Amylou R. v. County of Riverside Appellant's Opening Brief

suspect 72 hours. (RT 1354-1355, 1405, 1411.~/ Plaintiff asked if she were free to
leave, and the detectives did not respond, but rather paused because they wanted to
continue the interview. (RT 725-26, 729, 737, 738.) Plaintiff asked if she could
leave to get a soda and cigarettes.
(RT 1230-31, 1775-1777.) They told her they
would get these items for her.
(RT 1775-1778.) Plaintiff indicated she wanted to get
the soda and cigarettes from her mother.
(RT 1778.) She then stated they needed a
court order to keep her and that she would tell her attorney they had illegally detained
her and threatened her. (RT 1779-1780, 2483.) She further stated she would not
cooperate with them any longer. (RT 1783, 2484.)
When the interview broke down, Lackie left to speak to his supervisor.
(RT
1786-1787.) At that point he discovered Mrs. Ryan had called an attorney, who was
waiting downstairs and demanding plaintiffs release. (Ibid.) He returned to the
conference room and told plaintiff she was not a suspect; he explained they had been
trying to clarify certain information and obtain as much information about the crime
as possible.
(RT 1788.) Plaintiff said "fuck you" several times and left the room.
(Ibid.)
4. Subsequent attempts to communicate with plaintiff.
After April 2, Moker and Lackie were told by Paul Zellerbach, the deputy
district attorney assigned to the case, to work through plaintiff's counsel, Joseph
Meyers.
(RT 1955.) Lackie testified about attempts to reach Meyers, that Meyers
never returned their calls, and that they were eventually told he would not do so.
(RT
1542, 1868.) Meyers testified that he had requested Moker and Lackie be kept away
from plaintiff and that he wanted to prevent any contact. (RT 958-959.)
~/ Lackie testified that he did not consider her a suspect, that there was a big
difference between believing plaintiff knew the murderer and her being involved in the
murder. (RT 1938-41.)
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