Scribd Logo
Upload

Welcome to Scribd!

  • 10K views

    11-27-23 Gov't Claim Final 3

    Uploaded by

    FOX 11 Los Angeles
    This document is a government claim notice sent on behalf of Michael and Kim Clinkunbroomer regarding the wrongful death of their son, Deputy Ryan Clinkunbroomer. It provides notice of claims against the County of Los Angeles and City of Palmdale stemming from Ryan being fatally shot on September 16, 2023 while on duty and stopped at an intersection in Palmdale. The claim alleges Ryan's death was a foreseeable result of the LASD forcing deputies to work excessive overtime, including 100+ hours per month for Ryan, which led to chronic exhaustion and made deputies targets. It seeks $20 million in damages for wrongful death, civil rights violations, and intentional infliction of emotional distress.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    11-27-23 Gov't Claim Final 3

    Uploaded by

    FOX 11 Los Angeles
    10K views3 pages
    This document is a government claim notice sent on behalf of Michael and Kim Clinkunbroomer regarding the wrongful death of their son, Deputy Ryan Clinkunbroomer. It provides notice of claims against the County of Los Angeles and City of Palmdale stemming from Ryan being fatally shot on September 16, 2023 while on duty and stopped at an intersection in Palmdale. The claim alleges Ryan's death was a foreseeable result of the LASD forcing deputies to work excessive overtime, including 100+ hours per month for Ryan, which led to chronic exhaustion and made deputies targets. It seeks $20 million in damages for wrongful death, civil rights violations, and intentional infliction of emotional distress.

    Original Description:

    11-27-23 Gov't Claim Final 3

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    This document is a government claim notice sent on behalf of Michael and Kim Clinkunbroomer regarding the wrongful death of their son, Deputy Ryan Clinkunbroomer. It provides notice of claims against the County of Los Angeles and City of Palmdale stemming from Ryan being fatally shot on September 16, 2023 while on duty and stopped at an intersection in Palmdale. The claim alleges Ryan's death was a foreseeable result of the LASD forcing deputies to work excessive overtime, including 100+ hours per month for Ryan, which led to chronic exhaustion and made deputies targets. It seeks $20 million in damages for wrongful death, civil rights violations, and intentional infliction of emotional distress.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    10K views3 pages

    11-27-23 Gov't Claim Final 3

    Uploaded by

    FOX 11 Los Angeles
    This document is a government claim notice sent on behalf of Michael and Kim Clinkunbroomer regarding the wrongful death of their son, Deputy Ryan Clinkunbroomer. It provides notice of claims against the County of Los Angeles and City of Palmdale stemming from Ryan being fatally shot on September 16, 2023 while on duty and stopped at an intersection in Palmdale. The claim alleges Ryan's death was a foreseeable result of the LASD forcing deputies to work excessive overtime, including 100+ hours per month for Ryan, which led to chronic exhaustion and made deputies targets. It seeks $20 million in damages for wrongful death, civil rights violations, and intentional infliction of emotional distress.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3
    At a glance
    Powered by AI
    Deputy Ryan Clinkunbroomer was shot and killed while on duty at a stoplight intersection in Palmdale. His family is filing a wrongful death claim alleging the death could have been prevented.

    On September 16, 2023, Deputy Ryan Clinkunbroomer was shot in the head and killed by Kevin Salazar while stopped at a stoplight in Palmdale. Salazar drove up alongside the patrol vehicle and shot Clinkunbroomer through his open window.

    It is alleged that chronic understaffing at the LASD led to deputies being overworked and fatigued due to mandatory overtime. Sheriff Luna is accused of knowing the dangers this posed but continuing the policy, leading to Clinkunbroomer's allegedly preventable death.

    Bradley C.

    Gage* _____________________________ Milad Sadr

    BRAD GAGE LAW Wayne Smith


    A Professional Law Corporation
    *A PROFESSIONAL LAW CORPORATION

    23002 VICTORY BOULEVARD ~ WOODLAND HILLS, CA 91367 ~ (818) 340-9252 ~ FAX (818) 340-9088
    Email: [email protected] Email: [email protected] Email:[email protected]

    November 27, 2023

    VIA: HAND DELIVERY


    City of Palmdale
    38300 Sierra Highway
    Palmdale, CA 93550

    County of Los Angeles


    Executive Officer, Board of Supervisors
    500 West Temple St.
    Attn: Claims, Room 383
    Kenneth Hahn Hall of Administration
    Los Angeles, California 90012

    Re: Government Claim

    Dear Sir or Madam:

    Please consider this a notice of governmental claim against both the County of Los Angeles (and
    Los Angeles County Sheriff’s Department) and the City of Palmdale.

    A. NAME OF THE CLAIMANTS:

    Michael Clinkunbroomer (Father to decedent)


    Kim Clinkunbroomer (Mother to decedent)
    Deputy Ryan Clinkunbroomer is the decedent.

    B. ADDRESS TO SEND ALL NOTICES:

    Brad Gage Law, APC, 23002 Victory Blvd., Woodland Hills, CA 91367.

    C. THE DATE, PLACE AND OTHER CIRCUMSTANCES OF THE OCCURRENCE


    OR TRANSACTIONS WHICH GIVE RISE TO THE CLAIMS ASSERTED:

    Wrongful Death; Assault; Battery; Civil Rights Violations.


    Saturday, September 16, 2023, approximately 5:57 p.m.
    Intersection of “E” Avenue and Sierra Highway, Palmdale, CA 91384
    Government Claim
    November 27, 2023
    page 2

    On or about September 16, 2023, Deputy Ryan Clinkunbroomer exited Palmdale Sheriff
    Station’s parking lot, drove west on E.Ave. Q, in a marked patrol vehicle. While stopped at a
    stoplight, Suspect Kevin Salazar, drove alongside Ryan’s driver’s side of the car and through his
    open window, Salazar shot Deputy Clinkunbroomer in the head, killing him. But the murder
    could have been prevented, but for the intentional actions of the LACSD and Sheriff Luna’s
    intentional actions in forcing LASD employees to work such massive overtime (in violation of
    past MOU’s) that created a known safety hazard, making such a tragedy foreseeable, and
    preventable but for the defendants actions.

    Due to consistent, historic executive mismanagement by the LASD, deputy vacancies average
    20% (2,000 deputies). LASD supervisors have mandated Palmdale Station patrol deputies to
    work overtime. Ryan was forced to work 100 + hours of overtime each month. As a direct and
    legal result of the intentional actions of the defendants, Deputy Ryan Clinkunbroomer (like other
    Palmdale Deputies) was physically and chronically exhausted, suffering from fatigue each
    month.

    Sheriff Luna and the Board of Supervisors knew of the dangers to their employees as a result of
    intentionally forcing overtime, but intentionally pursued such actions in conscious disregard of
    the rights and safety of deputies1. The result is that the Sheriffs Department knew or should
    have known that deputies would be targeted for execution and needed sufficient rest in order to
    avoid foreseeable tragedies of death. Disregarding the safety of his troops, Sheriff Luna
    continues to force his deputies work mind-numbing overtime resulting in Ryan’s death and the
    likely death of other deputies. This Government Claim and subsequent lawsuit seeks justice for
    the family and to save lives of other deputies.

    Other claims include:


    The Bane Act, and related civil rights claims under 42 USC section 1983.
    Wrongful death
    Intentional Infliction of Emotional Distress.

    D. GENERAL DESCRIPTION OF THE INJURY, DAMAGE OR LOSS INCURRED.

    General, special (economic and non economic) damages, wrongful death damages and punitive
    damages. Civil Penalties. Attorneys fees. Litigation Costs. Such other damages as the Court
    deemes proper. Amount of claim: $20,000,000

    1
    Sheriff Luna and the Board of Supervisors have made public statements acknowledging
    the lack of LASD deputy staffing and their contiuned mandated overtime, forced upon deputies
    each month, for years.
    Government Claim
    November 27, 2023
    page 3

    E. NAME OF PUBLIC EMPLOYEES CAUSING THE INJURY, DAMAGE OR


    LOSS TO COMPLAINANTS INCLUDE BUT ARE NOT LIMITED TO THE
    FOLLOWING:

    Sheriff Luna. As to others, this is still being investigated.

    F. THE AMOUNT OF CLAIMED DAMAGES: $20,000,000. JURISDICTION WILL


    BE PROPER IN SUPERIOR COURT.

    If you contend this is not the proper location for a Governmental Claim, please advise of the
    proper address. Further, if defendant contends there are any administrative claims or remedies
    not pursued by complainant, please advise so that we can fulfill any administrative remedy
    requirements now. Thank you.

    Very truly yours,


    Brad Gage Law
    A Professional Law Corporations
    /s/ Bradley C. Gage
    By Bradley C. Gage

    O:\C\CLINKUNBROOMER\GOVERNMENT CLAIM\11-27-23 Gov't Claim final 3.wpd

    You might also like