D

Jesse Amend

Captain, Koh's and Byer's chain of command — Deposition 3 of 7, Byer v. City of La Palma.

Deposition 3 of 7

Jesse Amend

City employee · Captain, La Palma Police Department (Koh's and Byer's chain of command)

Transcript excerpts reviewed
Deposed: August 12, 2025 (Vol. I)
Called by: Plaintiff (Petronelli)
Pages reviewed: 15–16, 21–25, 31–38, 43–45, 47–50, 65–70, 79–80, 87–90, 98, 101–110, 118–119, 123–126, 129–134, 143 (of 143)

Who he is

Amend was a captain in the La Palma Police Department throughout the relevant period and remains employed there. He testified the chief of police is the department's highest-ranking position and reports to the city manager, and that “overall responsibility” for ensuring officers follow department policy “lies on the chief of police.” He described a rapid turnover at the top of the department — Ron Wilkerson served as chief for about a year (mid-2023 to late summer/early fall 2024) before being succeeded by current Chief Joe Guerrero. Sergeant Koh reported up through Amend's chain of command; Amend testified he prepared roughly two of Koh's own annual performance evaluations.

Connection to the case

Amend was the first member of command staff Byer went to. Around January 2023, Byer texted Amend asking to speak “informally,” and the two met off-site at a coffee shop outside city limits rather than at the station. Byer told Amend that Sergeant Koh — who supervised both Byer and his shift partner, Officer Jay Choi, while both were still on 18-month probation — was personally making traffic stops (“sergeant specials”) and then calling Byer over to complete the resulting paperwork, and that he felt he was being treated differently than Choi. Amend testified he told Byer he would raise it with Koh, but it was “a matter of several weeks” before he actually did, and Byer raised the concern with him multiple times in the interim. Amend confirmed he never documented the initial complaint, any follow-up conversations with Byer, or the eventual conversation with Koh — on a personnel complaint form or “at all.”

Key testimony

When Amend finally raised the issue with Koh (with then-Captain Ron Wilkerson also present), he testified he told Koh that Byer “didn't seem to be receiving what Koh was doing very well” and suggested Koh “reevaluate your approach,” and separately told Koh it wasn't appropriate to have told Byer to “tell your wife your job is on the line.” But Amend testified, repeatedly and specifically, that he never told Koh to stop assigning sergeant specials to Byer, never told Koh he was prohibited from retaliating against Byer, never asked Koh how his stop counts for Byer compared to Choi, never opened any investigation into Byer's complaint, and is unaware of anyone at La Palma ever opening one. He also testified he never spoke with Choi at all about Byer's concerns, and never asked Choi whether he felt he was being treated more favorably than Byer because of his race. Separately, Amend testified that Officer Zachary Goble had raised a “similar complaint” about Koh's sergeant-special practice to command staff, and that Koh had confronted Goble in a parking lot after learning he'd complained — though Amend said he didn't recall the specific “bitching and moaning” language Goble reported to him. On Byer's performance, Amend testified that Koh alone decided and wrote Byer's “needs improvement” annual evaluation, that Amend never independently verified Koh's claim that Choi wasn't having similar performance issues, and that everything negative he knew about Byer's performance came from Koh. Walked through La Palma's own Personnel Complaints Policy and Anti-Retaliation Policy during questioning, Amend agreed, section by section, that supervisors are required to document complaints, acknowledge and route them to the chief through the chain of command, investigate them, and monitor for further retaliation — and confirmed he did none of those things after Byer's complaint. Amend also confirmed that Sergeant Koh was involved in a December 2024 pursuit that ended in a collision killing a 67-year-old woman, Maria Casey, and that Koh remains employed by La Palma as a sergeant.

Possible relevance to the verdict

Amend's testimony on the complaint-handling process: Amend is the captain Byer went to first, months before the exit interview Wilkerson later documented, and his own testimony establishes that La Palma's written anti-retaliation policy required documentation, notification up the chain, investigation, and monitoring — and that none of it happened. Amend's account of confronting Koh only about specific remarks, without ever restricting the underlying practice Byer complained about or verifying Koh's justification for it, mirrors the pattern Wilkerson's and Choi's testimony already suggests: complaints reached command staff without a formal investigation identified in the testimony reviewed. His acknowledgment that Koh alone authored Byer's negative evaluation, unchecked, adds a direct link between the alleged retaliatory conduct and a concrete employment consequence — evidence relevant to both the discrimination and retaliation claims. The Goble parking-lot confrontation, if credited, suggests a pattern beyond Byer alone.

This summary is based on selected excerpts (highlighted portions of a 143-page transcript, not the complete document). It does not reflect the full testimony, cross-examination in its entirety, or any context the excerpted portions omit. Some questions in the reviewed excerpt were limited or objected to on Pitchess grounds (personnel-record confidentiality), and Amend's answers on certain disciplinary topics were correspondingly restricted.