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STATE OF NEW YORK COUNTY OF ST. LAWRENCE In the Matter ofthe Claim of EDWARD F. NARROW, Claimant, NOTICE OF CLAIM -against- COUNTY OF ST. LAWRENCE, ST. LAWRENCE. ‘COUNTY DISTRICT ATTORNEY'S OFFICE, ST. LAWRENCE COUNTY DISTRICT ATTORNEY ‘MARY E, RAIN, INDIVIDUALLY AND IN HER OFFICIAL CAPACITY AS ST. LAWRENCE COUNTY DISTRICT ATTORNEY, Respondents TO: THE CLERK OF THE COUNTY OF ST. LAWRENCE and ‘THE CLERK OF THE BOARD OF LEGISLATORS OF ‘THE COUNTY OF ST. LAWRENCE PLEASE TAKE NOTICE that the above-named claimant hereby makes claim against the against St. Lawrence County, and the St, Lawrence County Distict Attorney, Mary E. Rain, Individually and in her Official Capacity, as follows: 1, ‘The name and address ofthe claimant and his attomey are: Claimant ‘Attomey Edward F. Narrow, Esq, Robert Ballan, Esq. 18 Chapel Street Dumas & Narrow, P.C. Canton, New York 13617 20 Park Street ‘Canton, New York 13617 (G15) 386-8500 2. Thenature ofthe claim: This claim arises from the Respondents illegal and improper setions and conduct causing harm tothe Clsimant. The improper and illegal ations complained ‘of are malicious prosecution, defamation, and prima face tort, and investigation as to the (Claimant Edward F. Narrow, Esq. The within claim encompasses causes of action for violations ‘of New York State Law, the New York and United States Constitutions, and civil law supporting, remedies of compensatory and punitive damages. The specific claims include but are not limited to the following: Malicious prosecut ‘Narrow; Esq, 3, defamation and prima facie tort causing harm to Edward F. . The Respondents’ intentional, malicious, reckless, and/or negligent actions and conduct subjected and caused Edward F. Narrow, Esq, to suffer deprivation of his civil rights, privileges and immunities secured by Federal Constitution and the laws and Constitution ofthe State of New York. 3. The time when, the place where, and the manner in which the claim arose on or about February 23, 2017, when Claimant was served with a notice of Special Grand Jury Report filed in the St. Lawrence County Cletks Office clearing him ofall alleged criminal charges that arose fom the fling of bail for Oral Nicholas Hillary on or bout September 23, 2015, and the (Claimant's representation of then Chief Assistant District Attorney, David A. Haggard, from September of 2014, to February of 2016, ina eivil ation in Ogdensburg City Court. 4. On September 23, 2015, the Claimant, Edward F. Narrow, Esq, filed bail on behalf of ‘defendant Oral Nicholas Hillary inthe amount of $200,000.00, in the form of certified cashier's check remitted by the Law Firm of Dumas & Narrow, P.C, at the St, Lawrence County Jal ‘Subsequent to the filing of the bail, Respondents claimed in open court on or about April 13, 2016, and on multiple ovcasions thereafter in the newspapers, radi, television and electronic ‘media that claimant had commited a felony related to the filing ofthe bail and it was the intention ofthe Respondents to indict the Claimant. 5. Onorabout April 13, 2016, the Respondents claimed in open court that Claimant and ‘Attorney Haggard had engaged in illegal and unethical conduct regarding Claimant's representation in Ogdensburg City Court of Attorney Haggard in Small Claims Court from September of 2014, to February of 2016, 6 Onorabout February 13, 2017, Respondent's released to Channel Seven News the ‘empaneling of a Grand Jury to investigate and indict Claimant in regard o his fling of bail inthe (Oral Nicholas Hillary case and Claimant's representation of Attomey David Haggard in (Ogdensburg City Court. Upon information and belief; Respondent, Mary E. Rain composed and keeps an “enemies list” of individuals upon whom she seeks to avenge herself for imagined ‘wrongs and slights. Upon information and belief claimant is on Respondent Rain’s lis. 7. The items of damages or injuries claimed are: Punitive and Compensatory damages resulting from the violations of law enumerated herein, together with the severe trauma and stress suffered by the Claimant, Edward F. Narrow, Esq, relative to said violations of law, intentional and other civil compensatory and punitive damages. Claimant suffered months of apprehension ‘and endured false accusations, prosecution, grand jury appearance, damage to his professional reputation, damage to his family reputation, damage to his relationship to his communi