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T aleghone : 912.236.9 559

Ruth F. Claiborne- OfCourxel

Amv W. Fox- Of Counscl

The Claibome Firm, P.C.

AttomeJ9 nt L w 410 E. Bay Strect

Savannah, Georgia 31,101




2 2013


Fiacsimile: 912.236. 1884

William R. Claiborne, Savannah Cnsey L. Reicha:radter, Savannah

writer's ernail: will@claibornefinn.com

September 30,2013



DELIVERY NO,: 7M7 1490 0004 6191 609

DELIWRY NO,: 7M7 1490 MM 6191 1493

The Honorable Edna Branch Jackson

Mayor, City of Savannah Savannah City Hall, 2"" Floor

2 East Bay Street Savannah, Georgia 31401


DELIVERY NO.: 70071490 00N 6t9t


The Honorable Al Scott Chatharn County Conrmission Chairman

P.O. Box 8l6l

Savannah, Georgia 3 l40l

Re: Clains of Trina Mayes

Stephanie Cutteq City Manager

P.O. Box 1027 Savannah, Georgia 3 1402



R. E. Abolt, County Manager

P.O. Box 8l6l

Savannah, Georgia 31412

Ladies and Gentlemen:

We have been retained by Detective Trina Mayes in connection with injuries she incurred

as a result of the conduct of Police Chief Willie Lovett, the Savannal/Chatham

Police Department, the city of Savannah and other government officials who knew or ihould


have known of that conduct and who allowed that conduct to occur or continue or who

participated in that conduct. That conduct includes, without limitation:

harassment, sexual and

otherwise, failure to promote because of gender, including refusal of sexual advances,

defamalion, both personally and with respect to her business reputation, assault, battery, invasion ofprivacy, placing Ms. Mayes in a false and negative light, both personal and with respect to her

business reputation, negligent hiring and retention, ratification of such conduct, seduction and loss of consortium from Ms. Mayes' husband, and conspiracy among numerous individuals under the employ or control of Savannaf/Chatham Metropolitan Police Department and/or the city o[ savannah and/or chatham county to accomplish some or all of this conduct. And given

the overwhelming circurnstances of liability in this matter, Ms. Mayes intends to pursue a ilai*

of abusive litigation, if litigation is necessary. In that regard, notice and demand under o.c.G.A.

Claibome & Fox, LLC is ofcounsel to The Claiborne Firn, p.C. Alla ta Ofrce: 60 Lennox Pointe, Atlanta, Georgio j0324 . (401) 442.6969 Charlotle O[ice:417 Eost Blvtt., Stite l0l, Charlo,te, North Corolina 28203 . (704) 202.0300

Mayor Edna Branch Jackson

Stephanie Cutter, City Manager AI Scott, Chatham County Commission Chairman R. E. Abolt, County Manager

September 30, 2013

$ 51-7-84 is hereby given that,you

voluntarity withdraw, abandon, discontinue or dismiss any

position you may assert ofnonJiability.

This letter will further serve

as ante ritem notice to porice chief willie Lovett, the


chatham county and tr," city oiiauannarr

starutes i egarding anie tiren iii,ce.

Mayes diiectly io ou, omcer,-w"

any claim ueor" ritiluiion i, ni.a

would like to exploie *r",n.",,

Savannah/_clratham Metropolitan police

under o.c.G.A. gg 36-l l-l, 50-2.1-j6, and all other Georgia

Please direct all further communications regarding Deteclve recommend to all our clients rhat lhey explore senlement of

and Ms. Mayes has accepted our recommendation. If you

please let us know by close ofbusiness on Friday, Octobei t t, 20[.


Reply also to:

S. Wesley Woolf


408 East Bay Street Savannah, Georgia 30401

Cc: File


S. Wesley Woolf, Esquire

Brooks W. Stillwell, III, Esquire

R. Jon Hart, Esquire

(Via Facsimile and Regular

(Via Facsimile and Regular Mail)


Claiborne & Fox, LLC is

of counse! to The Claibor,rc Fim, p.C.

Atlanta Ojice: 60 Lennox pointe,

Attonto, Georgio 3032,t - (lOi) IIZ.OCOC

Chorlotk Onlce:417 East Blvd., Suite toj, Chortotte, No;th Carotii


iAiU eo4) 702.0300




Mayor anil Aldermeh


Stephanie Cutte\ City *^*", /'lrfu


Sexual llarassment Allegations






Allegzitions of sexual harassment have bei:n made by an SCMPD police Olficer againsl

Chief Willie Lovett. An iirvestigation by an orrtsido legal firm iS in gogress. tnief

tovett has been notified of the allega1ion5 and investigalion. Upon completion of the

investigation, Council tvill be notified ofthe findings.

Please let me know ifyol have any quastions.

P.O. aox ro27, S^VANN^H, G! lr4o2

exoxE gi2.6tI.64rt Tott 9tz,6tr.67o?, Ej-r tr2-1t8.o872 sAVANNATTc^-cov


City of Savannah Responsive materials to ORA of 9/30//13 In rer Savannah Morning News


CITY OX'SAVANNAH Workplace Conflict Statement Form

Employee's Name !sBte-S-s.e,-fNgg;-

Dept. 1fu

L Datg time and location the event or discussion took place:

2. Give a briefstatement ofyour rvorkplace conflict including names ofall parties involved and any

persons who lvitnessed the conflict; (S!pk to,tje faSl9)

Stat€ rvhat you feel is a fair and just solution to this conflict:

4, Are you willing to mediate this conflict through a City certilied mediator?


Employee's Signa


oate: 'ilZrcl t3

Please complete and return to the Hurnan Resources Employee Relatiotrs coordinator,

Reytsed 5/06


City of Savannah Responsive materials to ORA of 9/30//13 In rei Savannah Moming News


My nanre is LaPrentice Mayes and I am curently employed in the police patrol division central precinct investigations. For the past 17 yearq I have been in several assigru]rents thoughout the departnrent to inolude investigations. I have worked under the direction ofWillie C Lovett for numerous years and in 2006, he promoted me to the rartk of Sergeant. Willie Lovett was a man I respeded admired and always wanted to do a good job to make him shine. I always thought we had a good Dear City ofSavannatq

worhng relationship and I felt I was able to talk with him about anything.

Captain Cedric Phillips is a man who I always respected and considered a true friend. We worked closely together for many years and he was my trusted and dear friend. When he moved up the ladder and achieved the rank ofcaptain. I was there for lis special day in his lifejust like

how he was for rno when I was promoted to thc rank of Sergeant. He was the person who pihned my badge on my chest.

Both ofthese nren betrayed all ofthat last week when my wife of six years revealed to

me she had an affair with chief Lovett and Captain Phillips paved the way for that tragic event to



On July 16, 2012, my wife and I were involved in a domestic dispute in our home that resulted in the police being called, and I was ordered out ofthe !'esidence. The next day, we were placed on administrative leave so internal affairs could conduct an investigation. While out ofthe

residencq Captairr Phillips who was a mutual fiiend to both ofus, he would check on each ofus to ensure we vr'ere okay. As tinte went ofl, the i[vestigation was lifted and we both were

removed frorn our investigatior assignment and placed back in the patrol division. Upon my

returned, I met with chieflovett and told him I was sorry for all the bad press and rnoving

forward, I will not let this type of stuff happen again. During this time, I would speak with my

wife and we decided to work out our disagreements. Even though we had already filed for divorcq and despite that, we wa$ed to give our marriage another chance.

In January 2013, I moved back into the house and we continued our rnariage. A few

months had past, and it was tirne for the Sergeants assessmeot. My wife took the test and past,

which nrade her eligible for promotion. During that time we both were baptized and gave our life

to god and was living the christel life. I also tried gettiug out ofprecinct 4 during that time

because I was not pleased with the commander. I called chieflovett and expressed my desire to

move and he said he would see what he could do and I was never moved. I then wenl to Captain Adams and asked if I could come to his precinct and he worked it out with the majors and I was trausferred to precinct 3. Prior to this incident, I rnet with chieflovett and asked hinr not to hold anything against my wife because she is a good employee. He looked me in the face and said," If

she doesn't get promoted, it will be because of her own doing". I mncluded my interview and

left his office. Merward, the promotions were annouced and my wife took it hard. She kept


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City of Savannah Responsive materials to ORA of 9/30//13 In re: Savannah Morning News