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Officers regardless of their tactical mistakes. box was out from cover near the malibu s driver s side. eric o donnell and rinkus were exposed on the passenger side or the safety of the positions these other officers took. even officers who were behind cover and thus mostly protected from any shots coming out of the suspects car were justified, according to kitsaris in firing as many shots as they did. moreover in kitsaris brelo reasonably perceived a threat justifying about 34 shots at the suspects. so where did brelo run afoul of the constitution? as kitsaris put it because at the point of going on the trunk of his own car, 238 and then on the malibu s hood he is taking action that is not trained, not ....