This complaint filed against Gregory Deger, employed by the City of Santa Clara as a peace officer, is neither frivolous nor silly as there is certified documentation and witness testimony to support all claims.

Furthermore, this complaint is not without foundation. The City of Santa Clara and other peace officers admitted that Deger did not wholly document use of force and that he broke departmental and county policies. Additionally, multiple first-hand witnesses concur that Deger’s actions are not just violation of policy, he appears to have violated California Penal Code including omission of facts, embellishment of a police reports and false testimony while under oath.

Deger has not been exonerated from the claims listed in the original complaint filed on April 7, 2015.  A redacted version of that complaint can be found here: Complaint – Deger – redacted

1. Deger has a sustained and documented finding of misconduct for being untruthful during a major investigation.
2. Deger responded to a call for service, the reporting party (RP) was not on the property or in the subject residence.  The RP did not see an argument, did not see fighting, did not see the subjects he called about. The RP also told officers the sound he heard was a loud commanding voice, not a threat and not shouting.
3. After being warned of termination if he broke departmental policy again, Deger intentionally broke policy in responding to the call for service described in #2 above.
4. Deger testified as he walked towards the subject property all was quiet, he heard no voices or sounds.
5. Deger rang the doorbell.  A 61 year old resident answered, Deger told her the call for service originated from the subject property.  The resident explicitly told Deger the no one made a phone call.  The woman’s 41 year old son, visiting at the time with two female friends, told Deger that no one called emergency services.  Deger changed his story that a neighbor called.  The man figured Deger was at the wrong house and offered to introduce Deger to the neighbors, Deger replied, “we won’t be doing that.”
6. All four witnesses wrote statements and testified Deger proclaimed he was arresting the man for being Drunk in Public.  They told Deger that none of them were drunk and pointed out that they were on private property – the porch and inside the residence – not on public streets.  The images to the right are two Santa Clara Police Department forgot to crop before handing over to attorneys.  You can see from the other pictures that SCPD intentionally cropped them to eliminate the 647(f) before handing over to prosecutors and attorneys.  Under oath and penalty of perjury, Deger blamed the writing of 647(f) on officer Chris Bell who had nothing to do with the incident, there’s no way Bell knew of crimes alleged by Deger and Stewart.
7. Timothy T. Williams, retired Senior Detective Supervisor Los Angeles Police Department was hired by attorneys to investigate the incident.  Mr. Williams is an expert in police policy and helped write the Los Angeles manual for responding to domestic disturbance service calls.  He was quick to point out the inappropriate arrest that was not supported by physical evidence or testimony by EMT’s, medical records, or other officers who responded to the scene.  He also made note of emergency medical and hospital reports that described the man as cooperative, alert, and aware.
8. Mr. Williams continued his investigation by looking at cell phone records from Lauren Larsen, an officer who accompanied the man from the residence scene to VMC.  Retired Senior Detective Supervisor Williams observed a flurry of calls between Deger and Larsen that appeared to take place after officer Bell had taken his pictures and departed VMC.  Larsen and an evidence collection technician noted on paperwork that a blood sample was refused and no evidence taken.
9. The man was charged with PC148 (resisting arrest) and HS11550, under the influence of a controlled substance.
10. Senior Detective Supervisor Williams (LAPD ret.) provided his expert testimony that, after reviewing thousands of cases, “…it’s my opinion that someone must have instructed him [Deger] at the supervisor level or even at his peer level that you can’t arrest him for 647; you’ve got to find something else.”
    

    

11. Lauren Larsen, who didn’t know the letters D.R.E. stood for drug recognition expert testified she has never had a drug recognition expert course.
12. Larsen claims she performed a Romberg’s Test on the man while at Valley Medical Center.  Problem with this is no one ever saw her do it, the man testified it was never done, and a Romberg’s Test must be completed with the subject standing up, unrestrained.  The man was laying down handcuffed to a gurney the entire time, never standing.
13. In her police report, which was written more than 48 hours after the incident, Larsen lists a number of observations she says indicates use of stimulants… (a) High pulse rate: 106bpm, (b) Fast Rhomberg Test [sic], (c) bloodshot eyes, (d) clammy skin/not to the touch, (e) rapid speech, (f) cotton mouth, (g) bizarre behavior, (h) inability to answer simple questions.”
14. Retired police supervisors William and Usoz, as well as all medical, EMT, and fire services wrote in reports and testified facts contradicting Larsen’s statements.  (a) According to the Mayo Clinic, the average resting heart rate is between 60 and 100 beats per minute, the man had been beaten to include multiple strikes to the torso, head and face just before Larsen observed him, medical staff wrote that a heart rate of 106 is normal given the man had been physically assaulted; (b) there is no such thing as a Fast Rhomberg Test, Larsen made it up; (c) bloodshot eyes, Colin Stewart wrote in his report and testified that he struck the man multiple times in his face, photo evidence proves that; (d) medical experts wrote in their reports that the man’s skin was normal, furthermore skin can’t be both clammy and hot to the touch at the same time; (e) rapid speech, all medical professionals and audio tape prove speech was normal; (f) cotton mouth claim is disputed by medical professionals; (g) bizarre behavior is not witnesses or noted in any other reports or on audio recording; (h) inability to answer simple questions is refuted by all medical reports and audio recording.
15. Derek Rush, a supervisor on the scene, sent an email to fellow police supervisors instructing them not to approve any police reports from that evening, he would personally do it.
16. Rush testified that Deger and Larsen’s charge of HS11550 was never forwarded to the District Attorney as they had no evidence and police never even attempted to look for alleged narcotics.

As of May 2020, the City of Santa Clara has not found Deger to be exonerated from any of the above allegation of policy violation or crimes.