Confidential — Not for Public Distribution|UC Compliance Use Only · § 8547.10 · Policy 1100171
Bruin Watch
Petition for Independent Audit
and Records Reconciliation
California Whistleblower Protection Act (§§ 8547.2(c), 8547.5, 8547.10, 8547.11)
UC Internal Audit Charter, and Regents Policy 7503
Chapter 08of 11

Institutional Accountability
Questions 26 through 33

Compliance Officer Alexander Bustamante, Chief Ross, Lt. Echols, FLSA

This document was prepared with reasonable care to ensure accuracy of all citations, hyperlinks, and factual references as of its date of submission. Given the complexity of the record — spanning 37 years, multiple UC administrative systems, and over 30 exhibits — unintentional errors in citation format, hyperlink availability, or cross-reference numbering may exist. Any such errors are ministerial in nature and do not affect the substance of the questions presented or the underlying documentary evidence. The author welcomes correction of any inaccuracy identified by the Plan Administrator.

Chapter 08 Table of Contents

Q26.Question 26
Q27.Question 27
Q28.Question 28
Q29.Question 29
Q30.Question 30
Q31.Question 31
Q32.Question 32
Q33.Question 33

Section D: Institutional Accountability (Q26–Q33)

Question 26
Bustamante Unanswered Audit Request — November 9, 2021

Documents: On November 9, 2021, attorney Edgar A. Saenz, Esq. submitted a formal “Request for Audit of Charles A. Harold, Jr. files” addressed to Alexander Bustamante, Senior Vice President and Chief Compliance & Audit Officer, University of California. The letter was sent by certified mail and email to [email protected]. Gmail delivery was confirmed November 9, 2021 at 3:10 PM. The letter specifically requested: (1) an audit of Harold’s workers’ compensation and disability income case to determine his status; (2) an audit to determine what Personally Identifiable Information belonging to Harold was breached during UC data breaches; (3) an audit of Harold’s internal UC records to determine what records were lost during internal computer system upgrades; and (4) reversal of UC’s 2015 reclassification of Harold’s disability income to service retirement. As of April 14, 2026, that request has remained unanswered for over four years and five months.

(a) Please explain why UC’s Chief Compliance & Audit Officer did not respond to a formal audit request from an attorney of record regarding a documented whistleblower’s disability and benefits records.

(b) Has the Plan Administrator consulted with Mr. Bustamante’s office in connection with the current review? If so, what records did that office provide? If not, how does the Plan Administrator intend to make a determination without doing so?

Source Files: EX 34 2021-11-09 Ltr to Bustamante UC 2021.11.09.pdf [Forthcoming]
Question 27
Williams-Cook Full Timeline

Documents: The complete documented timeline of Williams-Cook’s 28-day assignment:

January 2026 (during the month): UC internally stopped deducting the $727.48 monthly premium from Harold’s pension. Unify Financial Credit Union records confirm the February 1, 2026 deposit increased by exactly $727.48.

January 29, 2026: Harold filed “Immediate Hold Request on Retiree Medical Coverage Changes” with RASC, notifying RASC of his upcoming February 25, 2026 cancer surgery.

January 30, 2026: Williams-Cook was assigned to Harold’s case.

February 11, 2026: Williams-Cook called Harold. Harold informed her of the evidence supporting his position. She said she would call back after his surgery. She never called back.

February 25, 2026: Harold’s radical prostatectomy. RASC had formal notice of this surgery date.

February 27, 2026: Williams-Cook DATED her denial letter — two days after Harold’s cancer surgery, while he was in active post-surgical recovery. She used the superseded UBEN 100 form (R10/21). She left the last digit off her phone number (800-888-826 instead of 800-888-8267). She never requested any of Harold’s supporting documents. She never addressed any of Harold’s six prior RASC filings.

March 29, 2026: Harold RECEIVED the letter via U.S. mail — 30 days after the date on the letter — per envelope postmark.

(a) What is the total number of communications Williams-Cook initiated with Harold during her 28-day assignment?

(b) Was Williams-Cook aware of Harold’s February 25, 2026 surgery when she dated the determination February 27, 2026?

(c) Explain the 30-day gap between the date on the determination (February 27, 2026) and the date Harold received it (March 29, 2026, per envelope postmark).

(d) Has the incomplete phone number (800-888-826) been corrected?

(e) What specific records did Williams-Cook review? List each document by name.

(f) UC executed the coverage cancellation in January 2026 — BEFORE Williams-Cook was assigned on January 30, 2026. How was her review genuine when the outcome had already been implemented?

Source Files: Williams-Cook Determination with postmarked envelope (Harold’s possession)  |  EX 35 2026-01-29 Immediate Hold Request on Retiree Medical Coverage Changes.pdf [Forthcoming]
Question 28
Workers’ Compensation Settlement, March 2003

Documents: Workers’ Compensation Claim No. 199650445, Date of Injury February 16, 1996. Settled March 2003. Settlement terms include lifetime health coverage and a CCW permit. Octagon Risk Services permanent disability determination dated August 8, 2001 has never been revoked. California Labor Code § 5803 provides that the WCAB retains continuing jurisdiction over settlements. No WCAB modification order revoking or modifying the settlement health coverage provisions is on record.

(a) Has the Plan Administrator reviewed the 2003 settlement terms? If so, reconcile the Via Benefits transfer with the lifetime health coverage provisions of the settlement.

(b) If the settlement file has not been reviewed, how does the Plan Administrator intend to make a determination without reviewing it?

(c) Identify any WCAB order modifying or terminating the settlement health coverage provisions. If none exists, state that for the record.

Source Files: EX 36 2001-08-08 UCLA Octagon letter.pdf [Forthcoming]  |  Workers’ compensation settlement file (UC custodial records)
Question 29
Karl Ross — Destroyed File

Documents: Former Acting Chief Karl T. Ross told Harold’s attorney that Harold’s personnel file was old and had been destroyed. Karl T. Ross was a named defendant in Harold’s civil rights case, SC022125 (Santa Monica Superior Court, filed January 29, 1993).

(a) If the personnel file was destroyed as represented by a named defendant in Harold’s own civil rights lawsuit, what “file” did Captain Chobanian review in August 2023 (Q4) and February 2026 (Q5)?

(b) If the file was reconstructed after the original was destroyed, when was it created, by whom, and from what source documents?

Question 30
UCLA PRR #26-6921

Document: UCLA Information Practices acknowledged Harold’s public records request on April 1, 2026 (Ayse Donmez, CC: Finex Ngai). On April 10, 2026 — the original CPRA determination deadline — Senior Public Records Analyst Rachel Pounds issued an extension letter pursuant to Cal. Gov’t Code Section 7922.535, citing the need to search for and collect requested records from field facilities separate from the processing office. UCLA extended its response deadline to April 24, 2026. IPA personal records deadline: April 30, 2026. POBR Government Code § 3306.5 runs parallel to and independent of the CPRA/IPA framework.

(a) Has the Plan Administrator coordinated with UCLA Information Practices regarding the records responsive to PRR #26-6921?

(b) Will the 90-day review incorporate records produced in response to PRR #26-6921?

Source Files: EX 38 Letter Stating Need for Extension 26-6921.pdf [Forthcoming]  |  UCLA Information Practices acknowledgment, April 1, 2026 (Harold’s possession)
Question 31
Lt. Echols — 41-Minute Reversal, February 24, 2026

Documents: Three emails from Lt. James Echols on February 24, 2026, all with Captain Chobanian and Lt. Richard Davis CC’d:

1:24 PM: “Your file has been located and is being sent to me.”

2:23 PM: Same: “Your file has been located and is being sent to me.”

3:04 PM (41 minutes later): “I am currently searching for your file. Because of the period of passed time since your retirement, your file has been archived.”

(a) What occurred between 2:23 PM and 3:04 PM on February 24, 2026, that caused a located file to become a file being searched for?

(b) Captain Chobanian was CC’d on all three emails and had previously confirmed reviewing this same file (Q4, Q5). Please identify the current location and status of Harold’s personnel file.

Source Files: EX 39 2026-02-24 Lt Echols TWO EMAILS.pdf [Forthcoming] (three emails, Harold’s possession)  |  Filed with POST complaints PUBLIC-26-000212, PUBLIC-26-000213, PUBLIC-26-000214
Question 32
Lt. Echols, April 1, 2026 — Wrong Box

Document: Email from Lt. James Echols, April 1, 2026. Echols stated: “I did receive a box that should have had your files in it, but it was not the correct box... locating your files, if they still exist, is a bit challenging.”

(a) How does the Plan Administrator intend to make a determination regarding Harold’s classification when UCLA PD cannot confirm whether the personnel file still exists?

(b) What records did Williams-Cook review (Q27(e)) if UCLA PD cannot locate the file?

Source File: EX 40 2026-04-01 ECHOLS I WAS SENT THE WRONG BOX.pdf [Forthcoming] (Harold’s possession)
Question 33
Federal FLSA Case and State Civil Rights Case

Federal: Case No. 2:96-cv-00396-WDK-AJW, U.S. District Court, Central District of California. University Police Officers, et al. v. Regents of the University of California, et al. Filed January 19, 1996. Judge William D. Keller presiding; Magistrate Andrew J. Wistrich. Harold as named plaintiff. Defendants: Clarence R. Chapman; Regents of the University of California; UCLA Police Department. This case resulted in over $1 million in FLSA back pay to UC police officers systemwide.

State: Case No. SC022125, Santa Monica Superior Court. Harold v. Regents of the University of California. Filed January 29, 1993. Named defendant Karl T. Ross — the same individual who later represented to Harold’s attorney that the personnel file had been destroyed (Q29).

Has the Plan Administrator reviewed the court records for either case in connection with this review? These cases establish Harold’s employment history, whistleblower status, and the institutional context for the records disputes documented herein.

Source Files: EX 37 1993-01-29 Harold v UCLA court docket.pdf [Forthcoming]  |  PACER docket for 2:96-cv-00396-WDK-AJW (publicly available)

Chapter Exhibits

The following exhibits are referenced in this chapter.

Ex.Document DescriptionDate
EX 34Letter to UC Senior Vice President and General Counsel Alexander Bustamante (Attorney Edgar Saenz)November 9, 2021
EX 35Immediate Hold Request on Retiree Medical Coverage ChangesJanuary 29, 2026
EX 36UCLA Octagon letter — Permanent & Stationary DeterminationAugust 8, 2001
EX 37Harold v. UCLA court docketJanuary 29, 1993
EX 38Letter Stating Need for Extension (26-6921)2026
EX 39Lt. Echols — Two EmailsFebruary 24, 2026
EX 40Gmail from Echols — “I was sent the wrong box”April 1, 2026

Documents referenced herein that were created by UC, issued by UC, filed by UC, retained by UC, or filed with the IRS under penalty of perjury, or generated by UC’s own contracted insurer, are UC’s own institutional record. Documents created by the undersigned were created in direct response to UC’s own records and communications. Where UC’s own institutional records are not produced to clarify this audit, the author will rely on California Evidence Code § 413, under which the failure to produce evidence within a party’s control permits the inference that such evidence would be adverse to the party withholding it.

Submitted for Regulatory Review and Public Accountability

Charles A. Harold Jr. Signature

Charles A. Harold Jr.
UCLA Police Department (Retired?), Badge #341
Founder and First President, Federated University Police Officers’ Association (FUPOA)

I affirm that the information contained in this document and its exhibits is true and accurate to the best of my knowledge and good faith belief, submitted under the protections of 31 U.S.C. § 3730(h) (False Claims Act anti-retaliation) and California Labor Code § 1102.5.