Case 2:18-cv-05838-DSF-JPR Document 319 Filed 11/02/21 Page 1 of 3 Page ID #:7180
1 RICKEY IVIE (S.B.N.: 76864)
2 rivie@imwlaw.com
DAVIDA M. FRIEMAN (S.B.N.: 232096)
3 dfrieman@imwlaw.com
4 IVIE McNEILL WYATT PURCELL & DIGGS, APLC
444 South Flower Street, Suite 1800
5 Los Angeles, California 90071
6 Telephone: (213) 489-0028
Facsimile: (213) 489-0552
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Attorneys for Defendants, COUNTY OF LOS ANGELES and LOS ANGELES
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COUNTY SHERIFF’S DEPARTMENT
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10 UNITED STATES DISTRICT COURT
11 CENTRAL DISTRICT OF CALIFORNIA
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13 SHELDON LOCKETT ) CASE NO.: 2:18-cv-5838-PJW
)
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14 Plaintiff ) DEFENDANTS’ PROPOSED
15 ) STATEMENT OF THE CASE
vs. )
16 ) Final Pre-trial Conference:
COUNTY OF LOS ANGELES, a ) Date: November 15, 2021
17 public entity; LOS ANGELES ) Time: 3:00 p.m.
COUNTY SHERIFF’S ) Courtroom: 7D
18 DEPARTMENT; a law enforcement ) Courthouse: First Street Courthouse
agency; former SHERIFF JIM ) 350 West 1st Street
19 MCDONNELL; MIZRAIN ORREGO, ) Los Angeles, CA
a Deputy Los Angeles County Sheriff; )
20 SAMUEL ALDAMA, a Deputy Los )
Angeles County Sheriff; and DOES 1 ) Trial
21 through 100, inclusive, ) Date: December 14, 2021
) Time: 8:30 a.m.
22 Defendants. ) Courtroom: 7D
) Courthouse: First Street Courthouse
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) 350 West 1st Street
) Los Angeles, CA
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) Complaint Filed: July 9, 2018
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DEFENDANTS’ PROPOSED STATEMENT OF THE CASE
Case 2:18-cv-05838-DSF-JPR Document 319 Filed 11/02/21 Page 2 of 3 Page ID #:7181
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Pursuant to the Court’s Order Re Jury Trial [DKT 283], Defendants County
3 of Los Angles, the Los Angeles Sheriff’s Department and Deputy Samuel Aldama
4 hereby submit their proposed Statement of the Case as follows:
5 Mr. Lockett, asserts that his civil rights, guaranteed under the laws of the
6 United States and under the United States Constitution, were violated by the
7 defendants Deputy Samuel Aldama, the County of Los Angeles, and the Los
8 Angeles Sheriff’s Department. Specifically, he claims that he was the victim of
9 excessive force by Deputy Aldama. Mr. Lockett also contends that the County of
10 Los Angeles and/or Los Angeles Sheriff’s Department had policies, practices,
11 and/or customs that tolerated deputy cliques which was the moving force that
12 caused Deputy Aldama to violate the laws of the United States and the United
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States Constitution by using excessive force on Mr. Lockett.
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Based on these claims, Mr. Lockett contends he has suffered personal
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injuries and damages.
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Deputy Aldama denies that he used excessive force and asserts that
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the force he used was objectively reasonable.
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The County of Los Angeles and Los Angeles County Sheriff’s
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Department deny they had policies, practices, and/or customs that violated the
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laws of the United States and the United States Constitution, and deny that they
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tolerated violations of the laws of the United States and the United States
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Constitution by deputy sheriffs
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DEFENDANTS’ PROPOSED STATEMENT OF THE CASE
Case 2:18-cv-05838-DSF-JPR Document 319 Filed 11/02/21 Page 3 of 3 Page ID #:7182
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All defendants further dispute the nature and extent of Mr. Lockett’s
2 claimed injures and damages.
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4 Dated: November 1, 2021 IVIE McNEILL WYATT PURCELL &
DIGGS, APLC
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By: /s/ Davida M. Frieman
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RICKEY IVIE
8 DAVIDA M. FRIEMAN
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ANTONIO K. KIZZIE
Attorneys for Defendants,
10 COUNTY OF LOS ANGELES
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12 DATED: November 1, 2021 SEKI NISHIMURA & WATASE, LLP
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By /s/ Andrew Pongracz
15 Gilbert Nishimura
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Andrew Pongracz
Attorneys for Defendant
17 SAMUEL ALDAMA
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DEFENDANTS’ PROPOSED STATEMENT OF THE CASE
