STATE OF NEW YORK. SUPREME COURT COUNTY OF MONROE In the Matter of the Claim of Kali Watkins, Claimant, y, ‘Webster Central School District, Carmen Gumina, Superintendent, Paul Benz, Principal- ‘Webster Schroeder High School, Jacqueline Goodwine, Assistant Principal-Webster Schroeder High School, Stephanie Reusch, Stacey Exner, and other agents, board members and employees, Respondents, NOTICE OF CLAIM TO: WEBSTER CENTRAL SCHOL DISTRICT 119 South Avenue Webster, New York 14580 PLEASE TAKE NOTICE that Claimant Kali Watkins (by and through his attorneys, Vahey Getz LLP), hereby notifies the Webster Central School District of his claim as follows: 1. Claimant resides at 1186 Woodhull Road, Webster, New York 14580. 2. Claimant is represented by Vahey Getz, LLP Inc., 144 Exchange Blvd, Suite 400, Rochester, NY 14614, Telephone: (585) 262-5130. 3. The subject incident(s)/ action(s) occurred on or about and between December 15, 2017 until and including August 26, 2019. 4, Upon information and belief, from December 15, 2017 until and including August 26, 2019, members of Webster Central School District, including employees, agents and others were engaged in the investigation and obtaining of information of alleged criminal conduct against Claimant made by a student. Upon information and belief these individualsknew or should have known the allegations levied against claimant were false, and otherwise not accurate 5. Upon information and belief, individuals employed by the Webster Central School District, including counselors and the superintendent, provided misleading, false and inaccurate information against Claimant. ‘This information includes, but is not limited to, alleging Claimant was in an inappropriate relationship with other student(s), had Claimant followed by an investigator, attempted to prohibit teachers and staff of the district to provide assistance to the Claimant, or otherwise cooperate with the defense of his case, or provide information about the allegation made by the student. Upon information and belief, members, employees, and agents of the Webster Central School District also failed to abide by policies and procedures and were otherwise negligent, careless and showed a wonton disregard for the protection of Claimant's rights. 6. Upon information and belief, the Webster Central School by and through their superintendent, employees, officers, agents and representatives, were negligent, careless and reckless, malicious and/or in violation of state and federal law because they: knew or should have known that the alleged crime for which Claimant was being investigated did not occur; failed in their responsibility and duties to complete an accurate and adequate investigation into the claim made by an individual student with initials M-E.; maliciously provided incorrect and inaccurate information about Claimant; wrongly accused Claimant; wrongly obtained harassed annoyed or alarmed Claimant; improperly obtained irrelevant information about Claimant and made this information available to the public in order to embarrass, harass and alarm Claimant without cause; was part of and/or participated in the wrongful arrest of Claimant; failed to investigate and obtain readily accessible evidence that would haveexonerated Claimant; intentionally obtained irrelevant documents to attempt to embarrass Claimant; was aware of exculpatory evidence and failed to properly investigate the evidence, which lead to Claimant’s wrongful arrest; individuals of the Webster Central School District provided irrelevant and embarrassing materials about Claimant and made these materials available to the public; tortuously interfered with Claimant's employment; publicly stated and insinuated that Claimant was guilty of a crime or crimes they had reason to know he did not commit; violated Claimant's federal and state protected rights; violated Claimant's state and federal Substantive Due Process rights; and the School district actors were otherwise negligent, careless and reckless. 7. As a direct and proximate result of the foregoing, and through no fault or culpable conduct of Claimant, Claimant has suffered serious injuries including, but not necessarily limited to: loss of liberty; loss of reputation; loss of employment; loss of dignity; emotional distress and other out of pocket pecuniary damages, including but not limited to attorney's fees (as a result of the foregoing) 8. Claimant will seek compensatory damages, as against the Webster Central School District, it's superintendent and others, in any fair, reasonable and proper amount as may be awarded by a jury of his peers, together with interest, costs, disbursements to the fullest extent permitted by law. These costs exceed $500,000.00. Claimant reserves the right to amend and/or supplement this Notice of Claim. PLEASE TAKE FURTHER NOTICE that the undersigned claimant presents this claim for adjustment and payment. You are hereby notified that unless it is adjusted and paidwithin the time provided by law from the date of presentation to you, the claimant intends to commence an action on this claim. Dated: allt Attorne§s for Claimant Kali L. Watkins Vahey Getz, LLP 144 Exchange Blvd., Suite 400 Rochester, New York 14614STATE OF NEW YORK SUPREME COURT COUNTY OF MONROE, In the Matter of the Claim of Kali Watkins, Claimant, v. ‘Webster Central School District, Carmen Gumina, Superintendent, Paul Benz, Principal- Webster Schroeder High School, Jacqueline Goodwine, Assistant Principal-Webster Schroeder High School, Stephanie Reusch, Stacey Exner, and other agents, board members and employees, Respondents. VERFICIATION, STATE OF NEW YORK ) )ss.: COUNTY OF MONROE ) KALIL. WATKINS, being duly swom, deposes and says: Ihave read the above Notice of Claim and I know the contents thereof. The foregoing, information is true and accurate to the best of my own knowledge, except as to those matters which are stated upon information and belief, and as to those matters, I believe them to be true. KALIL. WATKINS Sworn to before me this _20t day of_Aayambic 2019. JON R GETZ pullio, Biaie of New York At eS Public