LW Direct

Good [morning/afternoon/evening] Dr. White, could you please introduce yourself to the court, spelling your last name?

My name is Lander White, last name spelled W-H-I-T-E. Just like the color. I'm a licensed psychologist and the Director of Alturas Center for Youth and Development or ACYD, which if you ask my co-worker, stands for Always Caring for Young Dreamers. That's where I work with students and school resource officers to create safe school environments. I am also the chair of the safe schools committee where I work with educators to work against any threats that schools face.

Attorney: Why did you dedicate your career to working with students?

: I've always believed that every student has the potential to succeed, no matter what obstacles they face. I knew early on that I wanted to be the kind of person who helps them see their own strengths, even when they can't. I mean, I remember growing up in a time where people didn't talk about mental health. At ACYD, I get to do just that, whether it's evaluating gifted students with disabilities or simply being someone who listens. Seeing a student realize, "Hey, I can do this!"—well, there's no better feeling.

Attorney: What kind of work do you do with school resource officers?

Witness: At the Nevada Justice Center, I lead yearly "Banish Bullying" training sessions for school resource officers. These sessions focus on de-escalation techniques, understanding the unique needs of students with disabilities, and strategies for preventing bullying. It's about equipping SROs to be not just authority figures but also allies for students. My annotated CV has all the details of my educational and professional accomplishments—it's not exactly light reading, but it's thorough!

Attorney: Would you recognize your CV if I showed it to you?

Witness: yes

Attorney: Your honor, let the record reflect, I am now approaching opposing counsel with what has been marked for identification purposes as exhibit 2.

Judge: It shall reflect.

Attorney: Your honor, may I approach the witness with the same?

Judge: You may.

Attorney: Dr. White, I now hand to you what has been marked as exhibit 2. Would you identify it please?

Witness: Yes this is the most recent copy of my annotated Curriculum Vitae. It includes all of my educational achievements, professional experience, and publications from 2007 to the present that I wrote.

Attorney: Is this a fair and accurate representation of your CV?

Witness: Yes

Attorney: Dr. White, could you briefly explain your resume to the jury?

Witness: Yes, as shown in my CV, I've earned multiple degrees from Harvard and the University of Virginia and have worked extensively with students and SRO's for over a decade. I've also testified in courts on six previous occasions, five on behalf of the plaintiff and once for the defense. [Show the exhibit to the jury by pointing to it and picking it up]

Attorney: Dr. White, how are you familiar with Cole Caples?

Witness: I first met Cole when his guardian, Blair Bruneau, reached out to me. Blair expressed concern about some challenges Cole was facing at school, so I was asked to evaluate him. After spending some time with him and reviewing his behaviors, I diagnosed him with Asperger's syndrome using the DSM-IV diagnostic criteria. Cole's an intelligent young person, but like many with Asperger's, he sometimes struggles with social interactions and understanding non-verbal cues. It's a privilege to work with him and see him make progress.

Attorney: What were your impressions of Cole during your sessions with him?

Witness: During our sessions, Cole was truly committed to working through the challenges he faced. I saw a young person who was trying his best and wanted to do well. There were no signs of aggression or violent tendencies—just a lot of patience and perseverance. He was always cooperative and eager to please, which made our work together very positive. And I have to say, I was consistently impressed by his intelligence. Cole is incredibly sharp, and his curiosity about the world is something I deeply admire. It's not every day you meet someone with such a thoughtful mind.

Attorney: Dr. White, directing your attention to the case at hand, why are you here in court today?

Witness: For this case, I was specifically tasked to analyze the actions of SRO Marietta on October 13th, as well as on prior occasions when complaints had been filed against the officer. To reach my conclusions, I spent 40 hours analyzing all witness affidavits, and examining Exhibits 1-4 and 8-13. APD's policies, and Marietta's past incident reports were especially useful in my analysis.

Attorney: Would you recognize those incident reports if I showed them to you?

yes

Attorney: Your honor, let the record reflect, I am now approaching opposing counsel with what has been marked for identification purposes as exhibit 8.

Judge: It shall reflect.

Attorney: Dr. White, I now hand to you what has been marked as exhibit 8. Would you identify it please?

Witness: Yes these are the incident reports filed under the Alturas Police Department regarding Officer Marrietta. I saw these incident reports in Officer Marietta's case files during her time as both a patrol and school resource officer from 2011-2021. All of the reports were read and approved by Chief Flanagan.

Attorney: Is this a fair and accurate representation of the incident reports you described?

Yes

Attorney: Dr. White, what stood out to you about these reports? (State what an expert is 703)

Witness: A pattern. Exhibit 8 reveals six complaints of excessive force in only a decade. In one case, Marietta tased two unarmed, nonthreatening, African American teenagers, not with pepper spray, but with a taser. Not just once, but in rapid succession. These reports show a repeated failure to de-escalate.

Attorney: What did you conclude about Marietta's actions on October 13th?

Witness: Just like in the past, it seemed to me Marietta escalated instead of de-escalating. Based on my analysis, Cole was compliant. He sat down and reached to hand over his backpack as instructed. But Marietta pepper-sprayed the boy before confirming any real threat. Then, rather than ensuring his safety, Cole was left alone in a conference room, crying, with pepper spray still burning in his eyes.

Attorney: What impact can an experience like this have on a student like Cole?

Witness: Trauma like this doesn't just disappear. It reshapes the way a child sees authority, school, and even themselves. Psychological research shows that students who experience school-based trauma often develop anxiety, struggle to focus, and disengage from education entirely.

Attorney: Dr. White, in your experience, do patterns of trauma stop on their own?

Witness: No, they don't. Trauma lingers. It affects a person's ability to trust, to feel safe, to move forward. Once someone experiences that kind of harm, it doesn't just go away overnight—it can shape the course of their life.

Attorney: And based on your evaluation of Cole, what effect would this incident have on him?

Witness: Well in this incident alone, Cole experienced a pattern of traumatic events. First, he was pepper-sprayed, second, he was interrogated as a minor without a lawyer or guardian present, and finally, he was forced to leave behind his home and education, returning to Saipan. Based on my expertise, children like Cole may see one traumatic incident as a mistake, but twice? They see a deliberate choice. And three times? They see a pattern. And when trauma becomes a pattern, it doesn't just affect one person. It affects entire communities. That's why this pattern has to stop here, for both Cole's sake and for the people around him.