Officer Detail: Matthew R. Dunn

"....That “a former CCPD police officer revealed to the press that the CCPD was requiring officers to make two (2) to three (3) traffic stops per day and one (1) arrest per day” (SAC at para. 29) (emphasis added);

That “CCPD, with the insistence and oversight of Defendants Kelly and Dupuis, promulgated its [arrest quota] policy in a document titled ‘Chesterfield County Employee Development Program,’ which stated that officers ‘must maintain the shift average of traffic stops and that the shift ‘average was between two and three traffic stops’ per day, and, further, officers shall ‘maintain the expectation of one arrest per day’” (SAC at para. 31) (emphasis added);

That “the CCPD, through Defendant Kelly, confirmed at the time that they had no intention of terminating thhe use of Arrest Quotas. Instead, the CCPD continued to enforce the Arrest Quotas for their officers until long after Mr. Howell’s wrongful arrest....”