STATE OF NEW YORK SUPREME COURT COUNTY OF MONROE, In the Matter of the Claim of Kali Watkins, Claimant, v. Town of Webster and Webster Police Department, Chief Joseph Rieger, Investigator Alex Kirkpattick, Investigator Gretchen O'Dea, Sgt. Jeffrey Webster, John/Jane Doe Officers #15, Respondents. NOTICE OF CLAIM TO: TOWN CLERK, TOWN OF WEBSTER, 1000 Ridge Ra. ‘Webster, New York 14580 PLEASE TAKE NOTICE that Claimant Kali Watkins (by and through his attorneys, Vahey Getz LLP), hereby notifies the Town of Webster and Webster Police Department of his claim as follows: 1. Claimant resides at 1186 Woodhull Road, Webster, New York 14580. 2, Claimant is represented by Vahey Getz, LLP Inc., 144 Exchange Blvd, Suite 400, Rochester, NY 14614, Telephone: (585) 262-5130. 3. The subject incident(s)/ action(s) occurred on or about and between December 15, 2017 until and including August 26, 2019 4, Upon information and belief, from December 15, 2017 until and including August 26, 2019, members of Webster Police Department employees, officers and others were engaged in the investigation of alleged criminal conduct by Claimant. Upon information andbelief these individuals knew or should have known the allegations levied against Claimant were false, and otherwise not accurate. 5. Upon information and belief, Town of Webster and Webster Police Department, by and through their employees, officers, agents and representatives, were negligent, careless and reckless, malicious and/or in violation of state and federal law because they: knew or should have known that the alleged crime for which Claimant was being investigated did not occur; failed in their responsibility and duties to complete an accurate and adequate investigation into the claim made by an individual student with initials M-E.; maliciously arrested Claimant; wrongly arrested Claimant; wrongly obtained information about Claimant; harassed annoyed or alarmed Claimant; improperly obtained irrelevant information about Claimant and made this information available to the public in order to embarrass, harass and alarm Claimant without cause; was part of and/or participated in the wrongful arrest of Claimant; failed to investigate and obtain readily accessible evidence that would have exonerated Claimant; intentionally obtained irrelevant documents to attempt t0 embarrass Claimant; was aware of exculpatory evidence and failed to properly investigate the evidence, which lead to Claimant's wrongful arrest, met with individuals of the Webster Central School District in order to obtain irrelevant and embarrassing materials and made these materials available to the public; tortuously interfered with Claimant’s employment, violated Claimant's federal and state protected rights; violated Claimant's state and federal Substantive Due Process rights; and the Town actors were otherwise negligent, careless and reckless. 6. Further, Claimant makes a claim of the following: false arrest; false imprisonment; unlawful search and seizure; assault; battery; intentional, reckless andnegligent infliction of emotional distress; negligence and gross negligence; negligent hiring; negligent retention; negligent training; negligent supervision; negligent discipline; and deprivation of privileges and immunities under the Constitution of the State of New York, the United States Constitution (including, but not limited to, the Fourth and Fourteenth Amendments), 42 U.S.C. § 1983, and other applicable federal and state laws committed by agents, employees, and/or officers of the City of Webster and Webster Police Department, who were acting under pretence and color of state law, in their individual and official capacities, and within the scope of their employment. The conduct giving rise to the claim ‘occurred, at least in part, because of the policies, practices and/or customs of the City of ‘Webster and the Webster Police Department. 7. As a direct and proximate result of the foregoing, and through no fault or culpable conduct of Claimant, Claimant has suffered serious injuries including, but not necessarily limited to: lass of liberty; loss of reputation; loss of employment; loss of dignity; emotional distress and other out of pocket pecuniary damages, including but not limited to attomey’s fees (as a result of the foregoing). 8. Claimant will seek compensatory damages, as against the Town of Webster and Webster Police Department, in any fair, reasonable and proper amount as may be awarded by a jury of his peers, together with interest, costs, disbursements to the fullest extent permitted by law, in excess of $500,000.00. Claimant reserves the right to amend and/or supplement this Notice of Claim. PLEASE TAKE FURTHER NOTICE that the undersigned claimant presents this dlaim for adjustment and payment. You are hereby notified that unless itis adjusted and paidwithin the time provided by law from the date of presentation to you, the claimant intends to commence an action on this claim. Dated: Wad 05 Attorneys for’ ‘Claimant Kali L. Watkins Vahey Getz, LLP 144 Exchange Blvd., Suite 400 Rochester, New York 14614STATE OF NEW YORK SUPREME COURT COUNTY OF MONROE In the Matter of the Claim of Kali Watkins, Claimant, v Town of Webster and Webster Police Department, Chief Joseph Rieger, Investigator ‘Alex Kirkpatrick, Investigator Gretchen O'Dea, Sgt. Jeffrey Webster, John/Jane Doe Officers #15, Respondents. VERFICIATION STATE OF NEW YORK ) Js: COUNTY OF MONROE ) KALIL. WATKINS, being duly sworn, deposes and says: Ihave read the above Notice of Claim and I know the contents thereof. The foregoing information is true and accurate to the best of my own knowledge, except as to those matters which are stated upon information and belief, and as to those matters, I believe them to be true. Swom to before me this 2c! day of Wovember_ 2019. Notary Pubiié /