EXHIBIT B

In 2015, Attorney Ellis Jacobs, with Advocates for Basic Legal Equality, Inc. (“ABLE”), contacted the city of Oakwood to request traffic enforcement data. A similar series of requests was made in 2016 and 2017, and Mr. Jacobs was provided data for all years 2015-2017. In September 2019, Mr. Jacobs contacted the city of Oakwood again, requesting a meeting to review a report that he prepared with the assistance of Dr. Martha Hurley, Ph.D., University of Dayton Professor and Director of Criminal Justice Studies.

On October 1, 2019, Oakwood City Law Director Rob Jacques and Director of Public Safety Alan Hill met with Mr. Jacobs and Dr. Hurley. The day before the meeting, the city was provided with a five-page summary report stating that the authors recognize that there were limits on the analysis and data, but think the findings point to a problem on how traffic stops are conducted in Oakwood. The report solely focuses on data from calendar year 2016.

We take all matters related to the delivery of our public safety services very seriously and have already completed an initial review of the report. Through this review, we identified several areas that merit further discussion. They include:

1. 1.
   There is no underlying data or information provided with the report showing how percentages were calculated for use in the analysis.
2. 2.
   The report acknowledges that there is no evidence to corroborate the figures used in the pie chart showing the race of people ticketed after a random license plate check. It asserts that the tickets were “likely to have resulted from an officer running the license plate without observing a violation.” (ABLE Report, p. 2.) The Oakwood Public Safety Department does not track stops based on whether they were initiated by observed traffic violations or random license plate checks. Stops were differentiated by ABLE based on an assumption that a stand-alone licensing offense ”likely resulted from” a license plate check. This assumption may be true in some instances, but not all.
3. 3.
   The data is incomplete which was acknowledged in the report: “We did not have all of the data we would have needed to fully explore the causes and consequences of the racial divide in police stops in Oakwood.” (ABLE Report, p. 4.)
4. 4.
   As stated in the report, the authors were not able to examine or consider a number of variables, including unrecorded stops, time of day factors, individual officer practices, location of stops, and differential enforcement. (ABLE Report, pp. 4-5.)
5. 5.
   The use of Kettering as a benchmark for comparison is not explained, other than Far Hills Avenue and Shroyer Road continue into Kettering. During the October 1, 2019 meeting with the authors, they acknowledged that they did not consider:

   1. a.
      Differences in how the two departments conduct traffic enforcement;
   2. b.
      Differences in traffic patterns on each jurisdiction’s portion of these streets; and