D

Zachary Goble

Former officer, previously supervised by Sgt. Koh — Deposition 4 of 7, Byer v. City of La Palma.

Deposition 4 of 7

Zachary Goble

Former City employee · Ex-La Palma Police Officer, previously supervised by Sgt. Koh alongside Byer

Transcript excerpts reviewed
Deposed: June 30, 2025
Called by: Plaintiff (Petronelli)
Pages reviewed: 6–7, 14–17, 19–23, 25–26, 35 (of ~40)

Who he is

Goble worked as a patrol officer for the La Palma Police Department from summer 2021 until early January 2023, when his employment ended. He is no longer with La Palma and now works as a police officer for another department, with about five years total in law enforcement. For roughly four months in later 2022, Goble and Byer worked the same shift, both supervised by Sergeant Koh.

Connection to the case

Goble is an independent witness who worked directly under Sergeant Koh at the same time as Byer, giving him firsthand knowledge of Koh's supervisory style toward officers he perceived as pushing back on him. Goble testified that he "wouldn't have chosen Koh as my supervisor" because Koh was, in his word, "retaliatory" — that if an officer disagreed with him or didn't share his approach to police work, Koh "would go out of his way to make sure you were staying busy throughout the night." Goble described personally experiencing this: after Koh spotted him (via patrol-car GPS) parked and talking with another officer near the end of a shift, Koh told them, visibly upset, "I'm going to go out and find something for you guys."

Key testimony

Goble testified he raised this concern directly with command staff in a meeting with then-Captain Wilkerson, at which then-Captain Amend also appeared — asking, in substance, whether he was "doing something wrong for this sergeant to go out of his way and do those things." He testified their response was that he "needed to learn to work with other types of personalities." Goble also read into the record a contemporaneous phone note from April 12, 2022, describing Koh following him outside to confront him after learning — from someone other than Amend — about his "bitching and complaining"; Koh told him to bring future problems directly to Koh rather than Amend, adding that "his behavior wouldn't change" even if the problem went unresolved. Goble said Koh appeared "definitely upset" during that confrontation and that he believes, though isn't certain, that he raised it with HR afterward. Asked directly for his opinion of Byer's job performance, Goble testified — over an objection on foundation grounds that was ultimately allowed — that Byer was "effectively performing his job" as an officer. Separately, Goble testified his own employment was terminated about two weeks after he filed an unrelated HR complaint against a different sergeant (not Koh), under then-Chief Terry Kim; he believes his performance evaluation contained factual inaccuracies connected to that termination, but was careful to distinguish this personal grievance as unrelated to the Koh matter.

Possible relevance to the verdict

Independent, pre-dating corroboration of the command-staff pattern: Goble's account places both Wilkerson and Amend on notice of Koh's retaliatory work-assignment style roughly nine months before Byer's own January 2023 complaint to Amend — and shows them responding to that earlier warning with the same "learn to work with other personalities" deflection rather than any documented follow-up, investigation, or correction of Koh's conduct. That mirrors, and predates, the pattern Amend's own deposition already shows: complaints about Koh reaching command staff and going nowhere. As a witness with no apparent personal stake in Byer's specific claims (his own termination, on his own telling, was unrelated to Koh), Goble's testimony that Byer was performing his job effectively directly undercuts the "needs improvement" narrative that Koh alone authored and that command staff never independently verified. Combined, this deposition is consistent with the notice-and-failure-to-act theory the jury ultimately credited — that the City had actual, repeated notice of a supervisor's retaliatory pattern well before it affected Byer, and did not act on it.

This summary is based on selected excerpts (highlighted portions of a roughly 40-page transcript, not the complete document), including some passages affected by a mid-testimony video connection interruption. It does not reflect the full testimony, cross-examination in its entirety, or any context the excerpted portions omit. Goble's own termination and the sergeant involved in that separate complaint are distinct from the Koh/Byer matter and should not be conflated with it.