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The Claibome Firm, P.C.AttomeJ9 nt L w410 E. Bay StrectSavannah, Georgia 31,101www,claibornefirm.com

OFFICE OF THEocr 2 2013CITY ATTORNEY

Fiacsimile: 912.236. 1884aleghone : 912.236.9 559Ruth F. Claiborne- OfCourxelAmv W. Fox- Of Counscl

The Honorable Al ScottChatharn County Conrmission ChairmanP.O. Box 8l6l

William R. Claiborne, SavannahCnsey L. Reicha:radter, Savannahwriter's ernail: will@claibornefinn.com

September 30,2013VIA CERTIFIED MAIL/RETARNRECEIPT UIA CERTIFIED MAIL /RETARN RECEIPTDELIWRY NO,: 7M7 1490 MM 6191 1493 DELIVERY NO,: 7M7 1490 0004 6191 609The Honorable Edna Branch JacksonMayor, City of SavannahSavannah City Hall, 2"" Floor2 East Bay StreetSavannah, Georgia 31401YIA CERI-TFTED MAIL /RET'ARry SECEIPT VIA CERTIFIED MAIL /RETTJRN RECEIPTDELIVERY NO.: 70071490 00N 6t9t 1516 DEL|UERyNO,:7Uz tqg|MMiIgI IS2J

Stephanie Cutteq City ManagerP.O. Box 1027Savannah, Georgia 3 1402

R. E. Abolt, County ManagerP.O. Box 8l6lSavannah, Georgia 31412Savannah, Georgia 3 l40l

Re: Clains of Trina MayesLadies and Gentlemen:

We have been retained by Detective Trina Mayes in connection with injuries she incurredas a result of the conduct of Police Chief Willie Lovett, the Savannal/Chatham MetropolitanPolice Department, the city of Savannah and other government officials who knew or ihouldhave known of that conduct and who allowed that conduct to occur or continue or whoparticipated in that conduct. That conduct includes, without limitation: harassment, sexual andotherwise, failure to promote because of gender, including refusal of sexual advances,defamalion, both personally and with respect to her business reputation, assault, battery, invasionofprivacy, placing Ms. Mayes in a false and negative light, both personal and with respect to herbusiness reputation, negligent hiring and retention, ratification of such conduct, seduction andloss of consortium from Ms. Mayes' husband, and conspiracy among numerous individualsunder the employ or control of Savannaf/Chatham Metropolitan Police Department and/or thecity o[ savannah and/or chatham county to accomplish some or all of this conduct. And giventhe overwhelming circurnstances of liability in this matter, Ms. Mayes intends to pursue a ilai*of abusive litigation, if litigation is necessary. In that regard, notice and demand under o.c.G.A.

Claibome & Fox, LLC is ofcounsel to The Claiborne Firn, p.C.Alla ta Ofrce: 60 Lennox Pointe, Atlanta, Georgio j0324 . (401) 442.6969Charlotle O[ice:417 Eost Blvtt., Stite l0l, Charlo,te, North Corolina 28203 . (704) 202.0300

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Mayor Edna Branch JacksonStephanie Cutter, City ManagerAI Scott, Chatham County Commission ChairmanR. E. Abolt, County ManagerSeptember 30, 2013

$ 51-7-84 is hereby given that,you voluntarity withdraw, abandon, discontinue or dismiss anyposition you may assert ofnonJiability.This letter will further serve as ante ritem notice to porice chief willie Lovett, theSavannah/_clratham Metropolitan police Department, chatham county and tr," city oiiauannarrunder o.c.G.A. gg 36-l l-l, 50-2.1-j6, and all other Georgia starutes i egarding anie tiren iii,ce.Please direct all further communications regarding Deteclve Mayes diiectly io ou, omcer,-w"recommend to all our clients rhat lhey explore senlement of any claim ueor" ritiluiion i, ni.aand Ms. Mayes has accepted our recommendation. If you would like to exploie *r",n.",,please let us know by close ofbusiness on Friday, Octobei t t, 20[.

SWWmrg

Reply also to:S. Wesley Woolfs. WESLEY WOOLF, P.C.408 East Bay StreetSavannah, Georgia 30401Cc: FileClient

S. Wesley Woolf, EsquireBrooks W. Stillwell, III, EsquireR. Jon Hart, Esquire (Via Facsimile and Regular Mail)(Via Facsimile and Regular Mail)

Claiborne & Fox, LLC is of counse! to The Claibor,rc Fim, p.C.-. Atlanta Ojice: 60 Lennox pointe, Attonto, Georgio 3032,t - (lOi) IIZ.OCOCChorlotk Onlce:417 East Blvd., Suite toj, Chortotte, No;th Carotii iAiU eo4) 702.0300

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Mayor anil AldermehStephanie Cutte\ City *^*", /'lrfu *

Allegzitions of sexual harassment have bei:n made by an SCMPD police Olficer againslChief Willie Lovett. An iirvestigation by an orrtsido legal firm iS in gogress. tnieftovett has been notified of the allega1ion5 and investigalion. Upon completion of theinvestigation, Council tvill be notified ofthe findings.Please let me know ifyol have any quastions.

*smm:td"MEMORANDUMTO:FROM:SUBJECT:DATE:

Sexual llarassment Allegations20,2013

P.O. aox ro27, S^VANN^H, G! lr4o2exoxE gi2.6tI.64rt Tott 9tz,6tr.67o?, Ej-r tr2-1t8.o872 sAVANNATTc^-cov

City of Savannah Responsive materials to ORA of 9/30//13In rer Savannah Morning News10t2t13 ctTY000006

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CITY OX'SAVANNAHWorkplace Conflict Statement Form

Employee's Name !sBte-S-s.e,-fNgg;- Dept. 1fu

2. Give a briefstatement ofyour rvorkplace conflict including names ofall parties involved and anypersons who lvitnessed the conflict; (S!pk to,tje faSl9)

L Datg time and location the event or discussion took place:

Stat rvhat you feel is a fair and just solution to this conflict:

4, Are you willing to mediate this conflict through a City certilied mediator?YES Y .NO

Employee's Signa oate: 'ilZrcl t3Please complete and return to the Hurnan Resources Employee Relatiotrs coordinator,

Reytsed 5/06

City of Savannah Responsive materials to ORA of 9/30//13In rei Savannah Moming News10t2t13 c1TY000002

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My nanre is LaPrentice Mayes and I am curently employed in the police patrol divisioncentral precinct investigations. For the past 17 yearq I have been in several assigru]rentsthoughout the departnrent to inolude investigations. I have worked under the direction ofWillieC Lovett for numerous years and in 2006, he promoted me to the rartk of Sergeant. Willie Lovettwas a man I respeded admired and always wanted to do a good job to make him shine. I alwaysthought we had a good Dear City ofSavannatqworhng relationship and I felt I was able to talk with him about anything.

Captain Cedric Phillips is a man who I always respected and considered a true friend. Weworked closely together for many years and he was my trusted and dear friend. When he movedup the ladder and achieved the rank ofcaptain. I was there for lis special day in his lifejust likehow he was for rno when I was promoted to thc rank of Sergeant. He was the person who pihnedmy badge on my chest.

Both ofthese nren betrayed all ofthat last week when my wife of six years revealed tome she had an affair with chief Lovett and Captain Phillips paved the way for that tragic event tohappen,Backglound

On July 16, 2012, my wife and I were involved in a domestic dispute in our home thatresulted in the police being called, and I was ordered out ofthe !'esidence. The next day, we wereplaced on administrative leave so internal affairs could conduct an investigation. While out oftheresidencq Captairr Phillips who was a mutual fiiend to both ofus, he would check on each ofusto ensure we vr'ere okay. As tinte went ofl, the i[vestigation was lifted and we both wereremoved frorn our investigatior assignment and placed back in the patrol division. Upon myreturned, I met with chieflovett and told him I was sorry for all the bad press and rnovingforward, I will not let this type of stuff happen again. During this time, I would speak with mywife and we decided to work out our disagreements. Even though we had already filed fordivorcq and despite that, we wa$ed to give our marriage another chance.

In January 2013, I moved back into the house and we continued our rnariage. A fewmonths had past, and it was tirne for the Sergeants assessmeot. My wife took the test and past,which nrade her eligible for promotion. During that time we both were baptized and gave our lifeto god and was living the christel life. I also tried gettiug out ofprecinct 4 during that timebecause I was not pleased with the commander. I called chieflovett and expressed my desire tomove and he said he would see what he could do and I was never moved. I then wenl to CaptainAdams and asked if I could come to his precinct and he worked it out with the majors and I wastrausferred to precinct 3. Prior to this incident, I rnet with chieflovett and asked hinr not to holdanything against my wife because she is a good employee. He looked me in the face and said," Ifshe doesn't get promoted, it will be because of her own doing". I mncluded my interview andleft his office. Merward, the promotions were annouced and my wife took it hard. She kept

,)-_-*q '\c-^,-\^\ \-^ O\,1\a-__.- qlzu IB XCity of Savannah Responsive materials to ORA of 9/30//13 \J C1ry0000030tzt13 In re: Savannah Morning News

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