in the matter of miriam carey v. united states of america, et al

131
CLAIM FOR DAMAGE, INJURY, OR DEATH INSTRUCTIONS: Please read carefully the instructions on the reverse side and supply information requested on both sides of this form. Use additional sheet(s) if necessary. See reverse side for additional instructions. FORM APPROVED OMB NO. 1105-0008 1. Submit to Appropriate Federal Agency: United States of America; United States Secret Service and United States Capitol Police 2. Name, address of claimant, and claimant's personal representative if any. (See instructions on reverse). Number, Street, City, State and Zip code. Eric Sanders, Esq., of THE SANDERS FIRM, P.0 1140 Ave of the Americas New York, NY 10036 o/b/o Estate of Miriam Carey, !della Carey, Minor Child EF and Valarie Carey 3. TYPE OF EMPLOYMENT MILITARY CIVILIAN 4. DATE OF BIRTH 5. MARITAL STATUS 6. DATE AND DAY OF ACCIDENT 09/05/2014 7. TIME (A.M. OR P.M.) 8. BASIS OF CLAIM (State in detail the known facts and circumstances attending the damage, injury, or death, identifying persons and property involved, the place of occurrence and the cause thereof. Use additional pages if necessary). Claimants filed and presented previous federal tort claims surrounding the death of Miriam Iris Carey, those claims were DENIED. The United States Secret Service and United States Capitol Police in conjunction with the United States Attorney General for the District of Columbia and Metropolitan Police Department actively and fraudulently concealed both agencies role, as well as a FULL and complete disclosure of the facts and circumstances leading to the shooting death of Miriam Iris Carey, directly impeding claimants' ability to assert their constitutional, civil, statutory and related common law rights. 9. PROPERTY DAMAGE NAME AND ADDRESS OF OWNER, IF OTHER THAN CLAIMANT (Number, Street, City, State, and Zip Code). NONE BRIEFLY DESCRIBE THE PROPERTY, NATURE AND EXTENT OF THE DAMAGE AND THE LOCATION OF WHERE THE PROPERTY MAY BE INSPECTED (See instructions on reverse side). NONE 10. PERSONAL INJURY/WRONGFUL DEATH STATE THE NATURE AND EXTENT OF EACH INJURY OR CAUSE OF DEATH, WHICH FORMS THE BASIS OF THE CLAIM. IF OTHER THAN CLAIMANT, STATE THE NAME OF THE INJURED PERSON OR DECEDENT. The Estate of Miriam Iris Carey - Emotional Distress, etc. $50,000,000.00 Idella Carey - Emotional Distress, etc. $50,000,000.00 Minor Child EF - Emotional Distress, etc. $50,000,000.00 Valarie Carey - Emotional Distress, etc. $50,000,000.00 11. WITNESSES NAME ADDRESS (Number, Street, City, State, and Zip Code) 12. (See instructions on reverse). AMOUNT OF CLAIM (in dollars) 12a. PROPERTY DAMAGE 0.00 12b. PERSONAL INJURY 200,000,000 12c. WRONGFUL DEATH 12d. TOTAL (Failure to specify may cause forfeiture of your rights). 200,000,000 I CERTIFY THAT THE AMOUNT OF CLAIM COVERS ONLY DAMAGES AND INJURIES CAUSED BY THE INCIDENT ABOVE AND AGREE TO ACCEPT SAID AMOUNT IN FULL SATISFACTION AND FINAL SETTLEMENT OF THIS CLAIM. 13a. ATURE •F •A IV a ) MANT (S instructions on rever e side). vib ,. ‘ -- OK q N Z 13b. PHONE NUMBER OF PERSON SIGNING FORM 888-892-8952 14. DATE OF SIGNATURE 04/20/2015 CIVIL PENALTY FOR PRESENTING FRAUDULENT CLAIM The claimant is liable to the United States Government for a civil penalty of not less than $5,000 and not more than $10,000, plus 3 times the amount of damages sustained by the Government. (See 31 U.S.C. 3729). CRIMINAL PENALTY FOR PRESENTING FRAUDULENT CLAIM OR MAKING FALSE STATEMENTS Fine, imprisonment, or both. (See 18 U.S.C. 287, 1001.) Authorized for Local Reproduction Previous Edition is not Usable 95-109 NSN 7540-00-634-4046 STANDARD FORM 95 (REV. 2/2007) PRESCRIBED BY DEPT. OF JUSTICE 28 CFR 14.2

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After serious consideration, on April 20, 2015, the Carey family decided to file new $200 million dollar federal tort claims alleging a further government conspiracy.

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  • CLAIM FOR DAMAGE, INJURY, OR DEATH

    INSTRUCTIONS: Please read carefully the instructions on the reverse side and supply information requested on both sides of this form. Use additional sheet(s) if necessary. See reverse side for additional instructions.

    FORM APPROVED OMB NO. 1105-0008

    1. Submit to Appropriate Federal Agency:

    United States of America; United States Secret Service and United States Capitol Police

    2. Name, address of claimant, and claimant's personal representative if any. (See instructions on reverse). Number, Street, City, State and Zip code. Eric Sanders, Esq., of THE SANDERS FIRM, P.0 1140 Ave of the Americas New York, NY 10036 o/b/o Estate of Miriam Carey, !della Carey, Minor Child EF and Valarie Carey

    3. TYPE OF EMPLOYMENT MILITARY CIVILIAN

    4. DATE OF BIRTH 5. MARITAL STATUS 6. DATE AND DAY OF ACCIDENT

    09/05/2014 7. TIME (A.M. OR P.M.)

    8. BASIS OF CLAIM (State in detail the known facts and circumstances attending the damage, injury, or death, identifying persons and property involved, the place of occurrence and the cause thereof. Use additional pages if necessary).

    Claimants filed and presented previous federal tort claims surrounding the death of Miriam Iris Carey, those claims were DENIED. The United States Secret Service and United States Capitol Police in conjunction with the United States Attorney General for the District of Columbia and Metropolitan Police Department actively and fraudulently concealed both agencies role, as well as a FULL and complete disclosure of the facts and circumstances leading to the shooting death of Miriam Iris Carey, directly impeding claimants' ability to assert their constitutional, civil, statutory and related common law rights. 9.

    PROPERTY DAMAGE NAME AND ADDRESS OF OWNER, IF OTHER THAN CLAIMANT (Number, Street, City, State, and Zip Code). NONE BRIEFLY DESCRIBE THE PROPERTY, NATURE AND EXTENT OF THE DAMAGE AND THE LOCATION OF WHERE THE PROPERTY MAY BE INSPECTED (See instructions on reverse side).

    NONE 10. PERSONAL INJURY/WRONGFUL DEATH STATE THE NATURE AND EXTENT OF EACH INJURY OR CAUSE OF DEATH, WHICH FORMS THE BASIS OF THE CLAIM. IF OTHER THAN CLAIMANT, STATE THE NAME OF THE INJURED PERSON OR DECEDENT. The Estate of Miriam Iris Carey - Emotional Distress, etc. $50,000,000.00 Idella Carey - Emotional Distress, etc. $50,000,000.00 Minor Child EF - Emotional Distress, etc. $50,000,000.00 Valarie Carey - Emotional Distress, etc. $50,000,000.00 11.

    WITNESSES NAME ADDRESS (Number, Street, City, State, and Zip Code)

    12. (See instructions on reverse). AMOUNT OF CLAIM (in dollars) 12a. PROPERTY DAMAGE

    0.00

    12b. PERSONAL INJURY

    200,000,000

    12c. WRONGFUL DEATH 12d. TOTAL (Failure to specify may cause forfeiture of your rights).

    200,000,000 I CERTIFY THAT THE AMOUNT OF CLAIM COVERS ONLY DAMAGES AND INJURIES CAUSED BY THE INCIDENT ABOVE AND AGREE TO ACCEPT SAID AMOUNT IN FULL SATISFACTION AND FINAL SETTLEMENT OF THIS CLAIM. 13a. ATURE F A

    IV a ) MANT (S instructions on rever e side). vib ,. --OK q NZ

    13b. PHONE NUMBER OF PERSON SIGNING FORM

    888-892-8952

    14. DATE OF SIGNATURE

    04/20/2015 CIVIL PENALTY FOR PRESENTING FRAUDULENT CLAIM

    The claimant is liable to the United States Government for a civil penalty of not less than $5,000 and not more than $10,000, plus 3 times the amount of damages sustained by the Government. (See 31 U.S.C. 3729).

    CRIMINAL PENALTY FOR PRESENTING FRAUDULENT CLAIM OR MAKING FALSE STATEMENTS Fine, imprisonment, or both. (See 18 U.S.C. 287, 1001.)

    Authorized for Local Reproduction Previous Edition is not Usable 95-109

    NSN 7540-00-634-4046 STANDARD FORM 95 (REV. 2/2007) PRESCRIBED BY DEPT. OF JUSTICE 28 CFR 14.2

  • 13. Have you filed a claim with your insurance carrier in this instance, and if so, is it full coverage or deductible? Yes X No 14. If deductible, state amount

    NONE

    INSURANCE COVERAGE In order that subrogation claims may be adjudicated, it is essential that the claimant provide the following information regarding the insurance coverage of the vehicle or property. 15. Do you carry accident Insurance? X Yes If yes, give name and address of insurance company (Number, Street, City, State, and Zip Code) and policy number. El No NONE

    16. If a claim has been filed with your carrier, what action has your insurer taken or proposed to take with reference to your claim? (It is necessary that you ascertain these facts). NONE

    17. Do you carry public liability and property damage insurance? Yes If yes, give name and address of insurance carrier (Number, Street, City, State, and Zip Code). X No NONE

    INSTRUCTIONS Claims presented under the Federal Tort Claims Act should be submitted directly to the "appropriate Federal agency" whose employee(s) was involved in the incident. If the incident involves more than one claimant, each claimant should submit a separate claim form.

    Complete all items - Insert the word NONE where applicable. A CLAIM SHALL BE DEEMED TO HAVE BEEN PRESENTED WHEN A FEDERAL AGENCY RECEIVES FROM A CLAIMANT, HIS DULY AUTHORIZED AGENT, OR LEGAL REPRESENTATIVE, AN EXECUTED STANDARD FORM 95 OR OTHER WRITTEN NOTIFICATION OF AN INCIDENT, ACCOMPANIED BY A CLAIM FOR MONEY Failure to completely execute this form or to supply the requested material within two years from the date the claim accrued may render your claim invalid. A claim is deemed presented when it is received by the appropriate agency, not when it is mailed.

    If instruction is needed in completing this form, the agency listed in item #1 on the reverse side may be contacted. Complete regulations pertaining to claims asserted under the Federal Tort Claims Act can be found in Title 28, Code of Federal Regulations, Part 14. Many agencies have published supplementing regulations. If more than one agency is involved: please state each agency.

    The claim may be filled by a duly authorized agent or other legal representative, provided evidence satisfactory to the Government is submitted with the claim establishing express authority to act for the claimant. A claim presented by an agent or legal representative must be presented in the name of the claimant. If the claim is signed by the agent or legal representative, it must show the title or legal capacity of the person signing and be accompanied by evidence of his/her authority to present a claim on behalf of the claimant as agent, executor, administrator, parent, guardian or other representative.

    If claimant intends to file for both personal injury and property damage, the amount for each must be shown in item number 12 of this form.

    DAMAGES IN A SUM CERTAIN FOR INJURY TO OR LOSS OF PROPERTY, PERSONAL INJURY, OR DEATH ALLEGED TO HAVE OCCURRED BY REASON OF THE INCIDENT. THE CLAIM MUST BE PRESENTED TO THE APPROPRIATE FEDERAL AGENCY WITHIN TWO YEARS AFTER THE CLAIM ACCRUES. The amount claimed should be substantiated by competent evidence as follows: (a) In support of the claim for personal injury or death, the claimant should submit a written report by the attending physician, showing the nature and extent of the injury, the nature and extent of treatment, the degree of permanent disability, if any, the prognosis, and the period of hospitalization, or incapacitation, attaching itemized bills for medical, hospital, or burial expenses actually incurred.

    (b) In support of claims for damage to property, which has been or can be economically repaired, the claimant should submit at least two itemized signed statements or estimates by reliable, disinterested concerns, or, if payment has been made, the itemized signed receipts evidencing payment.

    (c) In support of claims for damage to property which is not economically repairable, or if the property is lost or destroyed, the claimant should submit statements as to the original cost of the property, the date of purchase, and the value of the property, both before and after the accident. Such statements should be by disinterested competent persons, preferably reputable dealers or officials familiar with the type of property damaged, or by two or more competitive bidders, and should be certified as being just and correct.

    (d) Failure to specify a sum certain will render your claim invalid and may result in forfeiture of your rights. PRIVACY ACT NOTICE This Notice is provided in accordance with the Privacy Act, 5 U.S.C. 552a(e)(3), and concerns the information requested in the letter to which this Notice is attached. A. Authority The requested information is solicited pursuant to one or more of the following: 5 U.S.C. 301, 28 U.S.C. 501 et seq., 28 U.S.C. 2671 et seq., 28 C.F.R. Part 14.

    B. Principal Purpose: The information requested is to be used in evaluating claims. C. Routine Use: See the Notices of Systems of Records for the agency to whom you are submitting this form for this information. D. Effect of Failure to Respond: Disclosure is voluntary. However, failure to supply the requested information or to execute the form may render your claim "invalid "

    PAPERWORK REDUCTION ACT NOTICE This notice is solely for the purpose of the Paperwork Reduction Act, 44 U.S.C. 3501. Public reporting burden for this collection of information is estimated to average 6 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Director, Torts Branch. Attention: Paperwork Reduction Staff, Civil Division, U.S. Department of Justice, Washington, DC 20530 or to the Office of Management and Budget. Do not mail completed form(s) to these addresses.

    STANDARD FORM 95 REV. (2/2007) BACK

  • EXHIBIT 1

  • 1140 Avenue of the Americas, 9th Floor, New York, NY 10036 Phone:

    Fax:

    Email:

    Facebook: thesandersfirmpc

    SANDERS FIRM,

    November 25, 2013

    The Honorable Eric Holder Attorney General of the United States U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530

    RE: Request for Investigation of the Shooting Death of Miriam I. Carey, An Unarmed African-American Female in the District of Columbia As A Civil Rights Violation

    Dear Mr. Holder:

    On behalf of the entire Carey Family and the international community, I am writing to respectfully request that the Department of Justice investigate the October 3 shooting death of Miriam I. Carey, an unarmed African-American Female in the District of Columbia as a civil rights violation and the disturbing response of government officials.

    I apologize for the lengthy letter, but, I need to address the sketchy fact and circumstances surrounding the shooting of Miriam I. Carey that has not been vigorously challenged investigated. Now that we have the sworn affidavit filed in this case by the Metropolitan Police Department in federal court, we are more confident than ever that these police officers' completely mishandled this simple "street encounter" and one or more of them should be criminally prosecuted for violating Miriam I. Carey's civil rights.

    Basic common sense tells you that things should have been done differently. Quite frankly, any properly trained professional law enforcement person, such as I (retired NYPD) or Valarie Carey (retired NYPD) will tell you that moving vehicles are not defined as "deadly weapons" under department Use of Force guidelines. Quite frankly, just about every major police agency in the United States including the District of Columbia "strictly prohibits discharging service weapons towards moving vehicles" for a host of philosophical and safety reasons, unless the person operating the moving vehicle is using "deadly physical force by means other than a moving vehicle." See, the onerous is on the United States Secret Service Uniformed Division, the United States Capitol Police or any other involved law

  • enforcement agency to justify their use of force against Miriam I. Carey. If their legal argument is that they were protecting the United States Capitol, White House or any other "property"... Well, you know the result, their actions are not justified. Remember, the use of force guidelines value life over property.

    Certainly, from a law enforcement point of view, the Miriam I. Carey case is not "complex" from a police science perspective to understand.

    These law enforcement officials completely mishandled at best, a simple "suspicious vehicle" car stop, such car stops are handled professionally by law enforcement officials all over the world every day without incident including in other cities with so-called "high value targets." Using the term "high value target" is nothing other than an emotionally charged red herring to distract the public from demanding relevant answers from government officials who obviously violated Miriam I. Carey's civil rights under the guise of protecting society from "Terrorism." I sarcastically call it the new civil rights Qualified Immunity defense. There are some publically reported suggestions that somehow in the District of Columbia there should a different legal standard, is intellectually disingenuous.

    The Department of Homeland Security was established with the passage of Public Law 107-296 which in part, transferred the United States Secret Service from the Department of the Treasury, to the new department effective March 1, 2003.

    Under the old guidelines, while part of the United States Treasury, the United States Secret Service discharge of their service weapons would NOT be justified... Read the old regulations. As soon as I find some reference to the new guidelines, while part of the Department of Homeland Security, I am quite confident the result would be the same, NOT justified. http://www.treasury.gov/about/role-of-treasury/orders-directives/Pages/to105-12.aspx The sworn affidavit for a Search Warrant clearly says on Page 1 "A USSS-UD (meaning United States Secret Service Uniformed Division) officer attempted to block the vehicle with a bicycle rack, however, the vehicle pushed over the bicycle rack, knocking the officer to the ground." Note Miriam I. Carey's actions occurred after she allegedly "refused to stop" at the vehicle checkpoint and made a U-turn and allegedly began to "flee." There were no laws violated as she was under no legal obligation to enter the checkpoint, turning around and leaving is also not violative of any laws. The question is: Why did the police pursue her? Later as the Carey family continues with its own independent investigation, we will reconcile each sworn fact with the surveillance video, other police records and Google Maps. On the surface, the sworn facts are internally inconsistent but, we will know more later on.

    Further, in the sworn affidavit, there is NO MENTION that Miriam I. Carey struck any officers either.

    2

  • An innocent unarmed United States Citizen with a toddler was killed right in front of the entire international community in the Nation's capital.

    We in this country deserve to be treated better than as "mere chattel," where personal legacies are much more important than human life. The framers of the United States Constitution fought for, died for and demanded it. We should expect no different in today's society either. We look forward to your timely response.

    Sincerely,

    Eric Sanders

    ES/es

    3

  • Exhibit 1

  • change.org

    Recipient:

    Letter: Greetings,

    Conduct a Swift and Independent Investigation into the MURDER of Miriam Carey by Capitol Police and Secret Service

  • Comments Name Location Date Comment Jacqueline Smith Brooklyn, NY 2013-11-14 Justice is right in Gods eye sight. Cynthia Bryan Brooklyn, NY 2013-11-14 Did this woman really have to be gunned down as she was? With a full

    investigation how can there be certainty in the thought that she was a threat? Why was she not subdued but killed? This could have been my mother, my sister or me! Change is needed now. We need to know what hapened nowt

    Joshua Ventress Marina, CA 2013-11-14 If it becomes acceptable for police officers to open fire upon unarmed civilians, I feel it will slowly become accepted as the norm and more and more innocent people will be murdered.

    Latisha McDougal Richmond, VA 2013-11-14 I am a friend of the family, I would like to see that true justice is done. Ree Williams San Diego, CA 2013-11-14 This is important to me because as a Veteran and an American, I want to

    ensure that our law enforcement officers understand and are trained properly, not from a fear based training, but from a logic rendering training. We can't have a repeat of this!

    Ayana Miller Brooklyn ny, NY 2013-11-14 To many people are dying at the hand of the govt. We all have family that care. They need explanations just like anyone else would.

    Grady Fuller Hurleyille, NY 2013-11-14 that could have been my sister CAROL SIMS Manhattan, NY 2013-11-14 Because that could have been my sister.

    Ricky Scott New York, NY 2013-11-14 I'm sending this petition, for a complete investigation into the murder of this young lady. It didn't have to end with a death. There was plenty of opportunities for officers to take other measures.

    Barney Terrell Johnson city, TN 2013-11-14 There is to much senseless killing going on in the US...we need more patience, and concern for the Human Life

    Zainab Bola Akinola brooklyn, NY 2013-11-14 It could have been my family member or friend. Clarity is needed.

    Betty Miller Valley Stream, NY 2013-11-14 I wouldn't want something like that to happen to one of my family members! Judy Florentine Carson City, NV 2013-11-14 First because I know and care for someone in Miriam's family, second because

    I don't like the way justice is being abandoned in America. Dian Taitt Miami, FL 2013-11-14 The family is a pain and this will help to ease their pain TAWONNA WILSON BROOKLYN, NY 2013-11-14 I FEEL THIS COULD HAVE BEEN HANDLE DIFFERENTLY ashley peake columbus, OH 2013-11-14 I believe us tax payers should get what we deserve. ALL cases should be

    investigated properly. Gail Johnson Bronx, NY 2013-11-14 We need to seek justice as to why the D.C. officers were allowed to use

    EXCESSIVE force that resulted in an UNARMED women being killed. We need to bring those who are responsible for this crime to Justice

    KIMBERLY JONES new bern, NC 2013-11-14 she was a friend of my cousin and she, her child and family deserves justice!

    MAYA FREEMAN san diego, CA 2013-11-14 Most police officers are shooting first and asking questions later when it a colored person involved. I question if she was Caucasian, would they have shot her, or the tires? The Jim Crow Laws need to end officially, Eric Holder is our only help as people of color to end this senseless shot first policy toward black people. Even if she was driving erratically, she did not deserve to die, a wrecked car yes, not death. Truly another United States Tragedy. :-(

    Charles McCray Queens Village, NY 2013-11-14 An abuse of authority resulting in the killing of an unarmed women Karen McKee Antelope, CA

    2013-11-14 This was wrong. This lady had a young baby in her car and was scared. She was ambushed. What a shame.

  • Name

    Tara Finch

    michaelno bruno

    Kisha Jackson

    Iris Fitzgerald

    Location

    Canton, MI

    bklyn, NY

    Willingboro, NJ

    Roanoke, VA

    MONIQUA WILSON

    cherise gittens

    Carol Johnson

    CORNELIUS PERRY

    Ramona Hamm

    Lynn Thompson

    Akeema Bryan

    SICKLERVILLE, NJ

    brooklyn, NY

    Brooklyn, NY

    JAMAICA, NY

    New York, NY

    Commerce City, CO

    Brooklyn, NY

    Date Comment

    2013-11-14 This is a Shocking and Sad case that I cant stop thinking about. 2013-11-14 supporting a old friend

    2013-11-14 I believe that justice needs to be served. 2013-11-14 I felt that incident was reenacted. In the beginning I watched as the police held

    the car at gunpoint. Why would someone be held at gun point for hitting a gate?

    2013-11-14 Miriam is my was and still my best friend and I would like for her name to be cleared and to have some justice served and that her family can some peace with this unforeseen incident

    2013-11-14 Justice for this unjustified murder of Miriam Carey 2013-11-15 They didn't have to kill her!

    2013-11-15 This can happen to any one of us in any city in the U.S. The police need to be stopped DEAD in their tracks

    2013-11-15 For change in way shootings are handled in our country 2013-11-15 Excessive force was not warranted in this case and because it could happen to

    any of us, it is very important to me.

    2013-11-15 I do not feel that she was particularly innocent due to the fact that the video shows that she evidently was leading a chase from the police but the officers taking her life especially while a baby was in the car is definitely unjustifiable.

    2013-11-15 Make sure Justice is served properly. 2013-11-15 Could have been my family member. I'd like to know if there is more to this

    than the media is telling us. 2013-11-15 This is important to me because I am sick and tired of the lack of respect, lack

    of justice and the lack of value for Black peoples' lives. 2013-11-15 We need accountability in the streets to keep the people safe. There are other

    ways to stop a person...stopping their life should be the last possible resort especially if they are unarmed.

    2013-11-15 It was reported that there was some mental illness but even from the footage, it didn't appear that all was done correctly to avert the police from killing her. Non-Lethal methods could have been deployed and I just can't understand how could they not see that there was a Baby in the back seat. And she was shot pretty much at point blank range multiple times. Investigation should be extensive, thorough, and totally objective.

    2013-11-15 knows what it's like to lose a sister

    2013-11-15 Because I feel a full investigation is needed, our sisters should not be gun down on the streets

    2013-11-15 Her sister is a friend of mine. I am supporting her family. 2013-11-15 Fight for justice. 2013-11-15 good friend

    2013-11-15 Miriam's family deserves a complete & through investigation 2013-11-15 I believe there need to be an investigation answering all questions 2013-11-15 Because i beleive in justice . 2013-11-15 I hate the misuse of power...it truly has to stop 2013-11-15 Could've been a family member. She harmed no one, therefore, they had

    options but chose murder!

    Malik Grimes Indianapolis, IN

    Tonya Williams Maxton, NC

    Oseye Mchawi Brooklyn, NY

    Ella Rucker Bronx, NY

    Craig Coggins Phoenix, AZ

    Kendra Scott Indianapolis, IN

    Juliette Merritt-Bailey Brooklyn, Barbados

    willa strong Charlotte, NC Nahisha McCoy Brooklyn, NY Darryl Jenkins Atlanta, GA

    Jamal Baker Baltimore, MD

    Nellie Williams Greer, SC

    denise daniels Marietta, GA

    Natalie Miller scarborough, Canada Val Johnson New York, NY

  • Name Location Date Comment NOEL LEADER BROOKLYN, NY 2013-11-15 JUSTICE SHOULD BE IMPORTANT TO EVERYONE STEVEN MASON Brooklyn, NY 2013-11-15 Accountability MICHAEL BELLO United Kingdom 2013-11-15 BLACK LIFE COUNTS TOO. Peter HOLOMAN BROOKLYN, NY 2013-11-15 BECAUSE THE FAMILY SHOULD HAVE CLOSURE. Connie Charles Locust Grove, GA 2013-11-16 I don't believe this unarmed woman with her yound child in the car was a threat

    to the white house. In addtion, I feel execessive force used was unwarranted. clayton hudson Middle Island, NY 2013-11-16 Incident is very suspicious. Patricia Smith NY, NY 2013-11-16 Because she was a baby, just needed someone to hear her. caytoya sharpe Beverly Hills, CA 2013-11-16 Justice!

    Jennifer Brannon ozone Park, NY 2013-11-16 Friend that would like to see investigation done Andrew Benson Greene Freetown, Sierra Leone 2013-11-16 This is important to me because murder of any human being is a serious crime

    nd must not be encouraged. There must be a stop to it because an authority with a gun can continue murdering innocent civilians at their whim

    Audreya Perry Jamaica, NY 2013-11-16 Cops can do better. Sabrina P Portland, OR 2013-11-16 You can't just shoot unarmed citizens. Nancy Vega Marina Del Rey, CA 2013-11-17 Why did six officers pull their guns on one unarmed mother with her baby

    present? How was she a threat? John Kern Charlotte, VT 2013-11-17 Why are so many facts surrounding this case still unknown? Without a

    thorough and independent investigation, we may never know if protocols were disobeyed or laws were broken.

    Jacqueline Dennis North Babylon, NY 2013-11-17 It could happen again to anyone of us!! Tana McDonald Nashville, TN 2013-11-17 Based on camera footage, I cannot see a reason why this woman was killed.

    Time to reign in the police who seem to kill more people than they protect and serve. Executing people whose behavior is puzzling should not be the first order.

    Edmund Diego Suffolk, VA 2013-11-17 THIS IS MY FAMILY!! Suzan Hutchinson Nashville, TN 2013-11-18 I saw news reports on this and it simply didn't make sense. What I saw didn't

    seem to match what I was hearing. And, when I learned she was Val's sister, I felt certain something was missing and needed to be addressed.

    isralah rivers atlanta, GA 2013-11-18 the killing of this young woman was senseless and more needs to be done to make for certain no other family goes through what the Carey family has experienced.

    kern Mitchell Euless, TX 2013-11-19 To prevent this from happening to other innocent people Monique Burks Dallas, TX 2013-11-19 Justice will be served Val..

    sandy jean-louis brooklyn, NY 2013-11-20 Valerie is a dear friend of mine, and i do believe her sister deserves justice carlaff campbell brooklyn, NY 2013-11-20 I want to see justice done Alexandra Bruce SAG HARBOR, NY 2013-11-20 Murder requiring investigation for justice to be served.

    Carmen Del Valle Broolyn, NY 2013-11-20 I believe there was wrong doing... Kym Hampton Brooklyn, NY 2013-11-20 Some police officers are too quick to shoot and kill. Andrea Battle Amherst, MA 2013-11-20 Want to know all circumstances around this tragic incident. Timica Roach Brooklyn, NY 2013-11-20 She was a special person a friend to me. She did not deserve this and should

    get justice. Lise Nicolas Elmont, NY 2013-11-20 This matter is dear to my heart.

  • Name Location Date Comment Von Doane Coram, NY 2013-11-20 I want to know why an unarmed women with a toddler in her car was shot and

    killed by capital police & secret service agents. in Washington D.C. on Oct. 3rd, 2013 and why the capitol police officiers have not been identify to the American public.

    Andrew DeCarlo staten island, NY 2013-11-20 too much excessive force exercized Angela Stewart Brandywine, MD 2013-11-20 I believe it's more to this story and I also believe the young lady is innocent

    and was wrongfully killed . toni bradshaw atlanta, GA 2013-11-21 One word, JUSTICE! Kisha Olug Brooklyn, NY 2013-11-21 I am an advocate of justice for all. Veronica Thomas Stone Mountain, GA 2013-11-21 Because the murder of Miriam Carey is a terrible injustice that could have

    happened to me. Theodore Collier dalzell, SC 2013-11-21 Because of injustice. Grover Reed Jr Brooklyn, NY 2013-11-21 Justice needs to be served Lureatha Crosby chicago, IL 2013-11-21 A woman of a young child was murdered unnecessarily. Richard Lippincott Newmanstown, PA 2013-11-21 Murdering an unarmed woman with a baby for erratic driving & fleeing the

    police is criminal. No excuse whatsoever. Those responsible need to be brought to justice. They r thugs, not hero's to be applauded by congress.

    James Hendon Dunlap, TN 2013-11-21 They blew her head off, she was no danger. Do your job for once Mr. Holder Dada Carter East St. Louis, IL 2013-11-22 I feel there was no reason for shooting this Woman, especially when a Child

    was inside the vehicle she was driving. There were other measures to have taken place. Road block, throwing spikes down to stop the vehicle, then take the person out and question to find out what was going on. That was a barbaric act and totally un-called for!

    Kathy Tribble

    Michael Jackson

    Sarah L. Freeman

    Joy Guglielmino

    Elizabethton, TN 2013-11-22 I am very upset that the Police murdered Miriam Carey when there was no need to kill her. This beautiful young mother is gone now and her blood is on many hands. I pray for her family and I pray that God brings the truth to light.

    Morton, IL 2013-11-22 It's the difference between truth and lies. It's the difference between liberty and a police state. Miriam Carey did nothing amiss to warrant such action and then to have members of Congress applaud her being gunned down in cold blood.

    Cumby, TX 2013-11-22 This is too sad, tragic & just plain wrong! This should never ever have happened to anyone & this young woman deserves justice to be served since it did happen to her & because that her poor little innocent daughter will now suffer from this injustice being done to her mother for the rest of her entire life! I believe that when any officers who have sworn to uphold the law & protect all our citizens from any & all harm commits a serious crime like murdering one of those innocent citizens that it should be taken extremely serious as we would address any attack from any foreign or homeland terrorist, because that's exactly what this is, an act of terrorism against our citizens, namely Miriam Carey & her infant daughter Erica! I hope my signature, input & passing this along to others will indeed help see justice served for them, because this breaks my heart!

    Kansas City, MO 2013-11-22 Justice is always important, but that this ils a possible President Obama travesty makes it multiply by exponenticially.

    PATRICK KILLLILEA HEMET, CA

    2013-11-22 It seems odd that she was shot and kill, after she exited her vehicle, as I understand.

  • doreen shaver

    Lisa Nydoske

    John Gilds

    Location Date Comment

    Ridgeland, MS 2013-11-22 This is important because life is a gift from God not man. None of the shooters were God or of His teachings. It was illegal, wrong, sinful and outright disgusting that lawlessnes is on rise. May God have mercy on the USA. There has to be an investigation for the good of the nation. USA is a God blessed nation. A country of light on the hill, a Judeo-Christain Republic, one nation under God.

    pleains, PA 2013-11-22 justice Albuquerque, NM 2013-11-22 Why is there no public outrage about the death of this beautiful young woman!

    The family deserves justice. My prayers go out to the family. Duncannon, PA

    2013-11-22 ditto to what Richard Lippincott posted:

    Name

    Gussie Stuffs

    Murdering an unarmed woman with a baby for erratic driving & fleeing the police is criminal. No excuse whatsoever. Those responsible need to be brought to justice. They r thugs, not hero's to be applauded by congress!

    Melvin Crager Delta, CO 2013-11-22 Many things are not right about what happened to this young woman. Sondra Young Lakeside, MT 2013-11-22 This women was murdered for a traffic violation. This never should have

    happened ever. Kamala Chunn Smyrna, TN 2013-11-22 Justice for Miriam Carey and her daughter. Marlyce Downen Louisburg, KS 2013-11-22 I am tired of all the cover ups of this administration! The shooting of this young

    woman hasn't made sense since I first read about I in the news - she was unarmed - why was she shot?

    Rudy Davis Forney, TX 2013-11-22 I want the TRUTH! Marvin Stewart Long Beach, CA 2013-11-22 I have zero tolerance for this kind of conduct. James Morgan Denver, CO

    2013-11-22 Justice charlene Jackson Upper Darby, PA 2013-11-22 The killing of this young woman unjust and the result of excessive force. Samuel Elson Glen Dale, WV 2013-11-22 The injustice of the death and subsequent silence by officials Jamie Sullivan Albuquerque, NM 2013-11-22 This beautiful lady was murdered in cold blood. She deserves a investigation

    into her murder. Mary Menefee Waterloo, SC 2013-11-22 Miscarriage of justice James Maclnness West Islip, NY 2013-11-22 An unarmed woman was gunned down. James Manning New York, NY 2013-11-22 The truth must be revealed to the American people. Jacqueline Parris San Diego, CA 2013-11-22 wanting justice John White Tucson, AZ 2013-11-22 I need to know the TRUTH and I'm to angry to comment more . I will said this ,

    I'm so very sorry for Miriam Carey and her family , God blessing on Miriam Carey and her family Amen

    Verdell Bennett New York, NY 2013-11-22 We need to ensure that justice is done for Miriam Carey with an investigation into this Capitol police and Secret Service incident.

    ronn remai 2013-11-22 I am a white male believer in Jesus Christ, and I want answers and may the truth be told. Jesus Christ will return and bring justice to this earth; though there be none now. Revelations 19:11-21 please read.

    Evelyn Parham Greenville, GA 2013-11-22 This important to me because this was a senseless murder that needs to be

    investigated. Luis Duque, Jr. Houston, TX 2013-11-22 Seeking truth. Peter CHVOSTOVSKY San Antonio, TX 2013-11-22 IF THIS WAS AN EXECUTION THERE NEEDS TO BE JUSTICE.

  • Name Location Date Comment FRED WILSON CHAPEL HILL, NC 2013-11-22 THIS WAS NOT ONLY AN INNOCENT WOMAN, BUT ALSO MY BEST

    FRIEND'S SISTER. I AM ALSO A WITNESS TO EXCESSIVE FORCE BY LAW ENFORCEMENT. I KNOW THAT OFFICERS ARE TRAINED TO USE EXCESSIVE FORCE AS A LAST RESORT BECAUSE I'VE HAD AND STILL HAVE FAMILY MEMBERS ON THE FORCE. FURTHERMORE, I DONT BELIEVE SHE HAD TO BE SHOT AND KILLED, SHE POSED NO IMMEDIATE THREAT. THIS HAS TO STOP NOW!

    2013-11-23 Highly significant because I am an American citizen committed to justice being done.

    2013-11-23 It is important because assassinations of innocent people cannot be tolerated any longer and the nefarious evil that is in control of our government has to be stopped.

    2013-11-23 We want justice for miriam carey. 2013-11-23 Because I do think she was murdered, for reason unknown to us. 2013-11-23 This was an unjustifiable homicide and cover up.This must not stand

    unchallenged.

    2013-11-23 Because a woman died needlessly from the excessive force used by the Capitol Police

    2013-11-23 Miriam Carey was the sister of a friend of mine (Valerie Carey) so this cause is near & dear to my heart. A beautiful & young spirit gone too soon, an innocent life cut down, extinguished. We as a people must speak up & out against atrocities such as this to prevent others from occurring.

    Maryam Jamilah clute, TX

    Kenneth Senese Hodgkins, IL

    Ali James Fort Lauderdale, FL

    Darlene Rowe West Covina, CA

    Nancy Smith

    Redding, CA

    JoAnn Bjorkman Sylvania, GA

    Dania Bermudez Corona, NY, NY

    My condolences to the Carey family

    R.I.P. Miriam Carey

    2013-11-23 "The Truth shall make you free!"

    2013-11-23 If it was my sister I would want answers...REAL answers not the tom foolery we hear on the news. They did NOT have to kill or shoot her. They easily could have shot out her tires like they "usually" do in cases like this.

    2013-11-23 The tragic death of Miriam Carey has to get a proper investigation. 2013-11-23 Is it really true that this petition has not reached 500 signatures yet? I thought I

    would be perhaps number 468 000 signing the petition, not 468. Incredible. 2013-11-23 I just feel that before a life is taken we must look at the Situation as if it was our

    personal family member and then make a judgement call. 2013-11-23 There's clearly a cover up going on here! She deserves justice! 2013-11-23 because police shoot and could have tazered instead to much foolishness and

    we wonder why this society is going to shit

    2013-11-24 Justice the her, her sister & the baby.

    2013-11-24 Because the family deserves justice. 2013-11-24 she is a black woman that had alot on her mind with a daughter that will never

    see her mother again please help us to stop this police the police from killing innocent people

    2013-11-24 This is one of my close friend's relative.

    2013-11-24 this is a coverup and disgrace to all humankind!

    Mary Spence

    Vikki Kennedy

    Magnus Johansson

    Magnus Johansson

    Shelbia Whitfield

    Kim Hipps

    DAVID VALENTINE

    Stoney Star Anderson

    Trinity Anderson

    kathy hines

    Washington, DC

    Stockholm, Sweden

    Stockholm, Sweden

    Newark, DE

    Nashville, TN

    glendale heights, IL

    Huntsville, AR

    Huntsville, AR

    Baltimore, MD

    Gregory Mitchell North Chesterfield. VA

    Rita Cooney foothill ranch, CA

  • EXHIBIT 2

  • FTCA Administrative Claims X IN RE: MIRIAM IRIS CAREY

    Claimant,

    -against-

    UNITED STATES OF AMERICA; UNITED STATES SECRET SERVICE and UNITED STATES CAPITOL POLICE

    Respondents X To:

    Respondents' UNITED STATES OF AMERICA; UNITED STATES SECRET SERVICE and UNITED STATES CAPITOL POLICE

    United States of America do United States Department of Justice 900 Pennsylvania Avenue NW Washington, DC 20530-0001

    United States Secret Service do United States Department of Homeland Security Office of the General Counsel 245 Murray Lane Mail Stop 0485 Washington, DC 20528-0485

    United States Capitol Police do Chief Kim Dine 119 D Street NE Washington, DC 20510

    United States Capitol Police do The Capitol Police Board S-151 The Capitol Washington, DC 20510

  • CLAIMANTS'

    1. The Estate of Miriam Iris Carey by and through her personal representative Valarie Carey on behalf of decedent's mother Idella Carey.

    2. Idella Carey, the decedent's mother and grandmother of minor grandchild EF, the decedent's daughter.

    3. EF, the minor child of decedent Miriam Iris Carey

    2

  • AMOUNTS OF CLAIMS

    Each claimant seeks $25,000,000.00 (Twenty-five million dollars). The aggregate sum certain sought by all claimants is $75,000,000.00 (Seventy-five

    million dollars)

    BASIS OF CLAIMS

    1. These claims for the wrongful death of decedent Miriam Iris Carey arise under

    the Federal Tort Claims Act (28 U.S.C. 1346(b), 2401(b), 2674, 2675(a), 2679, and 2680(h)); the Wrongful Death Act of the District of Columbia (D.C. Code 16 2701 et seq.); the Fourth Amendment (Unlawful Search of the Person, Unlawful Search of Property, Unlawful Seizure of Person, Excessive Force, Unlawful Seizure of Property); Fifth Amendment (Due Process and Equal Liberty) and other related local and common law claims.

    2. The claims arise from the numerous intentional, grossly negligent and reckless actions of police officers, supervisors, managers and other related employees' assigned to the

    United States Secret Service Uniform Division and United States Capitol Police, their

    collective actions caused the avoidable wrongful death of decedent Miriam Iris Carey.

    3. The decedent Miriam Iris Carey was born from the loving union of Leon Faules

    (deceased 1987) and Idella Carey on August 12, 1979 in Brooklyn, N.Y., the fourth of their five daughters.

    4. Mother, Daughter, Sister and Friend, decedent Miriam Iris Carey held an

    important place in the lives of many.

    5. Decedent Miriam Iris Carey grew up in East New York, Brooklyn, where she learned to face life's challenges with a spirit of self-determination.

    6. Decedent Miriam Iris Carey was an achiever who consistently sought to reach

    3

  • her life goals.

    7. Decedent Miriam Iris Carey had a passion for cooking and loved life. 8. Decedent Miriam Iris Carey's greatest joy was spending time with her minor

    child EF, as well as family and friends.

    9. Decedent Miriam Iris Carey, RDH, was a licensed dental hygienist.

    10. Decedent Miriam Iris Carey graduated from Brooklyn College with a Bachelor's of Science Degree in Health and Nutrition Services.

    11. Decedent Miriam Iris Carey aspired to teach others in the field of dentistry.

    12. At the time of decedent Miriam Iris Carey's death, 34, her minor child EF; Mother Idella Carey and Sisters Franchette R. Carey, Valarie Carey, Amy M. Carey-Jones, Andrea D. Carey and Cordelia Denise Jones-Hayden; Brother Kenneth Leon Jones and a host of other family members and friends survived her.

    ALLEGED FACTS OF THE CLAIMS1

    13. Decedent Miriam Iris Carey was traveling in her 2010 Infiniti G37XS Coupe near the vicinity of 15th Street NW and E Street NW, which is one of the White House gate entrances.

    14. Decedent Miriam Iris Carey was legally operating the vehicle, her minor child EF was seated in a child safety seat in the rear of the vehicle.

    15. Decedent Miriam Iris Carey being unfamiliar with the area, mistakenly drove past the first guard post at the White House gate entrance because the entrance was negligently maintained, covered and supervised by police officers, supervisors, managers and other related

    This administrative claim details information available at the time of filing. Claimants' reserves the right to amend this administrative claim for consideration during the presentment and investigation phase to the United States of America; United States Secret Service Uniform Division and United States Capitol Police.

    4

  • employees' assigned to the United States Secret Service Uniform Division.

    16. After realizing her innocent mistake, decedent Miriam Iris Carey made a U-turn

    to leave the area heading a short distance eastbound on E Street NW back towards 15th Street

    NW.

    17. For some inexplicable reason, instead of simply allowing decedent Miriam Iris

    Carey to leave the area, a police officer assigned to the United States Secret Service Uniform

    Division without provocation or legal justification, inconsistent with his or her police training, intentionally, negligently and recklessly threw a bicycle rack at the vehicle striking it.

    18. At the time, decedent Miriam Iris Carey had committed no crime or violation of

    any other law, thus, the police had no legal basis to stop her or use any amount of physical

    force against her.

    19. The police officer's actions slightly damaged her vehicle, more importantly,

    startled her which endangered her safety, her minor child EF and public.

    20. In the process of seeing the bicycle rack being thrown towards her vehicle, to

    protect herself and her minor child EF, decedent Miriam Iris Carey panicked and headed

    eastbound on Pennsylvania Avenue NW.

    21. Numerous police officers, supervisors, managers and other related employees'

    in government motor vehicles began to pursue decedent Miriam Iris Carey and her minor child

    EF endangering their lives and the public.

    22. Police officers, supervisors, managers and other related employees'

    inconsistent with their police training and department policies, failed to terminate pursuing

    decedent Miriam Iris Carey and her minor child EF as the risk to them, the public, the police

    officers, supervisors, mangers and other related employees' outweighed the benefit of

    5

  • investigating a harmless mistaken entrance through the White House entrance gate.

    23. Police management and radio dispatchers, inconsistent with their police

    training and department policies, failed to order police officers, supervisors, managers and

    other related employees' immediately to terminate pursuing decedent Miriam Iris Carey and

    her minor child EF, as the risk to them, the public, the police officers, supervisors, mangers and other related employees' outweighed the benefit of investigating a harmless mistaken

    entrance through the White House entrance gate.

    24. In complete fear, decedent Miriam Iris Carey continued traveling eastbound on Pennsylvania Avenue NW, then at the corner of 3"1 Street SW, made a right heading

    southbound on 3rd Street SW, still pursued by numerous police officers, supervisors, managers

    and other related employees in government motor vehicles.

    25. At the corner of Maryland Avenue SW, decedent Miriam Iris Carey made a left turn heading eastbound on Maryland Avenue SW and struck a curb near 10 Maryland Avenue

    SW after being forced over by numerous police officers, supervisors, managers and other

    related employees' in government motor vehicles.

    26. Police officers, supervisors, managers and other related employees' on foot

    assigned to the United States Secret Service Uniform Division and the United States Capitol

    Police surrounded decedent Miriam Iris Carey and her minor child EF.

    27. The immediate area moderately populated with vehicular and pedestrian traffic.

    28. The police officers, supervisors, managers, and other related employees' on

    foot approached decedent Miriam Iris Carey's vehicle with their service weapons drawn,

    pointed in the ready position to be fired.

    29. The senior police officers, supervisors and managers never established firearms

    6

  • control consistent with their police training and department policies.

    30. Decedent Miriam Iris Carey noticing these police officers, supervisors,

    managers and other related employees' approaching with their service weapons drawn,

    pointed in the ready position to be fired, in an attempt to protect herself and her minor child

    EF, panicked, placing her vehicle in reverse accidentally striking a marked police vehicle.

    31. Police officers, supervisors, managers and other related employees' from the

    United States Secret Service Uniformed Division and United States Capitol Police without

    establishing firearms control or legal justification, inconsistent with their police training and department policies discharged their service weapons at decedent Miriam Iris Carey's moving vehicle.

    32. Claimants' believe one or more of the discharged rounds entered decedent

    Miriam Iris Carey's vehicle striking her body, mortally wounding her.

    33. Claimants' believe decedent Miriam Iris Carey experienced shock and

    substantial pain throughout her body.

    34. At the time of the firearm discharges, the police officers, supervisors, managers

    and other related employees' from the United States Secret Service Uniformed Division and

    United States Capitol Police already knew decedent Miriam Iris Carey did not use any firearm

    or other form of deadly physical force against them or others.

    35. At the time of the firearm discharges, the police officers, supervisors, managers and other related employees' from the United States Secret Service Uniformed Division and United States Capitol Police already knew decedent Miriam Iris Carey had committed no

    crime or violation of any other law that would justify discharging their service weapons towards her.

    7

  • 36. At the time of the firearm discharges, the police officers, supervisors, managers and other related employees' from the United States Secret Service Uniformed Division and

    United States Capitol Police already knew decedent Miriam Iris Carey's minor child EF was

    in the rear passenger area of the vehicle but fired anyway.

    37. Despite having actual and/or constructive knowledge as indicated in Allegation

    Nos.: 1 through 34, the police officers, supervisors, managers and other employees from the

    United States Secret Service Uniformed Division and United States Capitol Police discharged their firearms anyway endangering decedent Miriam Iris Carey, her minor child EF and the public.

    38. The firearms discharge occurred as decedent Miriam Iris Carey headed

    eastbound on Maryland Avenue SW towards the Garfield Memorial, then northbound on 1st

    Street NW past the Peace Circle.

    39. Police officers, supervisors, managers and other related employees' from the

    United States Secret Service Uniformed Division and the United States Capitol Police

    continued to pursue now mortally wounded decedent Miriam Iris Carey in numerous

    government motor vehicles.

    40. Despite sustaining a mortal wound, decedent Miriam Iris Carey continued

    traveling northbound on 1st Street NW, then at the corner of Constitution Avenue NW, made a

    right heading eastbound on Constitution Avenue NW, still pursued by numerous government motor vehicles.

    41. Decedent Miriam Iris Carey stopped her vehicle near the corner of 2nd Street

    NE and Constitution Avenue NE.

    42. Decedent Miriam Iris Carey noticing even more armed police officers panicked

    8

  • abruptly turning left over a median, quickly reversing her vehicle where numerous police

    officers, supervisors, managers and other employees' from the United States Secret Service

    Uniformed Division and United States Capitol Police without establishing firearms control and legal justification discharged their service weapons.

    43. Decedent Miriam I. Carey sustained numerous injuries about her body, further shock, substantial pain and damage to her vehicle.

    44. Decedent Miriam Iris Carey was removed from the vehicle alive.

    45. Decedent Miriam Iris Carey's minor child EF was not physically injured. 46. Decedent Miriam Iris Carey was transported to Medstar Washington Hospital

    Center where she was pronounced dead by Dr. Christine Trankiem.

    47. Decedent Miriam Iris Carey was later transported to the Office of the Chief Medical Examiner for an autopsy.

    48. Claimant Idella Carey, decedent Miriam Iris Carey's mother, as well as Sisters Franchette R. Carey, Valarie Carey, Amy M. Carey-Jones, Andrea D. Carey and Cordelia Denise Jones-Hayden; Brother Kenneth Leon Jones and a host of other family members and

    friends viewed some or all parts of this very public shooting that was broadcasted live over the television airwaves.

    49. Since the death of decedent Miriam Iris Carey, not one federal government has

    contacted claimants' to express condolences for their loss.

    50. Other than questioning Claimant Idella Carey, decedent Miriam Iris Carey's mother, as well as Sisters Franchette R. Carey, Valarie Carey, Amy M. Carey-Jones, Andrea

    D. Carey and Cordelia Denise Jones-Hayden; Brother Kenneth Leon Jones and a host of other family members by the Federal Bureau of Investigation and the United States Secret Service

    9

  • about decedent Miriam Iris Carey's personal activities, not one member of the United States

    Secret Service Uniform Division or the United States Capitol Police officially notified them of

    decedent's death consistent with department policies.

    51. Because of the intentional, negligent and reckless actions of police officers, supervisors, managers and other related employees' assigned to the United States Secret

    Service Uniform Division and United States Capitol Police, they collectively caused the avoidable death of decedent Miriam Iris Carey.

    52. Because of the intentional, negligent and reckless actions of police officers, supervisors, managers and other related employees' assigned to the United States Secret

    Service Uniform Division and United States Capitol Police claimants sustained substantial damages.

    PRAYER FOR RELIEF

    Claimants pray that the United States of America; United States Secret Service

    Uniform Division and United States Capitol Police will:

    53. Conduct a full and comprehensive investigation into the claims;

    54. Determine there is substantial competent evidence to support claims presented

    herein;

    55. Determine the intentional, negligent and reckless actions of police officers, supervisors, managers and other related employees' assigned to the United

    States Secret Service Uniform Division and United States Capitol Police were

    acting within the scope of their employment;

    56. Determine as a result of the intentional, negligent and reckless actions of police

    officers, supervisors, managers and other related employees' assigned to the

    10

  • United States Secret Service Uniform Division and United States Capitol Police, they collectively caused the avoidable death of decedent Miriam Iris

    Carey, therefore, such wrongful actions are imputed to the United States of America; and

    57. Determine the United States of America is liable for the avoidable death of decedent Miriam his Carey and immediately pay all compensatory damages to the claimants.

    Dated: January 24, 2014 New York, NY

    Respectful submitted,

    By: Eric Sanders

    Eric Sanders, Esq. THE SANDERS FIRM, P.C. 1140 Avenue of the Americas, 9th Floor New York, NY 10036

    Website: http://www.thesandersfirmpc.corn

    11

  • EXHIBIT A

  • FIS TADERS FIRM, PC 1140 Avenue of the Americas, 9th Floor, New York, NY 10036 Phone: Fax: Email:

    Facebook: thesandersfirmec

    October 3, 2013

    Ms. Idella Carey o/b/o The Estate of Miriam I. Carey 1167 Stanley Avenue, Apt 2E Brooklyn, NY 11208

    MASTER RETAINER AGREEMENT

    I. LEGAL SERVICES FEE

    This Master Retainer Agreement will confirm the agreement between "You," the "Client" and THE SANDERS FIRM, P.C., the "Firm." "You," the "Client," have agreed to retain the "Firm" in connection with investigating claims related to Medical Malpractice, Civil Rights violations or other violations of law o/b/o Decedent Miriam I. Carey in the State of Connecticut, New York, the District of Columbia or any other jurisdiction. The "Firm" will handle and represent "You," the "Client" throughout the entire process of investigating any claims o/b/o Decedent Miriam I. Carey.

    "You," the "Client" will remit to the "Firm," a Legal Services Fee of 0.00, for its' acceptance of "You," as a "Client," for the purposes of investigating claims related to Medical Malpractice, Civil Rights violations or other violations of law o/b/o Decedent Miriam I. Carey, in the State of Connecticut, New York, the District of Columbia or any other jurisdiction. This Master Retainer Agreement does not cover Costs and Disbursements associated with investigating claims related to Medical Malpractice, Civil Rights violations or other violations of law o/b/o Decedent Miriam I. Carey in the State of Connecticut, New York, the District of Columbia or any other jurisdiction as defined in Paragraph II and III.

    "You," the "Client," agree that any Legal Services Fees due and owed to the "Firm" not paid within fifteen (15) days of receipt of the invoice will incur a monthly charge of one and one-half percent (1.5%) compound interest until PAID IN FULL.

    "You," the "Client," agree, that if you present a financial instrument to the "Firm" such as a check, money order and/or credit card, for the payment of legal services as defined in Paragraph I, that is dishonored then "You," the "Client," agree to reimburse the "Firm" for any service fees.

    II. COURT AWARDS

    As compensation for costs and services rendered in the future, the exact amount of which

  • is not ascertainable, in the event that the appropriate federal court award costs and fees in this matter, the calculations will be based upon the following rates:

    1. Hourly rate of Senior Attorneys/Partners $ 675.00; 2. Hourly rate of Senior Associates $ 525.00; 3. Hourly rate of Associates: $ 475.00; 4. Hourly rate of Paralegals/Support Staff: $ 175.00; 5. All other costs and fees billed against this matter will reflect the actual

    costs and fees incurred by the "Firm," with the exception of internal printing, photocopying, and scanning costs that will be billed at .12 cents per page; and 6. The compensation for costs and services as outlined in this paragraph

    applies regardless of any other monies owed and/or received pursuant to the Contingency Fee as defined in Paragraph IV hereafter.

    III. COSTS AND DISBURSEMENTS

    "You," the "Client," agree to pay the "Firm" at each stage of this matter, all Costs and Disbursements associated with investigating claims related to Medical Malpractice, Civil Rights violations or other violations of law o/b/o Decedent Miriam I. Carey in the State of Connecticut, New York, the District of Columbia or any other jurisdiction as incurred by the "Firm." This may include, but is not limited to, filing fees, service fees, sworn depositions fees, expert fees, printing, photocopying, scanning, emailing, etc. "You," the "Client," agree that any Costs and Disbursements due and owed to the

    "Firm" not paid within fifteen (15) days of receipt of the invoice will incur a monthly charge of one and one-half percent (1.5%) compound interest until PAID IN FULL. "You," the "Client," agree, that if you present a financial instrument to the "Firm"

    such as a check, money order and/or credit card, for the payment of Costs and Disbursements as defined in Paragraph III, that is dishonored, then "You," the "Client," agree to reimburse the "Firm" for any service fees.

    IV. CONTINGENCY FEE

    "You," the "Client" has further agreed that if investigating claims related to Medical Malpractice, Civil Rights violations or other violations of law o/b/o Decedent Miriam I. Carey in the State of Connecticut, New York, the District of Columbia or any other jurisdiction rights results in a settlement agreement, with or without the filing of a lawsuit and/or judicial intervention, then "You," the "Client" agrees to pay the "Firm," thirty-three and one third percent (33 1/3%) of any monies so received, as a Contingency Fee. V. RIGHTS AND RESPONSIBILITIES

    "You," the "Client" agrees that other members of the "Firm" and/or other members hired I Printing, photocopying and scanning costs are billed at a rate of .12 cents per page.

    2

  • by the "Firm," may perform substantial work on this matter and/or appear on your behalf. This may occur due to legal qualifications, time conflicts, illness, attention to other matters or in accordance with State Bar requirements, etc.

    "You," the "Client" agrees that you have an affirmative obligation to keep the "Firm" informed as to any changes that may influence the outcome of these matters.

    "You," the "Client" agrees that the "Firm" shall keep you informed as to the progress of these matters. These matters and the progress are open to "You," the "Client," for your physical inspection with advance notice to the "Firm."

    "You," the "Client" agrees that you are aware of the unique hazards of handling legal matters, and that despite the best efforts of the "Finn," the "Firm" CANNOT guarantee a result. However, the "Firm" will handle these matters expeditiously and efficiently in accordance with its goal to provide the highest legal and ethical standards.

    "You," the "Client" agrees that when these matters are ready for hearing and/or trial, any monies due and owed to the "Firm" must be PAID IN FULL otherwise, the "Firm" reserves the right to move to terminate the Attorney-Client relationship2 consistent with DR 2-110. 2 DR 2-110 [1200.151 Withdrawal from Employment A. In general

    1. If permission for withdrawal from employment is required by the rules of a tribunal, a lawyer shall not withdraw from employment in a proceeding before that tribunal without its permission.

    2. Even when withdrawal is otherwise permitted or required under section DR 2-110 [1200.15] (A)(1), (B), or (C), a lawyer shall not withdraw from employment until the lawyer has taken steps to the extent reasonably practicable to avoid foreseeable prejudice to the rights of the client, including giving due notice to the client, allowing time for employment of other counsel, delivering to the client all papers and property to which the client is entitled and complying with applicable laws and rules. 3. A lawyer who withdraws from employment shall refund promptly any part of a fee paid in advance that has not been earned.

    B. Mandatory withdrawal

    A lawyer representing a client before a tribunal, with its permission if required by its rules, shall withdraw from employment, and a lawyer representing a client in other matters shall withdraw from employment, if: 1. The lawyer knows or it is obvious that the client is bringing the legal action, conducting the defense, or asserting a position in the litigation, or is otherwise having steps taken, merely for the purpose of harassing or maliciously injuring any person. 2. The lawyer knows or it is obvious that continued employment will result in violation of a Disciplinary Rule. 3. The lawyer's mental or physical condition renders it unreasonably difficult to carry out the employment effectively.

    4. The lawyer is discharged by his or her client.

    C. Permissive withdrawal.

    3

  • In any event, the "Firm," will enforce its right under N.Y. Jud. Law 475, and petition the Court, to enforce an attorney lien upon the matter for recovery of its legal fees, costs and disbursements.

    VI. TERMINATION OF THIS MASTER RETAINER AGREEMENT

    "You," the "Client" agrees that if you elect to terminate this Master Retainer Agreement prior to the completion of all of the legal services contemplated by the "Firm," then "You," the "Client" will be promptly billed in accordance with the rates specified in Paragraph II herein.

    In any event, the "Firm," will enforce its rights under N.Y. Jud. Law 475, and petition the Court, to enforce an attorney lien upon the matter for recovery of its legal fees, costs and disbursements.

    "You," the "Client," agree that any outstanding Termination Fees and/or Costs and Disbursements due and owed to the "Firm" not paid within fifteen (15) days of receipt of

    Except as stated in DR 2-110 [1200.151(A), a lawyer may withdraw from representing a client if withdrawal can be accomplished without material adverse effect on the interests of the client, or if:

    1. The client

    a. Insists upon presenting a claim or defense that is not warranted under existing law and cannot be supported by good faith argument for an extension, modification, or reversal of existing law.

    b. Persists in a course of action involving the lawyer's services that the lawyer reasonably believes is criminal or fraudulent.

    c. Insists that the lawyer pursue a course of conduct which is illegal or prohibited under the Disciplinary Rules.

    d. By other conduct renders it unreasonably difficult for the lawyer to carry out employment effectively.

    e. Insists, in a matter not pending before a tribunal, that the lawyer engage in conduct which is contrary to the judgment and advice of the lawyer but not prohibited under the Disciplinary Rules. f. Deliberately disregards an agreement or obligation to the lawyer as to expenses or fees.

    g. Has used the lawyer's services to perpetrate a crime or fraud.

    2. The lawyer's continued employment is likely to result in a violation of a Disciplinary Rule.

    3. The lawyer's inability to work with co-counsel indicates that the best interests of the client likely will be served by withdrawal.

    4. The lawyer's mental or physical condition renders it difficult for the lawyer to carry out the employment effectively.

    5. The lawyer's client knowingly and freely assents to termination of the employment.

    6. The lawyer believes in good faith, in a proceeding pending before a tribunal, that the tribunal will find the existence of other good cause for withdrawal.

    4

  • Sincerely,

    Eric Sanders

    Idella Carey

    the invoice will incur a monthly charge of one and one-half percent (1.5%) compound interest until PAID IN FULL.

    "You," the "Client," agree, that if you present a financial instrument to the "Firm" such as a check, money order or credit card, for the payment of the Termination Fee and/or Costs and Disbursements as defined in Paragraphs II, III and VI, that is dishonored then "You," the "Client," agree to reimburse the "Firm" for any service fees.

    VII. APPEALS

    This Master Retainer Agreement does not cover any appeals to the State of Connecticut, New York, the District of Columbia or any other jurisdictions appeals courts, the Second Circuit Court of Appeals, District of Columbia Court of Appeals or the Supreme Court of the United States.

    VIII. ARBITRATION "You," the "Client" agrees that if a Fee Dispute arises, you may have the right to

    arbitration of such dispute pursuant to Part 137 of the Rules of the Chief Administrator of the Courts, a copy of which is available upon request.

    SIGNED AND ACCEPTED ON THE ABOVE TERMS

    5

  • DURABLE GENERAL POWER OF ATTORNEY

    NEW YORK STATUTORY SHORT FORM

    THE POWERS YOU GRANT BELOW CONTINUE TO BE E141+ECTIVE SHOULD YOU BECOME DISABLED OR INCOMPETENT

    Caution: This is an important document. It gives the person whom you designate (your "Agent") broad powers to handle your property during your lifetime, which may Include powers to mortgage, sell, or otherwise dispose of any real or personal property without advance notice to you or approval by you. Then powers will continue to exist even after you become disabled or incompetent These powers are explained more fully In New York General Obligations Law, Article 5, Title 15, Sections 5-1502A through 5-1503, which expressly permit the use of any other or different form of power of attorney.

    This document does not authorize anyone to make medical or other health care decisions. You may execute a health care proxy to do this.

    If there is anything about this form that you do not understand, you should ask a lawyer to explain it to you.

    THIS is intended to constitute a DURABLE GENERAL POWER OF ATTORNEY pursuant to Article 5, Title 15 of the New York General Obligations Law:

    64ei hereby appoint: 4kis9ie. (irEsertyour name and address)

    (If one person is to be appointed agent, insert the name and address of your agent above)

    (If two or more persons are to be appointed agents by you, insert their name and addresses above)

    my attorney(s)-in-fact TO ACT

    (If more than one agent is designated CHOOSE ONE of the following two choices by putting your initials in ONE of the blank spaces to the left of your choice:)

    E.:1e, Each agent may SEPARATELY act. [ All agents must act TOGETHER.

    (If neither blank space is initialed the agents will be required to act TOGETHER)

    IN MY NAME, PLACE AND STEAD, in any way which I myself could do, if I were personally present, with respect to the following matters as each of them is defined in Title 15 of Article 5 of the New York General Obligations Law to the extent that I am permitted by law to act through an agent:

    DIRECTIONS: Initial in the blank space to the left of your choice any one or more of the following lettered subdivisions as to which you WANT to give your agent authority. If the blank space to the left of any particular lettered subdivision is NOT initialed, NO

  • [V... (Q) each of the above matters iikritifipal by the following lette 4\-(1110

    2

    AUTHORITY WILL BE GRANTED for matters that are included in that subdivision. Alternatively, the letter corresponding to each power you wish to grant may be written or typed on the blank line in subdivision "(Q)", and you may then put your initials in the blank space to the left of subdivision "(Q)" in order to grant each of the powers so indicated.)

    ] (A) real estate transactions;

    ] (B) chattel and goods transactions;

    (C) bond, share and commodity transactions;

    ] (D) banking transactions;

    j (E) business operating transactions;

    ] (F) insurance transactions;

    ] (G) estate transactions;

    ] (H) claims and litigation;

    ] (I) personal relationships and affairs;

    ] (J) benefits from military service;

    ] (K) records, reports and statements;

    ] (L) retirement benefit transactions;

    ] (M) making gifts to my spouse, children and more remote descendants, and parents, not to exceed in the aggregate $10,000 to each of such persons in any year;

    ] (N) tax matters;

    ] (0) all other matters;

    ] (P) full and unqualified authority to my attorney(s)-in-fact to delegate any or all of the foregoing powers to any person or persons whom my attomey(s)-in-fact shall select;

    (Special provisions and limitations may be included in the statutory short form durable power of attorney only if they conform to the requirements of 5-1503 of the New York General Obligations Law.)

    This Durable Power of Attorney shall not be affected by my subsequent disability or incompetence.

    If every agent named above is unable, or unwilling to serve, I appoint (insert name and address of successor) to be my agent for all purposes hereunder

    To induce any third party to act hereunder, I hereby agree that any third party receiving a duly executed copy or facsimile of this instrument may act hereunder, and that revocation or termination hereof shall be ineffective as to such third party unless and until actual notice or knowledge of such revocation or termination shall have been received by such third party, and I for myself and for my heirs, executors, legal representatives and assigns, hereby agree to indemnify and hold harmless any such third party from and against any and all claims that may arise against such third party by reason of such third

  • 3

    party having relied on the provisions of this instrument.

    This Durable General Power of Attorney may be revoked by me at any time.

    In Witness Whereof, I have hereunto signed my name this day of I)1302019...943

    (YOU SIGN HERE:) -4

    (Signature of Principal)

    ACKNOWLEDGMENT (for use within the State of New York)

    STATE OF NEW YORK, COUNTY OF ar....

    ss.:

    On the (t1I day of `/ft O% in the year , before me, the undersigned, a Notary Public in and for said State, personally appeared

    ...11E1

    ..

    AA\

    personally known to me or proved to me on the basis of satisfactory evidence to be the individual(s) whose name(s) is (are) subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their capacity(ies), and that by his/her/their signature(s) on the instrument, the individual(s), or the person upon behalf of which the individual(s) acted, executed the instrument.

    Notary Public: State of New York CVS

    Nt). Dabis(;.1 7)6"aa eti41 ) ACKNOWLEDGMENT Ao,aovii

    (for use outside the State of New York)

    STATE OF , COUNTY OF ss.:

    On the day of

    in the year , before me, the undersigned, a Notary Public in and for said State, personally appeared

    personally known to me or proved to me on the basis of satisfactory evidence to be the individual(s) whose name(s) is (are) subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their capacity(ies), and that by his/her/their signature(s) on the instrument, the individual(s), or the person upon behalf of which the individual(s) acted, executed the instrument, and that such individual made such appearance before the undersigned in

    (Insert city or political subdivision and state or county or other place acknowledgment taken).

    (Signature and office of individual taking acknowledgment) 1/1/2000

  • EXHIBIT B

  • t

    AO 93 (Rev. 12109) Search and Sei7ACC Warrant

    UNI FED STATES DISTRICT COURT for the

    District Of Columbia

    In the Matter of the Search of 2010 Nissan Infiniti

    Bearing CT License Plate No. 323-YNS and )

    Vehicle Identification No: JNICV6EL413M261683 )

    Case 1: 13-inj-744 Assigned to: Magistrate Judge Deborah A. Robinson Assigned Date: 10/4/2013 Description: Search and Seizure Warrant

    SEARCH AND SEIZURE WARRANT

    To: Any authorized law enforcement officer

    An application by a federal law enforcement officer or an attorney for the government requests the search of the following person or property located in the N/A District of Columbia

    A 2010 Nissan Infiniti, black in color, Conneticut License No. 323-YNS and Vehicle Identification Number JN I CV6EL413M261683.

    The person or property to be searched, described above, is believed to conceal expended bullets or bullet fragmenM vehicle ownership paperwork; maps, documents, and/or photographs of, or pertaining to, the White House; alcohol or drugs (legal or illegal); and/or evidence of a mechanical malfunction or tack thereof may be inside the sus t vehicle

    I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or ProPettY.

    YOU ARE COMMANDED to execute this warrant on or before (not to exceed 14 days)

    El at any time in the day or night as I find reasonable cause has been establ ished.

    ]in the daytime 6:00 am. to 10 p.m.

    Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the property was taken.

    The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory as required by law and promptly return this warrant and inventory to United States Magistrate Judge

    (name)

    Ell find that immediate notification may have an adverse result listed in 18 U.S.C. 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized (check the appropriate box) q for days (not to exceed M-

    O until, the facts justifying, the later specif date of

    Date and time issued: -OCT -4 2013 City and state: Washington, D.C.

    e signs

    Deborah A. Robinson, U.S. Magistrate Judge Printed name and title

  • 93 . 12/09 Search and Sei=urr Warrant (Page 2)

    Return

    Case No..- i -- -. r71- 4

    Date and lime warrant executed: fv-S 10/1/13 LoN ; loi 11 6 :0:43

    Copy of warrant and inventory left with:

    OW-i cer C7 L cccov._%,,\-1- Invent made in the presence of : Lt . r tuce...5,11.55t Po.u.k. tu ass; yes_ z-c)C1S-D ite3 \AC.-,,rf`.. )1A(SS rnoiael okfirciNi usSS a.,65,-11, k.illori,s'API:. evr-yev* CC Er Inventory of the property taken and name of any person(s) seized:

    (LI (AWA-0T-C-ret1-5 1-ifi:)" c rt--)je.r-AL' le5 (-1) 'C' rctr-p-QuNt ""vr-l.kiv ",t-CAICA-C

    FILED OCT- 8 2013

    Clerk U.S. District & Ban Courts for the District of Columbia

    Certification

    I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the designated judge.

    Date: 107- 1. 3 al 6* Executing r 's signarkeire

    Fe. lic; 6thcf...cs / hit eui-t()G,-t i MR Printed name and fide

  • Applicant's si ture

    AO 106 (Rev. 06/09) Applicatioe fora Starch Warrant

    UNITED STATES DISTRICT COURT for the

    District of Columbia

    In the Matter of the Search of (Briefly describe the properly to be searched or like:* the person by name and address)

    2010 Nissan Infiniti Bearing CT License Plate No: 323-YNS and

    Vehicle Identification No: JN1CV6EL413M261683

    Case 1: 13-mj-744 Assigned to: Magistrate Judge Deborah A. Robinson Assigned Date: 10/4/2013 Description: Search and Seizure Warrant

    APPLICATION FOR A SEARCH WARRANT

    I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under penalty of perjury that I have reason to believe that on the following person or property (ides,* the person or describe the property to be searched and give its /ocation):A 2010 Nissan Infiniti, black in color, Conneticut License No. 323-YNS and Vehicle Identification Number JN1CV6EL413M261683.

    located in the District of Columbia , there is now concealed (ideiri6 the person or describe the property to be seized): expended bullets or bullet fragments; vehicle ownership paperwork; maps, documents, and/or photographs of, or pertaining to the White House; alcohol or drugs (legal or illegal); and/or evidence of a mechanical malfunction or lack thereof may be Inside the suspect vehicle

    The basis for the search under Fed. R. Crim. P. 4I(c) is (check one or more): fif evidence of a crime; isf contraband, fruits of crime, or other items illegally possessed;

    property designed for use, intended for use, or used in committing a crime; 0 a person to be arrested or a person who is unlawfully restrained.

    The search is related to a violation on.

    Code Section

    18 U.S.C. 242 Deprivation of Rights Under or of Law

    The application is based on these facts:

    See Attached Affidavit in Support of Search Warrant

    !if Continued on the attached sheet. 0 Delayed notice of days (give exact ending date if more than 30 days:

    under 18 US.C. 3103a, the basis of which is set forth on the attached sheet.

    ) is requested

    Felicia Lucas, LT, MPD Printed name and title

    Sworn to before me and signed in my presence.

    Date: OC T 4 2013

    City and state: Washington, D.C. Deborah A. Robinson, United States Magistrate Judge Printed name and title

    _Offense Description

  • United States District Court For the

    District of Columbia Case 1: 13-mj-744 AFFIDAVIT IN SUPPORT OF A SEARCH WA Assigned to: Magistrate Judge Deborah A. Robinson

    Assigned Date: 10/4/2013 Description: Search and Seizure Warrant

    FOR THE ENTIRE VEHICLE, INFINITY, G37XS, VEHICLE IDENTIFICATION NUMBER (VIN#) JN1CV6EL413M261683, CONNECTICUT LICENSE # 323-YNS. THE VEHICLE IS DESCRIBED AS A TWO (2) DOOR, BLACK COLORED, 2010 NISSAN INFINITI LT. RESUME: Your affiant is a sworn member of the Metropolitan Police Department, assigned to the Internal Affairs Bureau (IAB), Internal Affairs Division (IAD), and has been so employed for more than (19) nineteen years. Your affiant is currently assigned to the Internal Affairs Division (IAD). Your affiant has investigated a variety of criminal offenses. She has arrested and assisted in arresting numerous subjects for various offenses, and assisted with the preparation and execution of numerous search warrants.

    POLICE REPORT: On Thursday, October 3, 2013, Detectives of the Metropolitan Police Department's Internal Affairs Division, became involved in the investigation of a police involved shooting.

    This incident began on Thursday, October 3, 2013, at approximately 2:18 p.m. at a vehicle checkpoint to the White House, located at 15th and E Street, Northwest, Washington, D.C. Members of the United States Secret Service, Uniformed Division, (hereinafter, "USSS-UD), encountered the aforementioned vehicle at 15th

    and E Streets Northwest, Washington D.C.. The suspect vehicle was being operated by a black female (hereinafter, "Decedent"). Decedent refused to stop at the vehicle checkpoint and made a U-turn and began to flee in the vehicle. A USSS-UD officer attempted to block the vehicle with a bicycle rack, however, the vehicle pushed over the bicycle rack, knocking the officer to the ground.

    Officers from the USSS-UD initiated a pursuit of the suspect vehicle. Decedent was observed operating the vehicle erratically, violating several District of Columbia traffic regulations. Decedent entered a traffic circle against the flow of traffic and drove onto a curb in front of #10 Maryland Avenue, Southwest, Washington DC. The suspect vehicle was immediately surrounded by officers from the USSS-UD, and United States Capitol Police (hereinafter, "USCP"). Decedent then drove the suspect vehicle in reverse, striking a USSS-UD police vehicle. Members from both. USSS-UD and USCP then discharged their service weapons at the vehicle. Decedent then drove the suspect vehicle off the curb, traveling northbound on First Street, Northeast and then eastbound in the 100 block of Constitution Avenue, Northeast, Washington, D.C. Officers from USSS-UD and USCP pursued the suspect vehicle to et

    Street and Constitution Avenue, Northeast where Decedent stopped the suspect vehicle abruptly, and then

    1

  • turned left and drove over a median strip. Decedent then drove in reverse in the 200 block of Maryland Avenue, Northeast, where Decedent again refused to stop.

    At this point, officers from both USSS-UD and USCP fired several rounds into the suspect vehicle, striking Decedent. The vehicle came to rest on the median area directly behind the guard's booth on the United States Capitol grounds.

    Decedent, along with an uninjured child, were removed from the vehicle. Decedent was transported to the Washington Hospital Center where she was pronounced dead by Dr. Christine Trankiem of the medical staff. Decedent's remains were transported to the Office of the Chief Medical Examiner for the District of Columbia pending an autopsy.

    The suspect vehicle was recovered as evidence and has remained in police custody. Based on the above facts and circumstances, your affiant believes that the vehicle described above is of evidentiary value and may contain physical evidence such as expended bullets or bullet fragments fired by the officers; vehicle ownership paperwork; maps, documents, and/or photographs of, or pertaining to, the White House; alcohol or drugs (legal or illegal); and/or evidence of a mechanical malfunction or lack thereof may be inside the suspect vehicle.

    Your affiant respectfully requests that a District Court Search Warrant be issued for the entire vehicle known as a 2010 Nissan Infiniti G37XS, VIN#JN1CV6EL413M261683, Connecticut License # 323-YNS.

    ece.i M

    Affiant United ates Attorney

    OCT -4 2013 Subscribed orn to before me this

    day of 2013

    Mag s rate United States District Court DEBORAH 4. ROBINS4.1.;

    MAG1STP.ATE JUDGE

    2

  • EXHIBIT C

  • GOVERNMENT OF THE DISTRICT OF COLUMBIA DEPARTMENT OF HEALTH CERTIFICATE OF DEATH: -

    FILE DATE: OCTOBER 15, 2013 FILE NUMBER: 108-201 3-00409 I

    FULL NAME OP DECEASED: MIRIAM IRIS CAREY

    SEX: FEMALE.

    DATE OF DEATH: OCTOBER 03, 2013 TIME OF DEATH: 3:08 PM

    PLACE OF DEATH: WASHINGTON HOSP1TAt. CENTER, ...SSI`:

    DATE OF BIRTH: AUGUST 12, 1979 - BIRTHPLACE: BROOKLYN, NEW YORK

    MOTHER'S MAIDEN NAME: IDELLA CAREY

    FATHERS NAME: LEON FAULES .

    MARITAL. STATUS:NEVER:MARRIED EDUCATION: BACHELOR'S DEGREE (E.G.BA,BS)

    SURVIVING SPOUSE:

    RESIDENCE: STAMFORD, CONNECT1Cyk- RACE:: BLACK OR AFRICAN AMERICAN /,`,e

    FUNERAL HOME: ALEXANDER S "0:000;

    E - DC HiSi,ANic ORIGIN: NOT i" ' SPANISH/FIISPANIC/LATTNO

    DATE OF DISPOSITION: OCTOBE

    MANNER OF DEATH: HOMICIDE

    CAUSE OF DEATH

    A. MULTIPLE GUNSHOT WOUNDS

    ()TILER SIGNIFICANT CONDITIONS: NONE

    F DISPOSITION::

    C D 2 3 9 5 6 2 This document certifies that this is a true and, correct reproduction or abstract of tne official record filed in the Vital Records Division of the District of ColUmbia Department of Health. DATE ISSUED

    WARNING: IT IS UNLAWFUL TO MAKE COPIES OF THIS DOCUMENT AND PRESENT THEM AS OFFICIAL COPIES

  • EXHIBIT D

  • Grace Funeral Chapels 607 North Conduit Blvd Brooklyn, NY 11208 Tel: 718-2354088 800-378-7857 Fax: 718-235-6008 www.gracefunerals.com

    Printed 101912013

    Statement of Funeral Expenses

    GRACE

    Case Number: 2013-326 Arrangement; 1010812013 Invoice To:

    Name of Deceased: Miriam Carey

    Date of Death: 1010312013 Age: 34

    Vaiarie Carey

    Funeral Home Charges

    1 Transfer of Remains 1 @ $1,100.00 $1,100.00 2 Embalming of Autopsied Remains $595.00 3 Other Preparation - Dressing/Casketing $100.00 4 Other Preparation - Cosmetology $60.00 5 Basic Arrangements $495.00 6 Supervision for Visitation $450.00 7 Supervision for Funeral Service (with Procession to Cemetery) $300.00 8 Use of Facilities for Visitation (Large) $500.00 9 Use of Facilities for Funeral Service (Large) $500.00 10 Hearse - Outside New York City $400.00 11 Passenger Limo (Long Local within 25 miles) $800.00 12 Memorial Cards Color or B&W Photo (per 100) $400.00 13 Register Book $175.00 14 Hairdressing $75.00 15 Additional prayer cards that come with American rose $20.00 16 Disk from live broadcast $30.00 17 $69.95 18 Casket or Alternative Container $1,695.00

    Supplier: Aurora Casket Company, Model: Orchid Blend Gray 18 Gauge Steel

    Subtotal of Funeral Home Charges: $7,764.95

    Cash Advances

    1 Mailing Fee 1 @ $15.00 $15.00 2 Cemetery or Crematory $4,762.00

    Pinelawn Memorial Park 3 Death Certificate Transcripts 4 @ $18.00 $72.00 4 Livery 1 @ $30.00 $30.00 5 Gratuities $20.00 6 Alexander Pope Funeral Home $350.00 7 Organist $150.00

    Subtotal of Cash Advances: $5,399.00

    GFC-NY 2013-326 Miriam Carey Page 1 of 2

  • Grace Funeral Chapels 607 North Conduit Blvd Brooklyn, NY 11208 Tel: 718-235-8088 800-378-7857 Fax: 718-235-6008 www.gracefunerals.com

    Printed 10/9/2013

    Statement of Funeral Expenses

    G R AC .E

    Case Number: 2013-326 Arrangement:; 10/08/2013

    Invoice To: Name of Deceased: Miriam Carey Date of Death: 10/03/2013 Age: 34

    Valarie Carey

    Summary of Charges Funeral Home Charges: $7,764.95 Cash Advances: $5,399.00 Adjustment: $0.00 Total Funeral Charges: $13,163.95 Payment: $8,163.95 Balance Due: $5,000.00

    GFC-NY

    2013-326 Miriam Carey Page 2 of 2

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  • EXHIBIT E

  • PETITION/ADMINISTRATION OR PROBATE OF WILL PC-200 REV. 7/13 Page 1

    STATE OF CONNECTICUT RECORDED:

    COURT OF PROBATE [Type or print in ink file in duplicate.]

    [Complete Confidential Information Sheetfor PC-200 on last page. Use Second Sheet, PC-180, for additional data.]

    TO: COURT OF PROBATE, Stamford DISTRICT NO. 53 DA I E OF PETITION 11-5-2013

    ESTATE OF [Include all names and initials under which any asset was held.] Miriam I. Carey

    DATE OF DEATH 10-03-2013

    151 WRONGFU