2200 Quarry Lake Deve MILLER | STERN Bato, MD 1209 UL tawyers ‘sroaw.rae ft tosieae December 7,2022 ‘VIA HAND DELIVERY James L, Shea, City Solicitor Baltimore City Law Department 100 North Holliday Street, Suite 101 Baltimore, MD 21202 Office of the Mayor Brandon Scott 100 North Holiday Street City Hall Rm. 250 Baltimore, MD 21202 Mayor & City Council of Baltimore 201 E, Baltimore Steet Baltimore, MD 21202 Department of Law CContral Bureau of Investigation TE, Redwood Steet, 6th Floor Baltimore, MD 21202 Housing Authority of Baltimore City 4ITE, Fayette Street, Suite 1339 Baltimore, MD 21202 Baltimore City Risk Management 401 E, Fayette Street, Unit 700 Baltimore, MD 21202 Jan Goslee {417 E Fayette Steet, Suite 1210 Baltimore MD 21202 “Maryland Department of Housing and Community Development “7800 Harkins Road Lanham, MD 20706December 7, 2022 Page 2 Hon. Dereck E, Davis, Treasurer Goldstein Treasury Building. 80 Calvert Street Annapolis, Maryland 21401 Maryland Stadium Authority Dereck E. Davis, Treasurer clo Insurance Division Louis L. Goldstein Treasury Building 80 Calvert Street, Room 442 ‘Annapolis, MD 21401 RE: Notice of Personal Injury Claim: Rachel Butrim, Individually, and as Personal Representative ofthe Estate of Paul Butrim, and as mother and next friend of Paisley Buarim, a minor, 1 Get Around Drive, Colora, MD 21917; Gloria Elena Lacayo, Individually, and as Personal Representative ofthe Estate of Kenneth Lacayo, 3900 Bel Pre Road, Condo #5, Silver Spring. MD 21906; Jose Lacayo, Individually, and as father and next friend of Kenneth Lacayo, 14404 Bel Pre Drive, Silver Spring, MD 21906; Lacey Marino, as Personal Representative of the Estate of Kelsey Sadler, and as Personal Representative of Pamela Gay Hopkins, mother and next friend of Kelsey Sadler, 1723 Castleton Road, Darlington, MD 21034; slerry Norman, Individually, and as father and next friend of Kelsey Sadler, 1348 ‘Knopp Road, Jarreusville. MD 21084; Brandon Sadler Individually, widower of Kelsey Sadter, $13 E Michaelsvlle Road, Perryman, MD 21130; and, John MeMaster, Individually 1926 Edgewood Road, Loch Raven, MD 21286 Date of Injury: January 24, 2022 Location: 205 S, Stricker Stet Our firm represents Rachel Butsim, Individually, and as Personal Representative of the Estate of Paul Butrim, and as mother and next friend of Paisley Butrim, @ minor; Gloria Elena Lacayo, Individually, and as Personal Representative of the Estate of Kenneth Lacayo; Jose "nile Str Lawyers presently does not epetent sme ofthe potential claimants icing, bu not limited to Richard A. Burn, Sr tnd Ulonds BB MILLER | STERNDecember 7, 2022 Page 3 Lacayo, Individually, and as father and next friend of Kenneth Lacayo: Lacey Marino, as Personal Representative of the Estate of Kelsey Sadler, and as Personal Representative of Pamela Gay Hopkins, mother and next friend of Kelsey Sadler; Jery Norman, Individually, and as father and next friend of Kelsey Sadler; Brandon Sadler Individually, widower of Kelsey Sadler, and John MeMaster, Individually, for personal injuries/oss of life sustained on January 24, 2022. Please consider this leter as our formal notice of potential claim) against 1. ‘The Mayor, Brandon Scott, and City Council of Baltimore City pursuant to Mb. Crs, 81D. PRoc. § 5-304; 2. The State of Maryland pursuant to Maryland Tort Claims Act, Stale Government Article, § 12-101 et seq The Baltimore City Fire Department; Housing Authority of Baltimore City; ‘Maryland Department of Housing and Community Development; Former Chief of the Baltimore City Fire Department, Niles Ford? (Collectively “Respondents”) lease direct all correspondence to my office. 1 Background: Paul Butrim, (°Mr. Butrim”), Kelsey Sadler (°Ms. Sadler”), Kenneth Lacayo (‘Mr Lacayo"), and John McMaster (collectively Claimants”) were all active-duty firefighters who pid the ultimate sacrifice as well as sustained life-threatening injures on January 24, 2022, wien they responded to the vacant house fire on 208. Sticker Street in Baltimore, Maryland. As a direct and proximate result of the actions/omissions of the above named Respondents, by fing to demolish the condemned property located at 205 S, Sticker Steet, prior to January 24, 2022, among other things, there was a collapse that resulted in the loss of three lives and injuries to ‘others. ‘The injuries and wrongful deaths that occurred on January 24, 2022, were solely the result, ‘of these named Respondents’ actions/omissions, without any negligence on the part of the above Claimants or their decedents ‘This investigation is presently open and on-going. There may be several allegations involving the wrongful deaths of the above referenced Claimants sgainet The Mayor and City Council of Baltimore City, The State of Maryland, and their actual andlor apperent ‘employces/agents including, but not limited to, claims for negligence in the failure to demolish and/or adequately secure/maintain safely the vacant property located st 205 S. Stricker Steet; and/or intentionally mismanagement of money; andlor misappropriation of money; and/or violations of ther civil rights and/or constitutional protections; cancellation ofthe “Code X-Ray.” Departmental Order 102-10; failure of the Mobile Data Terminal; failure of the Computer-Aided Dispatch program; among other claims, against but not limited to the above refereaced Respondents, * As these clans ae sill under investigation this i is not exhautive and maybe supplemented MILLER | STERNDecember 7, 2022 Page 4 ‘The loss of life and injuries that occurred on January 24,2022, could have and should have been prevented. This was a devastating occurrence that should never happen again. As a direct and proximate result of the City of Baltimore and the State of Maryland’s negligence, by and through its employees and agents, Mr. MeMaster, and the families of Kelsey Sadler, Kenneth, Lacayo, and Paul Butrim, have suffered and will continue to suffer severe emotional anguish and hhave los and will continue to lose the solatium and companionship of their loved ones. Further, there is a loss of household services, financial support, and olver related losses. As such, and: ‘notwithstanding the statutory cap, the personal injury, wrongful death and survivor claims exceed $10,000,000.00. ‘This claim is about more than money and requires change at the highest levels ‘within the City of Baltimore, State of Maryland, and our elected oficial, Accountability must oceur in order to effect change Our legal system allows for sccountabilty, and the Claimants deserve the answers and changes they seek. The excuses offered by the City Council are unacceptable and show their true colo. While the line of duty report highlights several failures by Baltimore City and the Baltimore City Fire Department, itis not the ‘complete story, and it is far ftom the accountability expected, ‘This was a vacant property that all firefighters should have been aware of (dating back to fires in 2015 & 2016), as it presented a risk to their safety. 205 S. Stricker should have been ‘demolished years ago, after the fist fire there, but the City of Baltimore and its elected officials, agents, and employees chose to allocate the City’s resources elsewhere, including but not limited 1 eliminating the Code X-Ray program and filing to implemen! the CORE project appropritely Full transparency is necessary t0 reach a final resolution for these families, all of our first responders and for the etizens of Maryland, Ifyou for any reason you believe tha this letter does not provide sufficient notice to these entities a5 required by applicable law, please contact us immediately. Should you have any ‘questions or require any additional information, please do not hesitate to contact us. Very truly yours, Sa_gs- KEVIN STERN, ES & DANiet MILLER, Es MILLER | STERN