CITY OF TACOMA CLAIM FOR DAMAGES FORM' General Uability Claim Form

Pursuant to Chapter 4.96 RCW, this form is for filing a claim against the City of Tacoma. Some of the information requested on this form is required by RCW 4.96.020 and may be subject to public disclosure. Pursuant to the new law, Claim for Damages forms cannot be submitted electronically (via e-mail or fax).

Mail or deliver original claim to:

City of Tacoma City Clerk's Office

747 Market Street, Suite 220 Tacoma, WA 98402

Business Hours: Mon. " Fri. 8:00 a.m .. 5:00 p.rn. Closed on weekends and holidays.

CLAIMANT INFORMATION

For Official Use Only

~ECEIVED SE? 02 20m

LilY ClERlfS OFFICE

No.

1. Claimant's name: -!:J~a~ck~s?\,o!!.!nL.....- ---1K~e~l.!Jvil!1n ~-:-:-;- ~0~3/:=2~5/!...!1~9~7--:-:1--;---:-:-:-:_-;-

Last name First Middle Date of birth (mm/ddlyyyy)

2. Current residential address: 8017 65th Ave Ct. SW, Lakewood. WA 98499

3. Mailing address (if different): 2s",,-am!..U!ii<eW;a;u;sua!iUb,:),o,uv~e,-- _

4. Residential address at the time ofthe incident (if different from current address):

same as above

5. Claimant's daytime telephone number: --':'27<5""'3,...,-5 ... 8=8'-'-2=.>2=..21'-"'9 _

Home

253-5074184

Business

INCIDENT INFORMATION

6. Claimant's e-mail address: "-th.!Sa""d!.>::@~t",h""a""d""fa,-",w..,-.c",oem.!.L-- _

7. Date ofthe incident: 05{26/2010 - prese~ Time: Da.m. 0 p.rn,

(mmiddlyyyy) (check one)

8. If the incident occurred over a period of time, date of first and last occurrences:

from May 2010 Time: D a.m. 0 p.m. to Present Time: D a.m. 0 p.m.

(mm/dd/yyyy) (check one) (mm/dd/yyyy) (check one)

9. Locationofjncident~~a~s~hain~gwt04n~P~je~r~c~e--~T~aDc~oumaa~ ~T~a~c~o~m~a~ ~

State and county City, if applicable Place where occurred

10. If the incident occurred on a street or highway:

Name of street or highway

At the intersection with or nearest intersecting street

11. City agency or department allegedly responsible for damagelinjury: Human Rights and Human Services

12. Names, addresses, and telephone numbers of all persons involved in or witness to this incident See Exhibit A.

13. Names, addresses and telephone numbers of all City employees having knowledge about this incident:

China Fortson, 747 Market Street, Room 836 Tacoma, WA 98402, (253) 591"5164; Charles Leech, 747 Market Street, Tacoma, WA 98402, (253) 591-5849; Tracy Storwick, City of Tacoma Legal Department, 747 Market Street, Tacoma, WA 98402, (253) 591"5885; Grant Blinn, 930 Tacoma Ave S Rm 946, Tacoma, WA

98402-2102, (253) 798-7400, Also See ExhibitA. 0

14. Names, addresses, and telephone numbers of ali individuals not already identified in #12 and #13 above that have knowledge regarding the liability issues involved in this incident, or knowledge of the Claimant's resulting damages. Please include a brief description as to the nature and extent of each person's knowledge. Attach additional sheets if necessary.

See Exhibit A

15. Describe the cause of the injury or damages. Explain the extent of property loss or medical, physical or mental injuries. Attach additional sheets if necessary.

Since the Kelvin Jackson settled his claims from 2006-2009 with the City ofTacoma in May 2010, Mr. Jackson has been subject to repetitive harassment from China Fortson at the hands of the City of Tacoma. Ms. Fortson has filed ann-harassment orders against the Plaintiff in which he has been forced to defend himself. Ms. Fortson has made it impossible for the Plaintiff to obtain public record documents regarding his own children. The City of Tacoma has failed to protect the Mr. Jackson from Ms. Fotson who is still harassing and defaming Mr. Jackson. Mr. Jackson intends to bring claims against the City of Tacoma and Ms. Fortson for destruction of parent-child relationship, retaliation, negligence, harassment, defamation, negligent infliction of emotional distress, intentional infliction of emotional distress, negligent hiring retention and supervision, discrimination based on parentage.

16. Has this incident been reported to law enforcement, safety or security personnel? If so, when and to whom?

Charles Leech, City of Tacoma, 12/19/06, 112/07, 1/16/07, 1/17/07, 1/18/07

Grant Blinn, 930 Tacoma Ave S Rm 946, Tacoma, WA 98402"2102, (253) 798"7400, April 2008

17. Names, addresses and telephone numbers of treating medical providers. Attach copies of all medical reports and billings.

N/A

18. Please attach documents which support the claim's allegations.

19. I claim damages from the City of Tacoma in the sum of $ . ..!1.cO~O~O~O~O~O,,-!,O~O~ _

This Claim form must be signed by the Claimant, a person holding a written power of attorney from the Claimant, by an attorney admitted to practice in Washington State on the Claimant's behalf, or by a court-approved guardian or guardian ad litem on behalf of the Claimant.

D.elMl:tv of perjury under the laws of the State of Washington that the foregoing is true and correct.

r;/ja

Date

gO) '7 t. fJ'+':vf-'L ff J7V' L q ICe~d )' j'r/9?

Place (residential address, city and county) ,Plrertf.lZ_., to.

Exhibit A (question 12)

1. China Fortson, City of Tacoma, Office of Community Advocacy, 747 Market Street, Room

836, Tacoma, WA 98402, (253) 591-5164

2. Keisha Monique Jackson, Puyallup, W A

3. Charles Leech, 747 Market Street, Tacoma, WA 98402, (253) 591-5849

4. Tracy Storwick, City of Tacoma Legal Department, 747 Market Street, Tacoma, WA 98402,

(253) 591-5885

5. Kelly LeBlanc, 7903 Martin Way E PMB 125, Olympia, WA 98516-5719, (360) 491-7691

6. Grant Blinn, 930 Tacoma Ave S Rm 946, Tacoma, WA 98402-2102, (253) 798-7400

7. Quiymani Jackson, 8017 65th Ave Ct SW, Lakewood, WA 98499, (253) 588-2219

8. Kelvin Jackson Jr. Puyallup, W A, (253) 298-0285

9. Chendre Jackson (Proctor), Florida 10. Talayia Jackson, Puyallup, WA

II. Helen Keuper, 10004 2nd Ave Ct E, Tacoma, WA 98445,

12. Tonya Dran (Jackson) 8017 65th Ave Ct. Sw. Lakewood, WA 98499 (253) 310-

13. Kristy Crosky, CPS Caseworker, (253) 983-6200

14. Shannon Ross, CPS Caseworker, office (253) 798-4185, cell (253) 310-2583

15. Shannon Lightfoot, Youth Assessment Resource Center Counselor

16. Nathan Cusick, Badge No. 276, Puyallup Police Dept.

17. Pam Blades (friend of Keisha Jackson) (253) 678-9429

18. Maxine Butler, 4622 McKinley Ave, Tacoma, WA 98404, (253) 475-9577

19. Marilyn Duff, M.A., Mental Health Dept., American Lake VA Hospital,

20. Douglass and Noel Dran, 6603 82nd Street, Lakewood, WA 98499, (253) 581-0395

21. Audra Gideon (Turner), Lakewood, WA, (253) 229-2200

22. Charles Schmidt, (Keisha's Attorney)820 "A" Street, STE 600, Tacoma, WA 98401, (253) 627-8131

23. Detective Rocko, Lakewood Police Department, Lakewood, W, (253) 830-5000

24. Sgt. Snow, Okaloosa County Sherriff Department, Ft. Walton Beach, Florida

CITY OF TACOMA CLAIM FOR DAMAGES FORM General Liability Claim Form

For Official Use Only

Pursuant to Chapter 4.96 RCW, this form is for filing a claim against the City of Tacoma. Some of the information requested on this form is required' by RCW 4.96.020 and may be subject to public disclosure. Pursuant to the new law, Claim for Damages forms cannot be submitted electronically (via e-mail or fax).

PLEASE.tYeE{t:),R:,f>,Ri~ojj1i·N;j!N~g~;~t1:~:;{irl;[~t}~~~~;r·;;t:rih~t1~[~W:~~f:!~ii!ft;Jt%i~~[~ft·i\i;!@i}:*

Mail or deliver original claim to:

City of Tacoma City Clerk's Office

747 Market Street, Suite 220 Tacoma, WA 98402

Business Hours: Mon. - Fri. 8:00 a.rn, - 5:00 p.m. Closed on weekends and holidays.

R.ECEIVED SEP 02 2D1~

CrfV ClERKIS OFFICE

No.

CLAIMANT INFORMATION

1. Claimant's name: ..lo!J,!,!ac~k~s~0:!...!n ---,Q",:u""iCJ.!ym!..!..!""-a!..!Jnil....- ~ O",=1:'2./...!.1 ~8/-,1~9>!.97!...- --:-

Last name First Middle Date of birth (mm/dd/yyyy)

2. Current residential address: 8017 65th Ave Ct. SW, Lakewood, WA 98499

3. Mailing address (if different): ""sa .... m"'-"""e_,.a""s-'=a""'b""ov....,e"-- _

4. Residential address at the time of the incident (if different from current address):

7413 S. Montgomery, Tacoma, WA 98409 (06~09/07) 6611 82nd St. SW, Lakewood, WA 98499 (09/07~09/09)

5. Claimant's daytime telephone number: .£:2~5~3M~5~8""8'-*M2"""2'-'1""'-9 _

Home

Business

INCIDENT INFORMATION

7. Date of the incident: ---,-_---,- _

(mm/dd/yyyy)

Time: Oa.m. 0 p.m.

(check one)

8. If the incident occurred over a period of time, date of first and last occurrences:

from Nov 2006 Time: 0 a.rn. D p.m. to January 2009 Time: 0 a.rn. 0 p.rn.

(mm/dd/yyyy) (check one) (mm/dd/yyW) (check one)

9. Location of incidentW ",-,,",,a=s,,-,h,,,",in~g=to,,,-,n,-,-, .!...P=jeO!-'rc=e~ __ T-'-'a=c=owm ... a"__ __'_T=a=co=m~a _

State and county City, if applicable Place where occurred

1 O. If the incident occurred on a street or highway:

Name of street or highway

At the intersection with or nearest intersecting street

11. City agency or department allegedly responsible for damage/injury: HUman Rights and Human Services

12. Names, addresses, and telephone numbers of all persons involved in or witness to this incident:

See Exhibit A

13. Names, addresses and telephone numbers of all City employees having knowledge about this incident:

China Fortson, 747 Market Street, Room 836 Tacoma, WA 98402, (253) 591-5164; Charles Leech, 747 Market Street, Tacoma, WA 98402, (253) 591-5849; Tracy Storwick, City ofTacoma Legal Department, 747 Market Street, Tacoma, WA 98402, (253) 591-5885; Grant Blinn, 930 Tacoma Ave S Rm 946, Tacoma, WA

98402-2102, (253) 798-7400, Also See Exhibit A. D

14. Names, addresses, and telephone numbers of all individuals not already identified in #12 and #13 above that have knowledge regarding the liabifity issues involved in this incident, or knowledge of the Claimant's resulting damages. Please include a brief description as to the nature and extent of each person's knowledge. Attach addition a! sheets if necessary.

See Exhibit A.

15. Describe the cause of the injury or damages. Explain the extent of property loss or medical, physical or mental injuries. Attach additional sheets if necessary.

See Exhibit B.

16. Has this incident been reported to law enforcement, safety or security personnel? If so, when and to whom?

Charles Leech, City of Tacoma, 12/19/06, 112/07, 1/16/07, 1/17/07, 1/18/07

Grant Blinn, 930 Tacoma Ave S Rm 946, Tacoma, WA 98402-2102, (253) 798-7400, April 2008

17. Names, addresses and telephone numbers of treating medical providers. Attach copies of all medical reports and billings.

18. Please attach documents which support the claim's allegations.

19. I claim damages from the City of Tacoma in the sum of $_,_1""'0""0'-=0.1..:0'-"0'-=0,:.:.0:....:0'--- _

This Claim form must be signed by the Claimant, a person holding a written power of attorney from the Claimant, by an attorney admitted to practice in Washington State on the Claimant's behalf, or by a court-approved guardian or guardian ad litem on behalf of the Claimant.

I declare under pen a!!¥: of perjury under the laws of the State of Washington that the foregoing is true and correct.

8"()17 6o'ffA-Jt.., (!;Td# tITKH44/d 18'11"1

Place (reSidential address, city and county) f'k/!.JtL-

Date

Exhibit A (question 12)

1. China Fortson, City of Tacoma, Office of Community Advocacy, 747 Market Street, Room

836, Tacoma, WA 98402, (253) 591-5164

2. Keisha Monique Jackson, Puyallup, W A

3. Charles Leech, 747 Market Street, Tacoma, WA 98402, (253) 591-5849

4. Tracy Storwick, City of Tacoma Legal Department, 747 Market Street, Tacoma, WA 98402,

(253) 591-5885

5. Kelly LeBlanc, 7903 Martin Way E PMB 125, Olympia, WA 98516-5719, (360) 491-7691

6. Grant Blinn, 930 Tacoma Ave S Rm 946, Tacoma, WA 98402-2102, (253) 798-7400

7. Quiyrnani Jackson, 8017 65th Ave Ct SW, Lakewood, WA 98499, (253) 588-2219

8. Kelvin Jackson Jr. Puyallup, WA, (253) 298-0285

9. Chendre Jackson (Proctor), Florida

10. Talayia Jackson, Puyall~, W A

11. Helen Keuper, 100042n AveCtE, Tacoma, WA98445,

12. Tonya Dran (Jackson) 8017 65th Ave Ct. Sw. Lakewood, WA 98499 (253) 310- B. Kristy Crosky, CPS Caseworker, (253) 983-6200

14. Shannon Ross, CPS Caseworker, office (253) 798-4185, cell (253) 310-2583

15. Shannon Lightfoot, Youth Assessment Resource Center Counselor

16. Nathan Cusick, Badge No. 276, Puyallup Police Dept.

17. Pam Blades (friend of Keisha Jackson) (253) 678-9429

18. Maxine Butler, 4622 McKinley Ave, Tacoma, WA 98404, (253) 475-9577

19. Marilyn Duff, M.A., Mental Health Dept., American Lake VA Hospital,

20. Douglass and Noel Dran, 6603 82nd Street, Lakewood, WA 98499, (253) 581-0395

21. Audra Gideon (Turner), Lakewood, WA, (253) 229-2200

22. Charles Schmidt, (Keisha's Attomey)820 "A" Street, STE 600, Tacoma, WA 98401, (253) 627-8131

23. Detective Rocko, Lakewood Police Department, Lakewood, W, (253) 830-5000

24. Sgt. Snow, Okaloosa County Sherriff Department, Ft. Walton Beach, Florida

Exhibit B (question 15)

In 2006 Kelvin Jackson was involved in marriage dissolution proceedings for the dissolution of his marriage to Keisha M. Jackson. City of Tacoma employee China Fortson became involved as Keisha Jackson's advocate. Ms. Fortson worked for the City of Tacoma in Human Rights and Services, Office of Community Advocacy, regarding domestic violence. Over the course of the next three years Ms. Fortson harassed Mr. Jackson, submitted false and defamatory testimony regarding Mr. Jackson, and wrongfully interfered with Mr. Jackson's relationships with his children. Mr. Jackson will bring causes of action against Ms. Fortson and the City of Tacoma including, but not limited to: defamation (libel/slander); invasion of privacy/false light; tortious interference with the parent/child relationship (RCW 4.24.010); outrage; negligent infliction of emotional distress; negligence; and negligent hiring, retention, and supervision.

Ms. Fortson first came in contact with Mr. Jackson in 2006 on Thanksgiving day. Ms.

Fortson accompanied Keisha Jackson to the exchange point where Mr. Jackson was to pick up his children. Mr. Jackson was told that his son would not be going with him on that visit. Ms. Fortson had told Mr. Jackson's son that he was old enough that he did not have to go with Mr. Jackson for the visit if he did not want to go with Mr. Jackson. Ms. Fortson was also present during the exchange when Mr. Jackson returned his daughter to Ms. Jackson.

In December of 2006 Ms. Fortson filed a declaration with the Pierce County Superior Court slandering Mr. Jackson. See attached.

Ms. Fortson was present at every exchange of the Mr. Jackson's children. Ms. Fortson interfered with the Christmas 2006 exchange so that Mr. Jackson was not able to see his children. At the next exchange Ms. Fortson directed Mr. Jackson's daughter on what to do and say in order to avoid visiting with Mr. Jackson. When Mr. Jackson and his daughter arrived home they were visited by two people from Greater Crisis Control who told Mr. Jackson that they had received a call from Ms. Fortson who told them that they needed to check on Mr. Jackson's daughter.

On December 19, 2006 Mr. Jackson filed a complaint with Mr. Charles Leech from the City of Tacoma who was Ms. Fortson's supervisor. Mr. Jackson spoke with Mr. Leech on the phone the week after Christmas as a follow up and Mr. Leech told Mr. Jackson that he would get back to him.

On January 2, 2007 Mr. Jackson followed up with Mr. Leech about responding to his complaint. On January 16~ 2007 Mr. Jackson emailed Mr. Leech again and updated him that Mr. Jackson still did not know why Ms. Fortson was involved and asked Mr. Leech for a response. On January 17, 2007 Mr. Jackson filed a second complaint against Ms. Fortson via email to Mr. Leech. At this time the exchanges were getting more volatile and different people were starting to show up with Ms. Fortson at the exchanges. On January 18, 2007 Mr. Jackson emailed Mr. Leech again complaining and updating him on the situation. Ms. Fortson had showed up at a meeting with CPS and was appearing at the court dates with Ms. Jackson representing to the judge that she was with the City of Tacoma.

1

CPS visited Mr. Jackson's fiance's son at his school based upon a complaint raised by Ms. Fortson.

February 2007

By February of2007 Ms. Fortson was appearing at all court hearings and exchanges. Ms.

Fortson was often accompanied by her husband and children, who engaged in verbal confrontations with Mr. Jackson.

Ms. Fortson continued to be involved in the dissolution from March of 2007 through June of 2007. In May of 2007 the Guardian Ad Litem filed her report which indicated that Ms. Fortson was interfering with exchanges and that she had interfered with the GAL's ability to speak with Mr. Jackson's children. The GAL received a call from Mr. Jackson's daughter and could tell that Ms. Fortson was coaching Mr. Jackson's daughter on what to say in order to interfere with Mr. Jackson's ability to visit with his children. The GAL informed the court that Ms. Fortson was toxic to the case and she asked that the judge prevent Ms. Fortson from having further involvement in the case.

In June of 2007 Mr. Jackson's first dissolution trial was held. Ms. Fortson testified on Ms. Jackson's behalf. The judge found no evidence of domestic violence issues and questioned Ms. Fortson's involvement in the case.

In August of 2007 Ms. Jackson asked the court for permission to travel to Florida, allegedly to visit her sick father. Mr. Jackson asked the court not to give Ms. Jackson permission to travel to Florida because Mr. Jackson knew that Ms. Jackson had been evicted and was staying with friends and had been telling mutual friends goodbye and that she would not be returning to Washington. Ms. Fortson testified at court that Ms. Jackson's father was ill and that Ms. Jackson would return to Washington by September 3rd• In September of2007 Ms. Jackson did not return to Washington with Mr. Jackson's children. In October of 2007 Ms. Jackson was found to be in contempt of court. Ms. Jackson filed a letter with the court through Ms. Fortson.

Mr. Jackson hired a private investigator to locate Ms. Jackson in Florida. Mr. Jackson formally filed charges with the Lakewood, Washington police department on the contempt issue. In February of 2008 Mr. Jackson received documents from a court in Florida that Ms. Jackson was attempting to get a restraining order against Mr. Jackson. Mr. Jackson spoke with Lakewood prosecuting attorney Grant Blinn regarding the information he received from Florida. Mr. Jackson called Ms. Fortson to ask whether she knew where Mr. Jackson's children were.

In March of 2008 Mr. Jackson traveled to Florida to answer the restraining order. Ms.

Jackson was arrested at that time. Mr. Jackson still did not know where his children were. He spoke with employees of Florida's CPS and was told that there were claims of abuse against Mr. Jackson made by Ms. Fortson.

In April of 2008 Mr. Jackson received a telephone call from his daughter. She wanted to return to Washington. Ms. Jackson had been in jail for approximately one month. Ms. Jackson

2

was extradited to Washington in April. Ms. Fortson told the judge that she would pay Ms. Jackson's bail. City of Tacoma funds were used to bail Ms. Jackson out of jail.

On May 1,2008 Mr. Jackson sent for his daughter in Florida. Mr. Jackson immediately began receiving calls from Florida's CPS and a Sheriff's department asking Mr. Jackson if he had his daughter. A member of the sheriffs department told Mr. Jackson that Ms. Fortson called the sheriff's department, told them that she was with the City of Tacoma, and told them that Mr. Jackson had kidnapped his daughter. Ms. Fortson told the sheriff's department that Mr. Jackson had gone to a neighbor'S house in an unmarked police car, dressed in police clothing, and took his daughter. Mr. Jackson explained the situation regarding Washington's order to return Mr. Jackson's children and that Mr. Jackson's daughter had flown from Florida to Washington unaccompanied by Mr. Jackson. The person from the sheriffs department stated that he was going to file a complaint against Ms. Fortson for lying to him and costing their department time and money.

The next day Mr. Jackson went to court and received temporary custody of his children and a restraining order against Ms. Jackson. Mr. Jackson contacted the City of Tacoma's Human Resource Supervisor and made a complaint regarding Ms. Fortson's involvement in the case. Mr. Jackson called a week or so later to follow up and was berated for "stealing" his daughter and was told that Ms. Fortson was well within her rights. Mr. Jackson learned from his daughter that Ms. Fortson had been involved with the children all along. Mr. Jackson's daughter was even in Ms. Fortson's wedding.

In June or July of 2008 Mr. Jackson was contacted by Tracy Storwick in the City of Tacoma's investigations/legal department. Ms. Storwick interviewed Mr. Jackson about Ms. Fortson's involvement and Mr. Jackson's complaint. Ms. Fortson continued to attend exchanges and court hearings during this time. Mr. Jackson filed more complaints regarding Ms. Fortson until Ms. Fortson stopped attending exchanges, but other unidentified persons in City of Tacoma vehicles showed up instead. Mr. Jackson complained about these city employees attending exchanges and then officers from the Puyallup Police Department started to attend exchanges. An investigation into their presence showed that Puyallup PD officers were being paid by the City of Tacoma DV department to attend exchanges. Toward the end of July of 2008 Mr. Jackson attended a hearing where another employee of the City of Tacoma DV department was present on Ms. Jackson's behalf. Mr. Jackson called the city investigator and filed another complaint. This was the last time City of Tacoma employees were visibly present at court hearings or exchanges.

In August of 2008 Mr. Jackson attended a hearing where employees of two other domestic violence agencies testified that Ms. Fortson referred Ms. Jackson to them.

In September of 2008 the GAL was forced to resign from the case because Ms. Fortson made a complaint against her to the Washington State Bar Association.

In January 0[2009 Mr. Jackson received sole custody of his daughter and joint custody of his son. The judge commended Mr. Jackson for his determination and commitment and stated on the record that there was no evidence that Mr. Jackson committed any domestic violence

3

violations. The GAL testified regarding the City of Tacoma's and Ms. Fortson's involvement in the case. Ms. Fortson filed a complaint against the GAL in an attempt to remove her from the case. Mr. Jackson then filed another complaint with the City Manager's office.

4