because you didn't see any
3 particular weekend to focus in on?
4 A Yes, ma'am.
5 Q Okay. Besides the -- the central
6 policy of C.C.S. --
7 A C.S.C.'s.
8 Q C.S.C.'s.
9 A Criminal sexual.
10 Q Okay. So besides that analysis, are
11 there -- is there any other analysis that you have
12 done for particular special events?
13 A No, ma'am.
14 Q So have you ever looked at traffic
15 enforcement for the -- for Memorial Day weekend
16 specifically?
17 A Yes.
18 Q And when have you done that?
19 A Every year. There is a report -- and
20 maybe I should go back and say yes, I guess, it is
21 analysis. But it's a report out. We don't look
22 at it -- I don't look at it any -- anything beyond
23 just the numbers. So there's a report for traffic
24 violations for both the Harley week and the
25 Atlantic Beach bike festival.

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1 Q And is that report run at your
2 request?
3 A It is. And it's automatic.
4 Q Okay.
5 A So we do it every year.
6 Q And that is the case when you joined
7 the police department as well?
8 A I don't know if it happened before I
9 joined. I -- I -- I don't know. But I wanted to
10 see it when I got here.
11 Q And why -- why was that?
12 A I wanted to make sure that our
13 officers were not targeting African-Americans who
14 predominantly frequent the second bike event. I
15 just -- I wanted to see those numbers for myself.
16 Q And how would you from those numbers
17 determine if targeting was happening?
18 A We write less tickets for the Atlantic
19 Beach bike festival in that period of time than we
20 do for the Harley.
21 Q So -- and so there are more traffic
22 violations --
23 A For the Harley week.
24 Q -- than there are for the other?
25 A Yes. And -- and I don't -- I didn't

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1 perform any analysis to determine why. And I --
2 I -- I just didn't. I don't -- I don't know why
3 that occurs.
4 Q Do you do a similar reporting for
5 other special events during the summer?
6 A No, we don't have any other special
7 events in Horry County that deal with as much
8 traffic as we do for the festivals.
9 Q Okay. Have you ever looked at, for
10 example, over the Fourth of July weekend or
11 anything like that?
12 A No, because most -- no.
13 Q I'm sorry. You were going to say
14 because most --
15 A Most of the big events happen in the
16 city or in North Myrtle Beach. The only big event
17 that we've had here are the Little River
18 festivals. But that's predominantly a pedestrian
19 event. What I mean by that is folks walk around
20 in an enclosed area. Not so much driving. We did
21 have the air show that occurred last year and that
22 was unique for us here, at least for me. The last
23 time we had an air show was when the Myrtle Beach
24 Air Force base was in operation. That was an
25 anomaly for us.

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1 Q Is it happening again this year?
2 A No.
3 Q And did you look at, I assume, the
4 traffic management reports for that event?
5 A I did not because, again, we had a
6 traffic management plan set up where we shuttled
7 folks from a designated parking area into the air
8 base or the airport, sorry.
9 Q Have you done any similar reporting
10 out for the bike weeks for part one crimes?
11 A No. No, we haven't. And -- and
12 typically, I will look at events and monitor it.
13 And if I see a spike or anything or have some
14 concern, I'll ask for the reports just to validate
15 my observations. And I have not seen since the
16 last -- I've been here for going on almost three
17 bike events and I haven't seen a spike in any
18 particular crime that would concern me that would
19 be directly associated with the visitors that come
20 here for the bike events.
21 Q Have you ever looked back to see what
22 was happening sort of historically with the bike
23 events --
24 A No.
25 Q -- in Horry County? Is there any

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1 other reporting that you have looked at for the
2 bike weeks?
3 A Staffing. We have to -- a staff for
4 the different events that are occurring. And I
5 look at it every year to ensure we have adequate
6 staffing. One, that we don't overstaff, and
7 certainly, we don't want to understaff in
8 anticipation of anything that may go wrong.
9 Q And that is for both -- both rallies?
10 A It is.
11 Q Do you increase staffing for both
12 rallies from what you would in a typical time
13 period?
14 A Yes.
15 Q Do you increase staffing -- is it a
16 similar staff increase for both events?
17 A It is a -- yes. The numbers are
18 different. The Harley week predominantly operates
19 in Georgetown County, Murrells Inlet area. We
20 very rarely get large gatherings of the Harley
21 riders in unincorporated areas of Horry County.
22 There are pockets when certain restaurants or bars
23 are having events that are in unincorporated areas
24 of Horry County. But predominantly, it's all
25 happening in Georgetown County.

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1 Q And then what about for Memorial Day
2 weekend bike fest?
3 A For Memorial, we have everything
4 that's of course centered at Atlantic Beach, that
5 beach being a very small agency, less than five
6 officers. They have multiple support from
7 different agencies around the state, to include
8 Horry County.
9 Q And then what about unincorporated
10 Horry County?
11 A There is few gathering spots for the
12 second week, the Atlantic Beach bike festival
13 week. One in particular is Myrtle Beach Mall.
14 There's a large gathering there. We provide
15 staffing to ensure safety of our visitors or
16 guests and of our residents. And if we have any
17 other pop-up locations, we will provide presence
18 there.
19 Q But if I understand it, you have not
20 seen particular spikes in crime related to the
21 bike weeks --
22 A No, we haven't.
23 Q -- that are being attended?
24 A No.
25 Q And that's true for the Atlantic Beach

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1 bike festival in addition to the Harley Davidson
2 rally?
3 A Yes.
4 Q Any other reports that you've looked
5 at for those -- for the bike weeks?
6 A No, ma'am.
7 Q Any other data that you have looked at
8 for the bike weeks?
9 A No, ma'am.
10 Q You mentioned that you have multiple
11 events over the summer.
12 A Uh-huh.
13 Q What are those events?
14 A We have the Little River Crab
15 Festival, Blue Crab Festival. We have two events
16 in Little River, and they are all focused around
17 just community events, pedestrian events,
18 primarily. We had the anomaly last year, which
19 was the air show. There is the Socastee --
20 Socastee Heritage Festival. We have now, since
21 last year, a few 5K's that are very well attended.
22 Q I saw an ad for one of those when I
23 came in.
24 A Yes. Yes. And beyond that, just your
25 typical homeowners or community events that we

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1 normal -- normally don't staff. We are aware of.
2 And we don't require additional staffing to ensure
3 the safety of those folks there.
4 Q The Socastee Heritage Festival, does
5 that involve a lot of vehicular traffic?
6 A Foot traffic.
7 Q Foot traffic?
8 A For the most part. Redirection of the
9 vehicular traffic, we shut down the swing bridge.
10 It's a bridge that operates somewhat to allow
11 large boats to go up and down the intercoastal
12 waterway and -- and let me just go back for a
13 second. So we also have -- what's another
14 festival? I just lost it that quick. Sorry. I
15 think we -- there's another large event that we
16 have.
17 Q What type of event is it, if you
18 can --
19 A I can't -- I think -- I just had it.
20 I don't know. It will come to me.
21 Q Okay. Well, if it will come back to
22 you, let me know.
23 A Okay. Yes.
24 Q And have you looked at traffic
25 violations for any of those events?

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1 A No. We also -- sorry, here it is.
2 It's the Mustang week, which is custom Mustangs.
3 They come down here. They show off their cars.
4 They are primarily in a fixed location in the City
5 of Myrtle Beach. But occasionally -- well, every
6 year except for this year, we used the speedway
7 that's in unincorporated Horry County. And so in
8 years past, that had become kind of a traffic
9 nightmare. So we had officers that were stationed
10 along 90, I believe it is, nine--- 90 that would
11 allow for a smooth traffic pattern into the
12 speedway and out. And typically, what you saw is
13 that folks will go to the speedway, enjoy the
14 festivities and then they would use our roads as a
15 speedway. This year, that didn't happen because
16 of the flooding from Florence. That speedway has
17 been closed down permanently.
18 Q What types of traffic management would
19 you do to address that --
20 A It was --
21 Q -- occurrence?
22 A -- a lack of coordination from the
23 managers of the speedway, so Mustangs were
24 stacking up out on the main roadway. We had to
25 send officers down there to get an easy flow of

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1 traffic into the speedway. Much like the festival
2 I was talking to you about in Virginia, we had to
3 create another way into the park that was --
4 wouldn't block the main roadways. So you had to
5 open up a back gate that wasn't traditionally open
6 to flow that traffic in. And we used the main
7 entrance to flow them out.
8 Q That -- that was to facilitate access
9 to and egress from the --
10 A Yes.
11 Q Did you look at any data reporting on
12 crimes or traffic violation --
13 A No.
14 Q -- for that event? Okay. For any of
15 the other events that we discussed?
16 A No.
17 Q Besides the -- well, let me ask, what
18 are the busiest events in Horry County?
19 A Unincorporated Horry County?
20 Q Yes.
21 A Would be the festivals at Little
22 River. The Socastee Heritage Festival is big for
23 us. We -- that would -- that would be the -- the
24 largest events.
25 Q Are the -- would you say that those

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1 events are larger than the Atlantic Beach bike
2 festival or the Harley-Davidson rally in terms of
3 unincorporated Horry County?
4 A No. The bike events are larger as far
5 as personnel and staff requirements.
6 Q So you would also include the bike
7 events in the busiest events for Horry County?
8 A Yes.
9 Q Okay. What about other sort of busy
10 time periods or particular weekends or any other
11 busy weekends?
12 A Coming up, Easter. It's the start of
13 our season. July 4th is busy for us.
14 Q Any other events?
15 A That -- I would just say generally
16 typical holidays where folks can get down, day
17 trippers out of North Carolina or Virginia to
18 visit our beaches in our areas. And -- and busy
19 as in just traffic flow and people. Not so much
20 crime.
21 Q Which leads to my next question, which
22 is, have you observed any correlation between busy
23 time periods and increased crime or violence in
24 Horry County?
25 A Simply because of the number of people

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1 you have here, spring break, although it's not
2 super busy for Horry County unincorporated, you
3 have young people that frequent the beach and
4 sometimes they choose to stay in unincorporated
5 Horry County just because either the cost or
6 availability of rooms and you will get calls for
7 disorderly conduct, loud noise, just typical
8 partying. As far as any typical spikes in crime,
9 no, nothing, especially none of the part one more
10 serious crimes.
11 Q Do you receive -- or have you -- have
12 you observed an increase in the calls regarding
13 disorderly conduct during either of the bike
14 weeks?
15 A We get an increase of calls for noise
16 violations. And I couldn't give you any
17 specifics, but generally -- and I -- I don't know
18 if we get an increase, but we get calls for
19 reckless operation of motor vehicles from the
20 citizens who are traveling on the highways.
21 That's unfortunately typical behavior from bikers.
22 Q Have you noticed -- well, sorry. Is
23 that true for both rallies?
24 A Yes.
25 Q Have you noticed a difference in the

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1 sort of level of uptick between the
2 Harley-Davidson and the Atlantic Beach bike
3 festival?
4 A I have not.
5 Q What would you say the biggest issues
6 are that -- that face Horry County in terms of
7 your role as the Horry County police chief?
8 A General issues?
9 Q Yeah.
10 A Right now the biggest thing is opioid
11 addiction and the crimes associated with it.
12 Q In addition to opioids, are there
13 other sort of narcotic issues that the county
14 faces?
15 A There is.
16 Q And what are --
17 A Methamphetamines, cocaine, marijuana
18 to a certain extent. And the reason I say that,
19 it's just the sale or distribution of marijuana
20 and then the crimes associated with that industry.
21 Q Uh-huh. And do you have any drug
22 trafficking issues in the area?
23 A We do.
24 Q What about gang violence?
25 A We do.

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1 Q The issues we just addressed, so, you
2 know, the narcotics, gang violence, trafficking,
3 are those year-round issues?
4 A Yes.
5 Q Have you observed any increase in
6 those issues during the bike weeks?
7 A No, not particular those issues.
8 Q And that's true for both the Atlantic
9 Beach bike festival and Harley-Davidson. Right?
10 A Yeah. As far as crimes being
11 committed, yes.
12 Q Do you have any motorcycle gangs
13 during the bike weeks?
14 A We do.
15 Q Can you -- what -- what are they --
16 what are the gangs that you believe to be --
17 A The names of the gangs? Typically,
18 you have the Pagans, the Hell's Angels, the Wheels
19 of Soul, which is a predominantly African-American
20 group. Rough Riders. They are predominantly
21 sport bike riders. And gosh, there's probably
22 about 30 gangs. And -- and -- and let me rephrase
23 that. I -- I don't call them gangs. They are
24 groups of folks that come together to share a
25 common pleasure, and that's riding motorcycles,

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1 whether they are involved in criminal activity or
2 not. There are some that, yeah, we know they are.
3 But the most are not, to our knowledge.
4 Q And do those groups come for -- for
5 both bike weeks?
6 A You will see a crossover, but not all
7 the time. It's kind of hard to describe unless
8 you are part of that culture.
9 Q And do you -- well, are there groups
10 that attend each event?
11 A Yes.
12 Q Okay. Are there more groups attending
13 one of them versus the other?
14 A Rephrase that question, please.
15 Q Sure. So are there -- are there
16 more -- more motorcycle groups that attend the
17 Atlantic Beach bike festival in comparison to the
18 Harley-Davidson bike festival?
19 A I don't -- I don't know that to be
20 true.
21 Q So that's nothing that you have
22 observed?
23 A Yeah. I don't -- I don't know. I
24 can't -- I couldn't tell you that's a fact or not.
25 Q Do you do any monitoring of motorcycle

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1 group activity?
2 A We do.
3 Q And how do you do that monitoring?
4 A Numerous ways. Through the South
5 Carolina Fusion Center, which is a clearinghouse
6 for intelligence, and it's run by the South
7 Carolina Highway Patrol Department of Public
8 Safety. We also have our localized intelligence
9 gang units. We monitor social media sites to
10 alert us if groups are coming down. We monitor
11 those groups' open source sites, if they have
12 them, which is typically their Facebook social
13 media sites.
14 Q Yeah.
15 A And the reason we monitor is to look
16 for pop-ups or parties that may be occurring at
17 certain establishments that occur in
18 unincorporated areas of Horry County that we
19 are -- we are concerned about.
20 Q And is that something you do for both
21 Harley Davidson and Atlantic Beach bike festival?
22 A We do.
23 Q Okay. All right. That's my 21.
24 (Plaintiff's Exhibit 1
25 marked for identification.)

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1 Q Mr. Hill, I'm showing you what's been
2 marked as exhibit 1, if you will take a look and
3 let me know when you're done.
4 A Okay.
5 Q Is this the type of reporting that you
6 would get?
7 A Yes.
8 Q Okay. Who is Linda Turner?
9 A She was the crime analyst for Myrtle
10 Beach. She's no longer.
11 Q So is this report -- so this report,
12 was it done by Horry County Police Department?
13 A No. City of Myrtle Beach.
14 Q And then it just gets sent to you?
15 A Yes. All agencies.
16 Q Share among themselves?
17 A Yes.
18 Q Okay. What does O-M-G stand for?
19 A Outlaw motorcycle gang.
20 Q Okay. Is that a particular group?
21 A No, it's a -- it's a -- it's a
22 culture. And so a lot of motorcycle gangs --
23 and -- and let me just kind of back up for a
24 second. So motorcycle riders particularly form up
25 as a group to enjoy the past time of riding a

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1 motorcycle. Some choose to have a name to their
2 groups. Some choose to bear what they call colors
3 or a -- a rag on their back. And some groups take
4 that to a level that evolve themselves into
5 continuing criminal enterprises. Because a group,
6 I think the Daisy Boys, it could just be a
7 charitable group that likes to ride motorcycles
8 that has nothing do with crime. And then you've
9 got the Pagans, the Hell's Angels, the Reapers
10 that are known to be involved in criminal
11 activity. So it runs the spectrum, if you will.
12 Q And would you say that any of those
13 groups that are known to be involved in criminal
14 activity, do they come during both rallies?
15 A They do.
16 Q So it's not something that's isolated
17 to one of the rallies?
18 A No.
19 Q And I think you've kind of -- let's
20 see this one. Fifth page, it ends defendant 544.
21 A Okay.
22 Q And in that first section, there's
23 a -- some text in bold about halfway down the page
24 that says patrol officers should be aware that
25 outlaw motorcycle violence is not limited to

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1 motorcycle events.
2 A Yes.
3 Q Would you agree with that statement?
4 A Yeah, I would.
5 Q How closely do you work with the City
6 of Myrtle Beach Police Department?
7 A Closely is a relative term. So we
8 assist Myrtle Beach when they call for assistance.
9 We don't perform any routine police functions in
10 the incorporated areas of Myrtle Beach, in
11 particular Myrtle -- Myrtle Beach.
12 Q Do they -- do you assist them during
13 either of the bike weeks?
14 A We do.
15 Q Which ones?
16 A Both.
17 Q And what kind of assistance do you
18 provide?
19 A We provide up-staffing to cover our
20 areas. And let me just make sure I'm clear. We
21 don't provide any direct assistance to the City of
22 Myrtle Beach outside of the fact that we put
23 members of our criminal intelligence unit with
24 their units.
25 Q Okay.

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1 A We don't provide any boots on the
2 ground, if you will, in the City of Myrtle Beach.
3 Q Okay. Are there any other times of
4 the year that you provide a similar service?
5 A We do. They put on a country music
6 festival. We provide counterterrorism,
7 countersniper assistance to them. And we also
8 provide bomb dogs to those special events. And
9 lately, political events that are occurring in the
10 city, we provide resources to the city of Myrtle
11 Beach.
12 Q What types of resources?
13 A Bomb sweep dogs in particular.
14 Q What particular support do you provide
15 during the Memorial Day weekend bike fest?
16 A For the City of Myrtle Beach?
17 Q Yeah.
18 A We provide a member or two, depending
19 on staffing, to their intel unit.
20 Q And what is that intel unit
21 responsible for?
22 A Observation, report out. For
23 instance, we'll take this produced report, follow
24 up on any particular events that are being ongoing
25 in the city and report out activities, how many

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1 colors we see, how many folks we see, are we
2 observing any criminal activity, report that back
3 to the intel center and they can dispatch
4 officers.
5 Q Is that intel center separate from the
6 fusion center?
7 A It is. Fusion center is the state,
8 and then we have an intel center that's run out of
9 the City of Myrtle Beach.
10 Q What about for the Harley-Davidson
11 rally?
12 A I believe it's the same. Yes. It is.
13 Yeah.
14 Q And do you know anything about what
15 kind of support you were providing prior to your
16 tenure at Horry County Police Department?
17 A I do not.
18 Q And then you also mentioned the
19 country music festival. So you mentioned bomb
20 sweep dogs. Do you do anything similar with intel
21 center?
22 A I don't get those reports, so I can't
23 tell you if Myrtle Beach is -- is doing that. I
24 don't want to assume.
25 Q Okay.

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1 A But no, I don't get those reports.
2 Q Are there any other times of the year
3 that you send intel staffing to Myrtle -- to the
4 City of Myrtle Beach?
5 A Not unless there's a special event
6 that crops up, which would be a political rally,
7 excuse me, or something that comes up. But -- but
8 not on a routine, not like -- like the bike
9 events.
10 Q I think we alluded to this a little
11 bit earlier in -- in the morning, but how would
12 you describe the differences between the
13 Harley-Davidson rally and the Atlantic Beach bike
14 festival?
15 A The Harley Davidson events primarily
16 occur in the County of Georgetown or in Murrells
17 Inlet, which is -- we -- we butt up against.
18 It's -- it's concentrated there kind of more
19 spread out as folks get bored with the venues down
20 there. They may go to the beach. I don't have
21 any knowledge of that because we don't work in the
22 City of Myrtle Beach. And for the Atlantic Beach
23 festival, I see an increase of vehicular traffic,
24 not necessarily motorcycles, that I can only
25 assume is associated with the events that are

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1 going on. And I see a -- a heavy concentration of
2 both pedestrian, vehicular and -- and I'm going to
3 separate the two -- motorcycle traffic in the
4 confines of Atlantic Beach and surrounding areas
5 in North Myrtle Beach.
6 Q Do you similarly not -- do you not
7 have certain knowledge of what's happening in the
8 City of Myrtle Beach during that time period?
9 A Unless there is something that occurs,
10 I don't have general knowledge. I'm not getting a
11 hourly or daily report unless there is something
12 that the City of Myrtle Beach leadership wants the
13 other jurisdiction to know. It's not just Horry
14 County. It's everybody associated with the
15 events.
16 (Plaintiff's Exhibit 2
17 marked for identification.)
18 By Ms. Ramchandani:
19 Q Just if you will just let me know
20 after you've had a chance to review.
21 Mr. Caroti: I just want to ask that
22 you supplement, if I could.
23 Ms. Ramchandani: Of course.
24 Mr. Caroti: If you need to discuss
25 this -- any aspect of it with me, we have that

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1 right to do so.
2 The Deponent: Okay.
3 Mr. Caroti: But if you feel
4 comfortable with it --
5 The Deponent: Yes.
6 Mr. Caroti: -- just move on.
7 The Deponent: Okay.
8 Mr. Caroti: Is that all right?
9 Ms. Ramchandani: Yeah. But then I
10 have provided all of this to you a week before.
11 This would have been my --
12 Mr. Caroti: You did?
13 Ms. Ramchandani: Yeah.
14 Mr. Caroti: Oh, I must have missed
15 it.
16 Ms. Ramchandani: Yeah. There was a
17 Dropbox on Monday night, last Monday.
18 Mr. Caroti: If -- then -- then forget
19 what I just said.
20 The Deponent: Okay.
21 Mr. Caroti: I -- I just don't recall
22 that. And I'm sorry.
23 Ms. Ramchandani: No, that's okay.
24 By Ms. Ramchandani:
25 Q I just wanted to know, what -- what is

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1 the inner watch list?
2 A It is a report that each precinct
3 sends at the end of their shift to leadership in
4 the Horry County Police Department. And actually,
5 not just leadership, but everybody gets a watch
6 report. That's a way of us sharing information,
7 getting some limited details on events that take
8 place and -- yeah, that's it.
9 Q Okay. So this was just for this
10 precinct for this night?
11 A Yeah. This particular one --
12 Q Yeah.
13 A -- was, yes, just for the north
14 precinct.
15 Q Okay. And this is not something that
16 happens just for the bike rallies or --
17 A No.
18 Q It happens every day?
19 A It happens --
20 Q And do you know the average of that --
21 A -- four times a day.
22 Q Okay. That's what I was wanting to
23 understand. And so this report that we see at the
24 end, this special activity report, this is not
25 giving us any sort of total compilation. It

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1 just -- it's just for the north precinct for this
2 night. Is that right?
3 A Negative. This one here is the total
4 tickets written -- written for the 2017 Harley
5 rally.
6 Q For the night of --
7 A No.
8 Q -- May 15th?
9 A That is -- that is from the dates of
10 5/18 -- wait a minute. Let me see here. Yes.
11 That was just for the 18th.
12 Q Okay. And it would -- it would have
13 been just from the 18th, 6:00 p.m. to --
14 A Yeah.
15 Q -- 2:00 a.m.?
16 A That's true. Uh-huh.
17 Q Do you get this type of special
18 activity report regularly?
19 A Four times a night, a day. Actually,
20 eight times. So each precinct reports out. I
21 have two shifts, day and night. And so I get
22 eight total reports.
23 Q Every day?
24 A Yes.
25 Q Okay. Do you -- and well, this is

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1 what you were talking about when you were saying
2 you were -- you're monitoring to see --
3 A Yes.
4 Q -- what kinds of --
5 A Uh-huh.
6 Q -- upticks, et cetera?
7 A Yes, ma'am.
8 Q Okay. Prior to your tenure in the
9 Horry County Police Department, have you ever
10 attended either black bike week or Harley week's
11 rally?
12 A I have.
13 Q And when -- when have you attended
14 those?
15 A Four times. And I do the overlap, so
16 I will do the last two or three days of the Harley
17 week and I do two days of -- or did do two days of
18 the Memorial Festival. I quit coming down here
19 because of the traffic issues. And that was in
20 2012.
21 Q So were you coming down as a
22 participant in the event?
23 A As a biker.
24 Q As a biker?
25 A Uh-huh.

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1 Q Okay. And so you would have come the
2 end of -- the end of -- of Harley week and the
3 beginning of the Atlantic Beach Bike Festival?
4 A Yes.
5 Q Okay. Would you come with a
6 motorcycle club of any sort?
7 A I was coming both as a member of the
8 Buffalo Soldiers, which is a motorcycle club,
9 riding club, and also solo.
10 Q And when did you first start coming?
11 A '06.
12 Q And you think you came about four
13 times between '06 and 2012?
14 A Yes, ma'am.
15 Q Where would you stay when you would
16 come?
17 A North Myrtle Beach. I have a beach
18 house in Cherry Grove.
19 Q And why did you -- or what did you --
20 well, how long have you been riding motorcycles?
21 A Since I was 15. And what prompted me
22 to come down here is love the culture of riding
23 motorcycles with the fellowship with other riders.
24 The reason I do both weeks -- or did both weeks is
25 because the Harley weeks had more vendors, and

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1 motorcycle riders love vendors, toys and trinkets
2 you can put on your bike and so forth. The
3 Atlantic Beach Bike Festival was a curiosity to
4 me. I heard a lot about it. After the second
5 time, it was the last time I wanted to -- had any
6 desire to come down because of the traffic.
7 Q And was this because there was a lot
8 of traffic or --
9 A A lot of traffic and behaviors that
10 are not conducive to my lifestyle.
11 Q What type of behavior?
12 A Reckless motorcycle operation,
13 drinking while operating a motorcycle, what I deem
14 to be disrespect of females.
15 Q And did you see that at both rallies?
16 A No, ma'am. Just pre---
17 predominantly at the Atlantic Beach -- we didn't
18 call it that then. It was still black -- black
19 bike rally. That's where I saw most of those
20 behaviors.
21 Q Why did you stop coming to the -- to
22 Harley-Davidson?
23 A It -- scheduling a lot -- there was no
24 particular reason. Just scheduling. And at that
25 time, there was a lot of traffic associated with

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1 the Harley-Davidson week as well. Not as much as
2 the Atlantic Beach. Atlantic Beach was just it
3 for me. I was stuck in traffic going -- at that
4 time, I didn't know where I was, but I know it to
5 be 17 now -- two-and-a-half hours. My particular
6 bike is a water cooled bike which never overheats.
7 It overheated that day and that was it for me. I
8 was done. As far as Harley activities, I don't
9 have a Harley. They predominantly cater to the
10 Harley riders. So I lost interest in coming down
11 here.
12 Q During the time period when you were
13 coming down, is that when the helmet ordinance had
14 passed?
15 A Yes. So before the helmet ordinance
16 passed, and then it was two years after I started
17 coming down here when they passed the helmet law.
18 I wear a helmet regardless. I wear it here now.
19 Q Yeah.
20 A I ride to this day. That wasn't an
21 issue for me. But I got word back through
22 channels in that the feel of it changed and that
23 Harley riders boycotted Myrtle Beach and they
24 particularly stayed in Murrells Inlet. And that
25 exists to this day. They -- they have very long

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1 memories. And it's almost like punishing Myrtle
2 Beach for that helmet law, which is, you know,
3 kind of ridiculous to me, but that's the culture.
4 Q In your time coming -- coming down,
5 would you ever cruise on Ocean Boulevard?
6 A I -- I did. Yes.
7 Q And is that a -- well, I'm sorry. Was
8 that during both events?
9 A Yes.
10 Q Okay. And would that cruising happen
11 in the City of Myrtle Beach?
12 A It did.
13 Q Well, what is the purpose of cruising
14 during the -- during the rallies?
15 A Well, you get to show off your bike.
16 You get to see the sights. And it's -- it's part
17 of being -- the energy of the crowd, for me
18 personally. I don't know who -- I can't speak for
19 anyone else, but for me, it's the energy of the
20 crowd and the sights you see. You see a lot of
21 high-dollar motorcycles and that's what interests
22 me.
23 Q Okay.
24 A The second week, you couldn't get to
25 the Boulevard. Traffic was just gridlocked and it

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1 was just a waste of time. So I stayed at Cherry
2 Grove along with my friends and we entertained
3 ourselves, cooked out and just got caught up.
4 Q Were there people who were trying to
5 go cruise on Ocean Boulevard during cycle week?
6 A Oh, I'm sure. Yes. You couldn't get
7 to it. It -- it was more cars than motorcycles.
8 Q Is there a self expression element
9 to -- to the cruising?
10 A Sure. Folks invest a lot of money
11 into their motorcycles, lights, sound systems,
12 trinkets. They like to show that stuff off. They
13 also like to see what other folks have done to
14 their machines and replicate that a lot of times.
15 So yeah.
16 Q And is it sort of part of that sharing
17 and expression of that culture --
18 A Yeah.
19 Q -- to cruise --
20 A Part -- part of the culture. Yes,
21 ma'am.
22 Q Have you since 2012 participated in
23 either of the bike week events?
24 A No, ma'am. Other bike events from
25 around the country, but not Myrtle Beach.

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1 Q What other bike events do you attend?
2 A The Americade, which is in Lake
3 George, New York. It's more my speed. Mature
4 riders. Family friendly events. West Virginia,
5 same thing. They have this thing called the Honda
6 Hoot and the Wing-Ding, which is primarily for
7 Gold Wing riders, the fat old guys who ride those
8 bikes.
9 Q Have you ever attended Daytona, been
10 to Daytona Bike Rally?
11 A Not as a biker, no. I've been down
12 there, but no, not necessarily with a motorcycle.
13 Q Okay. Have you been down there during
14 the bike rallies?
15 A No.
16 Q What about Galveston?
17 A No, didn't know they had one.
18 Q Any other motorcycle rides that you've
19 attended?
20 A No, ma'am. Well, club rallies that
21 the Buffalo Soldiers would put on. And yeah,
22 we -- let me take that back. Yes, there's a thing
23 out there called -- oh, what's wrong with my mind?
24 Oh, the National Bikers Roundup, predominantly
25 African-American motorcyclists.

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1 Q And where -- when does that take
2 place?
3 A It -- it's -- rotates from city to
4 city, whatever city wins the -- the event. And
5 it's anywhere from Florida to Oregon.
6 Q How many times have you gone to that?
7 A Twice.
8 Q Where -- where did you attend it?
9 A Atlanta, Georgia, Pennsylvania. I
10 can't remember the city because the event was held
11 in one part of Pennsylvania and we lived in
12 another part -- or stayed in another part.
13 Q And what -- what years did you attend
14 those events?
15 A I don't recall.
16 Q Would you -- was it in the last ten
17 years or prior to that --
18 A It was after 2006 when I bought the
19 Gold Wing. And I stopped going to all of the
20 rallies probably around '12.
21 Q Why did you stop going to all of the
22 rallies around 2012?
23 A Gets old after awhile. It's the same
24 'ole/same 'ole.
25 Q When you were down here for the bike

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1 rallies between '06 and '12, did you notice any
2 difference in the way the events were policed?
3 A I did notice an increase in police
4 presence for the Atlantic Beach festival.
5 Q And was that the City of Myrtle Beach
6 police presence?
7 A No, highway patrol. South Carolina
8 Highway Patrol. In particular, the only reason I
9 noticed was because they were riding BMW's. Being
10 a police officer at the time, we all rode Harleys.
11 So I just thought that was different.
12 Q And during the rallies, did you spend
13 any significant time in the City of Myrtle Beach
14 throughout the rally?
15 A No.
16 Q So you were mostly in North Myrtle
17 Beach?
18 A Yes.
19 Q For both rallies?
20 A Yes.
21 Q Did you ever speak with anybody who
22 felt that there was any race discrimination that
23 was happening between the two rallies?
24 A Yes.
25 Q And who -- who did you --

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1 A I couldn't tell you who. Just bikers
2 in general.
3 Q And what was the sense that you were
4 hearing?
5 A That there was an increased presence
6 of law enforcement for the second event, which is
7 the Atlantic Beach bike festival, more so than the
8 Harley, from their perspective.
9 Q Did you witness that as well?
10 A I didn't. And the only reason I bring
11 it up, the fact that South Carolina was on BMW's,
12 was just that fact. And it -- it was before the
13 traffic chute or the traffic management loop.
14 They had traffic management on 17. And it -- just
15 something that stuck out. Nothing that I would
16 consider overkill or inappropriate. It was the
17 amount of bikers that you had to deal with. And
18 as a law enforcement officer, I looked at it as
19 seeing that's how you manage that traffic and
20 keeping people safe and keeping them moving.
21 Q But again, what you were seeing was
22 not what was happening within the City of Myrtle
23 Beach; is that right?
24 A As -- as an attendee?
25 Q Yes.

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1 A Yes, I was in the City of Myrtle Beach
2 a few times.
3 Q And did you see a difference in the
4 way that the events were being policed within --
5 within the City of Myrtle Beach?
6 A No. Actually, I -- I didn't. And I'm
7 trying to think did I recall seeing an inordinate
8 amount of law enforcement in the city. And --
9 because I cruised the Boulevard a few times, both
10 in the car and on the bike. And at that time, no,
11 I didn't see -- notice anything.
12 Q Have you -- or let me ask, was
13 there -- have you -- have you been down to the
14 City of Myrtle Beach during the Atlantic Beach
15 bike fest -- bike festival since you've come down
16 to the position as Horry County --
17 A I have.
18 Q -- Police Chief? How many times?
19 A I would say two to three times during
20 each event off duty and on duty.
21 Q And that would be in 2017 and 2018?
22 A Yes.
23 Q Were you -- you were not here for
24 2016?
25 A I was, but not for the bike rallies.

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1 Q Right. For -- for the bike rallies?
2 A Uh-huh.
3 Q And so you -- you would come down.
4 Where -- where do you go in those two or three
5 times?
6 A Family's in town. And these are
7 family members or friends that are -- either were
8 bikers or are bikers. And they are curious to see
9 what all of the hype is about, for lack of a
10 better word. So I would take them down into the
11 traffic; and in particular, my wife, who had some
12 opinions about how the events are managed. And I
13 wanted to show her first-hand as to why the events
14 are managed the way they are and the amount of
15 traffic it's -- and whatever that goes on.
16 Q And so you were -- so that was in your
17 off-duty capacity?
18 A Yes.
19 Q Okay. What were her opinions about
20 how the events were managed?
21 A She didn't want to stay very long.
22 It -- the amount of traffic for the Atlantic Beach
23 bike festival was just too much for her, along
24 with the noise associated with the motorcycles and
25 the pipes. So she saw all she had to see and went

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1 home.
2 Q What -- sorry, what were -- you said
3 you -- you took her down to see -- to see what was
4 happening because she had some opinions. What
5 were those opinions that she held?
6 A She believed that we were policing as
7 a profession down here differently for the events.
8 What I explained to her is that it -- it's two
9 different events. And there is two different
10 mindsets that I've observed for the Harley week
11 both as a rider and a law enforcement official and
12 the mindset and the behaviors in particular of the
13 Atlantic Beach bike festival attendees.
14 Q And how would you characterize the
15 difference in the mindset?
16 A Well, in particular, there are more
17 young people in cars that attend the Atlantic
18 Beach festival that weekend than there are
19 motorcycles. And she didn't believe that because
20 she -- all she hears is the bikes. And at the
21 Grand Dunes, you hear all the noise down there.
22 It's right off of 17. I wanted to show her how
23 many young people were in cars, jammed full of
24 people in cars that were attending the festival or
25 down here. And in particular, the reason that I

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1 knew they were down here attending the festival --
2 or assumed they were -- were from the tags,
3 out-of-state tags down here during that weekend.
4 And I wanted to show her there were more cars and
5 motorcycles. And that's why the increased traffic
6 flow.
7 Q What time of day did you go down to --
8 A From 11:00 until 1:00.
9 Q In the morning?
10 A Yes.
11 Q Which years?
12 A The first one, which was '18 -- I'm
13 sorry, '17 -- and I had some visitors that come --
14 that came down and they wanted to see the -- the
15 festival in -- in the second week. And so I took
16 them down in the evening and we got as far as we
17 could, which was 17 Bypass, before we encountered
18 massive amounts of traffic backup. And I told
19 them, I said, this is kind of what we deal with;
20 I'm not going into the city any further; you kind
21 of get the picture.
22 Q And what year was -- was that?
23 A That was last year.
24 Q And what time -- you said this was in
25 the evening. What time of the evening?

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1 A 8:00, 9:00.
2 Q In 2017, did you -- I'm sorry. You --
3 you said -- you said that you also went down
4 during Harley-Davidson --
5 A Yes.
6 Q -- rally? Okay.
7 A Yes. Well --
8 Q Where did you go?
9 A Off duty on my bike down to the area
10 of Georgetown County line. You have the Beaver
11 Bar on the right-hand side. And you have vendors
12 set up there. My wife and I went there.
13 Q So you weren't going into the City of
14 Myrtle Beach --
15 A No.
16 Q -- during Harley -- Harley week.
17 Okay. And what time --
18 A That was in the afternoon on a
19 Saturday. I would say about 2:00. Between 2:00
20 and 4:00.
21 Q And in 2018, did you go down to
22 Harley?
23 A I don't think so. No.
24 Q In 2017, did you drive in the loop?
25 A No.

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1 Q So where -- where in the city did you
2 go?
3 A 17 Bypass near the Dunes, living there
4 at the time, up through, into Horry County
5 unincorporated, what they call Restaurant Row,
6 which is down there by Tanger Outlet. And then on
7 to North Myrtle Beach during the daytime to look
8 at the fes--- the -- the traffic flow down there.
9 And this is all off duty.
10 Q Okay. So when you were -- when you
11 were going to look -- to look at that end between
12 11:00 p.m. and 1:00 a.m., where exactly were you?
13 A From the Grand Dunes, 17 Northbound
14 all the way to Atlantic Beach. We didn't go
15 beyond Atlantic Beach into North Myrtle Beach.
16 Q And so you weren't actually in the
17 City of Myrtle Beach limits at that point?
18 A No.
19 Q Have you ever been with -- have you
20 ever been -- well, in -- in 2017/2018, off duty,
21 did you go into the City of Myrtle Beach?
22 A Yes. During the bike events.
23 Q Okay.
24 A Yes.
25 Q And what -- what time did you do that?

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1 A Daytime. I wanted to get down there
2 before folks woke up. I'm assuming they were
3 sleeping late, so it was less traffic during the
4 daytime, because I wanted to see how they set the
5 loop up as far as the barriers. And that was --
6 had to be around between 11:00 and 1:00.
7 Q And those are the pedestrian barriers?
8 A Yes. Yeah. It's something new they
9 started in '17 -- '18 -- '18, when Amy Prock took
10 over. Forgive me if I got the timeframe wrong,
11 but last year, they put the bike barriers up to
12 keep the pedestrians from getting into the street
13 traffic.
14 Q Yeah. And I think those have been up
15 for some time, but --
16 A Have they?
17 Q Yeah.
18 A Okay.
19 Q So you wanted to go see the pedestrian
20 barriers?
21 A Yes.
22 Q Okay. So that's why you drove down?
23 A Uh-huh.
24 Q Okay. Have you ever been in--- inside
25 the boundaries of the City of Myrtle Beach while

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1 the loop has been in effect -- in effect?
2 A Yes.
3 Q And when was that?
4 A That was 2017. And I had a rider with
5 me, a chaplain, and then chairman, Mark Lazarus,
6 as a ride-along with me. And we had to meet up
7 with then Mayor John Rhodes at a restaurant that
8 was in the City of Myrtle Beach in -- off of 17.
9 I forget the name of the restaurant. It's owned
10 by a council member. So we were there at about
11 2:00 in the morning, from about 2:00 to 3:30.
12 Q Okay. And so did you -- when you
13 were -- when you were doing the ride-along, were
14 you able to go into the emergency access lane?
15 A No. I never went anywhere -- didn't
16 want to go anywhere near that place as far as
17 the -- the traffic management plan because once
18 you're in there, you're -- you're trapped for the
19 most part. I mean, I -- I could have turned my
20 lights on and got out, but I just didn't want to
21 be stuck in that if something went on in Horry
22 County.
23 Q Okay. So you didn't actually go into
24 the loop at that point?
25 A No.

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1 Q Okay. Did you see -- so you -- so you
2 didn't --
3 A I saw it, but I didn't go into it.
4 Q And where did you see it?
5 A Right where it starts. And I forget
6 the name of the street number.
7 Q Who were you riding with?
8 A 28th, 29th, wherever that is where the
9 chute actually starts with the -- what they call
10 Yodock barriers. And then the restaurant was down
11 about a block on the right-hand side, two blocks
12 down.
13 Q Okay. So you didn't go down to Ocean
14 Boulevard?
15 A No.
16 Q And what did you see -- or what --
17 what time -- what times -- and that was about 2:00
18 a.m. that you were seeing it?
19 A Yes, ma'am.
20 Q So it was towards the end of the loop?
21 A Yeah. So let me back up a little bit,
22 because you're right. They shut the loop down at
23 2:00, so it had to be -- it -- I'm sorry. It was
24 a long night.
25 Q That's okay.

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1 A So I think it was either -- let's --
2 let's say between 11:00 and 2:00.
3 Q Sometime in that timeframe?
4 A Yes.
5 Q And what did you observe?
6 A A lot of traffic, a lot of cars, a lot
7 of people.
8 Q Is there any other time that you have
9 gone and -- and -- and observed the loop --
10 A No.
11 Q -- while it's been in place?
12 A I -- I -- I make a point to stay away
13 from it.
14 Q And why is that?
15 A I don't want to be stuck in a traffic
16 jam, especially if -- if I'm working. If there's
17 an incident occurs in unincorporated Horry County,
18 I need to be present. And that's not my
19 jurisdiction. The only reason I went down there
20 that time -- two times was to observe the traffic
21 pattern they had set up, the bike barriers. And
22 the other time was I had a council member with me
23 who wanted to go to Myrtle Beach to meet up with
24 another politician.
25 Q So it was to help the council member

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1 get down there?
2 A Well, he was riding in my car. He
3 said he wanted to go there. And that was my boss
4 and so that's where I took him.
5 Q So you weren't going down for the
6 rally?
7 A No.
8 Q In -- in talk--- I'm sorry. Would you
9 agree that the demographics of the Atlantic Beach
10 bike festival would have been majority
11 African-American?
12 A Yes.
13 Q Are there any other events that take
14 place -- oh, I'm sorry -- and the demographics of
15 Harley-Davidson tend to be majority white?
16 A Yes.
17 Q Are there any other events that take
18 place that have a majority African-American crowd
19 here in Myrtle Beach in terms --
20 A I -- I can't speak for Myrtle Beach.
21 No, I -- I don't know. I -- I can't speak for
22 Myrtle Beach.
23 Q Are you -- or -- or Horry County?
24 A We don't have any other event that
25 draws a crowd that large with that demographics in

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1 Horry County unincorporated.
2 Q Do you think that there is -- well,
3 how -- you know, you described a little bit, you
4 know, it's a younger crowd for the Atlantic Beach
5 bike festival versus Harley-Davidson. Are there
6 other differences in the -- in the -- in the
7 behavior of the crowds' --
8 A Yeah.
9 Q -- behaviors?
10 A Yes. So you have a lot of young
11 people in cars, not necessarily motorcyclists.
12 And as a biker, what I've heard in my community is
13 that a lot of the bikers have shied away because
14 of the amount of -- number of cars. And it's
15 become transformed from a biker event to a college
16 Freaknik -- Freaknik event, which was an event
17 that was held by college sororities and attendees
18 in the Virginia Beach area. And that got shut
19 down a number of years ago after a huge riot.
20 So a lot of people remember that and
21 they see similarities in the Atlantic Beach bike
22 festivals. And a lot of folks have stayed away.
23 A lot of the bikers are now staying in North
24 Myrtle Beach and are not really venturing out --
25 and this is all anecdotal -- but not venturing out

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1 to go into the City of Myrtle Beach, especially
2 when the traffic management plan is in effect.
3 Q And why is that?
4 A They don't want to be caught with
5 traffic. It's just too large of crowds. And the
6 age difference, much like my experience, is not
7 conducive with their behaviors now. So if I --
8 Q Because they have gotten older?
9 A Yeah. They've aged out. Yeah.
10 Q Have you -- did you participate at all
11 in the sort of planning and -- and decision to put
12 in place the traffic loop?
13 A No, that's all the City of Myrtle
14 Beach.
15 Q And do you now participate at all?
16 A No. The City of Myrtle Beach.
17 Q What about the one-way traffic plan on
18 Ocean Boulevard?
19 A Myrtle Beach.
20 Q And the pedestrian barriers?
21 A Myrtle Beach.
22 Q If -- well, does -- does -- does the
23 Horry County Police Department have any control
24 over the traffic loop?
25 A Negative.

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1 Q Also in the City of Myrtle Beach?
2 A All Myrtle Beach. Yes.
3 Q Have you heard any complaints about
4 what the traffic loop does to the -- to -- to
5 traffic in the City of Myrtle Beach?
6 A Yes.
7 Q What have you heard?
8 A That's interesting. I'm trying to
9 think about my response here. So I -- I don't
10 want to be the one to add stuff to it, but for
11 this particular context, I will. So prior to the
12 traffic management plan, it was a free for all.
13 And I can say that because I was part of that as a
14 private attendee, not as a law enforcement
15 officer. What I mean by that is that traffic was
16 everywhere, bikes and cars cutting down side
17 streets, couldn't get to where they wanted to be.
18 Everybody wanted to be on the Boulevard for the
19 show, if you will. And because there was no
20 traffic management plan when I was here in 2008,
21 no one got anywhere. It was gridlock. Fast
22 forward to the traffic management plan, although
23 you have long lines to get down the Boulevard, my
24 opinion, my observation, it's orderly. So you get
25 inside the -- the traffic chute or traffic

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1 management plan, and eventually, you're going to
2 get down to the Boulevard to make your pass to get
3 out of the -- off the boulevard. It will
4 eventually happen. It may be a few hours, but it
5 will happen.
6 Q What do you base that opinion on, if
7 you haven't actually to -- seen the loop?
8 A Reasonable assumption. You're not
9 going to get into -- you're not going to start at
10 20th Avenue and never go anywhere. If you stop on
11 the Boulevard, I'm assuming that Myrtle Beach
12 Police is going to usher you down so you can fair
13 that way. I -- just assumption. And I haven't
14 heard anybody complain that I never got a chance
15 to see Ocean Boulevard. It is just that I'm in
16 the loop for long periods of time and then I'm
17 out. So that's what I base my assumption on.
18 Q Have you looked at any traffic studies
19 of how traffic has flown since the management plan
20 put in place?
21 A No, not personally. No.
22 Q Do you know if anybody is looking at
23 those?
24 A Not to my knowledge.
25 Q And do you know if there were any

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1 traffic studies done before the loop was put in
2 place?
3 A I don't know that personally, but I
4 can only assume.
5 Q So it's obvious, but you don't have
6 any personal knowledge or any knowledge based on
7 the studies --
8 A Actually, I do. So I know that
9 whomever was in charge of the planning visited
10 other motorcycle rally communities, in particular
11 Ormond Beach and Daytona to look at their traffic
12 management plan. I don't know who went. I don't
13 know when they went. But they looked at
14 alternatives to the chaos that was the traffic
15 prior to the traffic pattern --
16 Q And how -- how do you know that?
17 A Hearing conversations that took place
18 from different part -- different people in the
19 city government -- and in particular, I think it
20 was the then Chief Warren Gall -- is that they
21 looked at this loop based on other traffic
22 management plans from other bike rallies or large
23 events.
24 Q Did you -- did you talk personally to
25 Chief Gall about that?

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1 A No, hearing conversations at the
2 chiefs meetings. Sidebar conversations.
3 Q Have you ever had any personal
4 conversations with any of the City of Myrtle Beach
5 Police Department about what they did --
6 A No.
7 Q -- to put in place the traffic loop?
8 A No.
9 Q And do you know what -- what if any
10 studies have been done since the traffic loop was
11 put in place to see if it's working?
12 A I have no knowledge of that.
13 Q And do you know why -- why a 23-mile
14 loop is put in place?
15 A I know why the traffic management plan
16 exists down on the boulevard. And I also observed
17 this, being a -- a rider myself. And I -- I
18 thought about it as I always do when I go places,
19 to apply my law enforcement background, just
20 curious, how do you get a rescue up and down the
21 Boulevard if you have an event, like a wreck, some
22 event that requires E.M.S.? How -- how do you get
23 an ambulance down a congested, blocked roadway?
24 And so that's one of the reasons that I stopped
25 going down there, because if that was me that was

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1 injured, had a medical condition, something
2 occurred, who's going to get there to help me?
3 And so I would rather not be in that position. So
4 I do know that -- I understand the traffic
5 management plan that's in place to facilitate ease
6 of access for emergency personnel.
7 Q And that's the -- the one-way on Ocean
8 Boulevard --
9 A Yes.
10 Q -- that's the emergency access lane.
11 Okay. But that's -- that's separate from the 23
12 mile that goes out into the -- out of the City of
13 Myrtle Beach. Is that right?
14 A Yes. I'm just talking about Ocean
15 Boulevard.
16 Q Okay. So my question was whether you
17 know why it is that it's required to have the
18 amount of -- of loop that goes into place.
19 A I don't know why it's required to have
20 that amount. I know it extends into Horry County
21 and the reason that the loop is set up. And this
22 is a conversation that I had with Chief Gall
23 because I asked that question myself, is because
24 if you don't, then traffic tends to flow back down
25 the open arteries. And we -- they have a hospital

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1 down there, Grand Strand. And it's a good
2 opportunity -- it's a good chance that the
3 traffic's going to be blocked and will block the
4 hospital ingress/egress. That's what he told me.
5 Q Have you ever done any of your own
6 analysis of what the other options for the loop --
7 A No.
8 Court Reporter: Can we take a little
9 break?
10 Ms. Ramchandani: Absolutely.
11 (Whereupon, a break was taken
12 from the proceedings.)
13 (Plaintiff's Exhibit 3
14 marked for identification.)
15 By Ms. Ramchandani:
16 Q If you could just read this e-mail and
17 let me know when you're done. Sorry, it's exhibit
18 3 and it's defendant's 72426.
19 A Okay.
20 Q So I understand this is an e-mail, but
21 yeah, you know, it was before you were here --
22 here in Horry County. Would you agree that
23 there's a difference between wrecking a bike at 30
24 miles an hour and 70 miles an hour?
25 A Yes.

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1 Q In terms of the type of injuries?
2 A Yes.
3 Q Is this something you would ever --
4 this concern something that you would have heard
5 about since you have been here?
6 A Not this particular -- well, yes,
7 absolutely. The amount of wrecks that occur
8 during the whole month of May --
9 Q Uh-huh.
10 A -- is a concern for Grand Strand,
11 which has limited capabilities.
12 Q Yeah. And had you heard about the
13 concern that the way the loop was designed was
14 going to send bikers out into areas where they
15 could drive faster?
16 A Not as -- no. Not as far as the
17 speed. More concerning was the blocking of routes
18 to the hospital.
19 Q So this is not something you had heard
20 about before?
21 A No.
22 Q Have you ever followed up with anybody
23 at Grand Strand about whether they are seeing an
24 increase in injuries because of the route the loop
25 send people out on to?

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1 A No, ma'am.
2 Q Okay.
3 A Grand Strand is also located in the
4 City of Myrtle Beach.
5 Q Okay. So it's not something within
6 your jurisdiction?
7 A No, ma'am.
8 Q Okay. Have you ever spoken with fire
9 rescue about -- about this concern?
10 A Not about speed increases because of
11 the traffic loop. I have spoken with fire rescue
12 about the -- what they see as far as the
13 seriousness of motorcycle crashes.
14 Q And do you know what they are seeing?
15 A That primarily, you're seeing low
16 speed wrecks where folks are not properly dressed
17 to ride a motorcycle. I mean, boots, jeans, long
18 pants, shirts, blah, blah, blah, helmets. Just
19 about that.
20 Q So you've spoken with them about that
21 issue?
22 A Yes, I have.
23 Q Okay. Have you done any studies --
24 have you looked at any studies about the speed of
25 crashes, speed -- speed during crashes during the

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1 bike weeks?
2 A No, ma'am.
3 Q And do you know if anything was done
4 in designing the traffic loop to address the
5 concerns that Mr. Crosby raised here?
6 A To -- to my knowledge, the traffic
7 loop has been the same way it's always been from
8 its original design and implementation.
9 Q Okay. And that's something you
10 participated in?
11 A No, ma'am.
12 Q And I just want to make sure I'm
13 clear, that you mentioned hearing about research,
14 for lack of a better term, that was done about the
15 traffic loop. But you don't have any specific
16 knowledge of what was done?
17 A No, ma'am.
18 Q And you haven't seen any studies of
19 what was done?
20 A No.
21 Q And do you have any specific knowledge
22 of what has been done to see whether or not the
23 traffic management plan that was put in place
24 during black bike week is working?
25 A No.

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1 Q Okay. That's not something you've
2 done either?
3 A No.
4 Q Okay. You mentioned that you have
5 looked at traffic violations within Horry County's
6 jurisdiction, at least from this jurisdiction, to
7 see whether there was any discriminatory
8 enforcement. Right?
9 A Yes.
10 Q Do you know if the City of Myrtle
11 Beach has done the same thing?
12 A Not to my knowledge.
13 Q Would you agree that if you are
14 staying at a hotel -- so if you -- let's say 27th
15 North Ocean Boulevard.
16 A Uh-huh.
17 Q Okay? And you go to a restaurant at
18 8th South and you want to leave that restaurant
19 after 10:00 p.m. during one -- during Friday,
20 Saturday or Sunday of black bike week when the
21 loop is in place --
22 A Uh-huh.
23 Q -- that it would take you a very long
24 time to get back to your hotel?
25 A I -- I don't know that to be for

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1 certain because I don't stay in the hotel at
2 Myrtle Beach during that time, or have not stayed
3 in a hotel during that time. I can only assume
4 traffic flows would restrict your ability to go
5 anywhere in a timely fashion.
6 Q And you know about how the loop -- do
7 you have a general idea of how the loop operates?
8 A Yes, ma'am.
9 Q Okay. So if you were at that exit,
10 you only have the option of going south on Ocean
11 Boulevard. Right? And then -- is that right?
12 A Yes.
13 Q And then you would have to -- to get
14 back to somewhere north on Ocean Boulevard,
15 traverse the entire loop to be able to -- and then
16 go back into the entrance point --
17 A Yes.
18 Q -- to go -- get back to your hotel.
19 Is that right?
20 A Yes.
21 Q Okay. And from what you have
22 observed, that could -- well, have you observed
23 how long that might take?
24 A No.
25 Q Okay. Do you have any sense of

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1 whether that might take some time?
2 A Depending on how many folks
3 participate. And there's a lot of variables to
4 that. Time of day, weather conditions.
5 Q So we're talking about the loop being
6 in place. So it's after 10:00 p.m. You're out
7 and the loop is in place?
8 A Sure. But even with the loop in
9 place, I'll give you a prime example, last year,
10 we saw a considerable amount of rain, less
11 attendance. There was hardly anybody in the loop.
12 So that particular day, if you wanted to go out in
13 your car or bike, you could get to some place
14 rather quickly. If it's a pretty day and nice,
15 warm night, it may be more difficult.
16 Q Who makes the decision to -- to take
17 down the loop or put it in place, the loop?
18 A That would be the chief. Someone from
19 the City of Myrtle Beach.
20 Q Okay.
21 A Normally, I hear from the chief of
22 police of Myrtle Beach that we're ending the loop
23 due to whatever, lack participation, weather. We
24 have done that several times during both '17 and
25 '18 rallies.

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1 Q And when you say we have done that,
2 has that been -- have you been involved in that
3 decision?
4 A Well, no. And -- and let me rephrase
5 that. So I get the word that they are taking it
6 down and that we kind of reduce our staffing based
7 on what -- the loop being terminated early.
8 Q Why do you reduce your staffing
9 because of the loop being terminated?
10 A There's no need to have additional
11 patrol out there if the loop is not in place. And
12 it's also an indicator to me that -- that
13 attendance is low more so than the actual loop
14 is -- that if the attendance is low for whatever
15 particular reason, normally it's weather, we don't
16 need to have folks stationed at some of our
17 checkpoints.
18 Q Why -- why is it that when the loop --
19 well, understanding you use it as a proxy to tell
20 you about how many people are out on the
21 streets --
22 A Uh-huh.
23 Q Is that fair to say?
24 A Yes, ma'am.
25 Q Are there other things independent of

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1 the number of attendees that require more staffing
2 during the loop?
3 A No.
4 Q Since --
5 A Not from Horry County's perspective.
6 Q From Horry County's perspective.
7 Okay. But you don't -- you're not the one
8 evaluating whether -- or Horry County Police
9 Department is not evaluating whether the loop
10 should be taken down?
11 A No.
12 Q That's City of Myrtle Beach?
13 A Yes.
14 Q And again, you haven't looked at any
15 studies of how long it takes to traverse the loop?
16 A No. And there would be so many
17 variables in that -- that observation, attendees,
18 weather, it's just -- it's a lot of variables.
19 Q And do you know -- are you -- do you
20 know whether the City of Myrtle Beach keeps any
21 data on that?
22 A I do not.
23 Q Have you looked at study -- any
24 studies about emergency access response time on
25 Ocean Boulevard?

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1 A No.
2 Q Is that something you've talked about
3 with fire rescue -- Horry County Fire Rescue at
4 all?
5 A No.
6 Q And so you don't know con--- what --
7 what that data might show. Is that right?
8 A No, I don't.
9 Q And do you know whether there are
10 other options that would be available for traffic
11 management on Ocean Boulevard? Do you have any --
12 have you -- have you looked at what other options
13 would be available or is that outside of your
14 jurisdiction?
15 A Outside my jurisdiction.
16 Q Okay. So you haven't looked at that?
17 A No.
18 Q And do you -- have you -- do you know
19 whether the City of Myrtle Beach has looked at
20 other alternatives?
21 A I have not.
22 Q Are there any other times of the year
23 when a 23-mile traffic loop is put in place --
24 A No.
25 Q -- in the area?

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1 A Not to my knowledge.
2 Q And do you have any specific knowledge
3 of what is happening in other jurisdictions around
4 motorcycle rallies in terms of traffic management?
5 A Around the country?
6 Q Yeah.
7 A I do.
8 Q What -- and what knowledge do you
9 have?
10 A Daytona Beach, from law enforcement
11 associates that have rallies in their area. And
12 that -- not so much rallies, but events. And I'm
13 trying to think of any place else. Nothing other
14 than from my personal observations.
15 Q And that would be events that you
16 attended that we discussed?
17 A Yes.
18 Q Have you ever experienced a 23-mile
19 traffic loop at any of those events that you've
20 been to?
21 A No, ma'am.
22 Q And do you know -- have you ever
23 experienced a traffic loop in any of those events?
24 A I refer to it as a traffic management
25 plan, so maybe it's some different terminology

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1 here. And what I mean by that is officers or
2 attendants directing vehicular traffic,
3 motorcycles or cars into a particular venue. I --
4 I've experienced that.
5 Q Where there's a gathering point --
6 A Yes.
7 Q -- per venue? Okay. But -- but is
8 that taking place during -- is there a -- is there
9 a specific venue where people are being directed
10 to --
11 A Yes.
12 Q -- during black bike week?
13 A Uh-huh -- oh, are we talking about --
14 Q During Memorial -- over Memorial Day
15 weekend, is there a venue that bikers are being
16 directed to with the traffic management plan
17 that's in place?
18 A Yes. Yes.
19 Q And what venue is that?
20 A Atlantic Beach. So I don't know the
21 number -- street number, but North Myrtle Beach,
22 right prior to getting to Atlantic Beach, the
23 right lane is reserved for motorcycles and folks
24 that are attending the event. Left lane is
25 through-traffic.

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1 Q Yes. I'm sorry. I asked a poor
2 question. In terms of traffic management plan
3 that's happening within the City of Myrtle Beach,
4 is there a venue people are being directed to in
5 the City of Myrtle Beach?
6 A Not to my knowledge, no.
7 Q What are the traffic management plans
8 that you're referring to in Daytona?
9 A It is their Boulevard. And again, I
10 haven't been there. But a friend of mine who's an
11 executive down there is involved in that. So they
12 have a one-way traffic management plan for the
13 Boulevard, so they allow motorcycles to park --
14 it's basically a parking management plan to
15 restrict vehicular traffic, so both come off
16 really from one vendor event to another.
17 Q Is that more similar to what you see
18 happening in Atlantic Beach?
19 A Yes. Yeah.
20 Q Where there's a -- it's a -- the --
21 the goal is to get people -- participants
22 interacting with each other?
23 A Yes.
24 Q But do you know whether in Daytona
25 they've put in place a -- a -- a -- a loop that

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1 doesn't allow people to return to venue --
2 A No.
3 Q -- without going up --
4 A I have no knowledge of that.
5 Q Okay. And do you know whether there
6 were -- or what options were looked at in terms of
7 options for emergency access to Ocean Boulevard?
8 A No, I don't.
9 Q Would you agree there are a number of
10 cross streets that intersect Ocean Boulevard
11 coming off of King's?
12 A Yes.
13 Q Are there any other times of the year
14 in which Ocean Boulevard is limited to one --
15 one-way traffic?
16 A Not to my knowledge.
17 Q Have you -- does Ocean Boulevard get
18 crowded -- do -- do you go down there in the
19 summer, to the --
20 A I do.
21 Q -- section of Ocean Boulevard at
22 Myrtle Beach? Okay. Does it get crowded during
23 other times of the summer?
24 A It does.
25 Q And can it be -- do you ever -- do you

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1 ever have similar concerns about roads access and
2 being able to get --
3 A Quite often.
4 Q -- to get places?
5 A Yes.
6 Q And what -- what are those concerns
7 based on?
8 A No matter where I go, I'm always
9 looking for a way out. Situational awareness. So
10 if I'm in crowds, I'm looking at how does the
11 emergency rescue or first responders get in -- get
12 in and out of a place? Where do I need to be in
13 case something goes wrong or where does my family
14 need to be? So these -- these are my personal
15 observations. It's kind of a self-preservation
16 thing that me and my family are trained to do.
17 Q And you've experienced that being down
18 Ocean Boulevard on a busy summer weekend?
19 A Yes.
20 Q Are you a member of any of the NAACP
21 chapters in this area?
22 A I am not.
23 Q Have you ever attended a special event
24 summit organized by the City of Myrtle Beach?
25 A I have.

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1 Q And when have you attended those?
2 A Seventeen.
3 Q And what happened at that?
4 A It's a conference to talk about plans
5 that are in place to thank the participants. We
6 have a lot of folks that come here from across
7 the -- actually, outside of South Carolina, across
8 the state and outside. And to get a briefing on
9 things that are -- that are occurring, and any
10 intel that's relevant and current to pass along to
11 the officers.
12 Q Is there a particular event that the
13 special event summit is linked to?
14 A It's all primarily the -- like the
15 month of May for the bike events.
16 Q And when does that summit happen?
17 A It's whenever Myrtle Beach schedules
18 it.
19 Q And who is -- who is in charge of
20 organizing that?
21 A Myrtle Beach.
22 Q Have you participated in the planning
23 of that summit?
24 A No, I haven't. Just as an attendee.
25 Q And you've only attended once; is that

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1 right? 2017?
2 A Yes. I missed this year's event.
3 Q And so -- I'm sorry. So that
4 includes -- the -- the -- are there presentations
5 at the conference or what -- what -- what
6 happened?
7 A There can be, depending on what's
8 going on. So we have -- and I may be getting the
9 two mixed up. So we have a mandatory meeting or a
10 training for -- it is a -- for lack of a better
11 term, this is not what they call it, a bias based
12 policing training.
13 Q That's the cops training that gets
14 done?
15 A Yeah. And it's mandatory for anyone
16 who's participating in the program. If you can't
17 make it, there is a video, a live presentation
18 that's done that you have to view. It's
19 basically, you know, it's will you be self aware
20 of biases and how to avoid that and how to not let
21 it interfere with your enforcement activities.
22 Q And that's a training that happens in
23 conjunction with the bike weeks?
24 A Yes.
25 Q Okay.

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1 A The whole month of May.
2 Q May. For the different jurisdictions
3 that are involved?
4 A Yes.
5 Q Okay. Have you been to -- and is that
6 what you're referring to when you talk about
7 supplement?
8 A Yeah. I -- I -- I may be getting them
9 mixed up because we attend several events in
10 Myrtle Beach. There's a training and there's --
11 there's a -- plus a bias training and then there
12 is an -- a meeting for all the participants a
13 couple of days prior to the event kickoff of all
14 of the law enforcement agencies that are in Myrtle
15 Beach participating. SCDNR, there's tons of them
16 there.
17 Q Okay. Separate from that, have you
18 been to an event where the City of Myrtle Beach
19 has gathered people from different jurisdictions
20 all over the country and talked about how they
21 handle special events?
22 A No, ma'am.
23 Q Okay. So that's nothing you've ever
24 attended?
25 A No.

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1 Q Okay.
2 (Plaintiff's Exhibit 4 and Exhibit 5
3 marked for identification.)
4 Ms. Ramchandani: That's 3 and 4.
5 Sorry. 4 and 5.
6 Mr. Caroti: 4 and 5.
7 By Ms. Ramchandani:
8 Q The top one is 4. You have just been
9 handed what's been marked as exhibits 4 and 5.
10 Exhibit 4 is native SLED 000721. Exhibit 5 is
11 native Horry 004871, just for the record.
12 Mr. Caroti: What are your numbers?
13 Ms. Ramchandani: My numbers are 22
14 and 23.
15 Mr. Caroti: Thank you.
16 Ms. Ramchandani: Yeah.
17 By Ms. Ramchandani:
18 Q If you could just look over these and
19 let me know when you've had a chance to do so.
20 A Okay.
21 Q So I just wanted to -- so these are
22 e-mails from May of 2018; is that right?
23 A Yes.
24 Q And in what was marked as exhibit 5,
25 is that -- P.S.L.T., that's public safety --

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1 A -- leadership team.
2 Q Okay. And there's a -- it's another
3 agenda and it references a traffic loop plan B.
4 Do you see that?
5 A Uh-huh.
6 Q Okay. And then in Chief Prock's
7 e-mail, there's a -- a -- a log-in for planning
8 meeting that the City of Myrtle Beach is having
9 and she references saying that she wants to follow
10 up with a conference call regarding any needs or
11 possible changes for Memorial Day weekend, if
12 there's a need, due to the possibility of
13 adjustments to our overall traffic plan, set up
14 the phone call. Do you remember why it was that
15 there may have been a need to change the traffic
16 plan?
17 A I -- I don't recall there being a
18 traffic loop plan B. I don't know why there would
19 be one. I -- I don't know why. I mean, I don't
20 know that.
21 Q Do you recall hearing anything about a
22 pending motion for preliminary injunction?
23 A Yes. Okay. Yes. Sorry.
24 Q Does that refresh your recollection --
25 A Yeah.

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1 Q -- recollection at all?
2 A Yes, ma'am.
3 Q Okay.
4 A Yeah.
5 Q Do you have a recollection of what the
6 traffic loop plan B was?
7 A No.
8 Q But you knew that there was -- there
9 was a plan of traffic management in case there was
10 a -- in case that motion was granted?
11 A Yeah, because I thought the injunction
12 was going to shut down the loop as -- in its
13 entirety. Reading this, I was incorrect in that
14 assumption. It appears that it was going to be a
15 reduction in the length of the loop on the traffic
16 management plan.
17 Q Do --
18 A But there would still be a management
19 plan in place.
20 Q Did you have any details of what that
21 management plan was going to be?
22 A If I did, I don't recall.
23 Q Would you have participated in putting
24 it together?
25 A No, ma'am.

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1 Q Okay. Would that be the City of
2 Myrtle Beach?
3 A City of Myrtle Beach unless it
4 affected Horry County, unincorporated Horry County
5 because there is a portion of the bike week that
6 is in Horry County, but it's staffed by the
7 Highway Patrol.
8 Q So who would have been responsible for
9 that planning?
10 A If it was any type of adjustment in
11 the unincorporated areas of Horry County, it would
12 have been either Sergeant Clemmons of the Highway
13 Patrol -- primarily would have been Clemmons.
14 Q Would you agree that the loop begins
15 in the City of Myrtle Beach?
16 A Yes.
17 Q Okay. And if the City of Myrtle Beach
18 did not want to have a loop, there would be no
19 loop?
20 A Yes.
21 Q And so does the unincorporated area
22 get involved only because of the plan the City put
23 in place?
24 A Yes.
25 Q But you don't -- so you do know that

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1 there was a alternate plan. You just don't know
2 what it was?
3 A Yes, ma'am.
4 (Plaintiff's Exhibit 6
5 marked for identification.)
6 Ms. Ramchandani: Exhibit 6. That was
7 my 26.
8 By Ms. Ramchandani:
9 Q You've been handed exhibit 6. It
10 starts with Bates number Horry 012601. You're
11 welcome to look over the exhibit, but I just
12 wanted to ask you in particular about 012604,
13 which is the public safety leadership team and
14 discussion notes from May of 2017.
15 A Okay.
16 Q What I want to point you towards is
17 the sixth bullet point. It starts with Randy
18 advised the information will be disseminated
19 nightly focusing more on traffic incidents
20 involv--- involving fatalities and fires during
21 Memorial Day weekend.
22 A Uh-huh.
23 Q Was there a -- a change in what the
24 E.O.C. was going to focus on?
25 A Yes.

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1 Q And what -- what was -- what do you
2 know about that change?
3 A So counter to what is in exhibit 5, I
4 believe it is, I don't recall us having set up
5 E.O.C. for the bike events last year. There was a
6 decision made by E.M.D. Director Webster, there
7 was no need to have an operational center.
8 However, it looks like they were still providing
9 information to us based on traffic fatalities. So
10 we're focusing in on law enforcement criminal
11 activity. There's enough information in
12 communications on the police channels. I can't
13 monitor the E.M.S. channels. So there was E.M.S.
14 issues, a traffic crash that would result in
15 traffic being blocked for periods of time. That
16 was going to be communicated through either --
17 either E.O.C. or 911 to all the support units
18 covering the bike events.
19 Q Okay. So there was a decision that
20 was sort of the most useful role they could
21 play --
22 A Yes.
23 Q -- was to communicate about those
24 types of incidents on the roads?
25 A Yes.

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1 Q Because the law enforcement stuff was
2 being covered by the different police departments?
3 A Yes.
4 Q That makes sense. And did that shift
5 indeed happen? Is that what -- is that what they
6 focused on?
7 A Yes.
8 Q Do you recall --
9 A Last year, we had a fatality of a
10 police officer who was down here enjoying the
11 events and wrecked his bike. And a lot of
12 information came through the E.O.C. not only
13 concerning the actual crash, traffic disruption,
14 but the condition of the officer, being part of
15 the brotherhood.
16 Q Where did that accident happen?
17 A Seventeen. Lost control of a sport
18 bike. I'm not sure where at on 17, but it was
19 unincorporated Horry County. Yes.
20 Q Was it in any of the area that's a
21 part of the loop?
22 A No, I don't -- I don't -- I don't
23 know. I don't -- I don't know.
24 Q And -- but that was -- that officer
25 wasn't here for -- for -- he wasn't on duty?

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1 A No, no. He was here as a participant
2 off duty from Connecticut.
3 Q Do you know why the traffic management
4 plan that's currently used for Memorial Day
5 weekend was put in place?
6 A I hesitate to answer that question
7 because I don't know for sure why it was put into
8 place. Per my observations, I would have to
9 guess.
10 Q Have you ever had any conversations
11 with anybody about why it was put in place when it
12 was put in place?
13 A Yes.
14 Q And who have you had those
15 conversations with?
16 A Then Chief Warren Gall.
17 Q And what was -- what do you recall
18 about that conversation?
19 A Out of curiosity, because I -- I lived
20 through that nightmare, the traffic prior to the
21 loop. And also, there was an event in 2014 where
22 there was a shooting. So I think -- and -- and
23 again, this is just Joe Hill's assumptions -- that
24 it was a mix of -- and -- and this is coming from
25 Chief Warren Gall, so let me concentrate on what

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1 he said first. Numerous complaints from citizens
2 who live in the confines of unincorporated Horry
3 County -- I'm sorry, incorporated Horry County,
4 the City of Myrtle Beach, about traffic
5 disruptions, noise, traffic in communities that
6 normally don't see that much traffic, and then
7 separate conversations about the concerns that
8 were raised after the 2014 multiple fatalities and
9 shootings. So combination of both. I was
10 tracking your question --
11 Q No, that's -- that's -- no, I think --
12 I think --
13 A I'm sorry about --
14 Q I think that's -- I was asking why the
15 loop was put --
16 A Yes. So --
17 Q -- why the traffic loop was put in
18 place.
19 A Yeah. And I -- again, Joe Hill's
20 assumption is that it was a combination of both
21 the traffic nightmare that was prior to the loop
22 and the criminal incident that occurred in 2014.
23 Q Do you know if the criminal incident
24 had anything to do with the people who were here
25 for the -- the bike week events?

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1 A I wasn't here during that event. But
2 I looked into it prior to coming down here,
3 applying for the chief's position, doing my
4 research. The attendees -- the folks involved in
5 that shooting were most likely here -- again, Joe
6 Hill's assumption -- for the bike rally, the
7 Memorial Day bike rally.
8 Q And what do you base that on?
9 A Demographics and time.
10 Q What -- what do you mean by
11 demographics?
12 A Young African-American males and
13 females, witnesses being the females. The actual
14 participants, suspects, decedents, were all
15 African-American.
16 Q And do you -- are there young
17 African-Americans who live in this area year
18 round?
19 A Yes.
20 Q Do you know whether the people who
21 were involved in the incident were local to the
22 area?
23 A That part, I don't know. I -- I don't
24 know.
25 Q Okay. So -- and do -- do -- and you

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1 don't know what their -- do you know for a fact
2 that they were here for the event or whether they
3 were just down on Ocean Boulevard?
4 A I have no way of knowing that.
5 Q Do people gather on Ocean Boulevard
6 throughout the course of the summer?
7 A Yes.
8 Q And so, I'm sorry, is it -- are -- do
9 you have the actual knowledge that that shooting
10 was linked to people who were here for black bike
11 week?
12 A I do not.
13 Q So that's all just assumption?
14 A Yes.
15 Q But you don't know whether it was
16 actually ever been determined why those
17 individuals were -- were here?
18 A Not to my knowledge.
19 Q Or were on Ocean Boulevard, not here?
20 A Yeah. I understand. Yeah.
21 Q Are there crime issues throughout the
22 year in the City of Myrtle Beach?
23 A Yes.
24 Q Are there shootings at other times of
25 the year?

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1 A Yes.
2 (Plaintiff's Exhibit 7
3 marked for identification.)
4 Ms. Ramchandani: Exhibit 7, and this
5 was my 12.
6 By Ms. Ramchandani:
7 Q I'm handing you what's marked exhibit
8 7, and it's Horry 004754. Just take a look and
9 let me know when you're done.
10 A Okay.
11 Q So this is a report that you got from
12 Randy Webster --
13 A Uh-huh.
14 Q -- 2017?
15 A Yes.
16 Q Does he do these just from the
17 E.O.C. operational?
18 A When there's an incident, whether it's
19 a environmental incident, weather event or a
20 special event, he will do this. And not
21 necessarily having the E.O.C. and operation. They
22 could do it from their phone or their desktop.
23 Q Do you do anything with these
24 situation reports?
25 A Yes. Depending on what the situation

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1 or what the intel that we gather, we would adjust
2 our staffing levels, our positioning of our -- of
3 our officers. In particular, if there's one
4 little spot that's problematic, we can get
5 officers closer to that event.
6 Q So is it -- is it really just a report
7 for communication -- it's -- it's for
8 situational --
9 A Situational awareness.
10 Q But you don't gather this, do any sort
11 of overall analysis with them?
12 A No.
13 Q Are you aware of any criticisms that
14 the NAACP has made of the traffic management
15 plan --
16 A I am.
17 Q -- associated with this -- what do you
18 know about those complaints or criticisms? I'm
19 sorry.
20 A From news reports, that they believe
21 it to be discriminatory to African-Americans.
22 Q And have you ever spoken with anybody
23 from the NAACP about that?
24 A Well, do you mean spoken to one on
25 one, in a group?

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1 Q I -- both. Yeah.
2 A Both. At one of our task force
3 meetings, former chief Willie Williams and an
4 attorney out of D.C. gave a presentation, which
5 was an alternative to the traffic management plan
6 that's currently in place. Didn't have a
7 one-on-one conversation, but just heard their
8 presentation.
9 Q And --
10 A And they were both representatives of
11 the NAACP.
12 Q Now, do you -- were you involved in
13 any -- well, do you know if that alternative
14 presentation was considered as an option?
15 A I would have to say no because we have
16 not changed the traffic management plan since I've
17 been here.
18 Q And besides seeing that presentation,
19 were you involved in any conversations about what
20 was presented?
21 A No, ma'am.
22 Q Do you know if any conversations were
23 had about what was presented?
24 A I -- I do not.
25 Q So that was not something that the law

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1 enforcement sub committee discussed, to your
2 knowledge?
3 A No. No. That would have been
4 primarily the focus for Myrtle Beach officials.
5 Q And you -- you -- Horry County Police
6 Department would have had -- would have had
7 representatives at the law enforcement
8 subcommittee task force meetings?
9 A Yes, ma'am.
10 Q So you would have known if it was
11 being discussed via reporting?
12 A It may not have gotten back to me
13 personally. If the conversation was had, it may
14 have been not communicated to me.
15 Q If Horry County had been involved in
16 the evaluation or decision-making process, would
17 that have been communicated to you?
18 A Yes, but we would not have been --
19 Q Do you have any recollection of what
20 the substance was of that alternative proposal?
21 A I believe it was a shortened version
22 of the existing traffic management plan. How
23 short, I -- I don't recall.
24 Q And did you do any analysis or
25 evaluation of whether that plan would have worked?

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1 A No, ma'am.
2 Q Okay. You don't remember --
3 A City of Myrtle Beach. No.
4 Q You don't have an opinion one way or
5 another?
6 A No.
7 Q Do you have any other criticisms other
8 than the criticisms by the NAACP that it made
9 about the traffic management place -- traffic
10 management plan that was put in place during
11 Memorial Day weekend?
12 A I am.
13 Q And what -- from who?
14 A Bikers, attendees.
15 Q And what are those -- what -- what are
16 the nature of those criticisms?
17 A There is some concern that the traffic
18 management plan is in place for one event and not
19 the other, that the traffic management plan locks
20 them into a route that they can't get out of and
21 it -- it -- it spoils their fun, using their
22 terminology.
23 Q Any other criticisms?
24 A No. That's it.
25 Q Is there any merit to the concern that

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1 the traffic management plan locks people in?
2 A It does. By design.
3 Q Does it concern you at all that the
4 only time that there's a traffic management
5 place -- traffic management plan in place that
6 locks people in in the City of Myrtle Beach is
7 during a majority African-American event?
8 A I've looked at it long and hard from a
9 participant, a rider and a law enforcement
10 official. No. No, as in no concerns.
11 Q And why is that?
12 A One, I -- I really didn't really have
13 an opinion because it happens in the City of
14 Myrtle Beach and doesn't concern Horry County,
15 from my perspective. As a rider who lived through
16 that nightmare prior to a traffic management plan,
17 my personal opinion, Joe Hill, being a civilian,
18 riding a motorcycle, you -- you need a traffic
19 management plan. It was utter chaos when I was
20 down here in '08. I would -- again, observation
21 from Joe Hill, less chaos now.
22 Q But you haven't actually been in the
23 traffic management plan since it's been put in
24 place?
25 A As a rider, no.

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1 Mr. Caroti: Did you finish your
2 answer, the one before the last one?
3 The Deponent: I don't remember. What
4 was the question?
5 By Attorney1:
6 Q I think the -- you had said that the
7 traffic management plan did not concern you. And
8 I had asked why and so you had given two responses
9 to that, that I remember.
10 A Yeah. Yeah. It just -- it happens in
11 the City of Myrtle Beach and it is not a concern
12 for Horry County.
13 Q Do you have any opinions about whether
14 a traffic management place -- traffic management
15 plan that is in place is the best traffic
16 management plan for the --
17 A No opinion.
18 Q Would it concern you if there were
19 less onerous ways to put that plan into place that
20 weren't being considered?
21 Mr. Caroti: Object to the form of the
22 question.
23 The Deponent: No. Again, I
24 resolve -- it's the City of Myrtle Beach's
25 concern, not Horry County.

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1 By Ms. Ramchandani:
2 Q As a -- as a rider, would it concern
3 you --
4 Mr. Caroti: Same objection.
5 The Deponent: If I was riding in that
6 traffic loop -- ask that question again, please.
7 By Ms. Ramchandani:
8 Q So if there were less onerous ways to
9 manage traffic during the event --
10 A Uh-huh.
11 Q -- would it concern you as a rider if
12 you knew that those less onerous ways were not
13 being considered?
14 A If I was going to subject myself to
15 that traffic management plan, yes.
16 Q Okay. I just need to look through my
17 notes and we should be done. Just give me a
18 minute.
19 (Off-the-record.)
20 By Ms. Ramchandani:
21 Q So one thing is we had talked about --
22 I think we covered all of your off-duty visits
23 down to the City of Myrtle Beach during Memorial
24 Day weekend --
25 A Uh-huh.

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1 Q -- which was -- I'm sorry, let me just
2 make sure I got -- I got -- I got the list. So
3 the -- you went down 2017 with your wife from
4 11:00 p.m. to 1:00 a.m. Right?
5 A No. 11:00 a.m.
6 Q 11:00 a.m.?
7 A Yes.
8 Q To 1:00 p.m.?
9 A Yes.
10 Q Okay. I think that's --
11 A That was with the -- the 11:00 p.m. at
12 night, roughly, to 1:00 or 2:00 was with
13 Councilman/Chairman Mark Lazarus.
14 Q Got it. So when you went down with
15 your wife in 2017, that was not while the loop was
16 in place?
17 A No.
18 Q Okay.
19 A That was actually to Atlantic Beach,
20 not to Myrtle Beach. And that was during the
21 daytime. That was during the lunch hour.
22 Q Okay. So I'm sorry. Let me just make
23 sure I have the -- the right list.
24 A Uh-huh.
25 Q Let's start with 2017. What were all

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1 the times you went down off duty? And where
2 exactly did you go?
3 A For both events? Are you talking
4 about the City of Myrtle Beach or the loop in
5 particular?
6 Q City of Myrtle Beach during Memorial
7 Day weekend.
8 A Okay.
9 Q During the Atlantic Beach bike fest in
10 2017.
11 A With the wife, it was in Atlantic
12 Beach. With a visitor who is also a rider, during
13 the -- prior to the loop going into place at
14 10:00, was at Myrtle Beach, the Boulevard.
15 Q And that was 2017?
16 A Yeah. That was to look at the road
17 barriers, the bicycle barriers they had put up.
18 And then either from 11:00 to 2:00 or somewhere in
19 that timeframe with Chairman Lazarus at the City
20 of Myrtle Beach. I could see the loop, but was
21 not in the loop.
22 Q And then what about in 2018?
23 A Yeah. 2018 -- I'm getting my dates
24 mixed up, or my years mixed up. No. There was
25 a -- so I think I may have visited not the loop,

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1 but in the city limits off duty once in '18.
2 Q And do you remember where -- where you
3 went?
4 A During -- during that event, had -- I
5 was on 17 and I think -- what did I go down there
6 for? I think I was showing a relative around. I
7 don't remember exactly where.
8 Q Did you go down Ocean Boulevard?
9 A Yeah.
10 Q And would that have been during the
11 daytime hours?
12 A Daytime. Yes. Typically, I had just
13 my shifts, so I'm working at night.
14 Q Yeah. Makes sense. Okay. So you
15 haven't been down to Ocean Boulevard at night
16 during Memorial Day weekend bike fest --
17 A No.
18 Q -- since you came as a participant.
19 A No. No. Not as a participant. No.
20 Q All right. I think I asked the
21 question poorly. You have not been down to Ocean
22 Boulevard at night during Atlantic Beach bike
23 festival in 2017 or 2018?
24 A Yes.
25 Q Is that right?

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1 A I -- I have been. With Mark Lazarus,
2 who was the chairman at that time.
3 Q So I thought you said you didn't go
4 all the way down to Ocean Boulevard that time.
5 A You -- you're saying to the City of
6 Myrtle Beach. Right?
7 Q To Ocean Boulevard.
8 A Oh, no. No, we didn't. No, we --
9 Q So that -- that -- Chairman Lazarus,
10 when you went to that restaurant --
11 A Yes.
12 Q -- where you saw the entrance to the
13 loop.
14 A Yes.
15 Q Okay.
16 A Sorry. I misunderstood you.
17 Q Are there any -- were there any other
18 on-duty times that you went into the City of
19 Myrtle Beach during the Atlantic Beach bike
20 festival?
21 A No.
22 Q So this is the sum total of all of the
23 times you went down?
24 A Yes.
25 Q And then during -- during Harley-

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1 Davidson week, you said that you had gone down to
2 Murrells Inlet during the day?
3 A Yes.
4 Q Were there -- then you would go into
5 the City of Myrtle Beach?
6 A No. We took the connector, so all
7 unincorporated areas of Horry County.
8 Q So you have not been into the City of
9 Myrtle Beach in the evening hours during
10 Harley-Davidson rally since becoming a police
11 chief?
12 A Yes, I have.
13 Q Okay.
14 A On duty.
15 Q What --
16 A I attended a stereo competition at one
17 of the restaurants on Restaurant Row. This was in
18 2017.
19 Q Restaurant Row is up north of --
20 A -- 17, yeah, north.
21 Q Okay.
22 A So 17. It's right there at -- before
23 you get to Tanger Outlets. And on our way back,
24 being curious to see the flow of traffic, I went
25 down Ocean Boulevard.

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1 Q And that was in 2017?
2 A Yes.
3 Q Okay. Do you remember what time of --
4 A Uh-huh. The sun was still out because
5 people were in their lawn chairs on the side. So
6 probably 8:00.
7 Q Okay.
8 A Yeah. No later than 8:30. And that
9 was for Harley week.
10 Q Because I think I have --
11 A Okay.
12 Q But the other time I just wanted to
13 make sure -- glad I asked because I had -- had it
14 wrong with your -- when you were down here with
15 your wife. Have you ever been down to the Ocean
16 Boulevard area during July 4th?
17 A Yes.
18 Q And when have you -- when have you
19 done that?
20 A Almost every year. We go either
21 from -- except for last year. We only go to
22 Broadway at the Beach and then I have a relative
23 that comes into town with her whole entire family
24 every year. It's tradition whether I'm in
25 Virginia or wherever. She's -- just tradition.

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141
1 So I take them down to see the sights, basically.
2 Q And does it get crowded down there?
3 A Very much so.
4 Q Do you have those same concerns about
5 emergency access that we discussed earlier?
6 A Always. And in particular, Broadway
7 at the Beach. I attended in 2017 and decided not
8 to attend any longer and didn't attend last year.
9 And they had an incident last year, thank
10 goodness.
11 Q That was the shooting last year?
12 A My fears -- well, alleged shooting.
13 Reports of gunfire.
14 Q And is the loop put in place at
15 Broadway at the Beach?
16 A No, ma'am.
17 Q And is there emergency access lanes
18 put in place?
19 A There is nothing. Should there be?
20 I'm sorry, no opinion, but...
21 Q Would you feel better if there was
22 a --
23 A I would.
24 Q -- if there was an emergency access
25 put in place? Okay.

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1 A Yes.
2 Ms. Ramchandani: Okay. I think that
3 is all I have.
4 Mr. Caroti: James?
5 Mr. Battle: No questions.
6 Mr. Caroti: I don't have any
7 questions, surprisingly. Thank you very much.
8 (Deponent excused.)
9 (Whereupon, at 12:02 p.m.,
10 the taking of the foregoing
11 deposition was concluded.)
12

13

14

15

16

17

18

19

20

21

22

23

24

25

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143
1 CERTIFICATE OF REPORTER
2 State of South Carolina
3 County of Florence
4

5 I, Roger Williamson, Court Reporter and


6 Notary Public for the State of South Carolina, do
7 hereby certify that the deponent in the foregoing
8 deposition was, by me, first duly sworn to testify
9 to the truth, the whole truth and nothing but the
10 truth; that said deposition transcript contains a
11 true record of the deposition of said deponent.
12 I further certify that I am neither attorney
13 nor Counsel for, nor related to or employed by any
14 of the parties connected to the action, nor am I
15 financially interested in the action.
16 Witness my hand at Florence, South Carolina,
17 this the 21st day of April, 2019.
18 ______________________
19 Roger Williamson
20 MY COMMISSION EXPIRES:
21 March 18, 2022
22

23

24

25

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144
1

2 STATE OF SOUTH CAROLINA


3 County of ____________
4

5 I hereby certify that I have


6 read the foregoing deposition by me given and that
7 the statements contained therein are true and
8 correct (as stated) (as corrected), to the best of
9 my knowledge and belief.
10

11

12

13 ___________________
14 Joseph Hill
15

16

17

18 Sworn to and subscribed before me


19 This _____ Day of __________, 2019.
20

21

22

23 ______________________________________
24 NOTARY PUBLIC, STATE OF SOUTH CAROLINA
25 MY COMMISSION EXPIRES:
26

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1

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2
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3
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large 15:12 109:24 85:3 132:8 26:4 43:17
17:13 48:20 legal 5:17,18 local 17:16 looking 38:25 51:5 60:22
49:14 51:11 length 118:15 125:21 40:21 42:18 72:4,7,9,23
51:15 90:25 Leslie 1:5 localized 59:8 94:22 112:9 72:25 74:20
92:5 95:22 let's 23:4 located 100:3 112:10 75:10,14
larger 54:1,4 28:14 61:19 location 1:12 looks 121:8 89:6,6,6
largest 16:11 89:1,2 52:4 loop 11:14 91:10,13,20
18:2 53:24 102:14 locations 18:8 21:16 22:14 91:22,23
late 86:3 135:25 25:25 49:17 79:13 84:24 104:3 106:18
lately 63:9 letting 23:22 locks 131:19 86:5 87:1,24 113:6 122:11

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loud 55:7 males 125:12 marijuana 35:18 36:9 mindset 82:12
love 71:22 Mall 49:13 56:17,19 36:15 37:1 82:15
72:1 manage 40:19 Mark 87:5 37:19 38:9 mindsets
low 100:15 79:19 134:9 135:13 138:1 38:13 41:6 82:10
105:13,14 managed marked 59:25 96:2 129:3 mine 110:10
lunch 135:21 81:12,14,20 60:2 66:17 130:8 minute 69:10
management 98:14 116:3 member 63:18 134:18
M 11:11,13 116:9,24 71:7 87:10 minutes 38:10
M 4:19 15:3 17:4,7,9 120:5 127:3 89:22,25 missed 67:14
M.D 30:25 17:11,13,18 127:7 112:20 114:2
ma'am 8:10,20 17:20 20:22 massive 83:18 members mission 18:24
8:24 9:25 21:6,9,14,24 matter 112:8 62:23 81:7 misundersto...
10:13,16 28:12 31:1 matters 5:17 Memorial 10:4 138:16
11:3,22 12:7 39:25 40:3 5:18 11:19 21:17 mix 123:24
12:14,18 42:6 47:4,6 Mature 76:3 25:2,10 mixed 114:9
17:7 25:20 52:18 79:13 Maurice 20:17 29:20 34:7 115:9 136:24
30:21 34:24 79:14 87:17 Mayor 87:7 34:11,22 136:24
38:11,20 92:2 93:12 mbattle@ba... 44:15 49:1,3 Monday 1:14
39:1 40:23 93:20,22 2:9 63:15 70:18 67:17,17
43:9 44:4,13 94:1,19 McLean 16:15 109:14,14 Monetary
50:6,9 70:7 95:12,22 mean 9:8 117:11 15:17
71:14 72:16 96:15 97:5 38:24 39:5 120:21 123:4 money 75:10
75:21,24 101:23 40:3 46:19 125:7 131:11 monitor 47:12
76:20 88:19 107:11 108:4 87:19 93:15 134:23 136:6 59:9,10,15
100:1,7 108:24 100:17 109:1 137:16 121:13
101:2,11,17 109:16 110:2 117:19 memories monitoring
103:8 105:24 110:7,12,14 125:10 74:1 28:15,17
108:21 118:9,16,18 128:24 memory 9:12 58:25 59:3
115:22 118:2 118:21 123:3 means 16:25 mentioned 70:2
118:25 120:3 128:14 129:5 media 59:9,13 39:7 50:10 month 9:16
129:21 130:9 129:16 medical 97:1 64:18,19 10:2,24
131:1 141:16 130:22 131:9 medium-sized 101:13 102:4 30:19 32:10
machines 131:10,18,19 18:20 merit 131:25 33:16 34:6
75:14 132:1,4,5,16 meet 87:6 Methamphet... 99:8 113:15
main 2:7 5:4 132:19,23 89:23 56:17 115:1
52:24 53:4,6 133:7,14,14 meeting 30:24 Metro 15:19 monthly 32:22
maintained 133:16 32:20,22 Metropolitan 33:15
10:17 134:15 33:11 35:8 14:15 months 13:16
Major 14:23 managers 36:22 37:16 Michael 2:8 morning 4:21
20:5,5,8,9,16 52:23 41:6 114:9 mile 97:12 4:22 6:11
20:17 mandate 42:9 115:12 117:8 miles 22:11,15 7:13 65:11
majority 90:10 42:9 meetings 26:15,25 83:9 87:11
90:15,18 mandatory 30:15,18 98:24,24 motion 117:22
132:7 114:9,15 32:6 33:9,18 military 14:15 118:10
making 42:8 March 143:21 35:5,11,14 mind 76:23 motor 55:19

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motorcycle Myrtle 1:4,8,9 119:3,15,17 105:16 78:16 85:7
17:17 34:19 1:9 8:22 11:7 124:4 126:22 112:12,14 85:15 91:23
42:5 57:12 11:25 12:13 130:4 131:3 117:12,15 102:15
58:16,25 12:16,22 132:6,14 121:7 132:18 103:14
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61:1,25 62:1 25:9 27:8,15 134:23 needed 30:6 139:19,20
66:3 71:6,8 27:22 33:3,5 135:20 136:4 42:21,22 Northbound
72:1,12,13 37:15 40:22 136:6,14,20 needs 117:10 85:13
76:12,18 41:20 43:1 138:6,19 Negative 3:16 Notary 143:6
95:10 100:13 43:17,19 139:5,9 69:3 92:25 144:24
100:17 108:4 46:16,23 neighbor 5:25 notes 120:14
132:18 49:13 52:5 N neither 143:12 134:17
motorcycles 60:9,13 62:6 N 2:1 3:1 4:1 never 38:4 notice 1:17
10:25 26:3 62:8,10,11 4:19,19 73:6 87:15 78:1,3 80:11
57:25 61:7 62:11,22 N.W 2:3 94:10,14 noticed 41:12
65:24 71:20 63:2,10,16 NAACP 11:5 new 21:7 76:3 55:22,25
71:23 74:21 64:9,23 65:3 11:10,24 86:8 78:9
75:7,11 65:4,22 66:5 112:20 news 128:20 nuisance
81:24 82:19 66:8,12 128:14,23 nice 104:14 39:17
83:5 109:3 71:17 73:23 129:11 131:8 night 67:17 number 6:5
109:23 74:1,11 name 4:23 68:10 69:2,6 11:6 17:22
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motorcyclists 78:13,16 21:21 33:22 88:24 104:15 42:8,12,20
76:25 91:11 79:22 80:1,5 61:1 87:9 135:12 54:25 88:6
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move 13:23 85:7,15,17 names 57:17 nightly 120:19 106:1 109:21
14:2 67:6 85:21 86:25 narcotic 56:13 nightmare 109:21 111:9
moved 13:11 87:8 89:23 narcotics 57:2 52:9 123:20 120:10
13:15 90:19,20,22 national 1:4 124:21 numbers 18:2
moving 79:20 91:24 92:1 18:14 76:24 132:16 18:3 44:23
multi-jurisdi... 92:13,16,19 native 116:10 nine--- 52:10 45:15,16
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multiple 8:15 93:5 94:11 nature 5:23 81:24 82:21 116:13
22:21 43:16 96:4 97:13 131:16 124:5 numerous
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65:16 73:24 107:19 65:24 76:12 104:21 o--- 25:23
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music 21:22 110:5 111:22 necessary north 5:4 O-M-G 60:18
63:5 64:19 112:24 30:4 26:22 33:5 oath 7:18
Mustang 52:2 113:17,21 need 8:1 25:2 46:16 54:17 object 7:22
Mustangs 52:2 115:10,14,18 30:5 66:24 66:5 68:13 133:21
52:23 117:8 119:2 89:18 105:10 69:1 71:17 objection

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134:4 94:15 97:7 7:25 8:1,25 115:17,23 103:7
objections 4:4 97:14 102:15 9:24 11:2 116:1,20 operating
4:12 103:10,14 12:5 14:1 117:2,6,23 72:13
objectives 106:25 15:24 17:10 118:3 119:1 operation 9:10
41:9 107:11 111:7 18:6 19:6,12 119:17 9:13 46:24
observation 111:10,14,17 19:21 20:13 120:15 55:19 72:12
63:22 93:24 111:21 21:2 22:24 121:19 127:21
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132:20 126:5,19 24:24 25:8 127:10 131:2 29:13 121:7
observations 137:8,15,21 25:22 26:19 134:16 127:17
47:15 108:14 138:4,7 27:20 28:1,4 135:10,18,22 operations
112:15 123:8 139:25 28:7,18 136:8 137:14 10:8,15
observe 89:5 140:15 29:10,13 138:15 opinion 93:24
89:20 off-duty 81:17 31:10 33:17 139:13,21 94:6 131:4
observed 134:22 35:23 39:9 140:3,7,11 132:13,17
54:22 55:12 Off-the-record 39:24 42:14 141:25 142:2 133:17
57:5 58:22 134:19 44:5,10 45:4 old 76:7 77:23 141:20
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96:16 103:22 officer 17:18 51:23 53:14 ole 77:24 81:12,19
103:22 27:7 38:22 54:9 58:12 ole/same 82:4,5
observing 78:10 79:18 59:23 60:4,8 77:24 133:13
30:6 64:2 93:15 122:10 60:18,20 on-duty opioid 56:10
obvious 95:5 122:14,24 61:21 62:25 138:18 opioids 56:12
Obviously 6:7 officers 16:25 63:3 64:25 once 23:18 opportunity
occasionally 18:21 20:1 67:2,7,20,23 30:19 33:16 98:2
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occur 25:15,23 45:13 49:6 69:12,25 137:1 11:10
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occurred 128:3,5 84:6,17 23:10 107:10,12
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52:21 29:3 130:4 97:11,16 133:19 134:8 73:13,15
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occurs 43:17 75:6 76:23 102:4,17 ongoing 63:24 organizing
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74:5 75:5 okay 5:16 6:4 111:5,22 operates Ormond 95:11
88:13 92:18 6:19 7:3,9,10 114:25 115:5 48:18 51:10 out-of-state

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outlaw 60:19 110:14 68:11 72:24 Pennsylvania personnel
61:25 parkway 24:12 73:5 78:8 77:9,11 17:8 54:5
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outside 32:5,7 41:17,25 93:11 95:10 22:5,16 79:8 106:5,6
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113:8 74:16 75:16 113:12 75:4 79:20 127:22
overall 26:12 75:20,20 120:12 128:3 82:17,23,24 phrase 28:14
41:2 117:13 77:11,12,12 136:5 141:6 89:7 91:11 pick 16:18
128:11 87:19 93:13 particularly 91:20 95:18 picture 83:21
overheated 95:18 122:14 39:15 60:24 99:25 105:20 pipes 81:25
73:7 122:21 73:24 109:9 110:4 place 10:6,18
overheats 125:23 parties 4:8 110:21 111:1 15:24 21:16
73:6 participant 59:16 143:14 115:19 21:17 24:20
overkill 79:16 70:22 123:1 partners 33:1 124:24 35:15 39:11
overlap 28:11 132:9 137:18 Parts 26:8 125:20 126:5 39:20 40:22
28:13 70:15 137:19 partying 55:8 126:10 132:1 68:8 77:2
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owned 87:9 110:21 113:5 113:10 perform 46:1 90:14,18
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P.D 15:10 92:10,15 28:1 39:25 40:2 97:5,18
P.L.L.C 2:2 104:3 patrol 18:24 42:6 101:23
p.m 1:15 69:13 participated 31:14,25 period 13:18 102:21 104:6
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P.S.L.T 116:25 114:16 Patrol's 32:3 54:23 94:16 108:13 109:8
Pagans 57:18 115:15 patrols 40:19 121:15 109:17
61:9 participation patrons 23:25 permanently 110:25
page 3:5 61:20 21:5 104:23 pattern 43:21 52:17 112:12 113:5
61:23 particular 52:11 89:21 person 12:10 118:19
pants 100:18 23:16,18 95:15 personal 5:14 119:23 123:5
parade 17:1 39:1,13 pedestrian 5:15,21 95:6 123:8,11,12
park 21:21,23 40:14 42:22 46:18 50:17 96:3 108:14 124:18 129:6
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24:1,6 53:3 54:10 57:7 86:12 17:19 74:18 135:16
110:13 60:20 62:11 pending 1:18 94:21 95:3 136:13
parking 47:7 63:13,14,24 8:4 117:22 95:24 130:13 141:14,18,25

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places 96:18 10:9,15 44:6 9:19 11:18 1:20 4:4
112:4 21:14 40:15 political 63:9 49:17 78:4,6 proceedings
Plaintiff 2:2 95:22 110:7 65:6 79:5 98:12
Plaintiff's 113:4 politician present 89:18 process 18:13
59:24 66:16 play 121:21 89:24 presentation 31:5 130:16
98:13 116:2 please 4:14,23 poor 110:1 114:17 129:4 Prock 27:9
120:4 127:2 7:6,13 8:2 poorly 137:21 129:8,14,18 86:9
plaintiffs 1:6 58:14 134:6 pop-up 49:17 presentations Prock's 117:6
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plan 11:11,13 plus 26:15 portion 119:5 presented 63:23
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planning 17:4 104:22 106:8 72:17 73:9 132:16 64:15 121:8
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119:9 82:6 114:12 preparing 8:19 128:4 144:24
plans 9:10,14 policy 15:3 presence 9:16 Procedure punishing

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74:1 104:14 127:6 134:1 116:11 7:11 16:4,16
purpose 5:2 quit 70:18 134:7,20 143:11 36:20 37:14
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purposes Randy 120:17 18:12 117:14 131:2
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pursuant 1:17 R 1:11 2:1 4:16 rarely 48:20 Redirection 137:2,7
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86:11 92:11 raised 101:5 really 20:25 18:25 118:15 57:22 58:14
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101:23 11:2 16:14 132:12 117:3,9 report 19:24
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putting 118:23 rally 16:14 recall 16:5 regardless reporter 1:16
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questions 67:24 98:10 reconstructi... 137:6 140:22 64:22 65:1
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142:5,7 116:7,13,16 record 4:24 113:10 127:24
quick 51:14 116:17 120:6 6:18,23 7:14 remained 22:8 128:20
quickly 14:11 120:8 127:4 7:15,16 34:5 remember 141:13

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129:10 130:7 responsible 71:20,22 rotates 33:10 saw 50:22
represented 17:3,12,19 78:9 88:7 77:3 52:12 72:19
5:7 20:21 25:12 90:2 132:18 Rough 57:20 81:25 88:3
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45:2 63:21 119:8 right 4:9 6:9 135:12 138:12
require 27:3 restaurant 13:24 19:2,7 round 125:18 saying 70:1
51:2 106:1 85:5 87:7,9 25:19 29:14 Roundup 117:9 138:5
required 97:17 88:10 102:17 33:22 56:10 76:24 says 61:24
97:19 102:18 57:9 59:23 route 17:1 SC 2:7,12
requirements 138:10 67:1,8 69:2 21:10,10 SCDNR 115:15
54:5 139:17,19 79:23 81:1 24:14 99:24 schedule 9:7,9
requires 96:22 restaurants 82:22 88:5 131:20 35:24 36:1
rescue 24:1,5 48:22 139:17 88:22 97:13 routes 99:17 schedulers
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100:9,11 110:15 103:11,19 65:8 schedules
107:3,3 restricted 22:3 107:7 109:22 Row 85:5 9:17 113:17
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