1 2 3 4 5 6 7 Gerald Singleton (SBN 208783) Brody A. McBride (SBN 270852) Trenton G. Lamere (SBN 272760) SINGLETON LAW FIRM, APC 450 A Street, 5th Floor San Diego, CA 92101 P: (619) 771-3473 F: (619) 255-1515 Brody@SLFfirm.com Trenton@SLFfirm.com Attorneys for Claimant 8 COUNTY OF SAN DIEGO 9 10 11 12 13 14 15 16 17 18 19 20 CLAIM FOR DAMAGES PURSUANT TO CALIFORNIA GOVERNMENT CODE SECTION 910 AND ALL OTHER CASE AND STATUTORY LAW THAT MAY APPLY ROSLYN CASSIDY, ) ) Claimant, ) ) v. ) ) COUNTY OF SAN DIEGO, SAN DIEGO ) SHERIFF’S DEPARTMENT, ) UNKNOWN SAN DIEGO SHERIFF’S ) DEPARTMENT DEPUTIES, ) ) Respondents. ) ) ) ) ) ) ) ) ) 21 /// 22 /// 23 /// 24 25 26 27 28 CLAIM FOR DAMAGES 1 1 This claim for damages is filed pursuant to California Government Code section 2 910. The purpose of this claim is to provide notice to the County of San Diego, and certain 3 of its law-enforcement personnel that, unless this claim is accepted and appropriate 4 compensation paid therefor, Claimant intends to file suit for the violation of Claimant’s 5 rights under the United States Constitution and for recovery under various federal and 6 California state laws. 7 1. Names of Claimant: Roslyn Cassidy. 8 2. Address/Where Notices to Be Sent: Singleton Law Firm, APC; 450 A 9 10 Street, 5th Floor, San Diego, CA 92101; c/o Brody A. McBride and Trenton G. Lamere. 3. Description of Occurrence from Which Claim Arises: On or about May 11 31, 2020, Claimant was physically injured by a currently unknown San Diego Sheriff’s 12 Department (“Department”) law-enforcement officer(s). While peacefully demonstrating 13 in San Diego, Claimant was standing in a public place. Without explanation, the 14 demonstration was declared an unlawful gathering, and Claimant began to leave the area. 15 Without warning, and without a reasonably sufficient time to comply with the dispersal 16 order, an unknown Department officer(s) pursued Claimant and fired on Claimant with a 17 weapon. A “less lethal” ammunition round, likely a rubber bullet, struck Claimant’s torso, 18 causing serious physical injury. 19 Based on the foregoing, unless this claim is accepted and appropriate compensation 20 is paid therefor, Claimant intends to assert the following causes of action against the 21 County of San Diego and the individuals named herein: 22 a. Violation of Claimant’s rights under the United States Constitution (pursuant 23 to 42 U.S.C. § 1983 and Monell v. Department of Social Services of the City 24 of New York, 436 U.S. 658 (1978)); 25 b. Negligence; 26 c. Negligent supervision and training; 27 d. Claim under California’s Bane Act (pursuant to California Civil Code § 28 52.1); CLAIM FOR DAMAGES 2 1 e. Battery; and 2 f. Intentional infliction of emotional distress. 3 4. Description of Injuries: Physical and emotional injuries, along with 4 medical and legal expenses, fees, and costs. Claimant thus seeks economic and non- 5 economic damages to compensate for these injuries. 6 5. Identity of Public Employees Involved: To date, Claimant is unaware of 7 the specific Department personnel that were involved in the incident giving rise to this 8 claim, as this information is in the possession, custody, and control of the Department. 9 10 11 6. Estimate of Claim: Claimant has sustained damages in an amount within the jurisdiction of the California Superior Court, and in excess of its limited jurisdiction. 7. Deficiency in Claim: If this claim fails to comply in any respect with any 12 requirements of California Government Code sections 910 or 910.2, you are required to 13 provide written notice of the insufficiency pursuant to section 910.8 of the same code. 14 15 Respectfully submitted, 16 SINGLETON LAW FIRM, APC 17 18 Dated: July 15, 2020 By: ________________________ 19 Brody A. McBride 20 Trenton G. Lamere Attorneys for Claimant 21 22 23 24 25 26 27 28 CLAIM FOR DAMAGES 3