VIII. Exhibits — Cross-Reference Index
The Bruin Watch evidentiary record is a continuously developing archive. The acts of reprisal, retaliation, records corruption, and benefit interference catalogued in Sections III and IV are themselves still occurring — in some instances on a daily basis — and the Complainant cannot maintain a real-time exhibit register concurrent with conduct that has not yet ceased. The exhibit index set forth below identifies every document presently relied upon in this Sworn Retaliation Complaint, each of which is already published and continuously hosted within the Bruin Watch documentary record. The University of California is in possession of every document referenced. The Complainant will supplement this index as additional records become reasonably available, and reserves the right to do so without prejudice to the sufficiency of the existing record or to the burden-shifting framework of Policy 1100563 § E.
The Complainant’s evidentiary record spans thirty-seven years, multiple UC administrative systems, more than one thousand individual documents, and over thirty formally designated exhibits published in the Bruin Watch series. The underlying institutional conduct catalogued in Sections III and IV remains active and continues to generate new evidentiary material on an ongoing basis; the Complainant therefore maintains and updates this index as records become reasonably available, and does not represent that the index is closed or static as of any single date. This cross-reference index was prepared with reasonable care to ensure accuracy of all citations, hyperlinks, and factual references as of the date of this submission. Given the scope and complexity of the record, unintentional errors in citation format, hyperlink availability, exhibit numbering, or cross-reference sequencing may exist. Any such errors are ministerial in nature and do not affect the substance of the allegations presented or the underlying documentary evidence on which they rest. This index does not constitute the complete evidentiary record — it constitutes the relevant records as known to the Complainant as of the date of filing. The complete evidentiary record, including all exhibits, is publicly hosted and continuously available at bruinwatch.org/dist-ucla-compliance/uc-audit-request/.
If the Locally Designated Official, the assigned Retaliation Complaint Officer, or any other University officer requires documentary proof of a specific factual assertion in this Complaint and is unable to locate the corresponding record within the Bruin Watch archive, the Complainant will produce the responsive record on written request directed to info@bruinwatch.org. Production on request is offered without prejudice to the sufficiency of the existing public record or to the burden-shifting framework of Policy 1100563 § E. The Complainant reserves the right to supplement this exhibit index upon discovery of additional relevant records, and welcomes correction of any inaccuracy identified by the Locally Designated Official or the assigned Retaliation Complaint Officer. Parallel regulatory filings are pending before state and federal agencies. Those records are not part of this submission.
| Exhibit | Date | Description | Bruin Watch Source |
|---|---|---|---|
| EX 01 | Aug 8, 2001 | UCLA Octagon letter — Permanent & Stationary disability determination, Workers' Compensation Claim No. 199650445 | chapter_04 |
| EX 02 | Aug 1, 2023 | Chobanian Active Retiree List | chapter_05 |
| EX 03 | Aug 22, 2023 | Email Harold to Chobanian — initial CCW renewal request | chapter_05 |
| EX 04 | Aug 25, 2023 | Email Chobanian to Harold — CCW denial citing "medically separated March 1, 1996" | chapter_05 |
| EX 05 | Feb 9, 2026 | Harold-to-Chobanian CCW Denial Response — POBR records request, litigation hold and preservation demand | chapter_05 |
| EX 06 | Sep 6, 2002 | UCLA PD CCW Issued — Chief Clarance Chapman | chapter_07 |
| EX 07 | Aug 29, 2013 | UCLA PD CCW Reissued — Chief James D. Herren | chapter_07 |
| EX 08 | Feb 27, 2026 | Williams-Cook Administrative Review Determination — UC RASC denial letter | chapter_09 |
| EX 09 | Apr 9, 2026 | Erin Morse RASC 90-Day Review acknowledgment | chapter_09 |
| EX 10 | Apr 12, 2026 | History of Racism and the Quest for Racial Justice at UCLA — institutional context | Master record |
| EX 11 | Feb 5, 2026 | 10-99 UC download history — contradicts UC representative statement | chapter_06 |
| EX 12 bundle | 2016–2025 | Bundle: UC IRS Form 1099-R for tax years 2016 through 2025 — ten years of UC-filed federal tax records establishing continuous disability/retirement coding | chapter_06 |
| EX 13 bundle | Aug 8, 2001 + 2015 | Bundle: Octagon Permanent & Stationary determination + UC 1099-R Forms for 2015 (two corrected forms) | chapter_06 |
| EX 14 | — | Account Number Discrepancy Table | Master record |
| EX 15 | Mar 12, 2021 | Ida Fong Email Thread — Harold to UCOP HR re: my son disability coding anomaly; UC institutional self-discovery | chapter_06 |
| EX 16 | Aug 8, 2001 | UCLA Octagon letter — re-cited reference copy | chapter_05 |
| EX 17 | Aug 1, 2023 | Chobanian Active Retiree List — re-cited reference copy | chapter_05 |
| EX 17a | Aug 21, 2023 – Feb 24, 2026 | UCLA PD Email Thread — Chobanian, Davis, Echols correspondence; seven contradictory written employment classifications | chapter_05 |
| EX 18 | Aug 22, 2023 | Email Harold to Chobanian — re-cited reference copy | chapter_05 |
| EX 19 | Aug 25, 2023 | Chobanian CCW denial — re-cited reference copy | chapter_05 |
| EX 20 | Feb 9, 2026 | Harold-to-Chobanian Response — CCW denial response; POBR records request; litigation hold and preservation demand | chapter_05 |
| EX 21 | Sep 6, 2002 | UCLA PD CCW Issued — Chief Clarance Chapman (re-cited reference copy) | chapter_07 |
| EX 22 | Aug 29, 2013 | UCLA PD CCW Issued — Chief James D. Herren (re-cited reference copy) | chapter_07 |
| EX 23 | Feb 27, 2026 | Williams-Cook Denial Letter — UC RASC Administrative Review Determination | chapter_09 |
| EX 24 | Apr 9, 2026 | Erin Morse RASC 90-Day Review acknowledgment | chapter_09 |
| EX 25 | Feb 5, 2026 | 10-99 UC download history — contradicts UC representative statement | chapter_06 |
| EX 26 | — | Account Number Discrepancy Table | chapter_06 |
| EX 27 | Feb 24, 2026 | Lt. Echols — two emails to Harold | Master record |
| EX 28 | Apr 1, 2026 | Lt. Echols Gmail — "I was sent the wrong box" statement | Master record |
| EX 29 | Jan 29, 2026 | Immediate Hold Request on Retiree Medical Coverage Changes | Master record |
| EX 30 bundle | 2016–2025 | Bundle: Stephen Agostini — Public Financial Leadership at UCLA + IRS Form 1095-B for tax years 2016 through 2025 (ten years of insurance coverage records) | chapter_07 |
| EX 31 | — | Letter Stating Need for Extension (26-6921) | Master record |
| EX 32 | Apr 2, 2026 | Anthem login screenshot | chapter_07 |
| EX 33 | — | RESERVED — number retired in renumbering; no exhibit assigned | — |
| EX 34 | Nov 9, 2021 | Letter to UC SVP Alexander Bustamante — verbal assurance re: insurance continuity, coerced conversion narrative | chapter_08 |
| EX 35 | Jan 29, 2026 | Immediate Hold Request on Retiree Medical Coverage Changes — re-cited reference copy | chapter_08 |
| EX 36 | Aug 8, 2001 | UCLA Octagon letter — re-cited reference copy | chapter_08 |
| EX 37 | Jan 29, 1993 | Harold v. UCLA court docket | chapter_08 |
| EX 38 | — | Letter Stating Need for Extension (26-6921) — re-cited reference copy | chapter_08 |
| EX 39 | Feb 24, 2026 | Lt. Echols — two emails (re-cited reference copy) | chapter_08 |
| EX 40 | Apr 1, 2026 | Lt. Echols "I was sent the wrong box" — 51 days after litigation hold | chapter_05 |
| EX 41 | Apr 9, 2026 | Erin Morse / RASC 90-Day Review email | Master record |
| EX 42 | Apr 17, 2026 | Allison Cumming / Elevance Health Anthem closure introduction email | Master record |
| EX 43 | Apr 17, 2026 | Lorena Rivera / Anthem case closure letter (Reference INQ-COMM-197295) | Master record |
| EX 44 | Apr 17, 2026 | UCLA Compliance Office CMP373 closure email — Cynthia Holmes | Master record |
| EX 45 | Apr 17, 2026 | Harold rejection of CMP373 closure — formal written rejection at 3:03 PM | Master record |
| EX 47 bundle | May 1, 2026 | Bundle: UCLA Compliance Office two-sentence email response to the § 8547.10 Petition (1:02 PM Pacific) plus Clicky visitor-detail forensic record (parent PDF, visitor-detail JPG, iCloud Private Relay JPG, visitor-summary PDF, visitor-list XML, epilogue-filter JPG, 7-day visitor-list XML) | Master record § 91 |
| EX 48 | Apr 22, 2026 | Navitus MedicareRx (PDP) disenrollment letter to my wife, reference V00200155603, form S9701_2026_ALL_DEN10A_V01_C, confirming disenrollment effective May 1, 2026 | Master record § 92 |
| EX 48a | Apr 30, 2026 | UBEN 100 (R4/26) signed by Chuck Harold cancelling UC Medicare PPO — UC High Option Supplement to Medicare effective April 30, 2026, with Comments-field rebuttal documenting the written threat from UC RASC Benefits Analyst III Beverly Jeanine Williams-Cooke (3 pages) | Master record § 92 |
| EX 48b | May 1, 2026 | medicare.gov/my/home screenshot logged in as Charles, showing Wellcare Value Script (PDP) coverage start 5/1/2026 and BLUE CROSS OF CALIFORNIA coverage start 1/1/2026 (captured 2:30 PM Pacific) | Master record § 92 |
| EX 48c | May 1, 2026 | medicare.gov/my/home screenshot logged in as Charles, captured at 2:39 PM Pacific (confirms persistence of the Wellcare and Blue Cross of California records nine minutes after EX 48b) | Master record § 92 |
| EX 49 bundle | May 1, 2026 | Bundle: Chuck Harold 4:25 PM Pacific reply email to UCLA Compliance Office in response to the May 1, 2026 1:02 PM disposition, plus Clicky visitor follow-up records (parent reply PDF + workstation visit, Tampa T-Mobile visit, dashboard captures, iCloud Private Relay visit) | Master record § 91 |
| EX 50 | Sep 7, 2005 | Andrew D. Parker, UCRP Disability Unit (UC Office of the President) — letter to Harold on UC letterhead processing his DDI “request for reinstatement” following July 8, 2005 Disney layoff; pre-authorized the voluntary affirmative-election mechanism Parker later testified to under oath in Jacobs v. Regents (B268758, 2017) | Master record § 34 |
| 1994 Filing | Jul 5, 1994 | Original Government Code § 8547.10 letter to Chancellor Young and President Peltason — signed under penalty of perjury, copied to Bureau of State Audits and Los Angeles Times | CH_15 |
| POSAD 212/213/214 | Feb 25, 2026 | Three POST Form 2-354 complaints — Capt. Chobanian, Chief Valenzuela, Lt. Echols (ret.) — acknowledged by POSAD | Act I, Behave Like Heroes |
/s/ C.A.H. — Chuck Harold · UCLA PD (Ret.), Badge #341 · April 30, 2026