exhibit a timeline


1 Exhibit A : Timeline

2 Detailed Timeline of Events November 21, 2018 (Wednesday): 8:32 a.m. Mr. Ramos-Gomez is arrested for an incident at Spectrum Hospital where he allegedly trespassed on the helipad after damaging a keypad. There is scorching under a sprinkler and some burnt items are found in his backpack. • The forms of identification Mr. Ramo s Gomez had with him when he was arrested according the Grand Rapids Police Department Police Report and his Inventory Property List stored at the GRPD included his: o U.S. passport-- which states that he was born in Michigan; o U.S. Marine Corps “dog tags”; and o Real ID-compliant driver’s license (w hich one cannot obtain unless one is lawfully present in the United States) that also identified him as a veteran. 11:42 a.m. - 11:55 a.m. GRPD Sgt. Griffin and Lt. Rogers interview Mr. Ramos-Gomez at the GRPD Detective unit. Sgt. Griffin texts w ith FBI agent Austin that the case involves “Vet, PTSD, But not a FBI issue.” 12:30 p.m. GRPD posts on the GRPD Facebook a ccount about the arrest at Spectrum Health, noting that there was “minimal damage” and “no additional concern for danger.” 12:34 p.m. The GRPD issues a press release about an arrest at Spectrum Health, noting that there dditional concern for danger.” was “minimal damage” and “no a 3:51 p.m - 4:45pm. Lt. Kristen Rogers sends an email requesting an update on the following morning about the charges issued agai nst Mr. Ramos Gomez and any special bond conditions. After one officer indicates that he is unable to follow up until Friday, November 23, Lt. Rogers assigns follow up to Det. Adam Baylis, who can respond the following morning. 4:02 p.m. A “Shift Summary” is sent to a ll sworn GRPD personnel. It contains information about the arrest of Mr. Ramo me and date of birth. The s-Gomez, and includes his na shift summary also states that “The Grand Rapids Police Department’s Detective Unit has taken custody of the suspect and is currently investigating the incident.” 5:00-6:00 p.m. According to the Internal Affairs report, Captain Vanderkooi stated that he saw reports regarding Mr. Ramos-Gomez’s arre st during either the 5:00 pm or 6:00 evening news. Either way, at 6:02 pm, Wood TV 8 airs an interview of Sergeant Dan Adams detailing the arrest, and names Mr. Ramos Gomez. See pect-arrested-after-hospital-incident- https://www.woodtv.com/news/grand-rapids/sus 9 

3 in-gr/1611179571 . The story includes his booking photo, in which Mr. Ramos Gomez is recognizably Latino, and uses his last name, which is Latino as well. 7:40 p.m. Captain VanderKooi, who is off-duty a nd watching the news at home, sends an email to Derek Klifman, an ICE officer who works for a unit of ICE responsible for convictions. Captai n VanderKooi’s email deportations of immigrants with criminal The description of the arrest from the asks: “Could you please check his status?” “Shift Summary” is pasted into the message. Although the shift summary states that the GRPD Detective Unit “is currently investigating the incident,” Captain VanderKooi claims that he did not consult anyone at GRPD regarding the status of the investigation before contacting ICE. According to the GRPD investigative report, Captain VanderKooi be lieved that Mr. Ramos-Gomez’s actions were potentially related to terrorism. The report states that Captain VanderKooi’s actions were motivated out of a concern that furthe r investigation would not take place until Monday, November 26, 2018—at which point Mr. Ramos-Gomez might have already bonded out of jail. November 22, 2018 (Thanksgiving): 1:08 am. Karen Johnson, whose email address i ndicates that she works for Kent County, sent the November 21, 2018 arrest log via email to ICE, the Department of Justice, and a “JBowman” (Joel Bowman of GRPD) from the City of Grand Rapids. The arrest log sent to ICE shows that the Grand Rapids Police Department is the arresting agency. It also shows that Mr. Ramos-Gomez’s country of birth as “USA”. 9:46-9:49 a.m. Det. Baylis, the assigned Detective presenting the matter to the Prosecutor for potential criminal charges, emails Lt. Rogers to update her about the charges authorized against Mr. Ramos-Gomez and th e bond issued by Judge Distel. Det. Baylis calls Mathew Brinkman from Spectrum Health to update him on the of the cost of repairs. Det. Baylis also status of the case and request an estimate sends a follow-up email to Mathew Brinkman reiterating his request for an estimate of the cost of repairs That morning Det. Baylis writes a report about his fo llow-up activities, including attaching video footage from the helip ad at Spectrum to the case file. November 23, 2018 (Friday): 6:27 a.m. ICE Officer Klifman forwards Captain VanderKooi’s message without further comment to Matthew Lopez, a Deportation Officer with ICE’s Enforcement and Removal Operations Division, which is re sponsible for deporting foreign nationals. 9:54 a.m. ICE Officer Lopez emails Captain VanderKooi about Mr. Ra mos-Gomez: “I was able to interview that subject at Kent County this morning, and he is a foreign national illegally in the U.S. Thank you for the lead he will be coming into our custody when he is released from his criminal case. Let me or Derek know if you ever have any other good leads.” 10 

4 • that message to other GRPD officers Captain VanderKooi subsequently forwards upon returning to work on Monday. November 26, 2018 (Monday): 9:27 a.m. Jana Forner, Grand Rapids Police De partment, emails Det. Bayliss and informs ioned he had been in contact with ICE Bayliss that “Capt. VanderKooi also ment about this guy. He was going to forwar d you his email conversation with them.” 9:32 a.m. Detective Bayliss responds to Officer Forner regarding a search of the interrogation video of Mr. Ramos-Gomez by Sergeant Griffin. Detective Bayliss was interested to see any statements Mr. Ramos-Gomez made to show his intent on November 21, 2018. 9:36 a.m. Upon returning to work, Captain Va nderKooi forwards his email correspondence with ICE to Det. Baylis. 9:49 a.m. Captain VanderKooi emails ICE officer Matthew Lopez, copying ICE Officer Klifman and GRPD assigned investigator Det. Baylis. The subject line of the email is: “Spectrum Helicopter Pad Loco.” “Loco” is a Spanish language term meaning “crazy.” • The email states: “It is not clear what ma d intent was involved in this breach of hospital security but here is the report.” A copy of the police report (which noted that Mr. Ramos-Gomez’s pa ssport was found on him when he was arrested) is attached. 1:27 p.m. — 3:40 p.m. Spectrum Security re ports that the value of the damaged keypad is cessary if Mr. Ramo $120.65, “So not even $200” (which is ne s-Gomez is to be charged with misdemeanor destruction of property over $200, one of the charges previously authorized by prosecutor Daniel Helmer). Prosecutor Helmer responds: “Well, can we say labor to insta ll and time spent to wipe off the soot?” Detective Bayliss responds “word.” 3:43 — 3:59 p.m. Det. Baylis forwards the message from ICE to Prosecutor Helmer, noting “Also looks like ICE will be taking cu stody upon release for a period of time...” • Prosecutor Helmer immediately responds: “I am confused. Didn’t his property have a US Passport in it? And he was a veteran?!” • Det. Baylis responds: “Who knows, not sure it was a US passport... I am not sure about the vet thing.” December 14, 2018 (Friday): ICE takes Mr. Ramos-Gomez into custody when he is due to be released from the Kent County Jail, and transports him to immigration detention in the Calhoun County Jail. 11 

5 December 17, 2018 (Monday): Mr. Ramos-Gomez is released from Calh oun County Jail after intervention by his family’s attorney. January 18, 2018 (Friday) s personal items from the possession of the Mar. Ramos-Gomez’ attorneys obtain hi GRPD evidence locker, which contains numerous forms of identification establishing Mr. Ramos-Gomez is a United States citizen and Marine veteran.  12 

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