Spring & Spring, LLC

Attorneys at Law Litigators Not Negotiators

Stanley A. Spring, Esq. - Florida Bar S. Stephen Spring, II, Esq. - Louisiana Bar 733 East Airport Avenue, Suite 104 Baton Rouge, Louisiana 70806 Telephone: 225-932-9671 Facsimile: 413-451-8923 Email: springlaw@gmail.com Web: www.springlaw.net

Spring & Spring LLC Communications House Mayfair London W1U 6PZ
Spring & Spring LLC Communications House Mayfair London W1U 6PZ

John S. Penton, Jr., Esq. - Florida Bar * David Mahdavi, Esq. - Virginia. Bar * Julie S. Page, Esq. - California Bar * * Of Counsel Member Wash. D.C.: 202-465-4696 Miami, FL: 305-677-3847 London: 44-208-181-6545 U.K. Fax: 44-208-181-6545

27 June 2012 (Transmitted Via email: kpgibson@crowleypolice.com) Honorable K.P. Gibson Chief of Police Crowley Police Department P.O. Gox 436 Crowley, Louisiana 70527 337.783.4114 (voice) kpgibson@crowleypolice.com (email) Re: Mitchell & Theresa Richard Death of their daughter/grand daughter from fire\ June 6, 2012

Dear Chief: We are pleased to represent the Mitchell & Theresa Richard family in all matters regarding their family, including things and events which have arisen from the loss of their daughter and grand daughter from a fire on or about June 6, 2012. It is our understanding that Mrs. Richard filed an Internal Affairs complaint with you regarding treatment received from members of your department. As a result, I would ask that from this date forward any and all communications through our offices and myself directly. My direct numbers are either 202.596.2354 or 225.892.2202. 1

In the interim, I would ask that as the Chief of the Police Department, and ultimate repository of authority for the department, that the following be preserved from the date of incident of the fire (i.e. June 6, 2012): As attorney for the Richard family, I must insist that any and all cooperation be coordinated through my office. Therefore, please be advised that no law enforcement is to make any inquiries from anyone in the Richard family without my presence. As the chief law enforcement officer and ultimate decision maker for the Police Department, I would respectfully ask that you instruct any and all officers, support personnel, task force members, or other agency law enforcement employees who participated in the investigation of the fire and/or subsequent arrest or attempted arrest of Mrs. Richard to preserve any and all rough notes, radio logs, 911 tape recordings which are evidence in this case. I believe this request to be reasonable since the Richards are entitled to have this evidence preserved. I would direct you to the following legal authority for this request. [ c.f.] Brady v. Maryland, 373 U.S. 83 (1963);United States v. Harrison, 524 F.2d 421 (D.C. Cir. 1975) United States v. Maynard, 476 F.2d 1170, 1176-78 (D.C. Cir. 1973); and United States v. Bundy, 472 F.2d 1266, 1267 (D.C. Cir. 1972). In the case of United States v. Terrell, 474 F.2d 872, 877 (2nd Cir. 1973)United States v. DeLeon, 498 F.2d 1327 (7th Cir. 1974).United States v. Harrison, 524 F.2d 421 (D.C. Cir. 1975), holding: the decision whether rough interview notes taken by agent in interviewing eyewitnesses are discoverable is for the Court and not the agent to make. See, also, United States v. Benzilar, 459 F. Supp. 614, 616-17 (D.D.C. 1978); United States v. Pollock, 417 F. Supp. 1332 (D. Mass. 1976). In the event that my request to preserve any and all evidence including rough notes, radio traffic logs, tape recordings of radio traffic and communications, and any 911 calls is problematic, please let me know. In the event that you see no problem with this request, it is not necessary to respond. Should you have any questions about this or any other matter, please do not hesitate to call. As per your request, we will negotiate the check tomorrow. Sincerely yours, Spring & Spring, LLC Attorneys at Law

S. Stephen Spring, II Attorney at Law Attorney for the Richard Family SSS:tbh