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WARNING:
 


It is unlawful to knowingly present or cause to be presented any false or fraudulent claim for payment of a loss or injury. (P.C. § 550(c)(1).) Every person
who violates this paragraph is guilty of a felony punishable by imprisonment in state prison for two, three, or five years and by a fine not exceeding fifty
thousand dollars ($50,000). (P.C. § 550(c)(1).) Pursuant to Code of Civil Procedure § 1038, the City may seek to recover all costs of defense in the event
an action is filed that is later determined not to have been brought in good faith and with reasonable cause.
Declaration and Signature of Claimant(s): I declare under penalty of perjury that I have read the foregoing claim for damages and know the contents
thereof; that the same is true of my knowledge and belief, save and except as to those matters stated on information and belief, and as to them, I
believe to be true.
Signature:___________________________________________________ Relationship:______________________________ Date: _________________
CCFORM 6 (Rev 12/14)


You are required by law to provide the information requested on page 1 inorder to comply with
Government Code § 910 and § 910.2. Additionally, in order to conduct a timely investigation the
City of Sacramento requests that you provide additional information:

1. Claimant(s) Social Security Numbers(s): ________________________________________

2. Claimant(s) Date of Birth: ___________________________________________________

3. Claimant’s Driver’s License Number and State: ___________________________________

4. Are you a Medicare Beneficiary? Yes No

5. Medicare HICN number: ____________________________________________________

6. If the claim involves a motor vehicle incident, please provide the following information:

Claimant(s) Insurance Company:____________________ Telephone: _________________

Insurance Policy No.:________________________________________________________

Insurance Agent:_____________________________ Telephone: ____________________

Claimant’s Vehicle Year/Make/Model________________ License Plate No. ____________

Please check here if there was no insurance coverage in effect at the time of the incident.
(Please attach any repair bills, estimates, and photographs of your vehicle damage.)

7. If this claim involves medical treatment for a claimed injury, please provide the name,
address and telephone number of any doctors, hospitals or other medical providers (e.g.
chiropractors, physical therapists, acupuncturists, etc.) providing treatment. (Government Code
§ 985).
_________________________________________________________________________________
_________________________________________________________________________________

8. Additionally, please provide the name, address and telephone number of any insurance
company (or other similar entity), which has or is expected to make payments to you or any
medical provider on your behalf as a result of your claimed injuries (e.g., Medi-Cal, unemployment
insurance, disability insurance, etc.). (Government § 985(c).) ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ
ͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺͺ

2
 CLAIM AGAINST THE CITY OF SACRAMENTO
INSTRUCTIONS
Please provide an original of the "City of Sacramento- Claim Form." The original, together
with one copy of all attachments, are to be filed with the Office of the City Clerk. Retain
one copy for your records. Please send to this address:

Office of the City Clerk

915 I Street
5th Floor, New City Hall Bldg.
Sacramento, CA 95814

NOTICE: The City Clerk's Office is the ONLY office to which claims may be submitted.
Claims are NOT to be sent to the City Attorney, Risk Management, or any other City
Department.

Please fill out claim form as instructed. Missing information will delay the processing
of your claim. Please Print.

PROCEDURES

Claims received by the Office of the City Clerk are forwarded to the City's Claims
Administrator. All claimants are then notified what action will be taken within 45 days (plus
additional days if the form is mailed to the City Clerk), or otherwise notified as to the claim
itself.

If your claim is recommended for denial you will be sent a letter notifying you of the action
taken, and any further action necessary or available to you.

The Sacramento Housing and Redevelopment Agency, Sacramento Regional Transit,

County of Sacramento, Sacramento Municipal Utilities District, and the Sacramento Unified
School District are separate from the City of Sacramento and any claims against them
must be submitted directly to the Agency or Authority.

***ALL CLAIMS ARE PUBLIC RECORD***

3
 CLAIM FOR DAMAGES
(AGAINST THE CITY OF SACRAMENTO and its INVOLVED CITY OF
SACRAMENTO POLICE DEPARTMENT OFFICERS)
Government Code Section 910.4

TO: CITY OF SACRAMENTO; CITY OF SACRAMENTO

POLICE DEPARTMENT OFFICER LINCOLN (#691);
INVOLVED CITY OF SACRAMENTO POLICE
DEPARTMENT OFFICERS; (names unknown)

FROM: BEN CRUMP LAW

1215 K Street, Suite 1700
Sacramento, California 95814
(866) 600-3742

LAW OFFICES OF DALE K. GALIPO

21800 Burbank Boulevard, Suite 310
Woodland Hills, California 91367
(818) 347-3333

CLAIMANTS: ISAIAH BROWN; LATOYA DOWNS, individually and

as the guardian for ISAIAH BROWN and SAMOAN
JONES; SAMOAN JONES

INJURY/DAMAGE: 1. Physical Injuries

2. Emotional Distress
3. General Damages
4. Punitive Damages
5. Attorney’s Fees

AMOUNT CLAIMED: In excess of $100,000

DATE OF INCIDENT: April 21, 2019

PLACE OF INCIDENT: 845 El Camino Avenue, Sacramento, CA 95815

WITNESSES: OFFICER LINCOLN (Badge #691); INVOLVED CITY

OF SACRAMENTO POLICE DEPARTMENT
OFFICERS (names currently unknown); PALADIN
PRIVATE SECURITY, INC. PERSONNEL (names
Attachment A
 currently unknown); EMPLOYEES AT
WIENERSCHNITZEL (names currently unknown); ON
SCENE WITNESSES (names currently unknown)

CLAIMS AGAINST: CITY OF SACRAMENTO; OFFICER LINCOLN

(Badge #691); INVOLVED CITY OF SACRAMENTO
POLICE DEPARTMENT OFFICERS (names currently
unknown)

STATEMENT OF FACTS:
On April 21, 2019, Isaiah Brown, a 12-year-old African American boy, was
spotted running away from a Paladin private security guard by two Sacramento
Police Department (SPD) officers, Officer Lincoln and DOE Officer 1, who had
been patrolling the area of Del Paso Boulevard and El Camino Avenue. As Isaiah
was running, he was stopped and detained by a Wienerschnitzel restaurant
employee until the private security guard caught up to him. The two SPD officers
decided to stop and assist the private security guard in detaining and arresting
Isaiah without reasonable suspicion or probable cause by placing handcuffs on
Isaiah. While being placed in handcuffs, Isaiah repeatedly asked the officers why
he was being arrested. After Isaiah had been handcuffed, the officers inquired as to
what Isaiah had done and the private security guard alleged that Isaiah had been
panhandling and asking people to buy things for him, which Isaiah disputed.
After bystanders questioned why Isaiah was in handcuffs and why his
parents had not been called, the officers moved Isaiah against his will to their
marked patrol vehicle in an attempt to place him in the vehicle. During the move,
Isaiah repeatedly asked for his parents to be called while the private security guard
had his arm against Isaiah’s neck and was choking Isaiah. After a short struggle
with the officers, Isaiah was placed on his stomach on the ground while DOE
Officer 1 placed a knee on Isaiah’s back and Officer Lincoln placed a knee on
Isaiah’s right thigh.
Additional SPD officers subsequently responded to the scene. Isaiah’s 15-
year-old sister Samoan Jones also arrived at the scene. After being told that Isaiah
had allegedly spit at one of the officers, DOE Officer 2 placed a spit bag over
Isaiah’s head. At the time the spit bag was placed over Isaiah’s head, Isaiah had
resignedly calmed down and was being held down in a prone position with his
hands cuffed behind his back. Isaiah repeatedly asked to be let up and informed the
officers that he could not breathe. Isaiah also repeatedly asked for the spit bag to be
taken off of him. Throughout the encounter, SPD officers failed to contact Isaiah’s
mother regarding the arrest. Ultimately, it was left to Samoan to contact Isaiah’s
mother about the detention and arrest.
Attachment A
 Thereafter, Isaiah’s mother Latoya Downs arrived on scene and saw her son
in handcuffs and with what appeared to be a bag over his head. Ms. Downs
panicked because Isaiah suffers from an upper respiratory disease and she worried
that he could enter into an asthma-like fit of breathing difficulties. Ms. Downs pled
with the SPD officers to remove the spit bag from her son’s head but her pleas
were ignored. After Isaiah was cited for battery on a peace officer and resisting
arrest, he was released to his mother’s custody.

CONTENTIONS OF THE CLAIMANTS:

(1) False Arrest/False Imprisonment (Isaiah Brown); (2) Battery (Isaiah Brown);
(3) Negligence (Isaiah Brown); (4) Failure to Train/Negligent Training and
Supervision (Isaiah Brown); (5) Integral Participation/ Failure to Intervene (Isaiah
Brown); (6) Violation of the Bane Act (Civil Code § 52.1) (Isaiah Brown); (7)
Negligent Infliction of Emotional Distress (Latoya Downs; Samoan Jones); (8)
Intentional Infliction of Emotional Distress (Latoya Downs; Samoan Jones).

AMOUNT OF CLAIM:
In excess of $100,000. Jurisdiction is designated as “unlimited.” The United States
District Court for the Eastern District of California and the Superior Court of the
State of California for the County of Sacramento would have jurisdiction over an
action filed with respect to this claim.

CLAIMANTS’ ADDRESS:

c/o Ben Crump Law

1215 K Street, Suite 1700
Sacramento, CA 95814

c/o Law Offices of Dale K. Galipo

21800 Burbank Boulevard, Suite 310
Woodland Hills, California 91367

CLAIMANTS’ TELEPHONE NUMBER:

c/o Ben Crump Law
(866) 600-3742

c/o Law Offices of Dale K. Galipo

(818) 347-3333

//
Attachment A