April 10, 2015

Dallas Police Department

Office of Internal Affairs
Jack C. Evans Building
1400 S. Lamar
Dallas, Texas 75215
This letter shall serve as my formal and official complaint against a number of Dallas Police
Department officers for their actions on March 27, 2015, approximately 4pm, at the scene of the
officer down incident on the Santa Fe Trail in East Dallas.
The officers engaged in unprofessional conduct by taking actions to prevent this Correspondent
from taking photographs of the emergency care of the down officer, either through verbal
orders, physical intimidation, threats to arrest and other harassing activities. this is completely
unacceptable by any stretch of the imagination or legal actions.
Each officer engaged in an activity which violated this Correspondents First Amendment right
to freedom of the press (collecting information on a news event), as well as violated various
Dallas Police Department General Orders regarding contact with the public, crime scenes
and public access to police activities. Some officers issued orders to others which in and of
themselves were illegal and should have been disregarded by the officers.
The names of these officers are unknown. The attached summary of actions includes
photographs of these officers (identified by nicknames or other descriptions). A complete set
of the nearly 100 photographs taken at the incident by this Correspondent is included on the
enclosed DVD.
If you have any questions, please do not hesitate to contact me.
Regards,
Avi S. Adelman
5620 East Side Avenue
Dallas TX 75214
avi@aviadelman.com
214-923-3562
cc

Mickey H. Osterreicher, General Counsel

National Press Photographers Association

Adelman, Page 1

Summary of events
On March 27, 2015, at approximately 4 pm, Correspondent was listening to a police scanner,
when he heard a report of someone having a medical emergency on the Santa Fe Trail near
Henderson Avenue.
This report included an Assist Officer comment, and a comment We need an ambulance here
right now!
Correspondent lives approximately three blocks from this location. He immediately grabbed his
camera and camera bag, and went to the scene.
On his arrival, he parked his vehicle about 500 feet from the scene and ran up the berm towards
the incident.
This series of photographs includes commentary describing approximately what was said by the
officers, or a description of their actions. It is not a verbatim repitition of statements made by
the officers.
Avi S. Adelman

Adelman, Page 2

Photo 1258, 401pm, March 27th

This photo was shot from about 300 feet from the scene.
Note that two officers - the female on the left and the black male standing close to the squad car are waving their hands at the photographer, indicating he was not to approach the scene.

Adelman, Page 3

Photo 1263, 401pm, March 27th

Upon arriving at the trail path, two officers are continuing to approach Correspondent. The
female officer was in the first photogaph.
The second bicycle patrol officer is standing next to the black officer, pointing towards the
photographer.

Adelman, Page 4

Photo 1270 402pm, March 27th

This officer knows Correspondent by name from his work on Lowest Greenville Avenue.
The officer verbally instructed Correspondent, by name, to stop taking photographs and to leave
the area immediately.
This order was repeated at least twice.

Adelman, Page 5

Photo 1280 402pm, March 27th

The white male officer leaves, to be replaced by another black male officer (nickname Rugby
Player).
Rugby Player was the most hostile of the officers on the scene. He verbally harassed
Correspondent, stood directly in front of the camera, and followed Correspondent as he walked
to his vehicle with notebook in hand in an attempt to collect personal information about the
Correspondent.

Adelman, Page 6

Photo 1293, 402pm, March 27th

Prior to this photograph, Correspondent had been told by another officer to not cross an
imaginary boundary indicated by a crack in the sidewalk on the path (a legal order). This
boundary was approximately 100 feet from the incident.
Correspondent then walked down the berm in order to walk around the scene, still staying at
least 100 feet away.
The Rugby Player than followed Correspondent down the berm and around the path.
The white male officer pointing at Correspondent again repeated his order to stop taking
photographs. The Bicycle Patrol officer, identified as Earnest Sherman, was telling someone (not
sure whom) to keep the Correspondent away from the scene.

Adelman, Page 7

Photo 1295, 402pm, March 27th

Rugby Player is getting closer to Correspondent and making some kind of (unintelligible)
comments.

Adelman, Page 8

Photo 1296, 402pm, March 27th

Rugby Player is now standing directly in front of Correspondent.

Adelman, Page 9

Photo 1297, 402pm, March 27th

Rugby Player is now standing directly in front of Correspondent.

Adelman, Page 10

Photo 1298, 402pm, March 27th

Rugby Player is now standing directly in front of Correspondent.

Adelman, Page 11

Photo 1299, 402pm, March 27th

Rugby Player is now standing directly in front of Correspondent, making comments to

Correspodnent. Note Bicycle Patrol officer on left and white male officer on right continuing to
monitor situation.

Adelman, Page 12

Photo 1301, 402pm, March 27th

Correspondent has moved to the other side of incident approximately same distance as first
defined boundary (100 feet.) Rugby Player begins verbal harassment of Correspondent, to wit
- Dont you have somewhere else to be??
- Why are you taking these photographs?
- You were told to stop taking photos. Why are you still here?
(These are not exact quotes)

Adelman, Page 13

Photo 1303, 402pm, March 27th

Correspondent has moved to the other side of incident approximately same distance as first
defined boundary (100 feet.) Rugby Player begins verbal harassment of Correspondent, to wit
- Dont you have somewhere else to be??
- Why are you taking these photographs?
- You were told to stop taking photos. Why are you still here?
(These are not exact quotes)

Adelman, Page 14

Photo 1305, 402pm, March 27th

Correspondent has moved to the other side of incident approximately same distance as first
defined boundary (100 feet.) Rugby Player begins verbal harassment of Correspondent, to wit
- Dont you have somewhere else to be??
- Why are you taking these photographs?
- You were told to stop taking photos. Why are you still here?
(These are not exact quotes)

Adelman, Page 15

Photo 1306, 403pm, March 27th

Bicycle Patrol officer instructs Rugby Player to keep Correspondent back at imaginary line.
Due to noise level of Rugby Player yelling at Correspondent, it is not clear if Bicycle Patrol
Officer told him to make sure Correspondent did not take any more photographs.

Adelman, Page 16

Photo 1312 403pm, March 27th

Rugby Player is joined by Asian Officer, and verbal harassment continues unabated.

Adelman, Page 17

Photo 1313 403pm, March 27th

As Correspondent moves to berm on left side of trail, Rugby Player follows while continue verbal
harassment and attempts to block photography.

Adelman, Page 18

Photo 1314, 403pm, March 27th

As Correspondent moves to berm on left side of trail, Rugby Player follows while continue verbal
harassment and attempts to block photography.

Adelman, Page 19

Photo 1315, 403pm, March 27th

As Correspondent moves to berm on left side of trail, Rugby Player follows while continue verbal
harassment and attempts to block photography.

Adelman, Page 20

Photo 1316, 403pm, March 27th

As Correspondent moves to berm on left side of trail, Rugby Player follows while continue verbal
harassment and attempts to block photography.

Adelman, Page 21

Photo 1317, 403pm, March 27th

Correspondent has returned to trail and continues to walk over berm along imaginary boundary
line. Rugby Player and Asian Officer follow Correspondent.

Adelman, Page 22

Photo 1321, 403pm, March 27th

In addition to officers, a teenage male now joins the queue to block Correspondent. He tells
Correspondent he is helping the officers block photography.
The officers do not attempt to prevent this person from participating, thereby setting a negative
role model of police activities as legitimate behavior.

Adelman, Page 23

Photo 1335, 404pm, March 27th

As Correspondent circles around the scene and heads to his vehicle. Rugby Player and Asian
Officer continue to follow, along with unidentified male.
Prior to this photo, Correspondent had walked to base of berm by street, followed by Asian
Officer. This officer pushed Correspondent into street, in an attempt to force him to walk into
right of way and risk a ticket. Correspondent confirms he asked this officer - Did you just
fucking touch me? The officer replied - Yes, I did.
As Correspondent starts to return to his vehicle, Rugby Officer follows with a notebook in hand,
in an attempt to get Correspondents vehicle information. Rugby Officer tells Correspodent Hey, if you did not do anything wrong, what are you worried about?
Correspondent stops walking to vehicle. After a few moments, Rugby Player leaves area.

Adelman, Page 24