09/23/2008 18:52

8037777319

GEOFFREY ALPERT

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Geoffrey P. Alpert
1905 Salem Church Rd. Irmo, South Carolina 29083
Telephone: (803) 732·1336 • Fax: (803) 777-7319

September 23, 2008
RB: Fortner v City of Memphis
I am a Professor of Crimjnal Criminology and Criminal Justice at the University of South
Carolina, and I have been ratained by Ms. Delois Fortner to provide my expert opinions
in this case. I have a Ph.D. in sociology from Washington State Univemty, and have
conducted research on police policies and customs for the past twenty yean. I have
published extensively in the area . of criminal justice, including scholarly articles
concerning internal affairs, early warning systems and use of force. I have worked with
nmnerous police agencies to develop policies, conduct training, and provide them with
other consulting services. I am familiar with police operating procedures as well as the
developed by practice. I base the statements contained herein on my education,
research, work experience, knowledge of police policies and customs, as wen as my
review of the documents and material provided to me for review set forth in·Exlubit G. I
have previously been accepted as an expert in an excessive force case by the appellate
courts in the Sixth Circuit in the published case of Champion v, Outlook Nasyhjlle, Inc.
380 F.3d 893 (6th Cir. 2004). A copy of my CV setting forth my qualifications and
documents is attached as Bxlu'bit A. A list of the cases that I have testified at trial or by
deposition is attached hereto as Exhibit B. A copy of my fee schedule is attached as
ExhibitC.

customs

I have previously been retained as an expert witness in civil rights cases against the City
of Memphis and reviewed extensi\le materials conccming the policies, practices and
customs of the MPD and have previously formulated opinions. In particular, I was
retained by the Plaintiff in the following cases to express opinions and prepare an expert
report: 1) Boyd v. City of Memphis, et al, No. 94-3077 HA; 2) Buckley y. Memphis, et
al.. No. 03-2875; and 3) Hampton y, Memphis. et al, No. 04-2537. I also provided
consulting expert services in Palazola v. Memphis, et al. but did not prepare an expert
n,port prior to the settlement of the case. I have also prepared an expert report in Blmg
y, Memphis, 07-CV-02388 on September 16, 2008, which I attach hereto as Exhl'bit D.
The information review in these cases and contained in these reports is also part of the
basis for my opinions and conclusions. In formulating my opinions, I have reviewed the
information identified in Exhibit E.

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