Citizen Report No. 1743009077 - 684954429

Below is a formal summary of the allegations concerning the Brady offenses and/or violations as detailed in the attached document:

Overview and Parties Involved
The complaint, filed in the United States District Court for the District of Colorado, is brought by plaintiffs Delbert Sgaggio and Zain Aguilera–Valdez. The defendants include several district attorney’s office employees and police supervisors—namely, Keeley Deback, Michael Allen, Brien Cecil, Wayne Lambert, Keith Wrede, Adrian Vasquez, Commander Douglas Trainer, and Timothy Stankey—who are alleged to have acted under color of law. The suit asserts that these officials conspired in a manner that led to a suppression of exculpatory evidence, thereby infringing on the constitutional rights of the defendant, Mr. Valdez.

Allegations of Evidence Suppression and Fabrication
A core allegation is that key exculpatory evidence—which included video and audio recordings showing events that could have established Mr. Valdez’s innocence—was deliberately suppressed. Specific accusations include:

• Falsification of Official Records: Defendants, particularly Wayne Lambert and John Granillo, are accused of fabricating and falsifying documents and affidavits (including both search and arrest warrant affidavits) that deviated from the factual record captured on video. These actions allegedly misrepresented the events that transpired during the incident, including the assault on witness Preslee Rodriguez.
• Conspiracy to Suppress Exculpatory Testimony: It is claimed that a coordinated effort among district attorney office supervisors and police investigators intentionally prevented Preslee Rodriguez from providing her testimony to investigators. Her account, which is asserted to be exculpatory regarding Mr. Valdez’s actions, was suppressed, and her requests to speak with investigators were denied. This suppression is argued to have directly contributed to forcing Mr. Valdez into a plea deal that resulted in a probationary sentence, significant restitution, and a lasting felony record. citeturn0file0

Retaliation and Free Speech Violations
The document further alleges that internal complaints—including those made by Delbert Sgaggio regarding the mishandling of the case—were met with retaliatory actions. Specifically:

• Retaliatory Conduct: Mr. Sgaggio’s internal affairs complaints and his protected speech (communications detailing the misconduct) are said to have been met with retaliatory suppression. Defendants are accused of fabricating narratives to silence these complaints, thereby infringing upon his First Amendment rights.
• Denial of Investigator Access: Multiple requests by Preslee Rodriguez to speak with district attorney investigators were systematically denied. This denial is presented not only as an obstruction to justice but also as a targeted effort to stifle dissent and protect those involved in the alleged misconduct. citeturn0file0

Constitutional Claims and Requested Relief
Based on these allegations, the plaintiffs have raised several constitutional claims under 42 U.S.C. § 1983, including:

• First Amendment Retaliation: Claiming that the suppression of protected speech constituted retaliation against Mr. Sgaggio’s constitutionally safeguarded right to free expression.
• Due Process Violations (Brady Violations): Asserting that the suppression of exculpatory evidence violated Mr. Valdez’s due process rights, in contravention of Brady v. Maryland, by preventing the disclosure of evidence favorable to his defense.
• Equal Protection Claims: Arguing that Mr. Valdez was treated differently compared to others similarly situated, which has led to severe and disproportionate harm.

The plaintiffs seek compensatory and punitive damages, declaratory and injunctive relief—including an order to permanently list the defendants on the Brady list—and relief to reverse the detrimental criminal record resulting from the plea deal, along with vacating related judgments and restitution obligations. citeturn0file0

Conclusion
In summary, the allegations assert that a concerted effort by the defendants—through the fabrication and suppression of key exculpatory evidence and retaliatory actions against protected speech—resulted in a miscarriage of justice. This, it is argued, culminated in severe personal and legal harm to Mr. Valdez, in direct violation of his constitutional rights.