D

Crystal L. Wilkerson

HR Analyst — Deposition 1 of 7, Byer v. City of La Palma.

Deposition 1 of 7

Crystal L. Wilkerson

City employee · Human Resources Analyst, City of La Palma

Transcript excerpts reviewed
Deposed: March 18, 2025
Called by: Plaintiff (Petronelli)
Pages reviewed: 9–10, 27–29, 34–39, 42–44, 50–51, 69–70, 74 (of 78)

Who she is

Wilkerson is a current City of La Palma employee, working as a Human Resources Analyst at the time of her testimony and during the events described. She reported to Ryan Hallett, whose title changed from Administrative Services Director to Assistant City Manager during the relevant period while he remained in the same supervisory role over HR. She testified that complaints about retaliation or discrimination are "processed by Ryan Hallett and solely through Ryan Hallett," and that she wasn't aware of anyone else at the City who decided which complaints got investigated.

Connection to the case

Wilkerson conducted Ross Byer's exit interview on June 8, 2023, the day he resigned from the La Palma Police Department. She testified that the reasons Byer gave for resigning were the same concerns she documented in her handwritten notes from that meeting — which she later typed up and sent to Hallett, without retaining the handwritten originals. Byer subsequently sent her two follow-up emails: one on June 28, 2023 (roughly three weeks after the meeting) with additional detail on his complaints, and another on October 25, 2023. She testified she believes she forwarded the June 28 email to Hallett, but does not recall receiving or forwarding the October 25 email at all — and when she later searched her own email for correspondence with Byer, that October email did not turn up in the search.

Key testimony

During the exit interview, Byer told Wilkerson that Sergeant Koh had instructed him to engage in what Byer believed was racial profiling, and that he had previously reported this to Captain Jesse Amend. Wilkerson testified the allegations "of course" caused her concern and that she "definitely believe[d] we should look into it" — but that the decision to investigate wasn't hers to make. Asked whether she was aware of anyone — Hallett, anyone else at the City, or anyone at the police department — investigating Byer's complaints at any point after the June 8 meeting or either follow-up email, she answered "correct" each time she was asked whether she was not aware of any such investigation. She also testified she had never seen the La Palma police officers' policy manual.

Possible relevance to the verdict

Direct evidence, not just inference: This excerpt shows the City's own HR analyst confirming she received Byer's discrimination and retaliation complaints on three separate occasions over about four and a half months (June 8, June 28, and October 25, 2023), routed them to the one official she said was solely responsible for deciding whether to investigate, and is not aware that anyone ever did. Combined with her testimony that she personally believed the allegations warranted a look, this is consistent with the failure-to-prevent-discrimination and retaliation claims the jury ultimately found for Byer.

This summary is based on selected excerpts (highlighted portions of a 78-page transcript, not the complete document) spanning the exit interview, both follow-up emails, and closing questioning. It does not reflect the full testimony, cross-examination in its entirety, or any context the excerpted portions omit.